221(d)(1)) incurred to pay qualified higher education expenses of the employee, but only if the employee provides evidence of such loan and such payments to the employer making the matching contribution. (II) Qualified higher education expenses The term qualified higher education expenses has the same meaning as when used in section 401(m)(4)(D). (iii) Applicable rules Clause (i) shall apply to an arrangement only if, under the arrangement— (I) matching contributions on account of qualified student loan payments are provided only on behalf of employees otherwise eligible to elect contributions under subparagraph (A)(i)(I), and (II) all employees otherwise eligible to participate in the arrangement are eligible to receive matching contributions on account of qualified student loan payments. . (e) 403 (b) plans Subparagraph (A) of section 403(b)(12) is amended by adding at the end the following: The fact that the employer offers matching contributions on account of qualified student loan payments as described in section 401(m)(14) shall not be taken into account in determining whether the arrangement satisfies the requirements of clause (ii) (and any regulation thereunder). . (f) Effective date The amendments made by this section shall apply to contributions made for years beginning after December 31, 2019. 114. Treatment of qualified retirement planning services (a) In general Subsection (m) of section 132 is amended by adding at the end the following new paragraph: (4) No constructive receipt No amount shall be included in the gross income of any employee solely because the employee may choose between any qualified retirement planning services and compensation which would otherwise be includible in the gross income of such employee. The preceding sentence shall apply to highly compensated employees only if the choice described in such sentence is available on substantially the same terms to each member of the group of employees normally provided education and information regarding the employer's qualified