how about employees themselves?

my wife works for a large health care provider/teaching hospital and I believe that they give substantial tuition reimbursement for employees getting degrees/certifications.

I believe that it is treated as taxable income, which would seemingly solve this issue. Give them tuition reimbursement for passing their classes and then a 1099 and call it a day. Notre Dame can make a strong argument that the value of the education is worth it, and make a case to compare it to CA schools (as an example) state income tax.