A church-affiliated elementary school currently offers school employees a tuition reduction program under IRC Sec. 117(d), where children of school employees can attend the school for reduced tuition. The school wants to offer a comparable benefit to church employees. I believe that Section 117(d) is inapplicable without an employer-employee relationship but was wondering if there are any special interpretations of this requirement due to the church affiliation, or any other way to provide the tuition benefit to the church employees on a tax-free or tax-deferred basis.