Another important factor is the amount of the "loan". If it is more than say 35% of the employee's average paycheck, if the employee walks before the 3-year period, the employer may not be able to recapture via payroll and would be wanting to make it wages - at least for "punishment" purposes. (A daily issue on payroll chat groups, how to recoup advances, sign on, moving, etc.)
If the OP is from the perspective of a preparer handling a question from a client (the employee), I would not (as preparer) step in the steaming pile. Let the employer handle it, correctly or incorrectly, and go from there. The employee reporting it as wages, when the employer has not, could result in the end of the employment. If the employee wants to work for someone who may be shady, so be it.
The main issue is it is taxable period. Trying to make it not is a problem, as it trying to tax shift (if the forgiveness is a wink and nod deal instead of documented).