Are We Required To Include the Cost Of a Personal Computer In the Cost Of Attendance?

Yes, if it is documented according to the school's own policy for documenting the rental or purchase of a personal computer.

Effective for the 2023-24 award year, Section 472(a)(2) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087LL(a)(2)] (under Amendment of Section), states that the cost of attendance (COA) must include "an allowance for books, course materials, supplies, and equipment, which shall include all such costs required of all such students in the same course of study, including a reasonable allowance for the documented rental or upfront purchase of a personal computer, as determined by the institution;"

How the school comes up with that allowance and how it documents the rental or purchase of the personal computer is entirely up to the school, as long as it reasonably reflects the student's computer cost. Here are some things to consider:

• The computer allowance must be based on the reasonable costs for the documented rental or purchase of a computer.
• The computer does not have to be required by the student’s program of study; it just needs to be educationally related.
• The computer may be purchased in the summer for use during the upcoming period of enrollment.
• A student can receive a computer allowance more than once if the school's COA policy allows for it. The statute does not set a limit on the number of times a student may rent or purchase a computer and have that cost included in his, her, or their COA; this limit is set by the school.
• The computer allowance is no longer limited to half-time students.
• The school might have a different COA for the first year of the program versus the remaining years of the program.

The statute requires that the school document the rental or purchase. The school is not required to document the cost. Once the purchase or rental is documented, the school can then assign a “reasonable allowance” to the student’s COA. If the school’s policy chooses to use the actual cost as its “reasonable allowance,” then it would have to document both the rental/purchase and the cost.

Whether the school includes the cost of the rental or purchase of a computer up front when constructing the student's COA depends on the school’s own policy for documenting that rental or purchase. For example, if the student’s academic program requires all students in the program to purchase a computer, and the school can document that purchase requirement, then it would include that cost up front when constructing the COA. On the other hand, if the school’s own policy requires each student to document the actual rental or purchase, then it must include that cost (reasonable allowance or actual cost) based on the documentation that is provided, either before or after constructing the COA. These are just examples and are not intended to limit the school's own discretion to establish another way of documenting the rental or purchase of a computer.

The school is not required to include the rental or purchase of a computer in every student's COA, since many students will already have a computer and will not request one. However, if the student provides documentation of a rental or purchase of a computer, the school must include a reasonable allowance for that rental or purchase in the student’s COA, in accordance with the school’s COA policy and the law.

Additionally, it is NASFAA’s understanding that the use of the term “upfront purchase” does not constitute a mandate to include this expense for all new students or for only new students. Rather, we believe it supports the longstanding requirement that the rental or purchase of a computer must be documented and related to the student’s current educational pursuit to be included in that student’s COA.

Whatever the school's policy, the school’s policies and procedures should include how the school establishes the computer cost allowance, the permitted amount, the required documentation, and how many times the school will allow for the rental or purchase of a computer over the course of a student's enrollment.