Must We Use the Term "Living Expenses" Or "Housing and Food" When Referencing the COA?

This AskRegs Knowledgebase Q&A was updated on June 9, 2023 to reflect a change in NASFAA's guidance based on the U.S. Department of Education's (ED's) Better FAFSA Better Future Overview and Timeline Webinar.

Per ED, the school does not actually have to use the phrase "living expenses" when referencing the cost of attendance (COA) but instead can use the phrase "food and housing" in its publications and websites, including financial aid offers. At a minimum, the school must convert room and board references to food and housing. See Dear Colleague Letter GEN-22-15 for more information.

The school does have the option of using "living expenses" and then further clarifying the "food and housing" costs within the "living expenses" component. NASFAA agrees that it would be a best practice to use "Living expenses, including food and housing" (as stated in statute), as "living expenses" can include more than just food and housing (like utilities); this will provide more transparency and be beneficial to students and families.

NASFAA's original interpretation was that, at a minimum the school was required to use the term "living expenses," as that is the wording in Section 472(a)(5) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087LL(a)(5)].