Note that the following general guidance only applied in the advance planning stage as schools were setting up their cost of attendance (COA) before packaging students for the 2020-21 award year. It does not apply to cost changes that are made after students are packaged. See AskRegs Knowledgebase Q&A, Are We Required To Recalculate COA Or Awards If We Adjust Charges Or Refund All Or Part Of Tuition, Fees, Room, Or Board Due To Coronavirus?
Scenario: The University is considering shortening in-person instruction during the Fall 2020 term in anticipation of a second wave of COVID-19. Students will be attending in-person (residential) classes at the start of the term and then moving to an all-online platform after Thanksgiving. The term would still be 16 weeks in length, but would be instructed in a hybrid style format with in-person and online instruction. Students who are living on-campus and who do not return after Thanksgiving would be charged a different rate for housing than those who live on-campus and return to the residence halls after Thanksgiving. We would be open and students would be allowed to return, but they would be encouraged to stay home.
Answer: It depends on whether the COA is reasonable and accurately reflects a student's costs over the payment period and academic year. As in all scenarios, housing costs need to accurately reflect your student's living arrangements. You will need to be able to justify the amount you use for each cost component in your COA to an auditor or program reviewer later. COA construction is entirely up to the school, and cannot be regulated by the U.S. Department of Education (ED). There may be many different ways to set living costs. However you derive your living costs, be sure to document it in your policies and procedures.
We understand that under Section 472 of the Higher Education Act of 1965 (HEA), as amended [20 USC 1087] there should be separate COAs based on living arrangements (e.g., on-campus, off-campus, living with parents). In the absence of guidance from ED on constructing a COA in a hybrid situation, you should determine what is most appropriate to the situation and account for the shift in living arrangements when constructing your COA up-front for the academic year. ED has always allowed schools to use averages when constructing the COA, so as long as the average shift in living arrangements is accounted for up-front, you would not need to recalculate the COA after Thanksgiving when the student moves off-campus or to living with parents. If you use actual costs in your COA, then you would need to adjust the COA when the student moves to off-campus (and online) after Thanksgiving. If you have separate budgets that reflect the different housing costs for each category of student, you will need to be able to properly assign the appropriate COA to the student up-front so you don’t have to adjust it later when the student changes plans.
It might not be appropriate to simply use last year's COA without fully considering any cost differences that might occur because of your shift in instruction and housing. Remember, there are other cost components that might be impacted by the shift in instruction, such as differences in fees, board, supplies for online classes, transportation, etc., which must be accounted for in your COA. However you proceed, you will want to evaluate whether there are actually differences in costs. In your area, for example, the costs for living off-campus may be the same as living on-campus.
Reference NASFAA's Developing the Cost of Attendance Monograph under Publications on the NASFAA website for assistance in evaluating and developing your COA.
Also note that the COA can be lopsided if your fall term is constructed differently than your spring term. If that is the case, there are packaging considerations. When packaging for the entire academic year, you would use the entire amount of the COA over the entire academic year. When packaging for a single term, you must use the single-term COA, expected family contribution (EFC), and estimated financial assistance (EFA) for the single term.
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