Can a School Choose Not To Include Housing and Food In the Cost Of Attendance?

No. Housing and food (living expenses) is a required cost of attendance (COA) component under the Higher Education Act of 1965, (HEA) as amended. Section 472 [20 USC 1087LL] of the HEA states:

§ 1087LL. Cost of attendance [HEA § 472]
"For the purpose of this subchapter, the term "cost of attendance" means-
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(5) an allowance for living expenses, including food and housing costs, to be incurred by the student attending the institution on at least a half-time basis, as determined by the institution, which shall include-

(A) for a student electing institutionally owned or operated food services, such as board or meal plans, a standard allowance for such services that provides the equivalent of three meals each day;

(B) for a student not electing institutionally owned or operated food services, such as board or meal plans, a standard allowance for purchasing food off campus that provides the equivalent of three meals each day;

(C) for a student without dependents residing in institutionally owned or operated housing, a standard allowance determined by the institution based on the average or median amount assessed to such residents for housing charges, whichever is greater;

(D) for a student with dependents residing in institutionally owned or operated housing, a standard allowance determined by the institution based on the average or median amount assessed to such residents for housing charges, whichever is greater;

(E) for a student living off campus, and not in institutionally owned or operated housing, a standard allowance for rent or other housing costs;

(F) for a dependent student residing at home with parents, a standard allowance that shall not be zero determined by the institution;

(G) for a student living in housing located on a military base or for which a basic allowance is provided under section 403(b) of title 37, a standard allowance for food based upon such student's choice of purchasing food on-campus or off-campus (determined respectively in accordance with subparagraph (A) or (B)), but not for housing costs; and

(H) for all other students, an allowance based on the expenses reasonably incurred by such students for housing and food;..."

A school cannot choose not to include housing and food costs in a student's COA when that student actually incurs housing and food costs during the period of enrollment. The term "may" is sometimes used in reference to the housing and food component of the COA only to allow for the possible instances when housing and food may be supplied at no charge, in which case that component of the COA would be zero. If the student is charged for the housing and food and the charge is then waived, the value of the housing and food is included in the COA, but is offset by including the amount waived in the EFA.

Note: Effective with the 2023-24 award year and application processing cycle, the COA component for “room and board” has been renamed "living expenses." "Room" has been renamed "housing" and "board" has been renamed "food."

See Dear Colleague Letter GEN-22-15 for more information.

Student Aid Reference Desk: For additional information, try the Student Aid Reference Desk. It is a central hub of all the important financial aid resources you need with direct links to legislation, regulation, Dear Colleague Letters, and other ED and NASFAA references. It is updated on a rolling basis with the latest news and changes. See Cost of Attendance.