Should We Include PLUS Loan Fees In the Cost Of Attendance?

Yes. The school is required to include both graduate and parent PLUS fees in the student's cost of attendance (COA)--that is, it is not optional. The wording in Section 472(a)(13) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087LL] is as follows:

"SEC. 472. [20 U.S.C. 1087LL] COST OF ATTENDANCE.
For the purpose of this subchapter, the term "cost of attendance" means-
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(13) for a student who receives a Federal student loan made under this subchapter or any other Federal law, to cover a student's cost of attendance at the institution, an allowance for the actual cost of any loan fee, origination fee, or insurance premium charged to such student or the parent of such student on such loan, or the average cost of any such fee or premium, as applicable;"

If average loan fees were not included up front, and PLUS is added later, this means the school will have to recalculate the student's package to include the loan fees.

Note: Effective with the 2023-24 award year, the COA component for loan fees may no longer include fees for nonfederal loans (e.g., private loans, conventional loans, etc.).

See Dear Colleague Letter GEN-22-15 for more information. See also AskRegs Knowledgebase Q&A, Does a School Have To Include Loan Fees In the Cost Of Attendance?