What Additional Fees Can Be Included In the Cost Of Attendance?

To be included in the cost of attendance (COA, or student budget), the fees must be necessary for all students, all students in a particular course of study, or all students in a broad category, such as undergraduates and graduates. Optional fees may also be added to student budgets on a case-by-case basis.

Costs for the rental or purchase of equipment, materials, or supplies are included in the books, course materials, supplies, and equipment component if required for all students in the same program of study.

Generally, the use of average expenses for tuition and fees is acceptable, rather than identifying actual costs for each student. As prescribed by the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087LL], the COA may include “tuition and fees normally assessed a student carrying the same academic workload as determined by the institution.” If you use average tuition costs, tuition expenses should be a weighted average to account for the number of students subject to the school’s different tuition charges. To be included in the COA, fees must be necessary for all students, all students in a particular course of study, or all students in a broad category, such as undergraduates and graduates, or students at different enrollment levels. Therefore, average amounts for fees may be calculated and applied to all students, students in a particular program of study, or to students in a defined category.

Optional fees may also be added to a student’s budget on a case-by-case basis. For example, fees paid to third parties, such as health insurance fees paid directly to an insurance company, may not be included in the COA unless they are included by the financial aid administrator exercising professional judgment (PJ) to accommodate an individual’s special circumstances—that is, not just because the institution charges the fee and the fee is then waived.

Any decisions your school makes about including average or actual costs for tuition and fees in the COA should be clearly outlined in your policies and procedures. If you also choose to address exceptional tuition-related or fee-related costs through PJ, make sure this is noted in your policies as well.

Also refer to NASFAA Monograph: Developing the Cost of Attendance, under Tools & Resources on the NASFAA website.

Note: Effective with the 2023-24 award year, the COA component for “books and supplies” has been renamed “books, course materials, supplies, and equipment.”

P&P Builder: NASFAA’s Policies & Procedures (P&P) Builder guides you step-by-step through the creation of a centralized, accessible policies and procedures manual. This is included in the cost of NASFAA Value Plus membership. There is an additional cost for other membership levels.