Can We Include Board Exam Costs In the Student's Cost Of Attendance?

It depends. The school must make a determination first. Is the board exam required for the student to obtain the licensure, certification, or first professional credential for employment in the student's field of study.

Effective with the 2023-24 award year, changes to Section 472(a)(14) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087LL(a)(14)] state that the cost of obtaining a license, certification, or a first professional credential is a required component in the cost of attendance (COA); it is no longer optional based on school policy, and it is no longer a one-time cost. If the board exam is required for professional licensure, certification, or credentialing for employment (including residency employment) in the student's field of study, then the institution must include that exam cost in the student's COA (or budget).

Additionally, NASFAA has confirmed with the U.S. Department of Education (ED) that longstanding guidance in the FSA Handbook still applies--that its, "the costs must be incurred during (not after) a period of enrollment, even if the exam is after the end of the period." The institution cannot add the board exam cost after the student is no longer enrolled, and it does not matter whether the board exam is required for graduation. Neither ED nor NASFAA can make this determination for the school.

According to Dear Colleague Letter GEN-22-15, an institution may use actual or average costs. COA-Q4/A4 states: "When implementing the requirement to include the cost of a first professional credential, does it have to be actual costs, or does the Department allow the use of average costs like it does for most other cost components?

For a student enrolled in a program requiring professional licensure, certification, or a first professional credential, the institution must now include the cost of obtaining the license, certification, or a first professional credential in the student’s COA. An institution can use actual or average costs of obtaining a first professional credential and licensure/certification based on student needs and program structure. If an institution chooses to use average costs, the institution will need to develop a reasonable basis for the average figure using the actual costs of a first professional credential that they are aware of for the profession that the program prepares the student to enter. The Act removed the one-time cost restriction, allowing institutions to include costs for multiple license or credential test attempts, if appropriate. However, institutions may set a reasonable limit on the number of attempts allowed to be included in a student’s COA."

NOTE: HEA Section 472(a)(14), [20 USC 1087LL] does not include the previous provision that the inclusion of the cost of obtaining a license, credential or first professional credential is limited to the "one-time" cost.

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.