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

It depends, and the school has to make a determination first. The key question is not whether the United States Medical Licensing Exam® (USMLE) is required for graduation. The key question is whether the USMLE is required for the student to obtain the professional license, certification, or credential required for employment in the student's field of study. Neither the U.S. Department of Education (ED) nor NASFAA can make this determination for you.

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.

If the USMLE is required for professional licensure, certification, or credentialing for employment (including residency employment) in the student's field of study, then you must include that additional exam cost in the student's COA/budget. If the cost is incurred by the student for multiple academic years, then it also must be included. Additionally, NASFAA has confirmed with ED that longstanding FSA Handbook guidance still applies–that, "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 exam cost that is paid after the student is no longer enrolled, and it does not matter whether the exam is required for graduation.

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

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. Search Cost of Attendance.