Does a School Have To Publish Its Cost Of Attendance On Its Website?

This AskRegs Knowledgebase Q&A was updated on July 27, 2023 to reflect additional clarification provided by the U.S. Department of Education (ED) to NASFAA.

Yes. Effective with the 2023-24 award year, Section 472(c) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087LL(c) Amendment of Section] states, "Each institution shall make publicly available on the institution's website a list of all the elements of cost of attendance described in paragraphs (1) through (14) of subsection (a), and shall disclose such elements on any portion of the website describing tuition and fees of the institution."

In Dear Colleague Letter GEN-22-15, ED provided additional guidance in question COA-Q8:

"Under the [FAFSA Simplification] Act, institutions must make publicly available on their website a list of all the elements of COA and disclose such elements on any portion of their website describing tuition and fees. Can the Department give further guidance on where and how institutions can meet this requirement?

As noted, institutions must make publicly available on their website a list of their COA elements and on any webpage discussing tuition and fees. Under the HEA, institutions otherwise have flexibility in determining specifically how and where to best provide the information. Institutions should be able to demonstrate to the Department a reasonable approach to providing the required information in all the appropriate places."

During the June 6, 2023 webinar, Better FAFSA Better Future Overview and Timeline, ED clarified:

"Where you do list all of your COA components, we definitely would expect to see what those costs would be for the various components that make up that student’s cost of attendance. If you are talking about tuition, we would expect to see tuition costs associated with that, as well as food and housing, transportation, etc. One question that has come up a lot is, 'Do we actually have to provide all of the components and all of the lists of elements every time tuition and fees are mentioned on any webpage?' We do want to stress here that Policy has received that question numerous times, and we’ve determined that in fact you do not have to provide all of those elements on every single webpage where you talk about tuition and fees, which I know will be welcome news for many of our schools. However, what that means is, where you do mention tuition and fees, you need to very clearly and conspicuously put out there links directly to the cost of attendance components and the various elements and where they reside. And, it should be very easy to get to, so we wouldn’t want to see that, in order to find all these elements, it would take me 15 clicks or scrolling through various webpages to try and find it. It should be very obvious, but yes you can actually use a link on that page to link back to the main page where you’re going to have a nice full description with the dollar amounts of all of your various costs of attendance components that the student might end up working with.”

Seeking further clarification, NASFAA received the following guidance from ED:

"[I]f a school chooses to use a link to provide a full description of all COA elements when a webpage discusses tuition and fees (whether dollar amounts are mentioned or not) the link must contain ALL required components including tuition and fees. The law clearly states that the school must list all COA elements enabling the student to fully comprehend what all of the possible costs could be when enrolling in a particular program and school. Piecemealing the various COA components across different webpages would cause confusion and seem to defeat the intent of the law with regards to providing clear consumer information about the student’s potential COA."

So, what does all this mean, really?

1. The point of the statutory requirement is to ensure transparency and clarity when it comes to how much it will cost the student and family beyond just tuition and fees.
2. You are not required to list all COA components on every webpage that mentions/describes/lists the words "tuition and fees" or provides tuition and fee dollar amounts.
3. If you have the words “tuition and fees” or provide tuition and fee dollar amounts on a webpage, you can provide a link to a webpage where the tuition and fee figures are provided, but only as long as all other cost components and dollar amounts are provided on that other webpage.
4. The school is not required to list all cost components/figures for all academic programs on a single webpage, but it could.
5. When there are programs with different COA components, you should be detailing those differences specifically, not referencing a general COA breakdown.
6. The COA is a Title IV-concept and is program-specific. If the academic program is not a Title IV-eligible program, you do not need to include the COA information; however, it is a best practice to do so.

With all of that taken into account, we know that as an association, the NASFAA board of directors, staff, and members are united in upholding our ethical responsibilities to provide students and parents with the tuition and fee dollar amount information they need to make good decisions about attending and paying for college. To that end, we urge institutions to embrace both the letter and spirit of the statute and sub-regulatory guidance contained in GEN-22-15 and provide all of the cost component dollar figures for programs in the same place so it is easily accessible for students.