Are We Required To Include the Cost Of a Professional License, Certification, Or Credential In the Cost Of Attendance Every Year?

It depends on when the costs are incurred by the student. A student's cost of attendance (COA) can only include costs applicable to the academic year in which the student is enrolled and incurring the costs.

Effective with the 2023-24 award year, the cost of of obtaining a license, certification, or first professional credential is a required component of the COA for students enrolled in a program requiring professional licensure, certification, or a first professional credential to enter the profession. As with any cost included in a student's COA, only the costs associated with the corresponding academic year can be included in that year's COA. This means that such costs must be included for the year in which the cost would be incurred by the student. This is usually the student's final academic year, but it could be something the student incurs over multiple years of the program.

Additionally, NASFAA has confirmed with the U.S. Department of Education (ED) that longstanding FSA Handbook guidance 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." For example, the institution cannot add a licensure or certification exam cost that is paid after the student is no longer enrolled.

See Section 472 of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087LL], and Dear Colleague Letter GEN-22-15.

See also the following AskRegs Knowledgebase Q&As: 

• What Types Of Costs Can Be Included For Licensure, Certification, Or the First Professional Credential?
• Is There a Limit On the Number Of Times the Cost Of a License, Certification, or Professional Credential May Be Included In the COA?