This guidance is specific to the 2023-24 award year and later.
No. However, the school must develop a living expenses component of the cost of attendance (COA) that is not zero for dependent students living at home with parents.
NASFAA has received confirmation from the U.S. Department of Education (ED) that the food component of the COA for this group of students may include three meals per day, or it may include fewer than three, stating "How the school determines the appropriate amount is up to the school." ED went on to say that "it’s up to schools to use the flexibility we are providing them to determine reasonable amounts for each of these categories...schools simply have to come up with reasonable costs (simply not zero) for students in this category based upon their student situations (surveys, meal plan purchases for commuters, etc.)." ED also noted that if a specific student finds their food budget is too low because they purchase more meals away from home due to their schedule, etc., the student can request a professional judgment (PJ) adjustment to the food cost component.
In Dear Colleague Letter GEN-22-15, ED provided the following guidance in COA-Q7:
"Under the new component associated with living expenses for students attending at least half-time, an institution must develop a living expenses allowance for students living at home with parents that cannot be zero. What are some examples of ways for institutions to derive a non-zero amount when the student is not charged for housing or food by the parents?
Aside from any specific requirements outlined in the HEA, institutions have very broad discretion when developing reasonable costs associated with COA elements. For this component, institutions should develop reasonable methods to determine a dollar amount greater than zero for living expenses of students living at home with their parents. This may include costs associated with food when taking in-person classes or participating in internships/externships. Institutions could use surveys or other methods to determine if there are any typical housing costs incurred by students while living at home, such as parents charging rent. Institutions must develop an amount greater than zero that is reasonable and supportable."
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