How Do We Determine the Cost Of Attendance Allowance For Three Meals Per Day?

How the institution establishes the cost of attendance (COA) allowance for food is entirely up to the institution. Neither the statute nor the U.S. Department of Education (ED) prescribes how an institution establishes the food allowance. The institution should use its own discretion to develop and document any reasonable methodology that supports the equivalent of three meals per day to meet the requirements under Section 472(a) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087LL(a)]:

"For the purpose of this subchapter, the term "cost of attendance" means-
***
(5) an allowance for living expenses, including food and housing costs, to be incurred by the student attending the institution on at least a half-time basis, as determined by the institution, which shall include-

(A) for a student electing institutionally owned or operated food services, such as board or meal plans, a standard allowance for such services that provides the equivalent of three meals each day;

(B) for a student not electing institutionally owned or operated food services, such as board or meal plans, a standard allowance for purchasing food off campus that provides the equivalent of three meals each day;..."

The food allowance can include actual or average costs and can be determined in a variety of ways, including but not limited to:

• Using existing meal plan costs that reasonably reflect the costs incurred by students or categories of students:
• Surveying the student population, or categories within the student population;
• Using local, regional, or national governmental data to determine food costs in the school's geographical area; or
• Any other reasonable methodology, as determined by the institution.

Can we use our 21-meal-plan cost for both our on-campus and off-campus students?

It depends. A longstanding principle of COA construction is that the cost component must reasonably reflect the costs incurred by a group of students within a cost component. If the school's 21-meal-plan cost reasonably reflects what on-campus students pay for food (whether they participate in the meal plan or not), then using the 21-meal-plan cost would seem to be an appropriate way to establish the on-campus food allowance. If most of the school's on-campus students do not participate in the meal plan and, instead, eat off-campus or at non-meal-plan on-campus vendors at lower prices, then the 21-meal-plan cost might not accurately reflect what most on-campus students pay for food--in which case, the school would need to come up with another way of constructing the food allowance, such as surveying on-campus students or using some other method.

If the school's on-campus 21-meal-plan cost accurately reflects what off-campus students pay for food, then using the 21-meal-plan cost would seem to be an appropriate way to establish the off-campus food allowance. However, if the 21-meal-plan cost does not accurately reflect what off-campus students pay for food, then the school will need to come up with another way of constructing that cost component, such as surveying off-campus students or using some other method. 

What if we don't offer a meal plan that includes three meals per day?

Here again, the school will have to come up with a reasonable methodology for estimating those costs. While the school is not required to offer a 21-meal plan, it might extrapolate a figure using an existing meal plan that represents what most students incur for food. For example, the school could calculate the cost per meal under its existing meal plan and then multiple that per-meal cost by 21. The school also could choose to survey its students to establish the allowance, or to use any other reasonable method at its disposal.

Can we still use different food allowances for different categories of students, such as on-campus and off-campus students?

Yes, if that is what it takes to accurately reflect the food costs of on-campus versus off-campus students at the equivalent of three meals per day.

Are we required to document how we came up with the food allowance? Yes. Whatever method the school uses must be documented in its policies and procedures. This should include how the school developed the method and how the food allowance reasonably reflects food costs incurred by its students, or within categories of students.

If students have special dietary needs for medical, religious, or personal reasons (e.g., diabetic, kosher, vegetarian, etc.), these requirements can be addressed using professional judgment (PJ) on a case-by-case basis with documentation.

Reference Dear Colleague Letter GEN-22-15. See also AskRegs Knowledgebase Q&A, Must Schools Include the Cost Of Three Meals Per Day In the Cost Of Attendance For a Dependent Student Living With Parents? (Award Year: 2023-24)