Which Cost Components Must Be Included Up Front When Constructing the Cost of Attendance?

Award Year: 2023-24 KA-36457 Helpfulness Rating 5,432 page views

This guidance is specific to the 2023-24 award year and later.

The following cost components must be included when constructing the student's cost of attendance (COA or budget), rather than added later only upon the student's request:

The following cost components must be added for students upon request or if the school has another way of identifying those students and assigning the cost component when constructing the COA, as applicable:

Special Populations: The cost components for students engaged in a program of study by correspondence must include only:

The cost components for confined or incarcerated students must include only:

The cost of attendance for less-than-half-time students must include only:

Under the statute, food and housing may be (but are not required to be) included for a less-than-half-time student up to three semesters, or the equivalent, with no more than two semesters being consecutive, if the student has such costs. Miscellaneous personal expenses cannot be included for less-than-half-time students.

Personal Computers: Whether the school includes the cost of the rental or purchase of a computer up front when constructing the student's COA depends on the school’s own policy for documenting that rental or purchase. See AskRegs Knowledgebase Q&A, Are We Required To Include the Cost Of a Personal Computer In the Cost of Attendance? (Award Year: 2023-24)

May or Must? Dear Colleague Letter GEN-22-15 is generally worded and uses the word "may" in several instances when the cost component is actually required. NASFAA has confirmed the above usage of the terms “may” or “must” with the U.S. Department of Education (ED).

Cost Components Must Be Separate: Note that each of the above cost components must be separate components within the COA. For example, the allowances for transportation and miscellaneous personal expenses can no longer be lumped together. Likewise, the nontuition and fees components cannot be combined into a single cost component, and so on. There is an exception in which the school can incorporate books, course materials, supplies, and equipment as part of their tuition and fees only as long as it meets the requirements under 34 CFR 668.164(c)(2).

Review the Statutory Text: It will be helpful to review the Amendment of Section statutory text in Section 472 of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087LL].

See also AskRegs Q&A, Are We Required To Have Separate COAs For Students In Different Living Arrangements? (Award Year: 2023-24) 

AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.