Are We Required To Have Separate COAs For Students In Different Living Arrangements?

Yes. Under Section 472 of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087LL], at a minimum, the school is required to have different, separate costs of attendance (COAs) for the following:

1. Students without dependents residing in institutionally owned or operated housing;
2. Students with dependents residing in institutionally owned or operated housing;
3. Students living off campus and not in institutionally owned or operated housing;
4. Dependent students residing at home with parents;
5. Students living in housing located on a military base or for which a basic allowance for housing (BAH) is provided under 37 USC 403(b); and
6. All other students.

Of course, if the school does not offer on-campus housing, then that school does not need to have a COA for #1 and #2 above.

This means the school will want to adjust its methodologies for developing each COA. For example, if the school uses a student survey to derive living expenses (food and housing), then the school will want to make sure its COA survey reflects the different COAs and accurately collects living expenses for students within each separate COA.

See Dear Colleague Letter GEN-22-15. Since the Dear Colleague Letter is generally worded in some cases, it will be helpful to review the statutory text cited above.

Note: With the exception #2 and #3 above, this requirement to have separate COAs is not new.