Can We Include Multi-Year Exam Costs In the Professional Licensure, Certification, Or Credential Cost Component?

Yes. If the licensure, certification, or credential requires an exam, and that exam is taken in multiple parts over multiple academic  years (such as the USMLE, COMPLEX, or other similar exams), then multiple exam costs must be included in the cost of attendance (COA or budget). Effective with the 2023-24 award year, such costs are no longer limited to "one-time" costs.

Additionally, NASFAA has confirmed with 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." The institution cannot add the exam cost that is paid after the student is no longer enrolled, and it does not matter whether the exam is required for graduation.

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