Will We Be Able To Package Above the COA If There Is a Negative Student Aid Index?

No. The U.S. Department of Education (ED) has shared at NASFAA's 2023 Leadership & Legislative Conference & Expo that schools cannot package above the cost of attendance (COA) if the student has a negative student aid index (SAI). Further, according to Dear Colleague Letter GEN-23-11:

"An applicant may receive a negative SAI as low as -1,500. When packaging students for need-based Title IV aid (Federal Pell Grant, Federal Supplemental Educational Opportunity Grant (FSEOG), Federal Work-Study (FWS), and Direct Subsidized Loan programs), convert any negative SAIs to a 0 SAI for awarding purposes. For example, consider an applicant with a $15,000 COA, a -500 SAI, and a $7,395 Federal Pell Grant. When calculating remaining need for other need-based programs, the school will change the -500 to 0 in the need-based calculation referenced above. The student’s remaining need will be $7,605 ($15,000 – 0 – $7,395 = $7,605).

Note that a negative SAI converted to 0 will also not increase a student’s eligibility for non-need-based aid."

See also OFA-Q1/A1 and OFA-Q2/A2 in the U.S. Department of Education's (ED's) FAFSA Simplification Questions and Answers.

According to ED, other pre-2024-25 general packaging rules will not change as it relates to exceeding the COA:

• Except when the student is receiving a Federal Pell Grant, if non-Pell Title IV aid is in the student's financial aid offer (package), you cannot package over the COA and must first adjust other forms of Title IV aid and/or other forms of aid over which the school has control to prevent the overaward.
• If there is only Pell and non-Title IV aid in the student's package, there is the exception noted in AskRegs Q&A, Does Aid Need To Be Reduced If Institutional Or Athletic Aid Plus a Federal Pell Grant Exceed the COA?
• If the student is only receiving non-Title IV forms of aid, non-Title IV aid can exceed the COA because the COA is a Title IV concept and only applies when Title IV aid is involved. See the above-referenced Q&A.

Disclaimer: The above guidance and NASFAA's understanding are subject to change when ED releases guidance for 2024-25.

Refer to NASFAA's FAFSA Simplification Web Center for additional resources and NASFAA's complete coverage of changes to Title IV federal student aid under the FAFSA Simplification Act.