How Are Resident Assistant (RA) Positions Treated For Title IV Purposes?

Award Year: 2024-25 KA-36667 Helpfulness Rating 326 page views

This guidance is specific to the 2024-25 award year and later. For 2023-24* award year guidance see AskRegs Q&A, How Are Resident Assistant (RA) Positions Treated For Title IV Purposes?

There are a few things to consider in regard to the Resident Assistant (RA) position.

RA positions often contain both a stipend and a housing/food component. You first need to check with your human resources (HR) department to see if the stipend, housing, and/or food award is considered employment under federal or state law.

Not Employment: If the stipend, housing, or food award is not considered employment, it is treated as other financial assistance (OFA). (See below for alternate treatment of the housing and food components.)

Employment: If the stipend, housing, or food is considered employment, you need to determine if the stipend, housing, or food was awarded to the student based on any form of need analysis (federal or otherwise). If the stipend, housing, or food award is employment awarded based on need, the amount of the award is treated as OFA (or alternate treatment below for room and board). If the stipend, housing, or food award is employment but not awarded based on need, the award is not treated as OFA; it is income and it will appear as income on the applicable year’s tax return and FAFSA (if one is filed). Whether it is then taxable income at the time the tax return is filed is a question for your HR department or a tax expert; this is not NASFAA's area of Title IV expertise.

Alternate Treatment of Housing and Food: If the housing and food award is not considered employment, or if it is considered need-based employment, it can be treated in one of two ways:

  1. It can be treated as OFA without an adjustment to the housing and food components of the student’s cost of attendance (COA); or
  2. It can be treated as a direct offset to the housing/food components of the COA--that is, you can reduce the COA housing/food component by the amount of the housing/food award and not treat the housing/food award as OFA.

[34 CFR 685.102(b); 673.5(c) Estimated financial assistance.] Effective with the 2024-25 award year, estimated financial assistance (EFA) becomes other financial assistance (OFA).

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