1. Jamie A. Malone | Dec. 2013 U.S. Department of Education 2013 FSA Training Conference for Financial Aid Professionals Foreign Schools Cost of Attendance Session #46

2. General Considerations 2

3. Where is COA in the Awarding Process? Cost of Attendance −EFC Financial Need COA varies by institution and program EFC stays the same at every school School tries to meet the student’s need 3

4. COA Theory Used to determine students’ eligibility for Direct Loan Sets a limit on total aid a student may receive Provides students with a projection of what costs will be Should be reasonable and realistic Does not imply that all costs will be funded Generally established through development of standardized COA 4

5. COA Theory COA is not intended to account for all expenses a student may incur in deciding to pursue a degree overseas Only those COA components specified in statute COA is for the student, not the student’s family Allowance for maintenance of a family is via the Income Protection Allowance (IPA) which offsets the student’s total income in the EFC Formula COA should allow the student to live reasonably as a student The institution, not the student, determines maintenance levels and how they translate into dollar amounts in the COA Use of standardized cost (while not required) is a best practice 5

6. Period of Time Covered by COA COA represents costs over a specific period of time Student’s aid (Direct Loan) is “packaged” for the period of time covered by the that student’s COA. Generally the academic year, e.g. fall/spring Could be a single term COA may only include those costs associated with a given period of enrollment 6

7. Use of Standard Cost Components Allows for use of averaged costs Facilitates packaging large numbers of students Establishes an overall framework for costs  More standard and useful to students looking at program costs than COA constructed on a student-by student basis 7

8. Averaging Expenses You may use average rather than actual expenses Must be averaged for students with the same enrollment status  Example: Using an average tuition and fees amount for all full-time students as opposed to the actual tuition and fees for each individual student You may have different standard costs for different categories of students If standard cost categories are established, you must apply cost allowances uniformly to all students in those categories 8

9. Averaging Expenses You cannot combine COA figures for different enrollment statuses Extra costs for certain programs may be accounted for even with standard costs components  Example: Lab fees for certain science courses 9

10. COA Components Overview COA is defined in the law (Higher Education Act, Section 472) Not subject to regulation by the Department Law specifies the types of costs included in the COA If a cost is not mentioned in the prescribed categories, it is not to be included in COA You must determine the appropriate and reasonable amounts to include for each eligible COA category at your institution 10

11. No Charge vs. Waivers Tuition amounts and/or fees provided free of charge are excluded from the student’s COA Tuition amounts and/or fees that are charged and then waived are included in the student’s COA The amount of any waiver is considered Estimated Financial Assistance (EFA) in determining the students eligibility for Direct Loan Room and board supplied at no charge is excluded from the COA Room and board that is charged and then waived is included in the COA  Amount of the waiver is considered EFA 11

12. Statutory Components 12

13. Tuition and Fees Tuition and fees are those normally assessed for a student carrying the same academic workload as determined by the institution May include cost of rental or purchase of equipment, materials or supplies required of all students in the same program of study Actual or average tuition charges may be used 13

14. Tuition and Fees COA may include a wide range of fees Fees are those required of all students in a given program of study  May include health insurance fee assessed all students in a program of study even if those fees are waived for those who can document they are insured  May not include health insurance for family members 14

15. Book and Supplies Cost of educational materials related to the student’s program of study Should not duplicate any costs already included under tuition and fees Consider separate allowance for students in programs with exceptionally high book costs e.g., art or engineering 15

16. Allowance For Personal Computer Reasonable amount for the documented purchase or rental of a computer suitable to student’s needs in a program  Not intended to cover whatever computer a student may want Maybe included as a standard amount in students’ COA  May be different cost for different categories of students  May be purchased in summer for use in fall School may require that student document need for computer Institution has flexibility and options  May be included on a yearly basis  May be allowed only once  May be allowed once with a set amount for annual upgrade 16

17. Transportation Cost of student’s daily commute to attend class  Generally public transportation if not housed on campus Cost of travel necessary to complete course of study Costs of operation and maintenance of a car, if needed  Is it necessary for educational purposes?  Government established mileage allowances are a good guide Cost of travel between student’s permanent residence and the institution  School determines how many trips are reasonable  May be average or actual per student May not include the expenses for the student’s family to travel 17

18. Miscellaneous/Personal Expenses Clothing, laundry, personal hygiene etc. Reasonable allowance for leisure/recreation  Based on living as a student  Not inclusive of needs of student’s family  Not meant to supplement tourism activities 18

19. Room and Board Students without dependents living at home with parents Institutionally determined allowance Students living on campus Standard amount normally assessed most residents for room and board Students living off campus and not with parents Reasonable allowance for student to rent living space off campus Average cost of apartment rentals in the city/geographic area Inclusive of estimated amount for meals Any allowance is for living arrangements suited to a student lifestyle 19

20. Dependent Care Allowance For students with dependents, an allowance for costs expected to be incurred for dependent care Covers periods including but not limited to class time, study time, field work, internships and commuting time Based on the number and age of dependents Should not exceed the reasonable cost in the community for the type of care provided 20

21. Professional License Allowance for the one-time direct costs of obtaining a first professional license or certificate for students enrolled in a program that requires such licensure or certification  Fees required to take a licensing exam  Costs of applying for and obtaining the license or certification  Costs incurred in travelling to a residency interview for medical students Provided one time per student per eligible academic program Costs must be incurred during the period of enrollment even if the exam is after the end of the period 21

22. Disability-Related Expense Reasonable allowance for costs related to the student’s disability  Special services  Personal assistance  Transportation  Equipment  Supplies Must be expenses not covered by another agency 22

23. Cooperative Education Program Reasonable allowance for costs associated with such employment May include commuting, meals, transportation or other reasonable expenses 23

24. Loan Fees For students receiving loans, the fees associated with the loan, Direct Loan and non-federal loans Exact fees or an average of fees charged to borrowers of the same type of loan at your school To be included in COA, loan fees for private loans must be charged to the borrower during the period for which the loan is intended 24

25. Professional Judgment 25

26. Professional Judgment Institutions have the statutory authority to use professional judgment to adjust the COA Adjustments must be done on a case-by-case basis to allow for special circumstances of an individual student  Cannot make same adjustment for category of students Adjustments cannot be made to circumvent the law Adjustments must be documented in the student’s file Professional judgment is not a vehicle for students to appeal the living standards deemed appropriate by the institution and reflected in the standard COA 26

27. Professional Judgment Institutions are never required to exercise professional judgment School’s decision cannot be questioned by auditor who does not agree  May be disallowed if not done on a case-by-case basis or not properly documented Student has no appeal rights Authority to make professional judgment adjustments may reside with a single person, several people, or a committee Be fair but judicious 27

28. Professional Judgment Examples of special circumstances may include:  Unusually high travel expenses  Special dietary needs  Lack of housing options at costs in-line with standard allowances  Need for specialized computer equipment 28

29. ED Contact Information Presenter Jamie A. Malone 1-312-730-1528 jamie.malone@ed.gov Foreign Schools Team E-mail: FSA.Foreign.Schools.Team@ed.govFSA.Foreign.Schools.Team@ed.gov Phone: 1-202-377-3168 Fax:1-202-275-3486 29

30. QUESTIONS? 30