(NCAA)	have	voted	to	expand	their	athletic	scholarships	to	cover	the	full	COA	for	athletes.	Previously,	only	the
components	listed	under	<Allowable	Costs	in	General=	in	this	chapter	were	included	in	COA.	This	change	only	applies	to
the	schools	in	the	Power	Five	but	it	may	be	adopted	by	other	schools	participating	in	Division	I	athletics	at	their	discretion.
One	exception	to	the	full	cost	COA	is	the	practice	of	a	school9s	paying	the	costs	of	an	athlete9s	insurance	against	injury	to
protect	against	loss	of	future	income.	This	expense	may	not	be	included	in	COA	(because	it	is	not	related	to	a	student9s
educational	program),	but	it	is	included	as	other	financial	assistance	(OFA)	for	the	student	in	the	aid	packaging	process.
For	packaging	guidance,	see	Chapter	3	of	this	volume.
Exclusion	of	State	Aid	From	COA	and	OFA
If	the	source	of	assistance	is	a	state	and	is	designated	by	the	state	to	offset	a	specific	component	of	the	student9s	COA,
the	amount	of	that	assistance	may	be	excluded	from	both	COA	and	OFA.	You	may	exclude	such	assistance	on	a	student-
by-student	basis,	but	if	it	is	excluded,	it	must	be	excluded	for	both	COA	and	OFA.	If	the	amount	excluded	is	less	than	the
allowance	provided	in	the	student9s	COA,	you	must	exclude	the	lesser	amount.
Costs	for	Programs	That	Become	Eligible	in	the	Middle	of	a	Year
When	awarding	aid	from	programs	other	than	the	Direct	Loan	Program,	you	may	not	count	toward	the	student9s	COA	any
costs	incurred	in	any	payment	period	prior	to	the	payment	period	during	which	the	program	gained	
Title	IV	eligibility.
When	awarding	aid	from	the	Direct	Loan	Program,	you	may	not	count	any	costs	incurred	in	periods	of	enrollment	(loan
periods)	prior	to	the	period	of	enrollment	during	which	the	program	gained	eligibility.	This	means,	for	example,	that	if	a
program	becomes	eligible	in	the	spring	semester	of	a	fall-spring	academic	year,	you	can	only	include	costs	incurred	in	the
spring	semester	when	awarding	aid	from	programs	other	than	the	Direct	Loan	Program.	However,	if	you	originate	a	Direct
Loan	for	a	loan	period	covering	the	full	academic	year,	you	can	include	costs	incurred	during	both	the	fall	and	spring
semesters	when	determining	the	amount	of	the	loan.
You	may	also	not	include	any	costs	incurred	in	payment	periods	(for	non-loan	programs)	or	periods	of	enrollment	(for
Direct	Loans)	that	the	student	has	already	completed.	For	more	details	on	how	programs	gain	Title	IV	eligibility,	see
Volume	2,	Chapter	5	of	the	FSA	Handbook.
Changes	in	Pell	Grant	COA
For	guidance	on	when	changes	in	the	Pell	Grant	COA	require	you	to	recalculate	a	student9s	Pell	Grant	award,	see	
Volume
7,	Chapter	7.
Costs	Waived	or	Paid	by	Other	Sources
Exclusion	of	State	Aid	From	COA	and	OFA
HEA	Section	480(j)(3)
DCL	GEN-06-05
Change	From	<EFA=	to	<OFA=
Dear	Colleague	Letter	GEN-23-11
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