When	a	specific	component	of	a	student9s	COA	is	waived	or	explicitly	paid	by	another	source,	special	treatment	may	be
necessary.	In	some	situations,	the	student	is	assessed	the	normal	tuition	and	fees	charge	with	an	offsetting	credit	issued.
In	other	situations,	the	student	is	never	charged	tuition	and	fees	at	all.	Although	this	section	discusses	this	concept	in
terms	of	tuition	and	fee	charges,	it	applies	to	any	of	the	components	of	a	student9s	COA.
In	some	cases,	such	as	under	Workforce	Innovation	and	Opportunity	Act	(WIOA)	programs,	a	student9s	tuition	and	fees	are
paid	by	another	organization	or	are	waived.	The	student9s	costs	are	based	on	what	the	school	is	actually	charging	the
student,	as	specified	in	the	agreement	between	the	school	and	the	student.
If	the	student	is	charged	for	the	tuition	and	fees,	even	if	the	charge	is	eventually	paid	by	someone	other	than	the	student
(e.g.,	a	scholarship	agency	or	other	source	of	aid),	then	that	tuition	and	fee	amount	is	included	in	the	COA	in	most
circumstances.	The	tuition	and	fees	payment	would	then	be	counted	as	OFA.	The	charge	is	documented	in	the	same	way
as	for	any	non-WIOA	student	(for	instance,	in	your	school9s	contract	with	the	student	or	in	the	agreement	with	the	WIOA
agency).	If	your	school	charges	the	student	for	tuition	and	fees,	your	school	would	have	to	expect	the	student	to	pay	the
charge	if	the	WIOA	agency	or	other	source	of	assistance	doesn9t	pay	on	the	student9s	behalf.
If	the	student	is	never	charged	for	tuition	and	fees,	then	the	COA	wouldn9t	include	the	tuition	and	fees	component.	Some
WIOA	agreements	with	schools	provide	that	the	school	can9t	charge	the	tuition	and	fees	to	the	student,	even	if	WIOA
doesn9t	cover	the	costs.	If	your	school	is	prohibited	under	such	an	agreement	from	charging	tuition	and	fees	to	the
student,	then	the	tuition	and	fees	aren9t	included	in	the	student9s	COA,	and,	therefore,	that	amount	would	not	be	included
as	OFA.
Even	if	there9s	no	tuition	and	fees	component,	the	student9s	budget	still	includes	the	other	costs	listed	previously,	such	as
an	allowance	for	living	expenses.	The	option	to	either	include	the	cost	and	aid	in	both	COA	and	OFA	versus	excluding	both
from	COA	and	OFA	only	applies	to	non-federal	sources	of	assistance,	and	only	when	that	assistance	is	designated	to	offset
specific	components	of	COA	(e.g.,	tuition,	housing,	and	food).
WIOA	Reimbursement	Contracts
Some	WIOA	contracts	operate	on	a	reimbursement	basis;	that	is,	the	student	must	fulfill	the	terms	of	the	contract	before
WIOA	will	reimburse	the	school	for	tuition	and	fee	costs.	If	the	student	doesn9t	fulfill	the	terms	of	the	contract,	the	school
is	left	with	an	unpaid	tuition	and	fees	charge.	The	school	isn9t	permitted	to	hold	the	student	liable	for	the	unpaid	tuition
and	fees.	Contracts	are	established	this	way	to	offer	schools	an	incentive	to	properly	train	and	place	students	enrolled	in
the	training	programs.	However,	if	a	tuition	and	fees	charge	is	included	in	a	
Title	IV	aid	recipient9s	budget,	the	student
would	be	liable	for	any	outstanding	charges	that	are	not	reimbursed	by	WIOA.	Therefore,	schools	that	enter	into
reimbursement	contracts	must	remove	the	tuition	and	fees	component	from	the	Title	IV	budget	because,	under	these
contracts,	schools	are	prohibited	from	holding	the	student	liable	for	outstanding	charges.
Effects	of	Waivers	on	COA
If	your	school	treats	a	waiver	as	a	payment	of	tuition	and	fees	that	have	been	charged	to	a	student,	then	the	waiver	is
considered	OFA	and	the	full	amount	of	the	tuition	and	fees	are	included	in	a	student9s	COA.
On	the	other	hand,	if	the	student	is	never	assessed	the	full	charges,	the	waiver	is	not	considered	to	be	financial	aid,	and
only	the	charges	actually	assessed	the	student	would	be	included	in	the	student9s	COA.
Volume	3,	Chapter	2,	Example	1:	Housing	and	Food	Waiver
A	school	saves	some	of	its	resident	assistant	jobs	for	students	with	exceptional	financial	need.	All	resident
assistants	receive	a	waiver	of	housing	and	food	charges.	If	a	student	who	is	employed	as	a	resident	assistant
quits	the	job,	the	waiver	is	removed,	and	the	student	must	pay	the	housing	and	food	charges.	All	students	at	the
school	have	housing	and	food	charges	in	their	COA.	For	students	who	are	resident	assistants	because	of	their
financial	need,	the	school	must	count	the	housing	and	food	waiver	as	OFA.	The	waiver	would	not	be	counted	as
untaxed	income,	but	if	included	in	the	student9s	adjusted	gross	income	(AGI),	such	a	waiver	would	be	reported	on
the	Free	Application	for	Federal	Student	Aid	(FAFSA®)	form	as	<grant	and	scholarship	aid	reported	to	the	IRS=	and
would	be	excluded	from	total	income	in	the	SAI	formula.
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