COA	for	a	Distance	Education	Student
The	law	prohibits	you	from	making	a	distinction	based	on	the	mode	of	instruction	when	determining	the	COA	for	a	student
receiving	all	or	part	of	their	instruction	through	distance	education.	However,	you	have	the	authority	to	use	professional
judgment	to	adjust	the	COA	on	a	case-by-case	basis	to	allow	for	special	circumstances.	For	example,	you	may	exclude
transportation	costs	if	you	determine	that	such	costs	will	not	be	incurred	by	a	student.	Such	adjustments	must	be
documented	in	the	student9s	file.	See	<Professional	Judgment=	in	Chapter	5	of	the	Application	and	Verification	Guide	for
further	guidance.
Costs	for	Full	Program	Charged	at	Start
A	school	may	charge	the	total	tuition	cost	for	a	program	at	the	beginning	of	the	first	period	of	enrollment.	If	the	program
is	longer	than	an	academic	year,	for	Direct	Loans	and	Campus-Based	aid	the	tuition	costs	apply	only	to	the	first	period	of
enrollment.	For	example,	if	a	school	charges	the	entire	$10,000	tuition	cost	for	a	program	up	front,	the	$10,000	will	be
included	in	the	first	academic	year9s	COA	when	packaging	Direct	Loans	and	Campus-Based	aid	but	would	not	be	included
in	the	second	academic	year9s	COA	components.	For	Pell	Grants,	you	must	prorate	these	charges	to	reflect	the	academic
year	in	accordance	with	the	procedures	outlined	in	
Volume	7.
See	also	the	example	of	apportioning	costs	that	are	charged	up	front	in	Volume	4,	Chapter	2	of	the	FSA	Handbook.
However,	it9s	important	to	understand	that	the	example	in	Volume	4	illustrates	prorating	total	costs	that	are	charged	up
front	for	purposes	of	determining	the	amount	of	aid	that	may	be	credited	to	a	student's	account	and	the	amount	that
must	be	paid	to	the	student	as	a	credit	balance.	This	is	a	separate	issue	from	the	determination	of	the	COA	that	would	be
used	in	calculating	the	specific	aid	amounts	that	the	student	is	eligible	to	receive.
Campus-Based,	TEACH	Grant,	and	Direct	Loan	Programs:	Costs	Based	on	Actual	Period	of	Enrollment
As	explained	earlier	in	this	chapter,	the	COA	for	Pell	Grants	is	always	based	on	the	full-year	costs	for	a	full-time	student
(see	Volume	7	for	more	information).	In	contrast,	the	COA	used	to	package	Campus-Based	aid,	TEACH	Grants,	and	Direct
Loans	is	for	the	student9s	actual	period	of	enrollment.	Therefore,	if	the	period	of	enrollment	for	which	a	student9s	aid	is
intended	is	longer	than	the	9-month	academic	year	for	which	costs	are	normally	determined,	you	must	use	a	higher	COA
that	includes	living	expenses,	such	as	food	and	housing,	for	the	longer	period	of	time.	If	the	student	will	be	attending	for
less	than	nine	months,	you	must	use	a	lower	COA.	You	can	choose	to	prorate	the	allowances	you	use	for	nine	months,	or
you	can	calculate	the	cost	in	any	other	reasonable	way.
As	an	example,	if	a	student	is	completing	a	program	of	study	by	taking	a	half-time	course	load	for	the	fall	semester	at
your	school,	and	that9s	the	only	term	that	the	student	will	be	attending	in	the	award	year,	you	could	use	the	actual	tuition
and	fee	charges	for	the	student9s	costs.	If	you	use	average	costs	for	living	expenses	for	a	9-month	academic	year	for
students	in	that	program,	you	may	divide	your	average	costs	by	the	number	of	terms	in	the	academic	year	to	find	the
Volume	3,	Chapter	2,	Example	2:	In-State	Tuition	Voucher
A	school	charges	all	full-time	students	the	same	tuition	charge.	However,	in-state	students	receive	a	voucher	to
cover	the	difference	between	what	most	states	consider	in-state	versus	out-of-state	tuition.	The	school	has	two
options:
The	first	option	would	be	to	include	the	same	tuition	charge	in	the	full-time	COA	for	all	students	and	include
the	amount	of	the	voucher	as	OFA	in	the	financial	aid	packages	for	in-state	students.
The	second	option	would	be	to	exclude	the	amount	of	the	voucher	from	both	COA	and	OFA	because	the
voucher	must	be	used	to	explicitly	pay	a	specific	component	of	the	COA.
Regardless	of	the	option	the	school	chooses,	it	must	apply	the	option	consistently.
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