Good morning!

I received an interesting email from my Financial Aid office this morning and discovered that in the 2023‐2024 Federal Student Aid Handbook, in the chapter on Cost of Attendance, there is a new requirement pertaining to the "Costs of obtaining a license, certification, or first professional credential." Namely ‐ we have to include the cost of obtaining said license in the Cost of Attendance.

I'll wait for you to finish screaming...

The handbook states:

For students enrolled in programs that require professional licensure, certification, or a first professional credential, the COA must include an allowance for the costs of obtaining the license, certification, or credential. Examples of allowable costs include fees charged to take a licensing exam, and costs of applying for and obtaining the license or certification. Under this provision, the costs must be incurred during (not after) a period of enrollment, even if the exam is after the end of the period.

Schools may use either actual or average costs when determining the amount of this allowance. If a school chooses to use average costs, it must develop a reasonable basis for the average amount using the actual costs of a first professional credential that the school is aware of for the profession that a program prepares a student to enter.

The allowance may include costs for multiple license or credential test attempts, though schools have discretion to set a reasonable limit on the number of attempts allowed to be included in a student’s COA.

Cost of Attendance for professional licensure is HEA Title IV, Sec 472 (a )(14): “for a student in a program requiring professional licensure, certification, or a first professional credential, the cost of obtaining the license, certification, or a first professional credential.” This may have been in law for a while, the CCA 2021 Act gave ED the authority to regulate sec 472 which they were not allowed to do in the past.

Their initial guidance is: FAFSA® Simplification Act Changes for Implementation in 2023‐24 | Knowledge Center which changes the professional licensing from may include to must include. We can’t ask students to provide documentation that they are incurring the charges so have to make assumptions about who will be incurring the charges, and what the amounts are. See specifically COA‐Q4

What does this mean for me/us: Connect with your Office of Financial Aid TODAY as this is non‐optional. We can use average costs and here at CU Boulder we're looking at either doing an average cost or the cost of a licensing exam in CO ‐ we're having a few discussions right now and will have a solid plan and process by early next week. Either way we're drafting some language that will clearly state that the cost listed is an estimate or only CO and direct students to the professional licensure website in their award letter to find the appropriate state agency.

Happy Friday?

Erika G. Swain
Associate Director for State Authorization
Office of Academic Affairs
University of Colorado System
e: swaine@cu.edu
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Assistant Director for Compliance and Authorization
Office of Data Analytics | Office of Institutional Research
University of Colorado Boulder
e: Erika.Swain@colorado.edu
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o: (303) 735‐8184
c: (518) 637‐9785

“Today I will be a Bulgarian Minister of Education,” Bokonon tells us. “Tomorrow I will be Helen of Troy.” – Vonnegut, Cat’s Cradle