Exploring How Institutions Build Their Cost of Attendance
The FAFSA Simplification Act greatly expanded the Department of Education’s authority by permitting it to regulate how institutions build their Cost of Attendance (COA) estimates. There have also been recent legislative proposals that would codify limitations on institutions’ discretion to construct a COA that best meets the needs of their unique student populations. While the Department of Education (ED) has not indicated that it plans to regulate COA in the near future, NASFAA felt it was worthwhile to proactively explore how institutions currently build COAs and offer considerations for stakeholders in this area.
As detailed in this report, NASFAA undertook a mixed-methods study to examine how institutions construct their COA. This work included a targeted survey of financial aid administrators, focus groups, and one-on-one interviews with institutional and state-level experts. The project aimed to document current COA development practices, identify common challenges, and elevate the perspectives of financial aid professionals responsible for constructing COA.
This research revealed consistent patterns across institutions and sectors while also highlighting variations based on institutional mission, capacity, and regulatory context. The findings detailed in the report offer timely insights for policymakers considering federal regulation of COA and provide practical considerations for institutions and professional associations to improve COA development practices.
Publication Date: 11/6/2025
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