529 Funding, Room and Board for Students Living at Home and A Couple of Curve Balls

[Curious One]

I'm trying to determine how much of my children's 529 accounts I can use for room and board expense, if any.  

My son is a part-time student at a local college and lives at home.  I have the figures from the college for COA R&B for students who live at home, but I don't know if funding these expenses via a 529 is subject to minimum course hours per term or any other determinant of matriculation status.  

I also have a daughter who is at the same college.  She is attending as an early admit student through her high school.  She has not yet graduated from HS, but is attending the college full-time and completing any necessary HS credits through the coursework she is taking at the college.  She has a college ID and she registered at the college for the coursework.  Presumably this means that she was admitted, and that seems to be borne out given her status as an early admission student, but I'm not entirely sure about this point.  She, too, lives at home.  The same COA R&B figures are applicable, but in this instance the question is whether she should be seen as a college student or a HS student.  Presumably if she can be treated as a college student, there isn't any issue in funding R&B out of her 529.  

If R&B funding is appropriate, can I take R&B for both of them from each of their 529s?

Thoughts?  Comments?  Other considerations?

[Hal_Al]

The student must be half time or more, in order for room and board to be considered qualified expenses for a 529 plan distribution. 

If the student lives at home, you may use the school's Cost of attendance figure for board, for a 529 distribution.   You may not claim "room" expense.

You daughter must be officially enrolled as a degree candidate to claim any college expense for a 529 plan.  The school should be able to tell you her status.  Some schools will not  admit students to a degree program if they do not  have a high school diploma or equivalent. 

[Curious One]

Again, a helpful response.  I have a bit of homework to do to find out both degree and F/T, P/T status for both of them.  That said, per college website, COA for R&B for students living with parents is 3861, while for those living independently it is 9750.  I guess the difference between the two is the "room" expense?

[Hal_Al]

I suspect the $3861 is all board.  I would use that number, since the school specifically identifies it as "for students living with parents".   

In pub 970, the degree requirement only  appears in the  credits and deductions section.   In the 529 plan section, only the word "enrolled" is used. 

[dhaag23]

I know this is a few years old now, but I don't see anything about room not being allowed but board being allowed as a qualified expense. All references in Pub 970 refer to both room and board being qualified. Has the law changed or am I missing something?

[DaveF1006]

It depends what you are referring to. Room and Board is not a qualified educational expense to determine your educational credit but is a qualified expense to use your 529 plan to pay for these expenses. 

Please review this link for further information regarding 529 Plan rules.  

@dhaag23 

[Hal_Al]

The rationale is this: board is not a fixed cost.  The student has to eat wherever he is living.  The costs of the parents home, "room", is fixed. Neither the parents or the student are out of pocket, for room, when the student lives at home.

But, you are right, you won't  find that in Pub 970.  But, the bottom line is: you are limited to the school's "allowance for attendance" (or "allowance for cost of attendance") which is usually less for students living at home. 

[prc99]

If my daughter wasn't attending community college, worked full time, but still lived at home, we would ask her to pay something to cover both her food AND the fact that she's living in a room we could use for something else, though not at market rates (e.g. maybe $300/month for housing plus actual food costs). 

Our community college lists an amount for "housing" that is about $3600 per school-year ($400/month if you figure 9 months) -- in addition to over $4000/school-year for food. 

So why can't we withdraw $300/month from her 529 Savings to cover her housing costs (in addition to her actual food costs), since her being in school full time is what's keeping her from being able to "pay her own way" for using our extra room, sharing the bathroom, having access to the rest of the house, etc.?

[Hal_Al]

Q. So why can't we withdraw $300/month from her 529 Savings to cover her housing costs (in addition to her actual food costs)?

A. You are limited to the school's "allowance for cost of attendance",  for students living at home; which is usually less than the school's actual charge for on campus students.