If you ask the IRS they would probably say
"Yes".Here is what the IRS posted as being new in 2016
"For tax years beginning after
June 29, 2015, generally tax year 2016 returns for most
taxpayers, the law requires a taxpayer (or a dependent) to
have received a Form 1098-T from an eligible educational
institution in order to claim the tuition and fees deduction,
American opportunity credit, or the lifetime learning credit.
However, for tax year 2016, a taxpayer may claim one of
these education benefits if the student does not receive a
Form 1098-T because the student’s educational institution
is not required to send a Form 1098-T to the student under
existing rules (for example, if the student is a nonresident
alien, has qualified education expenses paid entirely
with scholarships, or has qualified education expenses
paid under a formal billing arrangement). If a student’s educational
institution is not required to provide a Form
1098-T to the student, a taxpayer may claim one of these
education benefits without a Form 1098-T if the taxpayer
otherwise qualifies, can demonstrate that the taxpayer (or
a dependent) was enrolled at an eligible educational institution,
and can substantiate the payment of qualified tuition
and related expenses."
