Refunded 529 funds

[Xavier91]

My child just started her first year at college.  She decided last minute to change from living on campus to commuter status however the bill for on-campus room and board was already paid for with 529 funds.    A refund was just received by my child for $7500. 

I'm not planning to return the funds to the 529 plan for several reasons.  Does the following make sense?

1.  I'm planning to use the 2025-26 Cost of Attendance expenses provided by the college.  When living with parents it's $5,166 for food and $1000 for housing.  But that is for the full school year.  How do I clearly (for my records) distribute the COA allowance?  Half for 2025 and half for 2026?

2.  I do not want to charge my child rent because then I would have to claim that as income and defeats the purpose of the tax shelter.  But it sounds like the food expenses are legit.  Can I add on proportional monthly housing expenses other than rent?   Such as her direct proportional use of utilities (quite expensive), homeowners insurance, maintenance and upkeep, etc.)

3.  Do I need to record the actual food expenses, or do I need to contact the school to understand their "living with parent" calculations?  Or is it better to keep it simple and use COA provided by the college for my records?

4.  The refund check was sent to my child.  Does it matter from a reporting standpoint if she signs it over to me?  She is our dependent.

5.  Whatever remains from the refund as non-qualified for 2025, I am planning to use toward the 2026 spring semester tuition which needs to be paid in December 2025.

Lastly, this is my first time using the 529.  How well does the TurboTax questionnaire handle a refund other than asking for my 1099-Q?

Thanks in Advance!!

[Hal_Al]

Q.  How do I clearly (for my records) distribute the COA allowance?  Half for 2025 and half for 2026?

A. Yes.

Q.   Can I add on proportional monthly housing expenses other than rent?   Such as her direct proportional use of utilities (quite expensive), homeowners insurance, maintenance and upkeep, etc.)

A. Yes

Q.  Do I need to record the actual food expenses?

A. Technically, yes. But, you'll probably never need it.

Q. Do I need to contact the school to understand their "living with parent" calculations?

A. No.

Q. Or is it better to keep it simple and use COA provided by the college for my records?

A. Yes.  Bottom line: The IRS usually accepts the school's  COA number.

Q.  The refund check was sent to my child.  Does it matter from a reporting standpoint if she signs it over to me?  

A.  No.   Technically, the refund should go to the "recipient" of the 529 distribution. What she does with it (if it is not re-contributed), doesn't matter. 

Q.  Whatever remains from the refund as non-qualified for 2025, I am planning to use toward the 2026 spring semester tuition which needs to be paid in December 2025. 

A. That is allowed. 2026 Tuition (or other 2026 expenses), that are actually paid in in 2025 can be counted toward a 2025 529 distribution. 

Q.  How well does the TurboTax questionnaire handle a refund other than asking for my 1099-Q?

A. Fairly well. You must enter the info carefully.  You can get help, in this forum, or from TT experts, if you have trouble.  Since you are  still using the distribution for qualified expenses, you can avoid mentioning the refund, to keep it simple.