No, the payment can be made in 2020 or 2021 for the room and board. It does not matter when it was billed.
Please make the distribution from the 529 in the name of the student in the year the expense will be paid. It is easiest to have the funds transferred directly to the school if possible.
Payments count if they are paid in the tax year for expenses of that tax year and/or the first three months of the following year.
Room and board expense is NOT listed in Box 1 of the 1098-T. That is ONLY tuition and fees paid to the school.
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