529 and study abroad

[siremonger]

My daughter is doing a study abroad semester.  She is using IFSA, a third-party private provider, to arrange the semester. IFSA is not listed as a qualified educational institution on the federal list.  However, my daughter will receive a University transcript (from the overseas institution), which will be transferred to her home school to count towards graduation requirements.  The overseas University and my daughter's home school are both on the federal list. Does this mean that the cost of the semester (tuition and board) can be paid from the 529?  If so can we pay IFSA directly or do we need to issue the 529 withdrawal to my daughter who then pays IFSA?

Note: Her 529 is a California plan ScholarShare 529 (it is eligible for tuition a board). I contacted the plan but they didn't if this withdrawal  is an eligible withdrawal.

[SusanY1 · Accepted solution]

For a study abroad program, the "host school" must be an approved provider for a qualified 529 plan withdrawal.  It is my understanding that IFSA is not a host school, but that doesn't mean that there isn't one at play in the arrangement. 

I would check with your daughter's home school to see if they can tell you if there is a host school that would qualify.  If there is, then it is likely any other aid that she would normally receive at her home school is transferable to the school abroad - and this would offer some reassurance that the program she's in is qualifying for the 529 distribution purposes. However, if IFSA is simply arranging for her admission to the foreign university and facilitating the program, transfer of credits, etc. then the direct enrollment in the other program may not count fir a qualified withdrawal. 

  
EDIT: [4/16/24 6:50 PM PDT]  After a little more digging into IFSA, it appears that they are able to help many students use various forms of federal financial aid abroad.  What isn't clear to me is the methods used to achieve this. If the program for your student is eligible for federal financial aid, then it will also be qualified for 529 withdrawal purposes.   I would try to confirm this with IFSA, if possible, but it seems more likely than not (though not guaranteed) that the withdrawals would be qualified.