The 529 statutes and rules are ambiguous enough that stuff a lot simpler than this is not addressed. Based on your brief description of your daughter’s program, my advice is to use the school’s undergraduate COA for her first three years, and then use the school’s graduate COA for her senior year when she is taking graduate level courses. In any event, if by “room and board” you mean living in college housing and eating on a college meal plan, you can use 529 money to pay for these qualified expenses up to whatever the school charges.
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