This seems to be how Penn does it (see table below from their web site). They have three categories of COA used for calculating EFC. They definitely consider off-campus housing and dining as part of the COA, but this sounds like it’s highly school-specific.
| Living On Campus | Living Off Campus | Living With Family | |
|---|---|---|---|
| Tuition | $54,652* | $54,652* | $54,652* |
| Fees | $7,058* | $7,058* | $7,058* |
| Housing | $11,358* | $9,632 | $0 |
| Dining | $5,946* | $4,870 | $1,948 |
| Books and Supplies | $1,358 | $1,358 | $1,358 |
| Transportation | $922 | $984 | $1,566 |
| Personal Expenses | $2,004 | $2,004 | $2,004 |
| Total Budget | $83,298 | $80,558 | $68,586 |