Is the summer program at Middlebury College? Middlebury is an eligible educational institution, but I don't know if this designation applies to their summer immersion language programs. Do you know if a program participant can apply for a federal direct loan for program expenses? That might provide a clue about the program being a qualified 529 expense, and so would finding out whether or not she can earn PSU credit. Will the program consider her to be enrolled as at least a half-time student while attending the program? If no, that ends any discussion on room and board for the summer program being a 529 qualified expense. Finally, you can use the 529 money for anything you want, so if it comes to needing the money to pay for the language program, you can do it. Just know that if the program is not a 529 qualified expense, there will be tax owed on the earnings part of a 529 distribution used to pay for the program, plus a 10% penalty (unless an exception to the penalty applies).