According to the IRS interpretations and rulings, "students" are defined as anyone receiving instruction or training through a bona fide university educational program.

In addition to undergraduate and graduate students, the term "students" includes the interns and residents of a university teaching hospital.

Doctors, nurses, medical technologists and technicians and other allied health professionals may also be considered students of a teaching hospital if they are receiving recurrent or additional instruction in their respective fields such as through a continuing education program.