I'm surprised he got his refund at all... usually the IRS hands it over and you get a fun little letter stating that your refund has been redirected to pay for your defaulted student loan.
If your applicant is not a current student enrolled at least half-time (varies by school), I would count the student loans. The deferment period once you graduate or drop out is short. Once the loans are out of deferment, Sallie Mae doesn't care what other bills you have. Not only will you lose your refund, they WILL aggressively garnish.
Ask me how I know, lol.... Lesson learned!