A three-member panel of the D.C. Rental Accommodations Commission, in a precedent-setting move, has ruled that schools that rent apartments to students outside of dormitories must conform to the city rent control laws.

The ruling means students in such apartments who have been paying rent to the schools, above the rent control limit, may be eligible for refunds. Those schools will also be forced to lower their rents to conform with the rent control law, according to Paul Crumrine, an attorney-adviser for the commission.

A survey of four major private universities in the District indicated that only George Washington University would probably be directly affected by the panel's ruling. George Washington owns about 10 buildings within the campus boundaries that serve as student residences. Most of these buildings are managed by private firms.

Crumrine said that city law does not define what a dormitory is. But he said that the ruling, which was handed down Wednesday night, will apply to university-owned or operated buildings that do not have the usual dormitory amenities such as campus security, furnished rooms, resident hall assistants, or those that have a private company managing the building.

The case that led to the ruling was brought by a third-year George Washington University law student whose rent in a university-owned building was increased last year from $180 to $200 a month. The building, Milton Hall at 2222 I St. NW, is managed by the H. L. Rust Co. The commission panel concluded that the building's function was a commercial activity and not a dormitory.

The University can either request a hearing before the full nine-member commission or appeal the decision to the D.C. Court of Appeals, Crumrine said.

One housing official at GW said that if the commission upholds the panel's ruling, "we're going to take a hard look at what a domitory is... this is a major question for D.C. universities."

A public relations spokesperson for George Washington said that in the past six months ended in December, the University had lost about $33,000 on student housing. (The figure does not include about 16 units provided for medical center personnel.) "If we went on the open market," she said, "It's conceivable we could get rent increases. It's not profitable in any event."

According to officials at American, Catholic and Georgetown Universities, the rent control ruling would have little or no impact on their housing situation.