HOOSIER JUDGMENTM E L I N D A M I D D L E T O N

D I R E C T O R - R O S E - H U L M A N I N S T I T U T E O F T E C H N O L O GY

L E O H E RT L I N G

A S S O C I AT E D I R E C T O R - P U R D U E U N I V E R S I T Y

PROFESSIONAL JUDGMENTHEA 479; GEN-03-07; GEN 08-01

The financial aid administrator can exercise discretion in certain areas when a student’s family has special or unusual circumstances that are not adequately addressed by need analysis, regulations, or legislation. ED does not regulate PJ. The HEA explicitly authorizes the financial aid administrator to exercise PJ in the following areas:

Dependency status (dependent to independent only)

Certain data elements used to calculate the expected family contribution (EFC)

Cost of attendance (COA)

Satisfactory academic progress (SAP)

Denial or reduction of FFEL and Direct Loan eligibility

NASFAA MONOGRAPHS

Monograph 26: Professional Judgment in Eligibility Determination and Need Analysis

Monograph 26 identifies a variety of situations in which it may be appropriate to use professional judgment in need analysis. Alternative methods are suggested to assist financial aid administrators in better assessing the ability of a family to pay for postsecondary education.

Monograph 24: Developing the Cost of Attendance Defines acceptable expenses for cost of attendance purposes and outlines consistent methodologies for establishing reasonable budgets. It also covers adjustments to cost of attendance using professional judgment authority.

Monograph 25: Satisfactory Academic Progress Monograph 25 is the third edition of a NASFAA publication that first appeared in 1982. Practicing financial aid administrators and NASFAA staff have prepared this document for reviewing and evaluating an institution’s satisfactory academic progress standards as part of NASFAA’s continuing effort to assist financial aid administrators in fulfilling their professional responsibilities.

GUIDELINES FOR PJ

DOCUMENT

DOCUMENT

DOCUMENT

DOCUMENT

GUIDELINES

CASE BY CASE BASIS ONLY

TWO REASONS Adjust student’s cost of attendance Adjust the date used to calculate the student’s EFC

EFC AND COA

Section 479A of the Higher Education Act of 1965, as amended –

“(a) IN GENERAL – Nothing in this part shall be interpreted as limiting the authority of the financial aid administrator, ON THE BASIS OF ADEQUATE DOCUMENTATION, to make adjustments on a case-by case basis to the cost of attendance or the values of the data items required to calculate the expected student or parent contribution(or both) to allow for treatment of an individual eligible applicant with special circumstances”

On line review of PJ practices

http://ifap.ed.gov/qadocs/FSAVeriModule/

activity2verif.doc

PJ and Unemployment Benefits

DCL GEN- 09-04 DCL GEN- 09-05 DCL GEN- 11-04

SPECIAL GUIDANCE

With documentation, you can adjust the income from work and from unemployment to zero

Documentation can be state letter or other evidence that student is receiving unemployment

Other adequate documentation of the adjustment

STUDENTS WITHOUT PARENTAL SUPPORT

Documentation Parents refuse to provide information for hi FAFSA Parents do not and will not provide any financial

support to the student (date support ended)

If parents refuse to sign and date a statement, then you must get documentation from a third party.

Student will then qualify for Unsub Loans ONLYDCL GEN-08-12

BOILER JUDGMENT

Special Circumstance Appeal Adjustments to core criteria Adjustments to budget On-time appeal

Satisfactory Academic Progress Appeal

Pace (Credit completion) Maximum Time Frame Cumulative Grade Point

PURDUE SPECIAL CONDITIONS APPEALS OVER THE LAST 4 YEARS

2008-2009 2009-2010 2010-2011 2011-20120

100

200

300

400

500

600

700

800

900Special Conditions appeals

Special Conditions appeals

PURDUE BREAKDOWNSPECIAL CIRCUMSTANCE

41.00%

11.00%19.00%

5.00%

5.00%

2.00%

2.00%

11.00%3.00% 1.00%

UnemploymentJob ChangeOne Time IncomeLoss of Untaxed incomeDivorce / SeparationDeath of ParentEducational ExpensesMedical Extraordinary ExpensesParent in College

PURDUE BUDGET ADJUSTMENTS

Will not begin making budget adjustments until academic year has begun.

We only want to use the current information of the family situation.

Budget adjustments that are made will ONLY affect loan eligibility, never grant or equity assistance.

Statistically they have remained relatively level for the past 4 years.

PURDUE BUDGET ADJUSTMENTS

Adjustments are most commonly made to address living or transportation costs.

Adjustments made to reflect actual receipted costs Can be approved by committee member Denials go to full committee for review

Adjustments for computer expenses All go to full committee for review Only allowed 1 computer per 4 years• If appropriate documentation is presented, will allow for a 2nd

adjustment with significant proof.

PURDUE ON-TIME STATUS

Purdue has a priority deadline of March 10 of the year in which an academic year beings

State aid also has a hard deadline of March 10

Students may appeal “late” status if they can “prove” that they mailed the application prior to March 10.

If they do not have proof they may still appeal their late status

PURDUE LATE STATUS APPEAL

Primarily used for Freshman

Out-of-state students who do not know the priority status date are the most common

Allows incoming students to qualify for equity based financial assistance

While upperclassmen may appeal, very rarely is this appeal approved

Does not create eligibility for state aid automatically

Students may appeal directly to the state for an exception to the on-time status for state assistance

MARRIAGE OF DEPENDENT

Final Program Integrity Rules – pub. October 29,2010;

NPRM published June 18, 2010

Effective date July 1, 2011

Verification portions became effective July 1, 2012

Allows for the update of marital status to be updated at any time (34 CFR 668.55)

MARITAL STATUS CHANGES

An Expected Family Contribution (EFC) will not be calculated if the applicant attempts to update marital status.

Reject 21 will be set when student changes his/her marital status date to a date that is after the date the original application was completed and before the transaction receipt date. It is set in the correction process.

SAR comment Code 119 will be set.

Only an FAA can override the reject (Reject Override 21).

34 CFR 668.55 UPDATING INFORMATION

(a) If an applicant's dependency status changes at any time during the award year, the applicant must update FAFSA information, except when the update is due to a change in his or her marital status.

(b)(1) An applicant who is selected for verification of the number of persons in his or her household (household size) or the number of those in the household who are attending postsecondary institutions (number in college) must update those items to be correct as of the date of verification, except when the update is due to a change in his or her marital status.

(2) Notwithstanding paragraph (b)(1) of this section, an applicant is not required to provide documentation of household size or number in college during a subsequent verification of either item if the information has not changed.

(c) An institution may require an applicant to update FAFSA information under paragraph (a) or (b) of this section for a change in the applicant's marital status if the institution determines the update is necessary to address an inequity or to reflect more accurately the applicant's ability to pay.

Approved by the Office of Management and Budget under control number 1845–0041)

MARRIAGE OF DEPENDENT AT PURDUE

IS NOT TREATED as a special condition / professional judgment – part of the verification process for us

Carte Blanche – accept the change

Request the following documentsCopy of Marriage CertificateCopy of Spouse’s 2011 Tax Return or Transcript (Purdue is a QA school)Provide documents supporting asset information of the spouse and student

Override Reject 21

PURDUE SAP IN A NUTSHELL

PURDUE MONITOR GPACredits

completed Minimum GPA0-14 1.50

15-29 1.6030-44 1.7045-59 1.8060-74 1.9075-89 2.00

90-104 2.00105+ 2.00

Grad / Prof 2.00

PURDUE MONITOR PACE

Students must complete 67% of total cumulative hours attempted.

Transfer hours are counted in the total hours.

Courses being retaken are counted in attempted hours for each occurrence of taking. However, if taken more than once, only one passing grade is counted toward successful completion.

Once falling below 67% given one semester warning.

PURDUE MONITOR TIME

At such time a student passes 150% they become ineligible to receive further assistance.

All transfer hours are counted into attempted hours.

Purdue begins to warn individuals who are 45 hours away from maximum time frame and warns them again after every 15 hours are completed.

There are instances when a student will exceed the 150% of total hours allowed.

PURDUE MAXIMUM TIMEFRAME

Degree Program Maximum Hours

Maximum Associate's (71 hr. prog.) 107

Time Frame Bachelor's (128 hr. prog.) 192

Examples: Master's 80PhD. 213

PharmD. 396DVM 318

PURDUE URLS

Special Circumstances

http://www.purdue.edu/dfa/policies/specialcircumstances.php

Budget Adjustment

http://www.purdue.edu/dfa/policies/budgetadj.php

Satisfactory Academic Progress Policy

http://www.purdue.edu/dfa/policies/SAPPolicy.pdf

FIGHTING ENGINEERS SPECIAL CIRCUMSTANCE

Rose-Hulman Institute of Technology is a four-year private institution located in Terre Haute, IN. It is an institution that only produces engineers. The total population is around 2,000 students. The COA for the current year is $54,431. The current default rate is 1.0%.

9/1032 appeals

10/11 39 appeals

11/12 42 appeals

12/13 48+ appeals

RHIT SPECIAL CIRCUMSTANCE

Adjust EFC based on documentation provided to the Financial Aid Office by student or parent.

Adjustment to COA Student must provide documentation (ex: bookstore

receipts, laptop charges, and travel expenses) Overload Charges for a student taking more than 18

hours.

RHIT SATISFACTORY ACADEMIC PROGRESS

Maximum Time Frame 150%

Credit hours completed 67%

Cumulative GPA

1.8 Cum GPA for freshman (up to 44 credit hours)

2.0 Cum GPA for Upperclassmen

RHIT BUDGET ADJUSTMENTS

The only budget adjustments we make are for students who are overloading or provide documentation that they spent more than the COA has allotted for. (ex: books, laptop or transportation)

The adjustments affect only loans or in the case of ROTC or Lilly where Rose pays for Room/Board, we will increase the outside award.

We NEVER change any institute aid. Only Federal aid!!!

RHIT PROCESS OF PROFESSIONAL JUDGMENT

All students who are asking for a PJ, they are selected into verification.

The student and/or parent must fill out the PJ form and provide all documentation that is requested.

PJ only will help with loan types and federal aid ONLY. No institutional aid is changed.

RHIT SAP PROCESS

Students are identified after the May grades are posted.

A SAP Letter is sent to each student via mail and email.

Student has the opportunity to appeal the termination by writing why they GPA was not at standard.

Once the appeal is approved, student must make an appointment with Financial Aid Director to start the Academic Plan process.

RHIT SAP PROCESS

The student is given a form that is pre-populated with CUM GPA and credit hours.

The form must be signed by the Student, Academic Advisor and Director of Financial Aid.

The student will be looked at each term to make sure the student is progressing satisfactory with the plan.

RHIT SPECIAL CONDITIONS FORM

RHIT SPECIAL CONDITIONS FORM/SAP FORM

QUESTIONS???

CONTACTS

Melinda Middleton – Rose-Hulman Institute of Technology

middleto@rose-hulman.edu

Leo Hertling – Purdue University

lhertlin@purdue.edu