Transcript
Page 1: USA Funds University Professional Judgment - WFAA · Professional Judgment Professional judgment is the discretionary action available to a financial aid administrator to address

USA Funds University

Professional JudgmentWFAA ConferenceOct. 18, 2012

Page 2: USA Funds University Professional Judgment - WFAA · Professional Judgment Professional judgment is the discretionary action available to a financial aid administrator to address

Special Note

These materials are for the benefit of financial aid professionals and other campus administrators. They are intended to provide current facts and information and are not intended to be legal advice. These materialscontain information related to Federal Title IV student aid programs and have neither been reviewed nor approved by the U.S. Department of Education. You are encouraged to seek your own competent legal counsel in connection with the topics covered in these materials. USA Funds® disclaims all responsibility forany claim arising from reliance on the information provided.

© Copyright 2012 United Student Aid Funds, Inc. All Rights Reserved.

Questions regarding the content of this publication should be addressed to USA Funds University, P.O. Box 6028 Indianapolis, IN 46206-6028 or by calling (317) 806-0208.

Page 3: USA Funds University Professional Judgment - WFAA · Professional Judgment Professional judgment is the discretionary action available to a financial aid administrator to address

Professional Judgment

Professional judgment is the discretionary action availableto a financial aid administrator to address unusualcircumstances that affect a student’s ability to payeducational expenses. Financial aid administrators maymake adjustments on a case-by-case basis, and mustdocument justification in the student’s file.

Unusual CircumstancesSection 479A of the Higher Education Act of 1965, asamended, outlines what may constitute unusualcircumstances. The law notes that these circumstancesmust be considered on a case-by-case basis and that thecondition being addressed has differentiated an individualstudent from a defined group of students, rather thanconditions that exist across a group.

“Nothing in this part shall be interpreted as limiting theauthority of the financial aid administrator, on the basisof adequate documentation, to make adjustments on anindividual basis to the cost of attendance or the values ofthe data items required to calculate the expected studentor parent contribution (or both) to allow for treatment ofan individual eligible applicant with specialcircumstances.”

The school’s financial aid office is not required to seek outunusual circumstances. It is the responsibility of thestudent or parents to request that their circumstances beconsidered. According to the 2012-2013 Federal Student AidHandbook, aid administrators must make “reasonabledecisions that support the intent of the provision” (AVG-100). Schools are accountable for their PJ adjustments andfor documenting each decision. A financial aidadministrator’s decision is final and cannot be appealed tothe U.S. Department of Education.

The financial aid office may receive subsequent requestsfor an adjustment made in a prior year. It is acceptable tomake the same adjustment for multiple award years, aslong as updated documentation is submitted by the familyto ensure that the professional judgment still isappropriate.

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Trainer’s Tidbit

The Higher Education Relief Opportunities for StudentsAct of 2003, known as the HEROES Act, providesfinancial aid relief for individuals adversely affected bymilitary operations, national emergencies or naturaldisasters. The HEROES Act allows the U.S. Departmentof Education to waive certain statutory and regulatoryprovisions. The requirement that PJ be applied on acase-by-case basis for affected students and theirfamilies is one such waiver. Financial aid administratorsalso are encouraged to choose the method ofdetermining financial need that is most beneficial to theaffected individuals and their families.

Trainer’s Tidbit

The 2012-2013 Free Application for Federal Student Aidinforms applicants, “If you or your family has unusualcircumstances that might affect your financial situation(such as loss of employment), complete this form to theextent you can, then submit it as instructed and consultwith the financial aid office at the college you plan toattend.”

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Policies and Procedures If a school chooses to allow professional judgmentadjustments, the school should develop policies andprocedures to address conditions that will be consideredusing PJ. Students must be treated consistently whiletaking into account economic changes or unforeseenchanges in a family’s financial situation.

Policies and procedures should indicate who may utilizeprofessional judgment within the financial aid office. If anaid administrator determines that the student’s situationwarrants a PJ adjustment, the reasons for the adjustmentmust be documented so that the change could beexplained during an audit or program review. In addition,having a well-documented student file provides anyoneworking with the file in the future with an understandingof how PJ was applied to the student’s situation. The nameof the aid administrator and the date the adjustment wasmade also should be documented.

Some schools choose to create forms which students mustcomplete to request PJ. Forms should be clear andconcisely explain the information required, including whatinformation should be provided to sufficiently documentthe request. Information should be provided to the studentor family regarding how and when they will be notified ofthe outcome of the PJ request, along with information onany appeal process available.

It is considered a best practice to notify students whorequest a PJ adjustment of an anticipated timeframe inwhich they may expect a response to their request. Thistimeframe should be included in the institution’s policiesand procedures.

The Final Rule, published Oct. 29, 2010, requires schools tofollow long-standing ED guidance to perform verificationon selected applicants before completing professionaljudgment requests for those students. This provisionbecame effective July 1, 2012, for the 2012-2013 awardyear and applies whether the student is selected forverification by ED or by the school's own policies andprocedures. The requirement does not apply to studentsrequesting a dependency override.

Professional JudgmentCategories Most PJ decisions will fall within these four categories ofunusual circumstances:

1. Cost of Attendance.

2. Expected Family Contribution.

3. Dependency status.

4. Loan origination and eligibility.

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Trainer’s Tidbit

2012-2013 Federal Student Aid Handbook, AVG, Ch. 5.

Before a financial aid administrator can exercise PJ, allconflicting information must be resolved.

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Cost of Attendance A financial aid administrator may adjust a student’s Cost of Attendance for allowable expenses which exceed thestandard COA established by the institution.

The table below illustrates the components that may be adjusted and examples of acceptable documentation tosubstantiate the adjustment.

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Adjustments to Cost of Attendance

Component Documentation Examples

Tuition or fees not charged to the studentpopulation as a whole.

u Charges on student’s account.

Books and supplies expenses.

u Charges on student’s account.u Proof of out-of-pocket expenses.u Statement from instructor(s) requiring additional books or supplies.

Living expenses.

u Charges on student’s account.u Proof of out-of-pocket expenses.u Estimated expenses.

Student loan fees.u Documentation of actual fees charged.u Estimated fees charged.

Transportation expenses.u Proof of out-of-pocket expenses.u Estimated expenses.

Dependent care expenses.

u Proof of out-of-pocket expenses.u Estimated expenses.u Statement from provider.

Study abroad expenses.u Proof of out-of-pocket expenses.u Estimated educational, travel and living expenses.

Computer purchase expenses.u Proof of out-of-pocket expenses.u Estimated expenses.

Student disability-related expenses.

u Proof of out-of-pocket expenses.u Estimated expenses.u Statement from disability office on campus.

Cooperative education employment expenses.u Proof of out-of-pocket expenses.u Estimated expenses.

First professional credential expenses.Note: May be added to COA once per eligibleacademic program.

u Proof of exam fees or costs to obtain license or certification, incurredwhile enrolled.

u Statement from educational program director.

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COA Case Studies Kyle

Kyle is a third-year, independent undergraduate student at your school. Kyle lives in an off-campus apartment andrecently incurred $1,200 in expenses to make repairs to his 10-year old car, which he uses to drive to class each day. Hepaid for the repairs using a credit card, but is unsure how he will pay the bill, since he uses virtually all of the money froma part-time job to help pay his monthly living expenses.

Kyle’s COA is $12,500 and he receives a partial academic scholarship in the amount of $6,500. He is not eligible for aFederal Pell Grant, and the remaining $6,000 is covered through a combination of a $2,000 Federal Perkins loan and a$4,000 Federal Stafford loan. He comes to the financial aid office to see if you may be able to help him with his pendingcredit card bill for the necessary car repairs, and provides a copy of the bill for the repairs from the mechanic.

Is this a potential professional judgment?

If so, would you require additional documentation? What would you require?

What kind of adjustment can be made?

Does Kyle have remaining eligibility for federal aid to help cover the expense?

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Marilee

Marilee is a first-year, independent undergraduate student at your school. Marilee’s COA is $9,500, which includes anallowance of $750 per semester for dependent care. The allowance for dependent care is assigned to students who filethe FAFSA as:

u Married, with more than two people in the household; or

u Single, and have more than one person in the household.

The student also must confirm that the household size includes one or more people who require care in order for thestudent to attend class or academically related activities.

Marilee is a single parent and has three children in elementary school who attend after-school care while she attendsclass and works at a part-time on-campus job. The total cost of the after-school care program is $300 per month.

Marilee visits the financial aid office to inquire about any financial assistance that is available to help her pay theseexpenses. Marilee is not eligible for a Federal Pell Grant, and receives a Federal Stafford loan for $9,500 to pay her schoolexpenses.

Is this a potential professional judgment?

If so, would you require additional documentation? What would you require?

What kind of adjustment can be made?

Does Marilee have remaining eligibility for federal aid to help cover the child-care expense?

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Expected Family Contribution Financial aid administrators may use professional judgment to modify the value of the data elements reported on theFree Application for Federal Student Aid. The data elements are:

u Income.

u U.S. income taxes paid.

u Assets.

u Household size.

u Number in college.

Adjustments to the need-analysis formulas, the tables used in the calculation of a student’s Expected Family Contributionor direct changes to the EFC are not allowed.

Income Protection AllowanceIn making adjustments for unusual expenses, be aware that the income protection allowance, a component of the EFCcalculation, accounts for modest living expenses for the family.

Many schools consider it a best practice for professional judgment to determine whether the unusual expenses exceedwhat already is a consideration through the IPA. The IPA values can be found in the FAA Information section of theInstitutional Student Information Record.

The following table provides the amounts of IPA:

EFC Formula Guide, 2012-2013, page 18.

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The following table provides the percentages for each category of the IPA:

Additional GuidanceDear Colleague Letter GEN-09-04.Dear Colleague Letter GEN-09-05.Dear Colleague Letter GEN-11-04.

In April 2009, ED published Dear Colleague Letter GEN-09-04, reminding aid administrators of their authority to exerciseprofessional judgment for students applying for federal student aid. Because income-based adjustments affect the EFC,the DCL encourages administrators to consider the special circumstances of students and families during economicallydifficult times.

Dear Colleague Letter GEN-09-05, published in May of 2009, provides aid administrators information on documentingand making adjustments for independent students who are unemployed. Each state will provide recipients ofunemployment benefits with a letter encouraging them to consider enrolling in postsecondary education and applyingfor financial aid. Aid administrators may use this letter, or other evidence that a student is receiving unemploymentbenefits, to document that the student’s income earned from work is zero. Unemployment benefits also may beconsidered to be zero, for professional judgment purposes, because ED determined that unemployment benefits wouldnot have a measurable effect on the EFC of an independent student. The DCL indicated that if other members of thestudent’s family are receiving unemployment benefits, schools should make appropriate adjustments based on thefamily’s economic situation.

Dear Colleague Letter GEN-11-04, published in February of 2011, reminded aid administrators of their ability to helpmembers of the military and their families in two key areas of Title IV aid administration: through the use of professionaljudgment and by ensuring combat pay is reflected appropriately on the FAFSA. ED suggests that it is appropriate toconsider changes in circumstances affecting the "current and near-term economic situation," such as the loss of incomedue to either the Reservist's or Guard member's deployment or return to college. ED explains that it is acceptable toidentify a category of students and then assess the unique effect of that circumstance on each individual within thatcategory.

ED also clarified that the guidance provided in Dear Colleague Letters GEN 09-04 and GEN 09-05 remains in effect untilfurther notice.

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Income Protection Allowance Percentages

Food 30%

Housing 22%

Clothing and personal care 16%

Other family consumption 12%

Medical care 11%

Transportation expenses 9%

IPA x percentage of allowance = amount already taken into consideration in the EFC

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The following table illustrates examples of situations that may warrant adjustments of FAFSA data elements, andacceptable documentation to support the adjustment. Adjustments to the data elements used to calculate the EFC mayresult in either an increase or decrease in the student’s need. If the financial aid administrator uses PJ to adjust a dataelement, then the aid administrator must consistently use the resulting EFC for awarding funds through all federal aidprograms.

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Adjustments to EFC ElementsAdjustments may be made by reducing or increasing FAFSA data elements.

Expenses Documentation Examples Adjustment Options

Medical, dental or nursing homeexpenses not covered by insurance.

u Proof of out-of-pocket expenses.u Explanation of benefits forms from

the insurer.u Tax documents.

u Calculate amount that exceedsamount allowed in the IPA.

u Calculate expenses already includedin itemized deductions of tax return.

u Reduce AGI.u Increase taxes paid.u Reduce assets.

Support of extended family members. u Proof of out-of-pocket expenses.

u Reduce AGI.u Reduce assets.u Adjust family size.

Tuition expenses at an elementary orsecondary school.

u Proof of out-of-pocket expenses.

u Reduce AGI.u Increase taxes paid.u Reduce assets.

u Changes in a family’s income, assetsor a student’s status.

u Disability or illness.u Unemployment.u Separation, divorce or death.u Termination or change of child

support agreement.u Called to active duty in the armed

forces.u Bankruptcy or foreclosure.u Roth IRA Rollovers.u Unusual capital gains.u Custodial parent remarries after

application date.u Losses due to natural disaster.u Alimony payments not deducted on

tax return.u Layoff or furlough.u Dislocated worker status.

u Tax documents.u W-2s.u Final pay stubs.u Letter of change or termination of

employment.u Divorce or separation decrees.u Death certificates.u Other documentation to show the

change of income.

u Adjust income earned from work.u Adjust AGI.u Adjust taxes paid.

Unusual debt.u Proof of the unusual circumstances

that resulted in the debt.u Proof that the debt was paid.

u Adjust AGI.u Adjust taxes paid.u Adjust assets.

Parents enrolled in school.

u Proof of enrollment.u Proof of out-of-pocket expenses.u Proof of parent’s tuition

reimbursement or financial aidreceived.

u Adjust AGI.u Adjust taxes paid.u Adjust number in college.u Reduce assets.

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EFC Case StudiesClayton

Clayton will be an independent, third-year undergraduate student at your school for the upcoming award year. Claytonfiled the FAFSA, but is concerned that he will not be able to continue with school in the fall semester, because he recentlywas laid-off from a job with a large car dealership in their town. Due to the current economic conditions, Clayton doesn’tanticipate another position becoming available in the near future. He is receiving unemployment insurance benefitsbased on his base-year income of $54,000 and is seeking employment. For the award year, he earned $21,000 prior to thelay-offs at his company. His unemployment benefits are $250 per week. He comes to the financial aid office to seekassistance.

Is this a potential professional judgment?

If so, would you require additional documentation? What would you require?

What types of adjustments would you make?

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The Harris Family

Thomas and Kate Harris are both 58 years old and work full time. Their youngest child, Matthew, is the last of their fivechildren to attend college. Thomas and Kate financed their older childrens’ educations using Federal PLUS loans and have$75,000 in outstanding PLUS loan debt, with monthly payments of about $700 per month.

Matthew’s family used the FAFSA4caster during his junior year in high school, which estimated that their EFC would beapproximately $10,000. Matthew has been accepted as a freshman at your school for the upcoming academic year, buthis parents are concerned that he won’t be able to attend because they can’t take on any more debt and don’t have thefunds to pay for the family contribution based on their current combined income. Matthew and his parents come to thefinancial aid office to see what options may be available to the family. His parents provide copies of the promissory notesfor the PLUS loans borrowed on behalf of their other children.

Is this a potential professional judgment?

If so, would you require additional documentation? What would you require?

What types of adjustments would you make?

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The Dean Family

The Deans, a family of four, made plans for Robert to attend college in the fall and submitted the necessary financial aidforms by the suggested filing date of March 1. In June, Mrs. Dean was in an automobile accident and incurred $5,000 inuninsured medical expenses.

Robert is concerned that his parents cannot financially assist him and that his course load will not allow him to work parttime. The current financial aid award will not be enough to meet his educational expenses. Robert fears he may need towithdraw from school and comes to your office for guidance.

EFC Formula Guide, 2012-2013, page 18.

Is this a potential professional judgment?

If so, would you require additional documentation? What would you require?

What types of adjustments would you make?

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NOTES

Dependency Status Dear Colleague Letter GEN-03-07.

Dear Colleague Letter GEN-03-07, published in 2003, provides guidance for the financial aid community on the use ofdependency overrides. Students who do not meet the criteria to be classified as an independent student may beconsidered independent by professional judgment.

ED has interpreted “unusual circumstances” to mean conditions that make it inappropriate to expect a parentalcontribution. An abusive family environment or abandonment by parents may be grounds for a dependency override.

GEN-03-07 identifies four conditions that, individually or in combination with one another, do not qualify as unusualcircumstances for a dependency override.

u Parents’ refusing to contribute to the student’s education.

u Parents’ unwillingness to provide information on the FAFSA or for verification.

u Parents’ not claiming the student as a dependent for income-tax purposes.

u Student’s demonstrating total self-sufficiency.

Overrides do not carry over from one award year to the next; the financial aid administrator must reaffirm each year thatthe unusual circumstances persist and that an override still is justified.

The following table provides examples of situations that might be suitable for a dependency override, and supportingdocumentation.

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Adjustments to Dependency Status“Dependency override” is the term for an adjustment made to alter a student’s dependency status.

Scenario Examples of Acceptable Documentation

Death of a custodial parent, and the student does not haveany contact with the noncustodial parent.

u Written statement from the student.u Written statement from a third party, such as clergy, a

social worker or a family member.u Other forms of documentation that support a change to

a student’s dependency status.

Abandonment.u Location of parents is unknown.

Abusive environment.

Other unusual circumstances warranting an override of thestudent's dependency status.

Trainer’s Tidbit

The College Cost Reduction and Access Act of 2007 allows financial aid administrators to grant dependency overridesbased on a documented override at another institution for the same award year.

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Dependency Override Case Studies Cody

Cody is a 21-year-old, third-year undergraduate student at your school. Cody’s father died almost six months ago, and hismother’s exact whereabouts have been unknown for the past five years. Cody hears from his mother about once a year,and knows she is living in an adjacent state, but he has no way to reach her. Cody is living with his Aunt Teresa during thesummer, and will return to school housing for the fall term. Cody wishes to apply for financial aid, but calls your office forassistance to determine how he should proceed, since he is unable to reach his mother to obtain her information. Cody’saunt has told him that she would be willing to apply for a Federal PLUS loan to help him attend college, but he will needother financial assistance.

Is this a potential dependency override?

If so, what documentation would you require?

In lieu of a dependency override, can Cody’s Aunt Teresa complete the parental portion of the FAFSA?

Susan

Susan is a 22-year-old, fourth-year undergraduate at your school. For the past three years, her parents have supplied theparental data for the FAFSA. Based on the information provided, Susan has never qualified for need-based aid, but herparents have borrowed small Federal PLUS loans to help with Susan’s educational costs. Susan recently moved in with herboyfriend of two years, and even though her parents do not approve of the relationship, they remain in contact withSusan. Her parents are willing to provide their financial information on the FAFSA, but Susan and her boyfriend are payingtheir own bills, and Susan believes she could complete the FAFSA without her parent’s information.

Is this a potential dependency override?

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Loan Origination and Eligibility There are two types of professional judgment that affect loan eligibility.

Loan OriginationThe first type allows a school’s financial aid administrator to refuse to originate a student loan or reduce the borrower’sloan eligibility on a case-by-case basis. The reason for the action must be documented, nondiscriminatory and providedto the student in writing.

Loan Origination Case StudyDaniel

Daniel, a second-year, dependent student at your school, received a full scholarship during his freshman year. He did notmeet scholarship-renewal requirements, so he comes to your office to find out how he can pay his tuition and cover hisexpenses for books and housing. You explain that he is eligible for an unsubsidized Stafford loan of $6,500. After you givehim information about the loan and explain the application process, he decides to apply online. As he leaves your office,he indicates that he doesn’t mind borrowing the money because he is not planning to pay it back anyway. What do youdo?

If you decide to refuse to originate the loan, how would you document your decision?

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Loan EligibilityThe second type of professional judgment that affects loan eligibility is a result of the Higher Education Opportunity Actof 2008, which allows aid administrators to use professional judgment in order to offer dependent students unsubsidizedStafford loan funds, when the parent(s) refuse to complete the parental portion of the FAFSA and have ended thestudent’s financial support. Financial support includes not only contributions to educational expenses, but also othercash and non-cash support, such as housing.

Aid administrators must obtain documentation that the parent(s) have ended financial support of the student and refuseto complete the parental portion of the FAFSA. Obtaining self-certification from the student is not considered sufficientdocumentation. Generally, the documentation requirement may be met by obtaining a signed and dated notice from theparent(s) stating that they:

u Have ended their financial support, and provide the date the support ended.

u Will not provide financial support in the future.

u Will not complete the parental section of the FAFSA.

If the parent(s) refuse to provide a statement, documentation from a third party must be obtained describing theparental relationship with the student.

This professional judgment option exists solely in order to offer students the unsubsidized Stafford loan amountappropriate to their grade level. It does not apply to any other type of Title IV aid and is not treated as a dependencyoverride. All rules related to loan proration and loan limits continue to apply.

The maximum annual loan amount the student may receive is the “base” annual loan limit for the student’s grade levelplus the additional $2,000 that was added to the loan limits for dependent students under the Ensuring ContinuedAccess to Student Loans Act.

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Grade Level Base Unsubsidized Loan Additional UnsubsidizedLoan Total

1 $3,500 $2,000 $5,500

2 $4,500 $2,000 $6,500

3+ $5,500 $2,000 $7,500

Trainer’s Tidbit

Schools are subject to administrative action by ED, if they originate loans for ineligible students or for loan amountsthat exceed:

u Annual loan limits.

u Aggregate loan limits.

u Financial need.

u Cost of Attendance.

Administrative action may include fines, limitations, suspensions and terminations.

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Loan Eligibility Case StudiesJay

Jay is a third-year, dependent accounting major at your school. His parents filed the FAFSA for his first two years of schoolbut have informed Jay that they no longer will provide support to him effective June 1, 2012. His parents have provided aletter to the financial aid office indicating such, including their refusal to complete the FAFSA. Jay and his family continueto have a good relationship, and talk frequently. Jay lives in an apartment and has a part-time job at a local radio stationwhich provides enough money to pay his rent each month. He comes to your office to talk with you about options hemay have for obtaining aid to continue attending school.

Is this a potential professional judgment? Why or why not?

What documentation would you require, if any?

If you chose to approve a professional judgment for Jay, what is the maximum award he could receive in Title IV funds?

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Morgan

Morgan is a second-year, pre-law major at your school. She makes an appointment to talk with you regarding herfinancial aid for the upcoming year. Her parents, with whom she resides, cannot pay for her school expenses, and haveindicated to Morgan that she needs to complete the FAFSA herself this year. She has completed the student portion, butis unable to obtain her parents’ information or signatures. She explains that she has a good relationship with her parents,and they would help her if possible, but they are struggling to pay their own bills. She also indicates that her parents arewilling to provide a letter to your office with the information she has just shared.

Is this a potential professional judgment? Why or why not?

What documentation would you require, if any?

If you chose to approve a professional judgment for Morgan, what is the maximum award she could receive in Title IVfunds?

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Inappropriate Use of Professional Judgment Situations when PJ is not appropriate:

u Financial aid administrators may not use PJ to make an otherwise ineligible student eligible for federal student aid, forexample:

– Waiving general eligibility criteria for an ineligible noncitizen.

– Awarding funds to students who owe a Title IV overpayment.

u Financial aid administrators may not use PJ to circumvent the law or regulations, for example:

– Awarding a Stafford loan to a student enrolled less than half time.

– Changing an independent student to dependent.

– Awarding Federal Supplemental Educational Opportunity Grant funds to a graduate/professional student.

Reporting PJ Decisions EFC AdjustmentsWhen adjusting FAFSA data elements through FAA Access to CPS Online, the financial aid administrator must set the FAAadjustment flag and transmit the file to the Central Processing System for all Pell Grant-eligible files.

Financial aid administrators also should flag other adjustments to FAFSA data based on the institution’s policies andprocedures.

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Dependency Override AdjustmentsTo override the student’s dependent status on an initial application through FAA Access, the financial aid administratorshould change the Dependency Override flag to “Dependent to Independent.” If the student already has applied, theadministrator can use FAA Access to CPS Online to authorize or cancel an override.

Aid administrators cannot complete overrides on the Student Aid Report.

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Trainer’s Tidbit

2012-2013 ISIR Guide.

For 2012-2013 the following ISIR values apply to dependency overrides:

2012-2013 ISIR Guide.

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According to the 2012-2013 Federal Student Aid Handbook Application and Verification Guide:

“To authorize a dependency override on a paper FAFSA, the FAA marks the bubble for an override, labeled “D/O,” in the“College Use Only” area, fills in the school’s federal school code, and signs. A sepa rate letter attached to the application inlieu of making the override is not acceptable” (p. AVG-102).

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Trainer’s Tidbit

No FAFSA adjustments need to be reported for COA or Loan Eligibility PJ decisions.

Trainer’s Tidbit

For 2012-2013 a new dependency override flag has been added to the "College Use Only" field on the FAFSA. If ahomeless determination is made for a student 21 years of age or younger, a code of "4" should be used. For otherdependency override situations, a code of "1" should be used.

COLLEGE USE ONLY

D/O

FEDERAL SCHOOL CODE

FAA Signature

1

1

Homeless Youth Determination

4

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Putting It To WorkThe topics covered in this training session are conveyed in general terms to encompass learners from all types ofpostsecondary institutions. You should consider how the concepts covered in the training session apply to your school.

Schools often are given flexibility in administering and applying guidelines to certain federal student aid programs. That’swhy it is essential that you discuss these items (shown below) with your supervisor.

Your supervisor can give you institution-specific guidelines on how the material we discussed in this training session canbe applied to your job.

1. Does my school use PJ?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

2. Does my school have written policies and procedures to explain the various provisions dealing with PJ?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

a. How are my school’s policies and procedures made available to students?

_______________________________________________________________________________________________

_______________________________________________________________________________________________

3. How does my school receive PJ requests from students and parents?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

a. Are forms or directions available in hard copy or on my school’s Web site?

_______________________________________________________________________________________________

_______________________________________________________________________________________________

b. Are the forms clear about what documentation is needed to support a PJ request?

_______________________________________________________________________________________________

_______________________________________________________________________________________________

c. What factors are used to determine the effectiveness of a PJ request?

_______________________________________________________________________________________________

_______________________________________________________________________________________________

d. Is it clear how the student or parent will learn of the PJ decision?

_______________________________________________________________________________________________

_______________________________________________________________________________________________

4. How are PJ decisions made at my school?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

5. Is there a post-decision process in place to check for sufficient documentation and consistent treatment in making PJdecisions?

_________________________________________________________________________________________________

_________________________________________________________________________________________________

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Trainer’s ToolkitThe Trainer’s Toolkit is a listing of terms, websites andreference materials directly related to ProfessionalJudgment.

Terms, Acronyms andAbbreviations Code of Federal Regulations CFR

The collection of federal regulations written and publishedby the U.S. government. The U.S. Department ofEducation's regulations are codified in Title 34.

College Cost Reduction and Access Act of 2007 CCRAA

The College Cost Reduction and Access Act (P.L. 110-84)provides numerous changes in federal financial aidadministration. The CCRAA was signed into law Sept. 27,2007, with some provisions retroactively applied to the2007-2008 academic year; others were implemented Oct.1, 2007, and the majority took effect either July 1, 2008, orJuly 1, 2009. Technical amendments to the CCRAA weresigned into law Dec. 21, 2007 (P.L. 110-153).

Conflicting InformationInformation held by any of the school’s offices that mayaffect a student’s eligibility for Title IV aid and that conflictswith other information obtained about the student. Aschool must have an internal system to identify conflictinginformation that would affect a student’s eligibility,regardless of the source or whether the student is selectedfor verification. The school must resolve all conflictinginformation and discrepancies before disbursing Title IVfunds. If the school discovers discrepancies after disbursingfunds, it must reconcile the conflicting information andtake appropriate action under the specific programrequirements.

Cost of AttendanceCOA

An estimate of costs related to a student's enrollment in apostsecondary school for a defined academic period. COAcomponents are defined in the Higher Education Act of1965, as amended. Also referred to as student’s budget.

Dependency OverrideA financial aid administrator may use professionaljudgment to override an otherwise dependent student’sdependency status. The decision for the override must bebased on documented unusual circumstances that validatethe student’s independent status. The school may notoverride an otherwise independent student‘s dependencystatus.

Dependent StudentBy regulatory definition, a dependent student is notmarried, is younger than 24 years old, has no legaldependents, is not an orphan or ward of the court as ofage 13 or older, is not on active duty in the U.S. ArmedForces for purposes other than training, nor a veteran ofthe U.S. Armed Forces, is not an emancipated minor, is notin legal guardianship or is not determined to be anunaccompanied youth or homeless. Parents of adependent student must submit parental information onthe Free Application for Federal Student Aid for their childto be considered for federal financial aid.

Dislocated WorkerAccording to the Free Application for Federal Student Aid,workers are considered as dislocated if they meet one ofthe following conditions:

u They have lost their job.

u They have been laid off or received a lay-off notice fromtheir job.

u They are receiving unemployment benefits due to beinglaid off or losing a job and are unlikely to return to aprevious occupation.

u They are self-employed but are unemployed due toeconomic conditions or natural disaster.

u They are receiving unemployment benefits; however,they may not be considered a dislocated worker if theyhave quit their job and are receiving unemploymentbenefits.

u They are a displaced homemaker. A displacedhomemaker generally is a person who previouslyprovided unpaid services to the family (for example, astay-at-home mom or dad), is no longer supported by thehusband or wife, is unemployed or underemployed, andis having trouble finding or upgrading employment.

A person who voluntarily ceases to be employed generallyis not considered a dislocated worker.

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Ensuring Continued Access toStudent Loans Act of 2008 ECASLA

ECASLA (P.L. 110-227) provides numerous changes infederal financial aid administration. ECASLA was signedinto law on May 7, 2008, to ensure that students andfamilies would continue to be able to borrow federalstudent loans for the 2008-2009 academic year. ECASLAprovided an increase to annual loan limits forundergraduate Stafford loan borrowers.

Expected Family Contribution EFC

The Expected Family Contribution is a measure of howmuch a student and the student's spouse or family isexpected to contribute toward the student's Cost ofAttendance. The federal need-analysis methodology mustbe used to calculate the EFC. The EFC is not the amount ofmoney that a student or student's family must provide.Rather, the EFC is an index used to determine how muchfinancial aid a student will receive at a particular school.

FAA Access to CPS Onlinehttps://faaaccess.ed.gov/FOTWWebApp/faa.

Web tool that financial aid administrators use to inputapplication data, view student information, makecorrections, check batch status and request PINs forstudents.

FAFSA4casterwww.FAFSA4caster.ed.gov.

A tool created by ED to help students and families preparefinancially and plan for college before the student’s senioryear in high school.

Federal Pell Grant ProgramA federal grant awarded to undergraduate students whohave demonstrated need, and, in some instances, to thoseattending a post-baccalaureate teacher certificate programto help pay for postsecondary education.

Federal Perkins Loan ProgramThe federal campus-based loan program that offers low-interest (5 percent) loans for both undergraduate andgraduate students with exceptional financial need. Theschool is the lender, and the loan is made with governmentfunds with a share contributed by the school. The loan isrepaid to the school or through a third party servicercontracted by the school.

Federal PLUS Loan Non-need-based loan available to parents of dependentundergraduate students and to graduate or professionalstudents borrowing on their own behalf.

Federal Stafford LoanA federal loan available to students to fund educationexpenses. Both subsidized (need-based) and unsubsidized(non-need-based) Stafford loan funds are available.

Federal Supplemental EducationalOpportunity Grant Program FSEOG

A federal campus-based grant program for undergraduatestudents. These grants are designed to supplement PellGrant awards to students with exceptional need.

Financial Aid Administrator FAA

A staff member at an eligible school who is charged withthe administration of financial aid programs.

Financial Aid Office FAO

The office at a postsecondary school that is responsible fordetermining students’ financial need and awardingfinancial aid.

Free Application for Federal Student Aid FAFSA

www.FAFSA.gov.

The form that students and parents of dependent studentsmust complete annually to apply for Title IV assistance,including Pell Grants, Stafford loans, and PLUS loans. Astudent and parents of a dependent student must includefinancial information about their household so that theExpected Family Contribution can be calculated.

Higher Education Act of 1965, as AmendedHEA

The federal law that authorizes most of the programs andactivities that assist and enable students to enter andsucceed in postsecondary education. The primary focus ofthe HEA is student aid, in the form of grants, loans andwork-study assistance.

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Higher Education Opportunity Act of 2008 HEOA

The HEOA (P.L. 110-315) reauthorized the Higher EducationAct of 1965, as amended. The HEOA was signed into law onAug. 14, 2008, with some provisions retroactively appliedto the 2008-2009 academic year; others were implementedat later dates.

Higher Education ReliefOpportunities for Students ActHEROES Act

The HEROES Act provides financial aid relief for individualsadversely affected by military operations, nationalemergencies or natural disasters. The HEROES Act allowsthe U.S. Secretary of Education to waive certain statutoryand regulatory provisions. Provisions and waivers underthis Act currently are effective until Sept. 30, 2012.

Income Protection Allowance IPA

The income protection allowance is a modest allowancefor basic living expenses used in calculating the student'sfinancial need. ED indicates the following breakdown forthe allowance: 30 percent food, 22 percent housing, 9percent transportation, 16 percent clothing and personalcare, 11 percent medical care, 12 percent other familyconsumption.

Independent StudentA student who meets one or more of the following criteria:An individual who is at least 24 years old by Dec. 31 of theaward year; is an orphan or ward of the court; is serving onactive duty in the U.S. Armed Forces for purposes otherthan training; is a veteran of the U.S. Armed Forces; is agraduate or professional student; is a married person; is anindividual with legal dependents other than a spouse; is anindividual who is or was, immediately prior to attaining theage of majority, an emancipated minor or in legalguardianship as determined by a court in the student'sstate of legal residence; is a student for whom the school’sfinancial aid administrator determines and documents thestudent's independent status based on the administrator'sprofessional judgment of the student's unusualcircumstances.

Institutional Student Information RecordISIR

An electronic record provided to the school by the CentralProcessing System. The ISIR includes information providedby a student and parents on the Free Application forFederal Student Aid, the student’s Expected FamilyContribution and the results of federal database matches.

Professional Judgment PJ

The flexibility given to a financial aid administrator underthe Higher Education Act of 1965, as amended, to makeadjustments to student eligibility for federal aid on a case-by-case basis.

Satisfactory Academic Progress SAP

The level of academic progress required of a student by theHigher Education Act of 1965, as amended, in order toreceive Title IV aid. Each school must establish a standardfor evaluating a student's efforts to achieve an educationalgoal within a given period of time (quantitativecomponent) and at a specified level of competency(qualitative component). In making this evaluation, theschool must establish the normal time frame forcompletion of the program in which the student isenrolled, and a method, such as grades or work projectscompleted, to measure the quality of the student’sperformance. An undergraduate student who exceeds 150percent of the normal time required to complete theiracademic program is not eligible for additional Title IVassistance.

Student Aid Report SAR

A record provided to the student by the Central ProcessingSystem. The SAR includes information provided by thestudent on the Free Application for Federal Student Aid.The SAR also contains the student’s Expected FamilyContribution and the results of federal database matches(including citizenship and Social Security numbermatches).

Title IVA section of the Higher Education Act of 1965, as amended,that authorizes federal loan, work-study and grant studentfinancial assistance programs.

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U.S. Department of Education ED

The U.S. Department of Education is the governmentagency that administers federal student financial aidprograms, including the Federal Pell Grant, the TeacherEducation Assistance for College and Higher EducationGrant, the Federal Work-Study Program, the Federal PerkinsLoan Program, the Federal Family Education Loan Programand the Federal Direct Loan Program.

VerificationA school’s procedure for confirming the accuracy ofinformation reported by the student on the FreeApplication for Federal Student Aid. Verification mayinclude requesting a copy of tax documents from thestudent and, if applicable, the student's parents.

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References, Resources and Websites Federal Legislation or RegulationsHigher Education Act of 1965, as amended

Title IV —Parts A, C, E, F, H & J; also select portions of Titles VII & VIII.http://edlabor.house.gov/documents/111/pdf/legislation/HigherEducationActof1965-Updated.pdf.

Code of Federal Regulationshttp://ecfr.gpoaccess.gov.

U.S. Department of Education20120-2013 ISIR Guidewww.ifap.ed.gov

2012-2013 EFC Guidewww.ifap.ed.gov.

2012-2013 Federal Student Aid HandbookApplication and Verification Guide.Chapter 2: Filling Out the FAFSA.Chapter 4: Verification, Updates and Corrections.Chapter 5: Special Cases.www.ifap.ed.gov.

Dear Colleague Letter GEN-11-04Subject: Update on the Use of "Professional Judgment and Reminder of Combat Pay Exclusion."Feb. 28, 2011.www.ifap.ed.gov.

Dear Colleague Letter GEN-09-05Subject: Update on the Use of “Professional Judgment” by Financial Aid Administrators.May 8, 2009.www.ifap.ed.gov.

Dear Colleague Letter GEN-09-04Subject: Use of “Professional Judgment” by Financial Aid Administrators.April 2, 2009.www.ifap.ed.gov.

Dear Colleague Letter GEN-03-07Subject: Dependency Overrides.May 2, 2003.www.ifap.ed.gov.

Electronic AnnouncementSubject: Update on the use of Professional Judgment by Financial Aid Administrators.May 21, 2010.www.ifap.ed.gov/eannouncements/052110UpdateProfessionalJudgmentFAA.html.

FSA AssessmentsVerification Activity 2: Dependency Overrides and Professional Judgment.www.ifap.ed.gov/qahome/fsaassessment.html.

Higher Education Opportunity Actwww.ed.gov/policy/highered/leg/hea08/index.html#dcl.

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USA FundsUSA Funds University Online Course

Professional Judgment.Course 204.www.usafundstraining.org.

USA Funds Ask PolicyUSA Funds Ask PolicySM is a resource for schools and lenders who have questions about specific policies or other issuesrelated to the full range of Title IV federal student aid.www.usafunds.org/AskPolicy.

National Association of Student Financial Aid Administrators (Membership is required)

Monograph Number 22: Professional Judgment in Eligibility Determination and NeedAnalysis

May 2009.www.nasfaa.org.

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Appendix APossible Solutions for Case Studies COA Case Studies

Kyle

Kyle is a third-year, independent undergraduate student at your school. Kyle lives in an off-campus apartment andrecently incurred $1,200 in expenses to make repairs to his 10-year old car, which he uses to drive to class each day. Hepaid for the repairs using a credit card, but is unsure how he will pay the bill, since he uses virtually all of the money froma part-time job to help pay his monthly living expenses.

Kyle’s Cost of Attendance is $12,500 and he receives a partial academic scholarship in the amount of $6,500. He is noteligible for a Federal Pell Grant, and the remaining $6,000 is covered through a combination of a $2,000 Federal Perkinsloan and a $4,000 Federal Stafford loan. He comes to the financial aid office to see if you may be able to help him with hispending credit card bill for the necessary car repairs, and provides a copy of the bill for the repairs from the mechanic.

Is this a potential professional judgment?

Yes, if your school’s policy and procedures allows this type of adjustment.

If so, would you require additional documentation? What would you require?

Kyle has provided a copy of the bill, but indicated that he used a credit card to pay the amount due the mechanic.Depending on your policies and procedures, a copy of the receipt for the repairs may be required also.

What kind of adjustment can be made?

The miscellaneous or transportation components of Kyle’s budget could be increased based on thedocumentation provided.

Does Kyle have remaining eligibility for federal aid to help cover the expense?

The annual Stafford loan limit for a third-year, independent undergraduate student is $12,500. Kyle currently isborrowing $4,000 from the Federal Stafford loan program, so he has $8,500 in remaining eligibility. If yourschool’s policy and procedures allow this type of adjustment, he could borrow up to an additional $1,200 inStafford loan funds to pay the car repair bill.

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Marilee

Marilee is a first-year, independent undergraduate student at your school. Marilee’s COA is $9,500, which includes anallowance of $750 per semester for dependent care. The allowance for dependent care is assigned to students who filethe FAFSA as:

u Married, with more than two people in the household; or

u Single, and have more than one person in the household.

The student also must confirm that the household size includes one or more people who require care in order for thestudent to attend class or academically related activities.

Marilee is a single parent and has three children in elementary school who attend after-school care while she attendsclass and works at a part-time on-campus job. The total cost of the after-school care program is $300 per month.

Marilee visits the financial aid office to inquire about any financial assistance that is available to help her pay theseexpenses. Marilee is not eligible for Federal Pell Grant, and receives a Federal Stafford loan for $9,500 to pay her schoolexpenses.

Is this a potential professional judgment?

Yes, if your school’s policies and procedures allow an adjustment to the dependent care allowance alreadyprovided to students with dependents.

If so, would you require additional documentation? What would you require?

Any adjustment above the provided allowance should be documented. A statement or bill from the after-schoolprogram would be sufficient documentation.

What kind of adjustment can be made?

Marilee’s COA could be increased based upon the difference between the cost of the after-school program andthe allowance already provided in the school’s COA for students with dependents.

$300 per month x 9 months in academic calendar = $2,700.

$750 per semester allowance x 2 semesters = $1,500.

$2,700 - $1,500 = $1,200 increase to COA.

Does Marilee have remaining eligibility for federal aid to help cover the child-care expense?

Because Marilee is a first-year student, her maximum Stafford loan eligibility is $9,500. She already is receivinga loan in this amount, so any additional aid must come through another federal program, if funds are available.If no other funds are available, Marilee may be able to obtain a private education loan to help meet her cost ofattendance.

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EFC Case Studies

Clayton

Clayton will be an independent, third-year undergraduate student at your school for the upcoming award year. Claytonfiled the FAFSA, but is concerned that he will not be able to continue with school in the fall semester, because he recentlywas laid-off from a job with a large car dealership in their town. Due to the current economic conditions, Clayton doesn’tanticipate another position becoming available in the near future. He is receiving unemployment insurance benefitsbased on his base year income of $54,000 and is seeking employment. For the award year, he earned $21,000 prior to thelay-offs at his company. His unemployment benefits are $250 per week. He comes to the financial aid office to seekassistance.

Is this a potential professional judgment?

Yes, depending on your school’s policy and procedures. When the base year income and anticipated award yearincome differ, it may be more appropriate to use the current year estimated income.

If so, would you require additional documentation? What would you require?

GEN 09-05 allows aid administrators to use a letter from the state unemployment agency or other evidence thatthe student is receiving unemployment benefits, to document that the income earned from work for the studentis zero for purposes of adjusting data elements for the student on the FAFSA. Unemployment benefits also can beconsidered to be zero. If the letter from the state unemployment agency is not available, other documentation isan acceptable substitute. Other types of documentation could include a letter of termination, along with a finalpay stub, and information on unemployment benefits. The student’s base year and current year federal taxreturns also could be used as documentation of the change in income.

What types of adjustments would you make?

Based on GEN 09-05, change income and unemployment benefits received to zero.

Other options may exist.

The Harris Family

Thomas and Kate Harris are both 58 years old and work full time. Their youngest child, Matthew, is the last of their fivechildren to attend college. Thomas and Kate financed their older childrens’ educations using Federal PLUS loans and have$75,000 in outstanding PLUS loan debt, with monthly payments of about $700 per month.

Matthew’s family used the FAFSA4caster during his junior year in high school, which estimated that their EFC would beapproximately $10,000. Matthew has been accepted as a freshman at your school for the upcoming academic year, buthis parents are concerned that he won’t be able to attend, because they can’t take on any more debt, and don’t have thefunds to pay for the family contribution based on their current combined income. Matthew and his parents come to thefinancial aid office to see what options may be available to the family. His parents provide copies of the promissory notesfor the PLUS loans borrowed on behalf of their other children.

Is this a potential professional judgment?

Yes, depending on your school’s policy and procedures. Existing educational debt is not taken into considerationin Federal Methodology, and for many families the debt affects the ability to pay current college costs.

If so, would you require additional documentation? What would you require?

The school may request documentation of payments made each month, as well as outstanding balances of theloans.

What types of adjustments would you make?

The Harris’ annual loan payments could be subtracted from their income, or their taxes paid could be increasedby the amount of the annual payments. Another option would be to adjust their assets by the family’s totaleducational debt.

Other options may exist.

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The Dean Family

The Deans, a family of four, made plans for Robert to attend college in the fall and submitted the necessary financial aidforms by the suggested filing date of March 1. In June, Mrs. Dean was in an automobile accident and incurred $5,000 inuninsured medical expenses.

Robert is concerned that his parents cannot financially assist him and that his course load will not allow him to work parttime. The current financial aid award will not be enough to meet his educational expenses. Robert fears he may need towithdraw from school and comes to your office for guidance.

EFC Formula Guide, 2012-2013, page 18.

Is this a potential professional judgment?

Yes, depending on your school’s policy and procedures. It is not uncommon for a family crisis, such as a death,divorce, serious illness or disability to occur after the family has submitted the FAFSA for the upcoming schoolyear.

If so, would you require additional documentation? What would you require?

Robert and his mother should document the actual medical expenses not covered by insurance. Explanation ofBenefits forms from their insurer, copies of bills from the doctors or hospitals also may be necessary. In addition,if the debt is being paid over a period of time, information on the amount to be paid during the current yearwould be helpful.

What types of adjustments would you make?

Although not required, it is considered a best practice to determine the amount of income protection allowanceallocated to medical expenses for a family of four with one in college. Subtracting this amount from the $5,000will result in an allowable amount for the PJ adjustment to AGI.

IPA x percentage of allowance = amount already taken into consideration

$25,210 x 11% = $2,773.10

$5,000 - $2,773.10 = $2,226.90

If Robert’s mother pays her medical bills over time, you could make an allowance against income or assets forthe amount to be paid during the calendar year.

Other options may exist.

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Dependency Override Case Studies

Cody

Cody is a 21-year-old, third-year undergraduate student at your school. Cody’s father died almost six months ago, and hismother’s exact whereabouts have been unknown for the past five years. Cody hears from his mother about once a year,and knows she is living in an adjacent state, but he has no way to reach her. Cody is living with his Aunt Teresa during thesummer, and will return to school housing for the fall term. Cody wishes to apply for financial aid, but calls your office forassistance to determine how he should proceed, since he is unable to reach his mother to obtain her information. Cody’saunt has told him that she would be willing to apply for a Federal PLUS loan to help him attend college, but he will needother financial assistance.

Is this a potential professional judgment?

Yes, depending on your school’s policy and procedures. Due to his father’s death, and his mother’s whereaboutsbeing unknown, Cody could, with appropriate documentation, be declared independent through professionaljudgment.

If so, what documentation would you require?

Acceptable documentation would include a statement from the student, as well as a knowledgeable third party,such as his aunt, who could attest to the unknown whereabouts of Cody’s mother. A copy of the father’s deathcertificate also may be requested.

In lieu of a dependency override, can Cody’s Aunt Teresa complete the parental portion of the FAFSA?

Federal regulations do not permit an individual to substitute for a parent when completing the FAFSA. Inaddition, his Aunt Teresa cannot apply for a Federal PLUS loan on Cody’s behalf.

Susan

Susan is a 22-year-old, fourth-year undergraduate at your school. For the past three years, her parents have supplied theparental data for the FAFSA. Based on the information provided, Susan has never qualified for need-based aid, but herparents have borrowed small Federal PLUS loans to help with Susan’s educational costs. Susan recently moved in with herboyfriend of two years, and even though her parents do not approve of the relationship, they remain in contact withSusan. Her parents are willing to provide their financial information on the FAFSA, but Susan and her boyfriend are payingtheir own bills, and Susan believes she could complete the FAFSA without her parent’s information.

Is this a potential professional judgment?

No. Because Susan does not meet any of the criteria on the FAFSA to be considered independent, and cannotmeet any of the criteria outlined in GEN 03-07 warranting a dependency override, she must supply her parent’sinformation in order to apply for federal financial aid.

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Loan Origination and Eligibility Case Studies

Daniel

Daniel, a second-year, dependent student at your school, received a full scholarship during his freshman year. He did notmeet scholarship-renewal requirements, so he comes to your office to find out how he can pay his tuition and cover hisexpenses for books and housing. You explain that he is eligible for an unsubsidized Stafford loan of $4,500. After you givehim information about the loan and explain the application process, he decides to apply online. As he leaves your office,he indicates that he doesn’t mind borrowing the money because he is not planning to pay it back anyway. What do youdo?

If you decide to refuse to originate the loan, how would you document your decision?

You heard Daniel state that he will not repay the Stafford loan; therefore, you could choose to refuse to originatethe loan. You must document the conversation and provide a written statement to Daniel stating your decision.You also should retain the documentation in his financial aid records.

Jay

Jay is a third-year, dependent accounting major at your school. His parents filed the FAFSA for his first two years of schoolbut have informed Jay that they no longer will provide support to him effective June 1, 2012. His parents have provided aletter to the financial aid office indicating such, including their refusal to complete the FAFSA. Jay and his family continueto have a good relationship, and talk frequently. Jay lives in an apartment and has a part-time job at a local radio stationwhich provides enough money to pay his rent each month. He comes to your office to talk with you about options hemay have for obtaining aid to continue attending school.

Is this a potential professional judgment? Why or why not?

Yes, if your school’s policy and procedures allow this type of adjustment.

What documentation would you require, if any?

The letter his parents provided is sufficient to perform the professional judgment. Jay then could complete andsubmit the student and certification portions of the FAFSA.

If you chose to approve a professional judgment for Jay, what is the maximum award he could receive in Title IV funds?

An unsubsidized Stafford loan in the amount of $7,500 is the maximum award he could receive in Title IV aid.

Morgan

Morgan is a second-year, pre-law major at your school. She makes an appointment to talk with you regarding herfinancial aid for the upcoming year. Her parents, with whom she resides, cannot pay for her school expenses, and haveindicated to Morgan that she needs to complete the FAFSA herself this year. She has completed the student portion, butis unable to obtain her parents’ information, or their signatures. She explains that she has a good relationship with herparents, and they would help her if possible, but they are struggling to pay their own bills. She also indicates that herparents are willing to provide a letter to your office with the information she has just shared.

Is this a potential professional judgment? Why or why not?

No, in this situation you could not exercise professional judgment to award unsubsidized Stafford loan funds toMorgan. Since Morgan still lives with her parents, they are continuing to provide non-cash support.

What documentation would you require, if any?

N/A.

If you chose to approve a professional judgment for Morgan, what is the maximum award she could receive in Title IVfunds?

N/A.

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