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Time Out! The FAFSA Didn’t Ask Me

About….

Professional Judgment

VASFAA Annual ConferenceMay 19, 2014

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Objectives

• Review Professional Judgment basics• Discuss the way appeals “flow” through your

office• Highlight what can and cannot be considered via

a Professional Judgment appeal• Learn from your peers….discuss scenarios!

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What is Professional Judgment?

• Authority granted under the Higher Education Act

• Ability to take into account special (e.g., unusual) circumstances when determining aid eligibility

• Regulated to some degree, but a lot of flexibility• All schools do not handle this the same way

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Authority

• 2013-14 Federal Student Aid Handbook, Application and Verification Guide 2013-2014, Ch. 5 – Special Cases (Page AVG 114)

• HEA Sec. 479A(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.

• .

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More From FSA Handbook

In addition, nothing in this title shall be interpreted as limiting the authority of the student financial aid ad ministrator in such cases (1) to request and use supplementary information about the financial status or personal circumstances of eligible applicants in selecting recipients and determining the amount of awards under this title, or (2) to offer a dependent student financial assistance under section 428H or a Federal Direct Unsubsidized Stafford Loan without requiring the parents of such student to file the financial aid form prescribed under section 483 if the student financial aid administrator verifies that the parent or parents of such student have ended financial support of such student and refuse to file such form. (Page AVG 104)

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Professional Judgment “Musts” and “Must Nots”

• Must:– Be a condition that differentiates a student from a group of students

rather than exist across the entire group– Be documented

• Must Not:– Modify the formula or tables used in the EFC calculation– Adjust data elements or the COA because you believe the tables and

formula are not adequate or appropriate– Waive general student eligibility requirements or circumvent the intent of

the law or regulations– Include post enrollment expenses in the COA (e.g., professional

licensing exam fees)

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Licensing Exception

• 2013-14 Federal Student Aid Handbook, Volume 3 - Calculating Awards & Packaging, Ch. 2 - Cost of Attendance (Budget), Page 3-35

• An allowance for the one-time direct costs of obtaining a firstprofessional license or certificate for students who are enrolled in a program that requires such professional licensure or certification. This allowance may only be provided one time per student per eligible academic program. Examples of allowable costs include fees charged to take a licensing exam, costs of applying for and obtaining the license or certification, and, at the discretion of the school, costs incurred in traveling to a residency interview for a medical student. Under this provision, the costs must be incurred during (not after) a period of enrollment, even if the exam is after the end of the period.

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PJ Examples

• Tuition expenses at an elementary or secondary school• Medical or dental expenses not covered by insurance• Unusually high child care costs• Job loss or unemployment• The number of parents enrolled at least half-time in a

degree or certificate program• Cost of Attendance increases• Roth IRA rollovers• Dependency overrides

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PJ & Verification

• If the student was selected for Verification (by the school or CPS), then Verification must be completed before PJ changes are made

• If the student is not selected, then Verification is not required

• Remember to set the PJ indicator on the ISIR for all PJ changes

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PJ Flow

• What is the flow of appeals in your office?• Do you have a committee?• Do you review them independently?• Do you request students/parents submit

an appeal?• Do you only respond to appeals initiated

by a student/parent?

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PJ Scenarios

• What is the most prevalent type of appeal request you receive, and how do you handle them? (any increases in the past year or so?)

• What others types do you receive?• What problems are you experiencing?

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Job Loss

• On January 15, 2014 Jill and her parents submitted a FAFSA for the 2014-15 school year

• In March 2014 Jill’s father lost his job• Jill’s mother is a “stay-at-home mom” with no

regular source of income and Jill has two younger siblings who have not graduated from high school

• What do you do?

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Private Secondary Tuition

• Parents of one of your students file an appeal because they are paying tuition for the student’s sister to attend a private high school

• They have good public schools in their area, but believe this private high school will provide her with better opportunities

• What do you do?

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Married Parents With Two Separate Households

• Johnny goes to your college and his mother has submitted an appeal based on her living situation with her husband

• She and her husband are happily married and have two children • She resides in a house in South Carolina while her husband resides in a

house in North Carolina during the work week• The distance between dad’s job in NC and their house in SC is too far for

him to commute during the week• The children grew up in the SC house and their parents did not want to

uproot them from their friends and school, so they decided to keep two households until both children are in college and then mom will relocate to NC

• Dad goes to SC on the weekends to be with his family• The reason for the appeal is they would like some special consideration for

keeping up with two households• What do you do?

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Student Raised by Non-Parental Family Member

• Betsy is selected for Verification and then schedules a meeting with you to discuss what forms are needed to complete the process

• When you explain to her that parental information is needed, she tells you that her grandmother raised her and her mother never had anything to do with her

• Her father is in prison• What do you do?

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Religious Belief

• A student and her parent were in a dispute about her attending college

• According to the student, her parents do not want her to attend college because of their religious beliefs

• The student left home to be on his own and is seeking your assistance in securing enough aid to go to school

• What do you do?

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Dependency Overrides

• 2013-14 Federal Student Aid Handbook, Application and Verification Guide 2013-2014, Ch. 5 – Special Cases (Page AVG 115)

• A financial aid administrator (FAA) may do dependency overrides on a case-by-case basis for students with unusual circumstances…However, none of the conditions listed below, singly or in combination, qualify as unusual circumstances meriting a dependency override:

1. Parents refuse to contribute to the student’s education;

2. Parents are unwilling to provide information on the FAFSA or for verification;

3. Parents do not claim the student as a dependent for income tax purposes;

4. Student demonstrates total self-sufficiency. • Unusual circumstances do include an abusive family environment or abandonment

by parents and may cause any of the above conditions. In such cases a dependency override might be warranted.

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Homosexual Student

• A homosexual dependent student explains to you that his parents will not provide their information to complete the FAFSA

• His parents love him, but do not agree with the choices he is making so they are withholding their information

• The student wants to attend your college and is submitting an appeal asking that you treat him as an independent student

• What do you do?

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Interracial Dating

• A 19 year old Caucasian girl comes to your office and tells you that her parents have disowned her because she is dating an African American man

• The young lady explains that her parents will not provide their information for the FAFSA unless she breaks up with her boyfriend

• She is an excellent student and you do not want to lose her at your school

• What do you do?

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Medical Expenses

• The parents of a dependent student file an appeal to consider their out-of-pocket medical expenses

• Mom has a medical condition that required them to pay $8,000 in out-of-pocket medical expenses during the FAFSA base income year (i.e., 2013 on 2014-15 FAFSA)

• What do you do?

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Income Protection Allowance

• 2013-14 Federal Student Aid Handbook, Application and Verification Guide 2013-14, Ch. 5 – Special Cases (Page AVG 114)

• The Income Protection Allowance (IPA) is included in the EFC calculation to account for modest living expenses– 30% is for food– 22% is for housing– 9% is for transportation expenses– 16% is for clothing and personal care– 11% is for medical care– 12% is for other family consumption

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Summary

• You can do wonderful things for people with Professional Judgment

• It’s time consuming, but can change lives• Don’t be scared, just document your actions• Be sensitive as people are appealing for

reasons that may be difficult for them personally

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Contact Information

Brad Barnett, MS, AFC®, CPFM

James Madison University

Senior Associate Director of Financial Aid

E-mail: barnetbd@jmu.edu