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 AVG 2011-2012 Ch. 5 p.104
Corrections, Updates, Adjustments There are situations where the original application information may need to be changed Errors need to be corrected Dependency status, HHS, or # in College must be updated An aid administrator has the discretion to use professional judgment to account for special circumstances and adjust data AVG 2011-2012 Ch. 5 p.99
Verification and PJ All special circumstances must be verified first You must resolve any inconsistent or conflicting information shown on the output document before making any adjustments. AVG 2011-2012 Ch. 5
Examples of PJ Situations The following may merit a professional judgment call Loss of Income Additional Expenses One-time payouts Student’s Cost of Attendance Additional Expenses Dependency Overrides Can you determine which PJ is missing from this list?
What Data can be Adjusted by an FAA on the FAFSA? AGI Wages Earned Taxes Paid HHS # in College Additional Financial Information Untaxed Income Asset information Dislocated Worker Status Dependency Status
But First and Foremost….. DOCUMENTATION IS THE KEY!!! Statement from student or parent outlining circumstance Copies of Taxes W-2’s Last payment stub Letter from employer 3 rd party support documents Legal documents Your Institution’s Data system
Special Circumstances What is a Loss of Income? Unemployment or Income Reduction Death of a parent/spouse Divorce Loss of child support Dislocated Worker Military combat pay What is an Additional Expense? Extended family support Private school costs for children in elementary or high school Unusual medical/dental expenses not covered by insurance (must exceed 11% of IPA) Unusual debt (must exceed 12% of IPA) Each of these scenarios could impact the EFC
Dependency Overrides Any student who answers no to all the dependency questions are dependent even if student is self- supporting FAFSA 2011-2012 Questions 45-57 Students who have extenuating circumstances can file a Request for Independent Status
Denying a Dependency Override None of the following examples merit 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 student as a dependent for income tax purposes 4. Student demonstrates total self-sufficiency
What’s Included in the Budget? Standard Components that make up a student’s Cost of Attendance 1. Tuition & Fees 2. Books & Supplies 3. Room & Board 4. Transportation 5. Personal/Miscellaneous FSA-Handbook Vol. 3 Ch.2 & NASFAA Fall 2010-11Training Handout Basic COA Components
Additional Cost of Attendance Allowances Dependent Care Disability-Related Costs Employment Expenses for Cooperative Education Study Abroad Expenses First Professional Credential Educational Loan Fees
COA Restrictions/Exceptions Less than Half-Time Students Correspondence Program Students Incarcerated Students
Examples of Budget Adjustments Additional mortgage/rent charges Unusual car repair or transportation costs Dependent care costs Computer/Laptop expenses Unusual medical/dental expenses not covered by insurance Unusual Debt Stafford loan fees (if applicable) Nursing Home Expenses not covered by insurance Elementary/Secondary Private Tuition
Before taking in a Loss of Income or Additional Expense Is the EFC already Zero? Who is the change coming from Student/Spouse, or Student/Parent? Does the EFC come mainly from Parent’s Income or Assets? Does the EFC come mainly from Student’s Income or Assets? Will the change make a difference to the award? (Sub Max, Pell Grant Eligibility if EFC change)
Before Making an Adjustment to the COA… Has the student’s COA been met? Does the student currently reflect need? Does the student have the Max Subsidized Stafford Loan? Does the student have their Max Stafford Loans awarded? What is the students current enrollment?
How does this information apply to Professional Judgment? Know when to suggest a PLOI/SLOI, One-Time Lump Sum, an Additional Expense, or a Student COA adjustment Keep from processing unnecessary paperwork
Apply what you’ve learned Professional Judgment Exercise!
Resources Dear Colleague Letters regarding Professional Judgment GEN-11-04 GEN-09-04 GEN-09-05 IFAP 2011-12 Application Verification Guide (AVG) EFC Chapter 3, PJ Chapter 5, IFAP: Student Aid Handbook: Volume 3 Chapter 2 COA/Budget 2010 NASFAA Fall Training An Institutional Approach to Developing and Revising Cost of Attendance Components Special Populations: NASFAA FAFSA Tips for Applicants in Unique Situations