Presented by: Tanya Grigg Director of Financial Aid Samuel Merritt University Mike MacCallum, PhD Dean of Financial Aid, EOPS & Veterans Affairs Long Beach City College PJ - Basics to Advanced WASFAA 2011

Financial Aid Professionals Need to treat all applicants with equity. Rules and regulations help maintain horizontal and vertical equity.

Parents and Students Families want as much financial aid as they can get. The underlying premise of need and equity is not a concept that is readily accepted or acknowledged by families. Financial Aid is often viewed as a reward for doing well, not as a social tool for access and choice.

So, how do we reconcile the underlying premise of financial aid with the reality of the students?

Using Professional Judgment Guidelines for Good Practices

Professional Judgment The Higher Education Act of 1965, as amended, authorizes the financial aid administer to exercise discretion in the following areas: Independent student status Need Analysis: Calculation of the Expected Family Contribution (EFC) Cost of attendance (COA) Denial or reduction of eligibility for loans under the William D. Ford Federal Direct Loan Program or the Federal Family Education Loan Program Satisfactory academic progress requirements

HEA 479A

Can use discretion in certain areas when a student’s family has unique or extraordinary circumstances Circumstances must differentiate an individual student from a class of students Must be made on an individual case- by-case basis Across the board changes are not permitted Policies and procedure to objectively identify students Subjective-no wrong or right answer Basic PJ Principles Each aid administrator must make their own decision!

Recommended Written letter from parents Bills Receipts Pay stubs Other third party documentation Document Decision made and how it was reached Decision date Description of actions taken School policy and procedure citation Name and title of decision maker Keep a Good Audit Trail You have the authority to request and use supplemental information. Special circumstances and action taken should be documented in the student’s file.

Independent Status Dependent students can be made independent by professional judgment due to an adverse home situation Should obtain documentation from a third party, if at all possible Document the decision Update yearly

Independent Status Dependent students can NOT be made independent by professional judgment if Parents refuse to provide information for the FAFSA Parents refuse to pay for the student’s education Parents do not claim the student on their tax return Student is self supporting

Financial Aid Eligibility: Two Ways to Make Adjustments 1.Change items in the need analysis 2.Increase student costs of attendance

Changes in Need Analysis Cannot modify general formulas or tables used in the calculation of the EFC. You can change the actual numbers used to input into the calculation. Projected income, projected school year income Additional tax burden Reduction of value of assets Medical and dental expenses Family size Number in college Private education expenses

Changes in Need Analysis Your goal: “…use information that realistically reflects the individual's and/or family's current and near-term economic situation.” DCL GEN The decision of the financial aid administrator is final. There is no appeal. By law, neither the school's president nor the US Department of Education can override the financial aid administrator's decision.

Changes in the Cost of Attendance Tuition and Fees Room and Board Books & Supplies (inc. computers) Transportation Childcare Costs Miscellaneous Expenses

Bottom line EFC Alter the need analysis formula or change table values because you do not think they are fair Create a new category of cost Fill in for parents’ unwillingness to pay Change an independent student to dependent Make an otherwise ineligible student eligible for Title IV aid Can NOT Use Professional Judgment To

Make across the board changes Circumvent the intent of the regulations Circumvent FSEOG eligibility criteria Can NOT Use Professional Judgment To REMEMBER: FAIRNESS AND EQUITY

Updated NASFAA Monograph NASFAA updated Monograph #22 to reflect current guidance as well as provisions from the recently enacted College Cost Reduction and Access Act. Be sure to look at Appendix B: “Guide to Addressing Special Circumstances” May 2009 #22

Legitimate Appeals vs. Negotiation How do you tell if it’s a legitimate appeal? How do you ensure consistency in handling appeals? What pressures do you feel from others ?

Legitimate Appeals Loss or Reduction in Family Income Unusual Medical/Dental Costs not Covered by Insurance Death or Illness in Family Marriage or Divorce in Family Other Unusual Circumstances

The Economic Downturn Dear Colleague Letters GEN-09-04: Encourages schools to contact families affected by the economy and let them know about the availability of professional judgment. GEN-09-05: Allows colleges to treat unemployment benefits as zero income. These Dear Colleague Letters are in effect until further notice (USDE, May 21, 2010)

Student Loans Statute gives FAA’s the authority, using professional judgment, to deny or reduce Direct or PLUS loans The law requires: Determination must be made on a case-by-case basis Must document the reason for the decision Must provide written notification to the student (or parent, if a PLUS loan) Cannot discriminate on the basis of race, nationality, religion, sex, marital status, age, or disability status

Satisfactory Academic Progress Under the new regulations, schools may choose to not have an appeal process for student who don’t meet SAP Student appeal is based on What happened What has changed If the appeal is successful, the student is placed on probation and is eligible for Title IV aid for one payment period

Satisfactory Academic Progress At the end of the probationary payment period, the student Is making SAP—Ok to continue on financial aid Is not making SAP—Student is no longer eligible for Title IV aid unless the student successfully completed the provision of an academic plan

Professional Judgment Tips Describe your professional judgment procedures in your policies and procedures manual Document, document, document

Tips to Keep in Mind Be aware of your management’s philosophy. Make judgments that management can support. Be aware of your own biases. Be objective/open-minded. Separate your emotions. Share/discuss decisions with your team. Shared ideas and perspectives. Shared buy-in. Consistent decisions. Strength in numbers. Filter out the details, flesh out the core issues, and simplify.

CASES

James James lived in his car during part of high school and then moved in with a friend’s parent and paid rent. He worked three jobs to support himself during high school. James moved out because of physical abuse from his stepfather. He maintains contact with his mother and stepfather. His stepfather refuses to complete the FAFSA. His birth father has been out of the picture since he was 2 weeks old, but he has recently started to talk with him some over the phone. Is he independent? Does his homeless status during high school have any bearing on the case?

Sam Sam is a low-income, graduate student with a documented disability. He has been awarded aid to meet his standard college costs. Sam has suffered from a variety of medical and dental expenses over the years—many have been covered with loans. He needs carpal tunnel surgery and submits a request for $34,000 in uninsured medical expenses. He has some health insurance coverage.

Anna Anna's parents are listed as separated since March 2003 on the FAFSA form. Her file was selected for verification and the parents filed jointly and listed the same address. Anna explains that the family lives in a duplex and her father has moved into the apartment downstairs and only comes up for meals and occasionally helps with family expenses

Brian Brian is a dependent student Brian’s parents work as writers and are currently on strike. They are predicting their income will drop from $135,000 in 2009 to $35,000 in 2010.

Tara Tom and Trish married three years ago when Trish’s daughter Tara was a sophomore in high school. They signed a prenuptial agreement that Tom would bear no responsibility for Tara’s college. Tom is a physician, earning $250,000, Trish does not work outside of the home. Tara is the only child at home. Tara’s birth father is willing to contribute $5000 a year towards her college costs.

Antony Antony is a 21-year old junior. He answered all dependency questions "No", except "Do you have children who will receive more than half of their support from you between July 1, 2010 and June 30, 2011?". When your office asked for additional information, he stated that he and his girlfriend have a 2-year old daughter who lives with them. His girlfriend does not work and receives TANF. Antony provides all other expenses.

Oda Oda is a 25-year old graduate student applying for financial aid. Oda is living with her boyfriend who provides all of her expenses. He recently bought her a car and they are planning a trip to Paris for the holidays. Oda reports her income as $0 on the FAFSA.

Lily Lou and Louise have the ability to pay for their daughter Lily’s expenses, but are not willing to do so because they disapprove of decisions she has made. At 18, Lily moved out of the home, was pregnant, had an abortion and lives with her boyfriend—all against her parents religious beliefs. Should you make her independent?

Michael Michael is a “lost boy” from the Sudan and has no family he can locate. He is independent and is eligible for aid based on his refugee status. He has experienced many difficulties during his attendance and most recently was admitted to a hospital for mental illness He lost his computer during this required hospital time. He can’t remember what happened during the last three days. His computer had been purchased with financial aid funds. He could receive unsubsidized loans to purchase another one. What would you consider in deciding his request?

John John is a graduate student. He works part-time, earning about $25,000 per year. On his FAFSA form he answered "Yes" to regarding support of other dependents. When asked to explain, he stated that, although he lives with his parents, their only income is Social Security and he pays all of the rent each month. He feels that he financially supports his parents and his younger brother.

And now, a little fun…

The Jolie-Pitt Family Angelina and Brad fall in love but never married. They adopt three kids, including Maddox. Brad adopts Angelina’s other child. They recently had a set of twins for a total of 6 children. They make pretty much the same income, but Brad has more assets. Who completes the FAFSA for Maddox and who is in his household?

The Cruise Kidman Family Tom and Nicole are divorced and both have remarried and both had one child with their new spouses. While married to each other, they adopted two children. Conner, their eldest son, is heading to your campus and applying for aid. He splits his time between his two parents, but last year because Tom was working on a movie, he and his sister were mostly with Nicole and her husband Keith. Who is the custodial parent and how many people are in the household?

The O’Donnell-Carpenter Family Rosie and Kelli marry in a same-sex ceremony in San Francisco They raise four kids and one is headed to your college Rosie is the bread winner of the household, Kelli has no income or assets of her own How many people are in the household and considered in college for the FAFSA?

The Leon, Ciccone, Ritchie Family Lourdes Leon has applied to your school. Her parent’s never married but Lourdes has split her time with both parents her entire life. Her Mom later married Guy Ritchie and had Rocco and adopted David. Madonna is now separated from Guy and all three children split their time between their parents. Who completes the FAFSA for Lourdes and how many people are in her household.

QUESTIONS