Professional Judgment

Professional Judgment Alexis Moynahan University of Maryland, University College

Brief Overview: Professional Judgment Areas FAAs can use Professional Judgment: • Dependency Override • Adjustments to Cost of Attendance • Adjustments to EFC data elements • Awarding unsubsidized loan eligibility

Dependency Override • Student must express an unusual circumstance • Schools can accept a dependency override from another school, within the Award Year. • General Rule: • You may make an otherwise dependent student, independent • You may not make an independent student, dependent

Dependency Override Conditions that do not merit an unusual circumstance: • Parents refusing to contribute to the student’s education • Parents unwilling to provide information on FAFSA, or for verification • Parents not claiming student as a dependent for income tax purposes • Student demonstrates total self-sufficiency

Dependency Override Unusual circumstances do include: • Voluntary or involuntary removal from parents’ home due to an abusive situation that threatened the student’s safety and/or health • Incapacity of parents such as incarceration or a disability or mental or physical illness • Inability of the student to locate the parent(s) after making reasonable efforts • Other extenuating circumstances sufficiently documented by a signed letter from a third party

Dependency Override Acceptable Documents (examples): • Signed statement from third party who knows student’s circumstance • Signed statement from student, or family member, detailing the circumstance • Any additional supporting documentation

EFC & COA • Changes to EFC data elements are only acceptable by the school who submitted the change • Student must present a differentiating circumstance • FAA’s decision is final and can not be appealed to the Department of Education

EFC & COA When is it appropriate to adjust an EFC data element? Examples: • Family member of student is a dislocated worker • Recent unemployment of family member or independent student • Roth IRA conversion Note: Can not make adjustments to EFC calculation

EFC & COA When is it appropriate to adjust the COA? Examples: • Elementary or secondary school tuition expenses • Medical, dental, or nursing home expenses not covered by insurance • Student must show proof that s/he has paid these costs • Unusually high child or dependent care costs • Student must show proof that s/he has paid these costs • Parents enrolled in college • Must show enrollment at an accredited college

EFC & COA Acceptable Documents (examples): • Tax Documents • Income documents (paystubs, W2’s etc.) • Termination letter from employer • Medical records • Canceled checks

EFC & COA Unemployment Insurance Benefits: • Dear Colleague Letter (GEN-09-05) allows an FAA to adjust income earned from work and unemployment to zero • Dear Colleague Letter (GEN-11-04) allows FAAs to continue to follow the information provided in GEN-09-05

Unsubsidized Loan Eligibility Students whose parents refuse to provide information on the FAFSA may still be eligible to receive non-need based aid. For determination student must provide: • Letter from student stating situation • Letter from parent stating they no longer provide support to student, and also provide the date when their support ended.

Scenario #1 Tom is 21 years old. He got in trouble in high school and was arrested, tried, and convicted for passing bad checks. He’s now on probation under very strict criteria. One of those criteria is that he is forbidden from having any contact with his mother who works for the probation department. He comes to you because he doesn’t know how he can get parental information to complete his FAFSA. His father is deceased and he has a married sister who lives close by.

Scenario #2 Rob is married and has two children. He worked almost full-time until June, then lost his job and has not been able to find another. He is the only family member in college. His wife earns $750/month babysitting for a neighbor’s child.

Scenario #3 Sarah’s parents own a rental home with a net worth of $150,000. The rental home burns down. The family loses potential rental income but has the potential for an upcoming insurance settlement.

Summary • Document, Document, Document! • Reason for the determination, as well as supporting documentation • Use your judgment, if something doesn’t “add up,” can you request additional documentation? Yes! • Maintain the documentation within the students file

Your School • Does your school have a business process in place for reviewing professional judgments? • Does one person review all special circumstances? Committee? • Is there a process that works particularly well for your school?

Alexis Moynahan Assistant Director – FA Counseling University of Maryland, University College amoynahan@umuc.edu 240.582.2685

Resources Information for Financial Aid Professionals: www.ifap.ed.gov Student’s Guide to FinAid: www.finaid.org

Professional Judgment