Professional Judgment in Financial Aid: Understanding HEA Section 479A
HEA Section 479A grants financial aid administrators the authority to exercise professional judgment (PJ) in making case-by-case adjustments for applicants with special circumstances. Learn about PJ policies, procedures, and responsibilities in making decisions regarding PJ requests.
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Presentation Transcript
PROFESSIONAL JUDGEMENT Katie Malone, Director of Financial Aid at North Central Michigan College Allyson VanConant, Financial Aid Officer at Saginaw Chippewa Tribal College
WHATS THE LAW ON PJ? HEA Section 479A establishes authority for the financial aid administrator to exercise professional judgment (PJ) discretion to make adjustments on a case-by-case basis in a number of areas when an applicant, parent, or spouse has special or unusual circumstances. The FAFSA Simplification Act prohibits institutions from maintaining a policy of denying all PJ requests. Institutions must have a published policy on PJ including; Provisional independent status Dependency overrides in subsequent award years Dependent students and unsubsidized loan changes Acceptable documentation Specific examples of special circumstance
WHATS THE DIFFERENCE BETWEEN A CORRECTION, AN UPDATE, AND A PJ ADJUSTMENT? Corrections: Corrections are changes to data elements that were incorrect at the time the FAFSA was filed. Corrections can be made by student or the school. Typically during verification errors can be found and corrected by the school via CPS. Updates: Updates are changes to data elements that were correct at the time of application, but changed since the FAFSA was filed. Updates are allowable only under very specific circumstances related to dependency status, number in household (household size), number in college, and marital status. Professional Judgment (PJ) Adjustments: Changes made to FAFSA data elements by an FAA exercising the PJ authority are called adjustments. Decisions are made on a case-by-case basis and must be thoroughly documented in the student's file.
PJ POLICIES AND PROCEDURES Framework and guidelines for identifying circumstances that may trigger a PJ review Road map for FAA Provide examples of circumstances which may be considered In writing
WHO IS RESPONSIBLE FOR PJ DECISIONS? School officials, the FAA, are the professionals empowered to exercise PJ on their campus. Some schools have one FAA assigned who performs the task others may allow all FAAs to process a PJ request KEY: PJ decisions should be made on a case-by-case basis and based on special circumstances which must be documented in the student's file.
ALL FAAS SHOULD ASK Is the student or the student s family actually experiencing unique circumstances not dealt with adequately in the need analysis formula, or by other Title IV provisions for which the use of PJ is permitted? Does the unusual situation warrant special treatment because it affects the student s or family s ability to contribute toward the cost of the student s education, or otherwise affects the student s ability to complete his or her program of study? What should the special treatment be? What documentation is needed to support this determination?
PJ CAN BE USED TO: Need analysis data elements Dependency status Satisfactory academic progress (SAP) PJ Authority Expected family contribution (EFC) Direct Loan eligibility Cost of attendance (COA)
PJ CANNOT BE USED TO: Change independent to dependent Make bottom- line EFC adjustment Create new COA category Adjust Federal Methodology formula or tables Make otherwise ineligible student eligible Make across- the-board changes Include post- enrollment costs in COA (1 exception) Circumvent intent of law or regulations Circumvent FSEOG award criteria
PJ DOCUMENTATION EXAMPLES Documentation will vary based on the reason for completing the PJ and may included, but not limited to: Letter from the student Letters from knowledgeable third parties Student/parent tax return Documentation of resources or in-kind support Statement from parents/documentation of estrangement Medical Bills Documentation of expenses exceeding COA components Obituary of relative of student Documentation of Family difficulties such as divorce or illness
LET'S PRACTICE! CASE SCENARIO 1 Fred is a second year student at your campus. He lives in student housing. Your COA includes housing for students in a three-person suite. This year, Fred has a private dorm room and is requesting a PJ to account for the increased cost. Is this eligible for a PJ? What documentation would you request? If you approved his PJ, what would you adjust?
COA ADJUSTMENTS Address special circumstance Documentation as to why a private room is needed Special needs? Medical? Academic? Lifestyle choice? Must be made within the COA categories defined in law Food and housing would be adjusted
LET'S PRACTICE! CASE SCENARIO 2 Velma is a new student attending your institution. She completed her FAFSA with her dad using his 2021 tax return. When speaking with Velma and her dad at a recent appointment, you discovered her dad has recently been let go from his full- time job at a tech company and has been working part-time at the local diner. Is this eligible for a PJ? What documentation would you request? If you approved her PJ, what would you adjust?
NEED ANALYSIS Elementary or secondary school expenses Circumstances Uninsured medical and dental expenses Special High dependent care costs Recent unemployment Half-time enrollment of parent
ALTERNATIVE-YEAR INCOME Use actual or estimated income for calendar year, award year, or other 12-month period. What does your institution use? How would you handle this situation?
LET'S PRACTICE! CASE SCENARIO 3 Shaggy is a potential freshman at your college. Upon his high school graduation, his dad and step-mom threw him out of the house and cut him off financially. His biological mother passes away 14 years ago. He has been living with friends throughout the summer. He wants to attend college, but does not think he can afford it. Is this eligible for a PJ? What documentation would you request? If you approved his PJ, what would you adjust?
DEPENDENCY OVERRIDE Dependency Override Cannot Occur because: Parents refuse to contribute to student's educational costs Parents unwilling to provide information on FAFSA or for verification purposes Parents do not claim student as a dependent for income tax purposes Student demonstrates total self-sufficiency
LET'S PRACTICE! CASE SCENARIO 4 Daphne is a junior on your campus and you evaluate SAP after every payment period/semester. After her fall semester, her GPA dropped to a 1.9. After the spring/winter semester, her GPA dropped to a 1.5. After receiving a letter saying she is now on financial aid suspension, she reaches out saying the last year was rough as she lost her dad in the fall semester and suffered injuries from a car accident this past year. Is this eligible for a PJ? What documentation would you request? If you approved her PJ, what would you adjust?
SAP STANDARDS Maximum timeframe Quantitative (pace) Frequency of evaluation Qualitative (grades) Same as or stricter than SAP Appeal policies Standards
SAP APPEALS AND PJ Financial aid warning allows Title IV aid for one more payment period only Available only to schools that monitor SAP at the end of each payment period Options on successful appeal: Financial aid probation status for one payment period if the student should be able to meet SAP standards by the end of the payment period; or An academic plan under which the student can continue to receive Title IV aid as long as the student complies with the plan s requirements
FINANCIAL AID PROBATION OR ACADEMIC PLAN Financial Aid Probation Meeting SAP requirements Review after one payment period Appeal Academic plan or ineligible Academic Plan Meeting plan requirements Periodic review against plan Appeal Ineligible
RESOURCES FSA Handbook Application and Verification Guide; Chapter 5 Student Aid Reference Desk Section 479A of the Higher Education Act of 1965 (HEA), as amended NASFAA Self-Study Guide AskRegs
THANK YOU!! Katie Malone, Financial Aid Director at North Central Michigan College kmalone@ncmich.edu Allyson VanConant, Financial Aid Officer at Saginaw Chippewa Tribal College avanconant@sagchip.edu
