Professional Judgment Jamie A. Malone U.S. Department of Education

1. Professional JudgmentJamie A. MaloneU.S. Department of Education

2. Discretion of 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 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. However this authority shall not be construed to permit aid administrators to deviate from the contributions expected in the absence of special circumstances.” • HEA, Section 479A 2

3. Special Circumstances “Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students.” • Professional judgment is award year specific • Cannot be carried forward from year to year

4. Cost of Attendance Adjustments Any component of cost of attendance may be adjusted • Tuition/Fees • Books/Supplies • Room/Board • Transportation • Miscellaneous • Student Loan Fees • Study Abroad Expenses • Cooperative Education Expenses • Dependent Care • Disability

5. Cost of Attendance Adjustments • Student drives 150 miles each way to attend school • Commuter school allots $.56 a mile for 60 miles round trip in transportation component of COA If you agreed to make an adjustment, what would you adjust in COA?

6. Adjust EFC Data Items • Cannot be done on initial FAFSA • Resolve conflicting information before making PJ adjustment • If selected for verification, must complete verification before making PJ adjustment

7. Adjust FAFSA Data Items • Parent loses job due to lay off • Base year income $100,000 • Based upon submitted documentation, current year income expected to be $45,000 If you agreed to make an adjustment, what would you adjust on FAFSA?

8. EFC Income Protection Allowance • Increases as number in household increases • Decreases as number in college increases • Represents family’s basic living expenses • Food 30% • Housing 22% • Transportation 9% • Clothing and personal care 16% • Medical care 11% • Other family consumption 12% • 13/14 FSA Handbook, AVG, page AVG-38

10. Adjust EFC Data Items • Student reports that child was ill in base year • Documents out-of-pocket medical expenses of $2,500 • Would you make an adjustment to FAFSA? ISIR shows • Family size 3 with 1 in college - $30,070 IPA • 11% of $30,070 = $3307.70

11. Adjust FAFSA Data Items • Large amount of assets reported on FAFSA • Family member has terminal illness and family expects to need those assets for medical expenses • Family can document illness and expenses If you agreed to make an adjustment, what would you adjust on FAFSA?

12. EFC Asset Protection Allowance • Increases with age of older parent or independent student • Older means more assets to be set aside for retirement and not available for educational expenses

14. Adjust EFC Data Items • $40,000 cash, savings, and checking reported as asset reported on FAFSA • Since filing FAFSA, parent has used $35,000 for expenses related to tornado • Family can document damage and expenses • Asset Protection Allowance is $39,900 Would you make an adjustment to assets?

15. Awarding Unsubsidized Loan Funds To a dependent student whose parent(s) refuse to file a FAFSA AND have ended financial support for the student • NOT DEPENDENCY OVERRIDE Must have signed and dated statement from parent(s) specifically stating that • Have stopped providing financial support to the student and the date support stopped; AND • Will not provide financial support to student in the future; AND • Refuses to complete current year FAFSA

16. Deny/Reduce Direct Loan Amount School may refuse to originate or may reduce the borrower’s determination of need • Put in writing • On case-by-case basis • Non-discriminatory • HEA, Section 479A(c) & 34 CFR 685.301(a)(8)

17. What You Cannot Do Cannot • Change an EFC directly • Change PC or SC directly • Make changes to EFC formula • Use PJ to circumvent the regulations and law • Use PJ to waive student eligibility requirements

18. Dependency Override Included in statutory definition of independent student • “is a student for whom a financial aid administrator makes a documented determination of independence by reason of other unusual circumstances.” • HEA, Section 480(d)(1)(I)

19. When Dependency Override is Not Allowed • Cannot never an independent student dependent • Cannot make a dependent student independent • based on student’s demonstrated self-sufficiency • because student not claimed as parent’s income tax exemption • DCL GEN-03-07 • 13/14 FSA Handbook, AVG, page AVG-115

20. Using Another School’s DO • A financial aid administrator may make a determination of independence based upon a documented determination of independence that was previously made by another financial aid administrator in the same award year. • HEA, Section 480(d)(2)

21. Your Feedback PleasePlease provide any comments to my supervisor-Jo Ann BorelTitle IV Training Supervisorjoann.borel@ed.govAND/OR complete the survey at:Thanks much! http://s.zoomerang.com/s/JamieMalone

22. QUESTIONS? Jamie A. Malone Training Officer U.S. Department of Education 312-730-1528 jamie.malone@ed.gov 22