Professional Judgment:
Dependency Overrides & Reduced Income
Presented by
Paul Simenson, Penn State University
Exercising Professional Judgment
Bananas, Onions, Garlic,
A Deck of Cards
& Other Secrets to Developing Your
Professional Judgment Framework
Exercising Professional Judgment
First Things First:
• Why are you here?
• What do you want from the
next 40 minutes?
Exercising Professional Judgment
Student Aid 101: (A brief history)
• UM to CM to FM to “Simplification”
• USDE Special Conditions Form
• HEA ’65 Reauthorized in 1992
& Finally August 14, 2008
• Remains Principally Unchanged
• Guidance From Department
• Releasing of Monograph 26
Exercising Professional Judgment
Immutable Truths:
• The “Reasonable Person”
Standard
• Perception is Everything
• Not A Rationing Device for
Available Funds.
• Responsibility of the Authority
Exercising Professional Judgment
Customer Service 101:
• Courage to Challenge
• Perception vs. Reality Thing
• Satisfaction =
Reality ÷ Expectations
Exercising Professional Judgment
Counseling 101:
• No Talking to Crazy People
• Hurt People (pause) Hurt People
• When in Doubt, Ask for
Documentation.
(Paper is an unemotional advocate)
Exercising Professional Judgment
Keep in Mind:
(there are differences between)
• Unwilling vs. Unable
• Actionable vs. In-actionable
• Institutional Policy vs.
Professional Judgment
• Role of Choosing
Exercising Professional Judgment
And Now….
To the Nuts & Bolts:
• What Meets the Measure of
an Exception?
• Is There Documented Support
from the Appropriate Parties?
• What Does Professional
Judgment Look Like?
Exercising Professional Judgment
More….
Nuts & Bolts:
HIGHER EDUCATION ACT of 1965, As Amended
Section 479A.
DISCRETION OF STUDENT FINANCIAL AID ADMINISTRATORS.
In General.- Nothing in [Part F, "Need Analysis"] shall be
interpreted as limiting the authority of the financial aid
administrator, on the basis of adequate documentation, to
make necessary adjustments on a case-by-case basis to:
• the cost of attendance
• 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.
Exercising Professional Judgment
Nuts & Bolts… con’t
HIGHER EDUCATION ACT of 1965, As Amended
Section 479A.
DISCRETION OF STUDENT FINANCIAL AID ADMINISTRATORS.
However, this authority shall not be construed
to permit aid administrators to deviate from the
contributions expected in the absence of
special circumstances.
Exercising Professional Judgment
More….
Nuts & Bolts:
• How Is it Exercised?
 Mitigating Circumstances
(Dependency Issues)
 Cost of Attendance
 Income / Assets
(Change of Circumstance
• How Is it Exercised?
Repeatable / Reliable /
Unrelenting
Exercising Professional Judgment
More….
Nuts & Bolts:
• So, How Good Does Your
Professional Judgment
Have to Be?
• Is There a Prescribed,
Document-Driven Process?
• Are Peers Involved?
Exercising Professional Judgment
So, What Are The Highlights?
• P.J. Can Only Occur With The
Collection of Supplemental
Information
• It Is Critical You Know Your
Institutional Policies & Process
• Policy Formation (or Invoking
Policy) is NOT P.J.
Exercising Professional Judgment
So, What Are The Highlights?
• The Tale of the Nun & The
Violin…
• Your Decisions Must Be…
Exercising Professional Judgment
Toolbox 101:
The Big three (3) “gots” to know
• Your Institutional Polices,
Processes & Procedures
• The Federal Law: HEA’65
CCRAA
HEOA’08
• Where to Seek Guidance
Exercising Professional Judgment
Toolbox 101:
Final Toolbox Thoughts
The financial aid administrator is expected to provide
leadership in:
 the development of institutional policies &
guidelines for exercising professional judgment
 ensuring the consistent application
of those policies.
When questions arise involving professional
judgment, the financial aid administrator may find it
helpful to consult colleagues at similar
institutions.
Exercising Professional Judgment
Toolbox 101:
Final Toolbox Thoughts
The financial aid administrator is expected
to provide leadership in:
A continuing dialogue among financial
aid administrators will prove beneficial in
refining professional judgment
Exercising Professional Judgment
Toolbox 101:
Final toolbox Thoughts
The objective is to serve
students more equitably &
compassionately.
Professional Judgment in Eligibility Determination And Resource Analysis
November 13, 1993, Monograph Number 10
Updated June 1997
Exercising Professional Judgment
Toolbox 101:
Final Toolbox Thoughts
The aid administrator should be able to distinguish between
changes in a family’s circumstances that are a function of
choice, and those that are a function of necessity.
Using this distinction will help the aid administrator make
better decisions….
[Professional Judgment] is not intended to be a rationing
device and therefore should not be tailored to available
financial aid funding.
Exercising Professional Judgment
Monograph
A
N A S F AA S e r i e s
Constructing Student Expense Budgets
April 1993, Monograph Number 9
Updated June 1997
Professional Judgment in Eligibility
Determination And Resource Analysis
November 1993, Monograph Number 10
Updated June 1997
Exercising Professional Judgment
Monograph
A
N A S F AA
S e r i e s
Professional Judgment in Eligibility Determination And
Resource Analysis
October 2007, Monograph Number 21
http://www.nasfaa.org/PDFs/2007/Monograph21.pdf
http://www.nasfaa.org/products/monographs/Monographs.aspx
Professional Judgment in Eligibility Determination And
Need Analysis
August 2012, Monograph Number 26
http://www.nasfaa.org/EntrancePDF.aspx?id=11073
Also:
Dear Colleague Letter
DCL ID: Gen-09-05
May 8, 2009
http://www.ifap.ed.gov/dpcletters/GEN0905.html
Exercising Professional Judgment
One Last Thing
As You Go……
Exercising Professional Judgment
Questions, Comments,
Concerns?
Exercising Professional Judgment
Thanks…
P.M. Simenson
Senior Manager for Administrative
& Constituent Services
Penn State University
(pms2@psu.edu)