Professional Judgment
Alexis Moynahan
University of Maryland, University
College
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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
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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
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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
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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
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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
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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
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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
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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
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EFC & COA
Acceptable Documents (examples):
• Tax Documents
• Income documents (paystubs, W2’s etc.)
• Termination letter from employer
• Medical records
• Canceled checks
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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
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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.
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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.
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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.
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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.
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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
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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?
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Alexis Moynahan
Assistant Director – FA Counseling
University of Maryland, University College
amoynahan@umuc.edu
240.582.2685
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Resources
Information for Financial Aid Professionals:
www.ifap.ed.gov
Student’s Guide to FinAid:
www.finaid.org
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