PJ - Basics to Advanced
WASFAA 2011
Presented by:
Tanya Grigg
Director of Financial Aid
Samuel Merritt University
Mike MacCallum, PhD
Dean of Financial Aid , EOPS & Veterans Affairs
Long Beach City College
Financial Aid Professionals
 Need to treat all
applicants with
equity.
 Rules and
regulations help
maintain
horizontal and
vertical equity.
Parents and Students
 Families want as much
financial aid as they can get.
 The underlying premise of
need and equity is not a
concept that is readily
accepted or acknowledged by
families.
 Financial Aid is often viewed
as a reward for doing well,
not as a social tool for access
and choice.
So, how do we reconcile the
underlying premise of
financial aid with the reality
of the students?
Using Professional Judgment
Guidelines for Good Practices
Professional Judgment
 The Higher Education Act of 1965, as
amended, authorizes the financial aid
administer to exercise discretion in the
following areas:
 Independent student status
 Need Analysis:
 Calculation of the Expected Family
Contribution (EFC)
 Cost of attendance (COA)
 Denial or reduction of eligibility for loans
under the William D. Ford Federal Direct
Loan Program or the Federal Family
Education Loan Program
 Satisfactory academic progress requirements
HEA 479A
Basic PJ Principles
 Can use discretion in certain areas
when a student’s family has unique
or extraordinary circumstances
 Circumstances must differentiate an
individual student from a class of
students
 Must be made on an individual caseby-case basis
 Across the board changes are not
permitted
 Policies and procedure to objectively
identify students
 Subjective-no wrong or right answer
Each aid administrator must
make their own decision!
Keep a Good Audit Trail
You have the authority to request and use supplemental information. Special
circumstances and action taken should be documented in the student’s file.
Recommended
 Written letter from
parents
 Bills
 Receipts
 Pay stubs
 Other third party
documentation
Document
 Decision made and how it
was reached
 Decision date
 Description of actions taken
 School policy and
procedure citation
 Name and title of decision
maker
Independent Status
 Dependent students can be
made independent by
professional judgment due
to an adverse home situation
 Should obtain
documentation from a third
party, if at all possible
 Document the decision
 Update yearly
Independent Status
 Dependent students can
NOT be made independent
by professional judgment if
 Parents refuse to provide
information for the FAFSA
 Parents refuse to pay for the
student’s education
 Parents do not claim the
student on their tax return
 Student is self supporting
Financial Aid Eligibility:
Two Ways to Make
Adjustments
1. Change items in
the need analysis
2. Increase student
costs of attendance
Changes in Need Analysis
Cannot modify general formulas or tables used in
the calculation of the EFC. You can change the
actual numbers used to input into the
calculation.
 Projected income, projected school year income
 Additional tax burden
 Reduction of value of assets
 Medical and dental expenses
 Family size
 Number in college
 Private education expenses
Changes in Need Analysis
Your goal: “…use information that realistically
reflects the individual's and/or family's current
and near-term economic situation.” DCL GEN09-04
The decision of the financial aid administrator is
final. There is no appeal. By law, neither the
school's president nor the US Department of
Education can override the financial aid
administrator's decision.
Changes in the Cost of Attendance
Tuition and Fees
Room and Board
Books & Supplies (inc. computers)
Transportation
Childcare Costs
Miscellaneous Expenses
Can NOT Use Professional Judgment
To
 Bottom line EFC
 Alter the need analysis formula or change table
values because you do not think they are fair
 Create a new category of cost
 Fill in for parents’ unwillingness to pay
 Change an independent student to dependent
 Make an otherwise ineligible student eligible for
Title IV aid
Can NOT Use Professional Judgment
To
 Make across the board changes
 Circumvent the intent of the regulations
 Circumvent FSEOG eligibility criteria
REMEMBER:
FAIRNESS AND EQUITY
Updated NASFAA Monograph
 NASFAA updated Monograph #22 to reflect current
guidance as well as provisions from the recently
enacted College Cost Reduction and Access Act.
 Be sure to look at Appendix B: “Guide to
Addressing Special Circumstances”
May 2009
#22
Legitimate Appeals vs.
Negotiation
 How do you tell if it’s
a legitimate appeal?
 How do you ensure
consistency in
handling appeals?
 What pressures do you
feel from others ?
Legitimate Appeals
 Loss or Reduction in Family Income
 Unusual Medical/Dental Costs not Covered by
Insurance
 Death or Illness in Family
 Marriage or Divorce in Family
 Other Unusual Circumstances
The Economic Downturn
 Dear Colleague Letters
 GEN-09-04: Encourages schools to contact
families affected by the economy and let them
know about the availability of professional
judgment.
 GEN-09-05: Allows colleges to treat
unemployment benefits as zero income.
 These Dear Colleague Letters are in effect until
further notice (USDE, May 21, 2010)
Student Loans
 Statute gives FAA’s the authority, using
professional judgment, to deny or reduce Direct or
PLUS loans
 The law requires:
 Determination must be made on a case-by-case basis
 Must document the reason for the decision
 Must provide written notification to the student (or parent,
if a PLUS loan)
 Cannot discriminate on the basis of race, nationality,
religion, sex, marital status, age, or disability status
Satisfactory Academic Progress
 Under the new regulations, schools may
choose to not have an appeal process for
student who don’t meet SAP
 Student appeal is based on
 What happened
 What has changed
 If the appeal is successful, the student is
placed on probation and is eligible for Title
IV aid for one payment period
Satisfactory Academic Progress
 At the end of the probationary payment
period, the student
 Is making SAP—Ok to continue on financial aid
 Is not making SAP—Student is no longer
eligible for Title IV aid unless the student
successfully completed the provision of an
academic plan
Professional Judgment Tips
 Describe your professional judgment
procedures in your policies and procedures
manual
 Document, document, document
Tips to Keep in Mind
 Be aware of your management’s
philosophy. Make judgments that
management can support.
 Be aware of your own biases.
 Be objective/open-minded.
 Separate your emotions.
 Share/discuss decisions with your team.




Shared ideas and perspectives.
Shared buy-in.
Consistent decisions.
Strength in numbers.
 Filter out the details, flesh out the core
issues, and simplify.
CASES
James
 James lived in his car during part of high school and
then moved in with a friend’s parent and paid rent.
He worked three jobs to support himself during high
school.
 James moved out because of physical abuse from his
stepfather. He maintains contact with his mother and
stepfather. His stepfather refuses to complete the
FAFSA.
 His birth father has been out of the picture since he
was 2 weeks old, but he has recently started to talk
with him some over the phone.
 Is he independent? Does his homeless status during
high school have any bearing on the case?
Sam
 Sam is a low-income, graduate student
with a documented disability. He has
been awarded aid to meet his standard
college costs.
 Sam has suffered from a variety of
medical and dental expenses over the
years—many have been covered with
loans.
 He needs carpal tunnel surgery and
submits a request for $34,000 in
uninsured medical expenses. He has
some health insurance coverage.
Anna
 Anna's parents are listed as separated
since March 2003 on the FAFSA form.
 Her file was selected for verification
and the parents filed jointly and listed
the same address.
 Anna explains that the family lives in a
duplex and her father has moved into
the apartment downstairs and only
comes up for meals and occasionally
helps with family expenses
Brian
 Brian is a dependent student
 Brian’s parents work as writers and
are currently on strike.
 They are predicting their income will
drop from $135,000 in 2009 to $35,000
in 2010.
Tara
 Tom and Trish married three years ago when
Trish’s daughter Tara was a sophomore in high
school.
 They signed a prenuptial agreement that Tom
would bear no responsibility for Tara’s college.
 Tom is a physician, earning $250,000, Trish
does not work outside of the home. Tara is the
only child at home.
 Tara’s birth father is willing to contribute $5000
a year towards her college costs.
Antony
 Antony is a 21-year old junior.
 He answered all dependency questions "No",
except "Do you have children who will receive
more than half of their support from you between
July 1, 2010 and June 30, 2011?".
 When your office asked for additional information,
he stated that he and his girlfriend have a 2-year
old daughter who lives with them.
 His girlfriend does not work and receives
TANF. Antony provides all other expenses.
Oda
 Oda is a 25-year old graduate student
applying for financial aid.
 Oda is living with her boyfriend who
provides all of her expenses.
 He recently bought her a car and they are
planning a trip to Paris for the holidays.
 Oda reports her income as $0 on the FAFSA.
Lily
 Lou and Louise have the ability to pay
for their daughter Lily’s expenses, but
are not willing to do so because they
disapprove of decisions she has made.
 At 18, Lily moved out of the home, was
pregnant, had an abortion and lives
with her boyfriend—all against her
parents religious beliefs.
 Should you make her independent?
Michael
 Michael is a “lost boy” from the Sudan and has no family he can
locate. He is independent and is eligible for aid based on his
refugee status.
 He has experienced many difficulties during his attendance and
most recently was admitted to a hospital for mental illness
 He lost his computer during this required hospital time. He can’t
remember what happened during the last three days.
 His computer had been purchased with financial aid funds.
 He could receive unsubsidized loans to purchase another one.
 What would you consider in deciding his request?
John
 John is a graduate student.
 He works part-time, earning about $25,000 per
year.
 On his FAFSA form he answered "Yes" to
regarding support of other dependents.
 When asked to explain, he stated that,
although he lives with his parents, their only
income is Social Security and he pays all of
the rent each month.
 He feels that he financially supports his
parents and his younger brother.
And now, a little fun…
The Jolie-Pitt Family
 Angelina and Brad fall in love but never
married. They adopt three kids, including
Maddox. Brad adopts Angelina’s other
child. They recently had a set of twins for a
total of 6 children.
 They make pretty much the same income,
but Brad has more assets.
 Who completes the FAFSA for Maddox and
who is in his household?
The Cruise Kidman Family
 Tom and Nicole are divorced and both have
remarried and both had one child with their new
spouses. While married to each other, they adopted
two children.
 Conner, their eldest son, is heading to your campus
and applying for aid.
 He splits his time between his two parents, but last
year because Tom was working on a movie, he and
his sister were mostly with Nicole and her husband
Keith.
 Who is the custodial parent and how many people
are in the household?
The O’Donnell-Carpenter Family
 Rosie and Kelli marry in a same-sex
ceremony in San Francisco
 They raise four kids and one is
headed to your college
 Rosie is the bread winner of the
household, Kelli has no income or
assets of her own
 How many people are in the
household and considered in college
for the FAFSA?
The Leon, Ciccone, Ritchie Family
 Lourdes Leon has applied to your school. Her
parent’s never married but Lourdes has split her
time with both parents her entire life. Her Mom
later married Guy Ritchie and had Rocco and
adopted David.
 Madonna is now separated from Guy and all three
children split their time between their parents.
 Who completes the FAFSA for Lourdes and how
many people are in her household.
QUESTIONS