PJ is the discretion granted to financial aid
administrators by law to override dependency status
and make adjustments to need analysis, including data
elements used to calculate the expected family
contribution (EFC) and costs within the cost of attendance
(COA) components
Section 479A of the Higher Education Act
of 1965, as amended (HEA) establishes
the authority for the financial aid
administrator (FAA) to exercise discretion
in a number of areas when an applicant
has special or unusual circumstances
The U.S. Department of Education (ED)
encourages the use of PJ for affected
individuals under the Higher Education Relief
Opportunities for Students (HEROES) Act of
2003
• PJ is not regulated by ED
• The law does NOT
• Restrict your authority to exercise PJ
• Require you to exercise PJ when you encounter
special circumstances
• Use PJ to circumvent the law
• Use PJ to waive student eligibility requirements
Professional
Judgment
Need and action
require adequate
documentation
Must be
administered on a
Case-by-Case basis
Similar situations
require individual
documentation &
review
Across the board
changes NOT
permitted
P&P should
establish policy
Extends authority to
request
supplemental
information
Should include
policies that provide
framework for
triggering review
FAA must make
and document their
own decision
An institution may
NOT automatically
accept another’s
adjustments
May arrive at same
conclusion, but must
document
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•
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Focus on unique circumstance that impacts family’s ability to pay
Review entire situation – are there items that offset the
circumstance?
Are there others on campus you might reach out to for more
information about the student’s situation?
Are you satisfied with the documentation you have received?
Look at each request independently, but be consistent
PJ should not be used as a rationing device for awarding limited
funds.
• What should you do if personal prejudices or assumptions
get in the way of performing a PJ?
• How do different staff members handle certain situations?
• Are you requiring similar documentation from all students?
• Discretionary vs. non-discretionary
• Necessity vs. lifestyle choices
• Can you make a logical argument for the PJ?
Professional
Judgment
Need Analysis
Cost of
Attendance
Dependency
Override
Satisfactory
Academic
Progress
Refusal or
Adjustment of
Loan Certification
Need Analysis
May make changes to
income, assets, exclusions,
family size & number in
college
Income adjustment can be
for any 12 month period
that most accurately
reflects situation
May NOT Directly
change formula
May NOT directly adjust
EFC
• What constitutes unusual circumstances?
• Is the student and/or family actually experiencing
unusual circumstances?
• Is special treatment warranted?
• What should the special treatment be?
• What documentation is needed?
• Loss of income due to lay off?
• Loss of income due to retirement?
• Loss of income due to voluntary resignation?
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Gambling winnings?
Reduction in overtime pay?
One-time bonus?
Reducing student’s income if they help with
household expenses?
• On New Year’s eve, Gena decided she’d had enough and quit
working as an exotic dancer at the truck stop at exit 186. Last
year she made $47,000 during her part time work as she went
to school. In March, she got a job at the Mule Trading Post and
will make $8.95 per hour, 20 hours per week as she finishes her
degree.
• Would you make an adjustment?
• What information would you collect?
• Kristen is a Senior at 4-year private school. She has always
received the Pell Grant on her award letter, except for this
year. She hit a progressive slots jackpot in Booneville and
brought home $25,000 in winnings, which is 4 times what she
makes in a normal year. She used the money on medical bills,
taxes, and a two week adventure in Colorado that she doesn’t
remember, but now gets lots of coupons from Taco Bell. What
would you do?
• Drew, a dependent student, realizes that he did not get as much
financial aid this year as he did in the previous year. His mom submits
a special circumstance form claiming a forced reduction in hours for all
employees. She includes a copy of a company wide letter as well as
paystubs of before and after that verify the reduction. She also asks
that you exclude the $14,000 withdrawal from her retirement account
as her income has not been enough to sustain her living expenses. She
explained that this is primarily due to high medical bills. You look at
the previous year and note that you did a PJ to exclude a similar
“one-time” withdrawal last year. Last year you also had a Schedule A
that showed about $9,000 in medical expenses. This year, medical
expenses were not high enough to qualify for a deduction.
• Would you exercise a PJ? If so, for what? Would you ask for any
additional documentation?
Cost of Attendance
Must be made
within categories
defined in HEA
Section 472
Cannot create a
new cost category
• Josh is a graduate student who moved from Southern California
to Northern Minnesota. He is asking for an increase in COA to
take into consideration U-haul rental, gas for U-haul, change of
climate clothing allowance, as well as the deposit he had to pay
for an apartment. He feels these cost fall under educational
expenses.
• Would you exercise PJ to allow for any or all of these
expenses?
Dependency
Override
Allowed
FAA may accept D/O from
another institution if it is for
the same academic year
Nature of relationship with
parents make it unsafe,
unreasonable, or
inappropriate to require
parental information and/or
support
Not Allowed
Parent’s refusal to contribute
or provide information, parent
not claiming student as
dependent, student
demonstrates self-sufficiency
May NOT change from
Independent to Dependent
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Documented physical or sexual abuse at home
Documented emotional or verbal abuse at home
Cultural differences related to higher education
Disowned due to sexual orientation
Disowned due to student’s lifestyle choices
• Justin is 22, lives on his own and pays $750 per month in rent,
pays for his own cell phone, utilities and is considered by his
peers to be self-sufficient. His parents do not claim him on their
tax return and have said they are unwilling to provide income
information, thus refusing to fill out the FAFSA. Would you grant
an override?
• Matthew is 22 and has lived with his grandparents since his
mother died 2 years ago. His mother had a one night stand, he
has never met his father and he has no idea where he is at.
Last year Matthew included his grandparents information on the
FAFSA and it wasn’t caught. What would you do?
• Crystal transfers to your fine institution from Avila University,
where last award year she was granted a dependency
override. She comes into your office, starts throwing things and
says she is independent. What should you do?
• Crystal doesn’t get a D/O at your school and decides to go
back to Avila, because they “care about students.” Now applies
and is admitted to your institution for the spring semester. What
happens?
•
Dependent student was living in a shelter for 6 months and now lives in an apartment
with her boyfriend. She was in the shelter at the time she applied for financial aid
and provided you with documentation from the shelter.
•
Parent student lived with is incarcerated. Student has recently reconnected with dad
and step-mom who are willing to help, but only have the means to offer the student
a cot in a room in the basement that is primarily used for storage. As such, student’s
permanent address is her campus address. On breaks, she either stays on campus or
goes home with a friend.
• Several years ago Mike’s family fell on hard times. Dad was injured
and could no longer work. Mom left and they have no idea where she
is. With no income, Mike and his dad became homeless. Fortunately,
families from their church have taken them in for periods of time over
the past 2 years, although there have been occasions when Mike has
lived with a family while his dad lived in his car or with another
family. You have a letter from their pastor verifying their situation.
• When Mike, now 18, submitted his FAFSA he answered YES to the
question, “On or after July 1, 2014 were you homeless or were you
self-supporting and at risk of being homeless?
• Mike did not have a homeless determination so answered NO to the
3 subsequent questions.
• Based on this information, would you approve the homeless status or
would you require Mike to add his father’s information to his FAFSA?
Refusal or Adjustment of
Loan Certification
May not discriminate based
on borrower’s race,
national origin, religion,
sex, marital status, age,
disability status, or income
Reason for determination &
actions taken must be
documented in student’s file
and provided to borrower
in writing
Possible reasons: High debt
burden, Unwillingness to
repay loan
• CortneyJo is a graduate student at your institution and has
accumulated $250,000 in debt. She is also a full time
employee at your institution and receives a 75% tuition
reduction. She has applied for a Graduate PLUS loan
maximum of $32,332 this year. What would you do?
• Does the situation warrant special consideration?
• Would you ask other questions about the family
situation? If so, what would you ask?
• What documentation would you request?
• What adjustments would you make?
• Lily is a 18-year-old student who lives with her parents. Her
parents do not trust the Federal government and vehemently
object to them requiring people to pay tax on their income. As
such, have not filed a tax return since Lily was a child.
• Unlike her parents, Lily has filed a tax return since she started
working as a waitress at the age of 16.
• Although they approve of her going to college, Lily’s parents
refuse to fill out any federal forms, including the FAFSA.
• What would you do?
Satisfactory
Academic
Progress
May exercise PJ to
waive SAP standards
due to undue hardships
Death of
relative
Personal
illness or
injury
Other special
circumstance
• If student is selected for verification, school must
complete verification before exercising PJ
• Regardless of whether or not student was selected
for verification, ALL PJ adjustments must be
reprocessed by CPS