By Rick Cox
This blog is a reminder of the changes, effective beginning with the 2023-2024 award year, that were implemented to Professional Judgment as part of the FAFSA Simplification Act. These changes were outlined in Dear Colleague Letter GEN-22-15.
They included new terminology for PJs:
- Special Circumstances – refers to financial situations, such as loss of a job, that justify adjusting elements in the Cost of Attendance or Student Aid Index calculations.
- Unusual Circumstances – refers to what has previously been known as a Dependency Override.
It is possible for a student to have both circumstances.
Institutional requirements related to Professional Judgments:
- Institutions cannot have a policy denying all PJ requests.
- Institutions must consider all PJ requests submitted.
- Institutions must disclose that students can request a PJ for Special Circumstances or Unusual Circumstances, or both.
- Institutions must inform the students of the process for reviewing PJ requests and the timelines by which a determination will be made.
- Institutions must provide the student with a final determination of their dependency status and awards as soon as practicable after reviewing all documentation.
- Institutions must review all requests for a determination of independent status, which includes homeless youth (unaccompanied or at-risk), foster care youth, orphans, wards of the court and students with unusual circumstances, as soon as possible but not later than 60 days after enrollment.
- Institutions may use an Unusual Circumstance determination (Dependency Override) made by a financial aid administrator at another institution in the same or prior award year.
It is important that institutions are making students aware of this process and how the student can request a PJ. Also, please remember that you must update your policies and procedures to reflect these changes.
Rick Cox is Global’s Executive Director of Regulatory Affairs and Compliance