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Professional Judgment is used by a Financial Aid Administrator (FAA) to make changes to Student Aid Report (SAR)/ Institutional Student Information Record (ISIR) because circumstances have changed since the student applied for financial aid. In situations where special circumstances exist, Professional Judgment can be used only on a case-by-case basis and cannot be applied to an entire group of students. All discrepancies or conflicting information on an output document (SAR/ISIR) must be resolved before professional judgment changes are made.
There is limited authority to make changes to the student's income information due to special circumstances. An FAA is not allowed to modify the formula or the tables used in the EFC calculation, but can change the cost of attendance or the values of specific data elements used in the EFC calculation. All changes must relate to the student’s special circumstances and the resulting EFC must be used consistently for all FSA funds awarded to the student.
In cases where Professional Judgment is used to make adjustments to the student's cost of attendance or EFC, documentation to justify all changes made must be collected. Some examples of special circumstances that can be used for considering professional judgment include, but are not limited to:
- divorce or separation;
- death or disability of wage earner;
- loss of income (income or benefits);
- medical or dental expenses paid or committed during the current year that are not covered by insurance;
- unusually high child care costs;
- nursing home expenses not covered by insurance;
- unusually high dependent care expenses;
- a student who is dislocated worker;
- parents’ refusal to complete a FAFSA*;
- other unusual circumstances.
* An unsubsizided Stafford Loan can be offered to a dependent student, without requiring the parents to file a FAFSA, based on documentation that the parents have ended financial support (including cash and non-cash support) and refuse to file a FAFSA. This is not considered a dependency override, and a student would be eligible to receive only an unsubsidized loan. A parent’s documented refusal to file a FAFSA cannot be used as a reason to make professional judgment adjustments to award any other Title IV assistance to a dependent student.
A provision effective beginning with the 2009-10 academic year allowing a college to use the documentation gathered by another school within the same academic year to apply a dependency status override, does not apply to other professional judgment adjustments. If a student applies to two schools and requests consideration for a professional judgment, the documents requested might be different and the outcome may be different based on the school. If the student attends one school early in the year and that school exercises professional judgment and then the student transfers to another school during the same award year, the second school has several options:
- the FAA can have the student request that the first school send copies of documents used to make a professional judgment decision;
- the FAA can opt to exercise their own professional judgment and request the documentation he/she believes is pertinent to the situation; or
- the FAA may decide not to exercise professional judgment at all.
Additional information about Professional Judgment and making corrections can be found in the Corrections, Updates and Adjustments chapter of the Application and Verification Guide in the FSA Handbook.
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