Prior Prior Year, Early FAFSA & PJs Debbie Turner, Director of Financial Aid, Concord University Candi Frazier, Senior Associate Director, West Virginia University

How We Looked Last Fall…..

Different School Perspectives on Prior Prior Year and Early FAFSA & Professional Judgments - West Virginia University Early FAFSA Increase in volume and type of communications sent to students and campus representatives ---– sent early and often (emails, campus listservs announcements, newspaper articles, social media, on campus outreach, scholarships for early filers) Changing timelines across campus (financial aid, housing, orientation, admissions, etc) Greater outreach efforts with on the location FAFSA filing System and process changes

Change from Quality Assurance school to federal verification Different School Perspectives on Prior Prior Year and Early FAFSA & Professional Judgments - PPY Preparing for C-Flag 399 Change from Quality Assurance school to federal verification System and process changes

Different School Perspectives on Prior Prior Year and Early FAFSA & Professional Judgments - Analyzed current PJs to see if student will most likely need to file again since income is not changing Significant form changes

Different School Perspectives on Prior Prior Year and Early FAFSA & Professional Judgments - Concord University Early FAFSA Sent email to prospective students to file FAFSA Article in Student and Parent Newsletters Will be mailing postcard to file FAFSA, email blast to returning students, posters around campus Hosting File your FAFSA on Sunday in November

PPY and PJs revisited…… Concord University PPY Preparing for C Flag 399 PJ’s Discussed increasing number of staff to do PJ’s

PJ Definition The Higher Education Act of 1965, as amended (HEA) provides authority for the financial aid administrator (FAA) to exercise discretion for individual treatment of a student who has special circumstances that are not sufficiently addressed by the standardized federal student aid formulas and delivery methods.

Principles of PJ Must be exercised on a case-by-case basis except for affected individuals under the HEROES Act FAA authority extends to requesting and using supplemental information he/she deems necessary for making a PJ decision Can not automatically accept PJ adjustments made for the same student by a FAA at another college Decisions cannot be appealed to ED

Consider the following when making a PJ decision: Is the student or the student’s family actually experiencing unique circumstances that are not dealt with adequately in the need analysis formula, or by other Title IV provisions for which the use of PJ is permitted? Does the unusual situation warrant special treatment because it affects the student’s or family’s ability to contribute toward the cost of the student’s education, or otherwise affects the student’s ability to complete his/her program of study?

Consider the following when making a PJ decision: What should the special treatment be? What documentation is needed to support this determination?

Areas of PJ Dependency status Need analysis Calculation of EFC Calculation of COA Denial or reduction of Direct Loan or Direct PLUS eligibility Direct Unsubsidized Loan eligibility for a dependent student without parental FAFSA data Satisfactory Academic Progress (SAP)

Dependency Override The following do not merit a dependency override, if: Parents refuse to contribute to the student’s educational costs; Parents are unwilling to provide information on the FAFSA or for verification purposes; Parents do not claim the student as a dependent for income tax purposes; and Student demonstrates total self-sufficiency.

Dependency Override Acceptable circumstances: Abandonment Abuse Cannot locate parent

Need Analysis Examples of special circumstances may include: Elementary or secondary school expenses Medical and dental expenses not covered by insurance Unusually high dependent care costs Changes in income (unemployment, change in job, illness, retirement; death of parent) Change in student or parent’s maritial status

Projected Income FAA may make adjustment that use estimated or projected income information for the Calendar year Award year Or another 12-month period that realistically reflects the student’s and/or family’s current economic situation. Adjustments must be reported to CPS

PJ Documentation Student documentation of situation Third-party documentation Copies of documents (last pay stub, death certificate, etc.) Institutional documentation of decision Policies to ensure consistency NASFAA Guide to Addressing Special Circumstances using PJ

Areas PJ Does Not Apply Change an independent student to dependent Create a new category of costs in the COA Adjust the “bottom-line” EFC (must change data elements) Change the FM formula or values in the tables Make across-the-board changes Make an ineligible student eligible for Title IV aid Circumvent the intent of the law or regulations.

Questions

Only one thing is missing……