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

2. How We Looked Last Fall…..

3. 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 ( s, 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

4. 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

5. 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

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

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

8. 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.

9. 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

10. 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?

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

12. 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)

13. 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.

14. Dependency Override Acceptable circumstances: Abandonment Abuse
Cannot locate parent

15. 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

16. 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

17. 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

18. 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.

19. Questions

20. Only one thing is missing……