1. Professional Judgement
ILASFAA Fall Workshops: Saving the Day with Financial Aid
November 2017

2. Roundtable Session Goal
To discuss Professional Judgement (PJ) options available to FAAs that have an impact on a student’s Title IV eligibility and share policy and procedure information.
Provide ideas and share resources that an FAA may use to design/improve their PJ process.

3. Must a School Use the Professional Judgement Option?
No, Exercising PJ is a choice but the school should have an established and published policy as to whether they do or do not.
Those that do exercise it should have policy and procedure as to how it will be performed and what will be considered proper “documentation”

4. Who is Responsible for PJ Decisions?
School officials, the FAA, are the professionals empowered to exercise PJ on their campus.
Some schools have one FAA assigned who performs the task others may allow all FAAs to process a PJ request
KEY: PJ decisions should be made on a case-by-case basis and based on special circumstances which must be documented in the student's file.

5. What Should the “Professional” Know to be Competent to Perform PJ?
Firm understanding of the laws and regulations that govern Title IV programs
Firm understanding of how an EFC is generated and what allowances are “built in” the formula
Sound judgment to determine what is a “reasonable” circumstance
Firm understanding of schools policy and procedure in performing PJ

6. What’s the Law on PJ?
Section 479A of the Higher Education Act of 1965 (HEA), as amended, provides the authority for financial aid administrators to exercise discretion in a number of areas when a student has special or unusual circumstances.

7. Under PJ, the FFA can:
adjust any of the data elements used to calculate the expected family contribution (EFC)
override a dependency status from Dependent to Independent
grant SAP Appeals
reduce or deny to certify/originate a student loan
approve Unsub loans for dependent student whose parents refuse to complete a FAFSA
Adjust their Cost of Attendance components (up or down)
The FAA cannot use PJ to adjust the need analysis formula or table values (e.g., income protection allowance values, tax rates, etc.) or to make bottom-line adjustments to the EFC itself.

8. What's the Difference Between a Correction, an Update, and a PJ Adjustment?
Corrections: Corrections are changes to data elements that were incorrect at the time the FAFSA was filed. Corrections can be made by student or the school. Typically during verification errors can be found and corrected by the school via CPS.
Updates: Updates are changes to data elements that were correct at the time of application, but changed since the FAFSA was filed. Updates are allowable only under very specific circumstances related to dependency status, number in household (household size), number in college, and marital status. Professional Judgment (PJ) Adjustments: Changes made to FAFSA data elements by an FAA exercising the PJ authority are called adjustments. Decisions are made on a case-by-case basis and must be thoroughly documented in the student's file.

9. The PJ Policy Should Address
Responding to special circumstance request outside the “standard” assessments
Judging the validity of the request
Establish the scope of adjustments
Documenting the action as to what, why, what proof, what determination was made and why
Maintain consistent opportunities and practices
Be mindful that situations are case-by-case, non discriminative and looking at current situation that can be documented

10. BEST PRACTICE Ask yourself this:
Am I utilizing an Institutional form to “begin” the review?
Has it been made clear to me what has been requested?
What data has been provided to support this request?
Is the request one that would circumvent the regulations or laws for Title IV programs?
Is the circumstances provided in the statement reasonable to be considered for a PJ?
Am I evaluating the PJ case-by-case not by a “class” of others in similar/same circumstances?

11. Department of Education Resources
IFAP has an Activity that schools should use to assess their PJ policy and procedure. On the Web it is located at: ifap.ed.gov/qadocs/FSAVeriModule/activity2verif.doc (see handout)
Information regarding professional judgment (PJ) can be found in in the FSA Handbook Chapter 5 of the Application and Verification Guide. In addition cited in HEA Sec. 479A (a) and the CFR (c). 

12. NASFAA Resource ASKRegs (screen shot of the page)
Professional Judgment
Knowledgebase > Category (browse) > Professional Judgment
Can a School Limit the Amount a Student Can Borrow?
Can We Use 2016 or 2017 Income As Projected-Year Income for Using Professional Judgment?
Can We Count a Live-In Boyfriend and His Child in the Dependent's Student's Mother's Household?
Can an Independent Student Update the Number in College?
Can a School Include Any Kind of Medical Expenses Using Professional Judgment (PJ)?
Can a Dependent Student Be Included in a Parent's and an Independent Sibling's Household Size During the Same Award Year?
Can We Update an Independent Student's Marital Status After the FAFSA Was Filed?
Can a Dependent Student Borrow an Unsubsidized Loan If Her Parents Refuse to Provide Information on the FAFSA?
Is a Spouse Included On the FAFSA If She Is Living and Maintaining a Separate Household In Another State?
Are We Required to Complete Federal Verification Before Using PJ to Perform a Dependency Override?
Can We Process a PJ Request After a Student is No Longer Enrolled For the Award Year?
Can a Student Appeal Dependency Status Based on Marriage?
Is Verification Required Before Updating the Student's Marital Status In Special Circumstances?
Can Satisfactory Academic Progress Be Denied Based on Excessive Student Loan Debt?

13. NASFAA Sample Q&A on PJ:Is a Divorced Student Under the Age of 24 a Dependent Student Again?
Yes. A student can be independent one year and dependent the next if he or she gets divorced before the FAFSA is filed and is still under age 24. In such a scenario, the student is dependent and must provide parental information on the FAFSA. If the student is separated but not divorced, the student is still an independent student. You should note that a student always must update his or her dependency status during an award year except when the change in dependency status is due to a change in the student’s marital status. However, the school may require the student to update his or her dependency status when the dependency status change is due to a change in the student’s marital status if the school determines the updated dependency status is necessary to address an inequity or to reflect more accurately the student’s ability to pay educational expenses.

14. Wrap UP- Ask yourself how do you….
“Initiate” a PJ? Who is the staff doing PJ?
Determine what is an “unusual” circumstance?
Determine what is appropriate documentation ?
Proceed if PJ results is approved?
Notify the student of approval results?
Notify the student if PJ results is a denial?
Review your policies and procedures? How often?
(see DACC Handout from our PM)

15. Danville Area Community College Danville, IL jingarg@dacc.edu
Thank you.
Janet Ingargiola, Director Student Financial Aid & Veteran’s Educational Benefits
Danville Area Community College Danville, IL
You can see our PJ form online at: