Professional Judgement (PJ) is one of the most powerful tools available to a financial aid administrator, but using it often induces anxiety. What will the auditors say? Will we get flagged for a program review? What if I’m doing it wrong? These are all valid concerns, so make sure you know the rules before you begin:
Rule #1: Every student must be considered individually – that’s not to say you can’t apply the same treatment to multiple students, but you can’t have a rule or procedure to automatically follow a certain course of action for a population or category of students.
Rule #2: You can’t change the elements used to determine eligibility; Expected Family Contribution (EFC) or Cost of Attendance (COA) – you can only adjust the data components used to calculate them.
Rule #3: You must have sufficient documentation on file so that a reasonable person, say your auditor, can follow your reasoning, even if he or she would not have reached the same conclusion.
Rule #4: You may use PJ (Dependency Override) to change a student’s dependency status from dependent to independent (but not the other way around) only in the most exceptional situations – read the Special Cases chapter in the Application and Verification Guide for the applicable award year to ensure you are familiar with these exceptional situations.
Now that you know the rules, create a process that works for both you and your students.
One thing that will be a real timesaver is to make your frontline staff experts in need analysis even if they don’t do any awarding. It is in everyone’s best interest to avoid encouraging a student to take the time to document a situation that will not create new or additional eligibility.
Also, families do not know the rules like we do and may come to you with a situation that seems reasonable to them but for which there is no special treatment. Further, the situation described by the student could very well be a symptom of a different family circumstance that can be considered. Here’s an example:
Student: I need more financial aid because my parents have a lot of credit card debt.
Financial Aid Administrator: Oh, I’m sorry to hear that. Let me ask you, do you know what caused this situation?
Student: Yes, my dad had surgery and his insurance didn’t cover much of the cost so he had to charge the rest.
While parent credit card debt cannot be used to create new or additional eligibility because it is not a factor in either of the need analysis components (EFC or COA), medical expenses not paid or reimbursed by insurance can be considered. Exploring just a bit more may yield results that help the student stay in school. If the student answered, “because they bought a yacht,” you would certainly take a different approach.
Next, don’t let the student decide what appropriate documentation is for his/her situation – give the student a list of options that includes a written explanation of the basis for the appeal with the student’s and potentially the parent’s signature. This will avoid starting/stopping/starting your review when you realize you don’t have enough information or the correct documentation.
Finally, to save your sanity at audit time, it’s a really good idea to add your own narrative to the file – whether it be on paper or digitally – to tell the story: the basis of the appeal, the documentation collected, the adjustment(s) made, the additional aid awarded, etc.
In summary, a good process for managing appeals/professional judgement requests includes:
- Providing need analysis training to all staff who counsel students even if they don’t award or review appeals;
- Training all staff who counsel students on the appropriate documentation for a variety of likely professional judgement situations;
- Document the situation, the decision made and any adjustments to the need analysis components or award so you don’t have to try to remember the specifics at audit time.
Additional resources to check out: