Professional judgment (PJ) is the “super-power” financial aid administrators can use to help students (in almost any situation) receive the financial assistance needed to attend college. With great power comes great responsibility, so read on for a refresher and an update on all things PJ.
PJ can be applied in situations where the base-year income is not indicative of the family’s current ability to contribute, where the students or family’s (unavoidable) expenses are higher than the standard, when students who would otherwise be classified as dependent have extenuating circumstances in their family or home life, or any other scenario where it seems the calculated financial aid eligibility is inaccurate for the student’s situation. Most of the rules for adjusting eligibility using PJ have not changed:
- Each request must be considered independently. There cannot be a ‘policy’ in place for a particular group of students.
- Each request must be documented, whether an adjustment was made or not, and the documentation must be sufficient for someone else, like an auditor, to be able to follow how you reached the conclusion you did even if they don’t necessarily agree with it.
- Neither the Student Aid Index (SAI) nor Cost of Attendance (COA) can be changed, only recalculated. Also, PJ cannot be used to waive any Title IV eligibility requirements.
- Applicants selected for verification must complete the verification process before additional adjustments can be made.
- Any conflicting data that results from the documentation received, even if the impact is on eligibility in prior award years, needs to be resolved before the adjustments are completed and aid disbursed.
- Adjustments must be transmitted to the Partner Portal with the FAA Adjustment flag set and/or a Dependency Override code of 1, depending on the nature of the adjustment.
Some changes to PJ went into effect for the 2023-2024 award year (see DCL- GEN-22-15). For example, the adjustments are named differently based on whether it is a financial adjustment (Special Circumstances) or a dependency adjustment (Unusual Circumstances). Students can have both adjustments made in the same award year if warranted. FAAs have expanded authority to make PJ adjustments during a disaster, emergency, or economic downturn, like the authority granted during the COVID-19 national emergency. Colleges can no longer have a ‘No PJ’ policy and they must disclose publicly that such adjustments may be requested. And, finally, a determination of independence under an unusual circumstance adjustment, whether by your financial aid office or one at another institution during a prior award period, may be continued without additional documentation in subsequent years. However, if the student reports a change, or conflicting information surfaces that may indicate a change in the student’s situation, a new review must be completed. Finally, there is now a required timeframe for responding to dependency override requests — as soon as possible but no later than 60 days after the student enrolls.
There is one change for 2024-2025 that you may have already seen. Students who indicate they have Unusual Circumstances on the FAFSA will provisionally be treated as independent in calculating SAI and federal aid eligibility and the record will be rejected until the FAA has reviewed and confirmed a dependency override. If the student does not qualify for a dependency override and is unable to provide the necessary parental information in the FAFSA®, they are only eligible for unsubsidized Stafford at the undergraduate annual maximum.
Here are some recommendations to make the PJ process less burdensome:
- Staff members who speak to or counsel students (even if not responsible for awarding) should know how the SAI and COA are calculated so they can properly screen students seeking adjustments. This will save you and the student time when, based on the situation, an adjustment isn’t possible.
- Once screened, if the student’s situation warrants further review, tell them explicitly what documentation they need to submit for consideration; and put this information in their records so if they submit incomplete or inappropriate information, your frontline staff can reiterate what is needed and you’re not collecting documentation “piecemeal”.
- Notate exactly what your determination is and how you got there. This will ensure that if you must explain the adjustment later, you won’t have to take time to re-review the documentation or try to remember what you were thinking at the time.
Lastly, but no less important, these changes need to be incorporated into your policy and procedure manual.
Are you stressed out at the prospect of having to perform PJ adjustments or training your staff to support the process? Email us at info@heag.us to learn how our interim staffing and training programs can make your job easier.