Transcript Professional Judgment

Professional Judgment
Julie Rice Mallette – North Carolina State
University
Rose Mary Stelma – East Carolina University
November 2006
What is Professional Judgment?
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Professional judgment is the authority
provided under the Higher Education Act for
financial aid administrators to exercise
discretion in specific areas of student aid
administration
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Professional judgment is not regulated by the
Department of Education
What Authorizes Professional
Judgment?
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Section 479A of the Higher Education Act states: “In
General,—Nothing in this part shall be interpreted as
limiting the authority of the financial aid administrator, on
the basis of adequate documentation, to make adjustments
on a case-by-case basis to the cost of attendance or the
values of the data items required to calculate the expected
student or parent contribution (or both) to allow for
treatment of an individual eligible applicant with special
circumstances. However, this authority shall not be
construed to permit aid administrators to deviate from the
contributions expected in the absence of special
circumstances.”
Professional Judgment . . .
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Authorizes case-by-case adjustments to:
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Cost of attendance
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Values of Federal Methodology data items
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Authorizes FAA to deny or reduce eligibility for
FFEL or Direct Loan
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Other statutory provisions allow for PJ regarding:
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Dependency status
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Satisfactory academic progress
Professional Judgment . . .
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Provides FAA with flexibility to deal with
unique circumstances affecting individual
students
Allows for personal intervention by FAA in
cases that merit individual attention
Enables FAA to respond appropriately to
student’s individual circumstances which can
never be fully anticipated in legislation or
regulation
How do you identify potential PJ
students?
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FAFSA tells student to report unusual
circumstances
Student might come into the office and speak
with an administrator
Special request form on your website
Other ways?
Questions to ask
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Questions to ask:
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Is student or student’s family experiencing unique
circumstances?
Does student’s unusual situation warrant special
treatment because it affects the student’s or family’s
ability to contribute to the cost of attendance?
What should special treatment be?
What documentation is needed to support these
determinations?
Areas you can make professional
judgments about:
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Statute governing the Title IV programs allows
aid administrators to exercise discretion in
specific areas:
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Dependency status
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Need analysis: calculation of Expected Family
Contribution (EFC) and cost of attendance (COA)
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Satisfactory academic progress
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Denial or reduction of eligibility for FFEL or
Direct Loan Program loans
When you CANNOT make a
professional judgment
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Professional judgment may not be used to:
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Change a student’s status from independent to
dependent
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Devise a new category of costs
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Adjust the bottom-line EFC
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Change the EFC formula itself
When you CANNOT make a
professional judgment
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Professional judgment may not be used to
(cont’d):
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Make an otherwise ineligible student eligible for
Title IV aid
Circumvent the intent of the law or regulations
Include post-enrollment expenses in COA
Circumvent FSEOG selection criteria
Possible Special Circumstances
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Loss of employment of family member
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Unusual family medical or dental expenses not
covered by insurance
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(Tuition expenses at elementary or secondary school
for student’s siblings or dependents
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Extraordinary dependent care expenses
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Divorce of parent or independent student
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Death of parent or independent student’s spouse
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Financial losses related to a natural disaster
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Other circumstances you consider?
NC State Procedures
PJs for EFC Changes
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Student submits request for reconsideration form and
verification documentation (if not already verified)
Assistant Director performs verification, and then uses
projected year data to recalculate EFC (if warranted)
Assistant Director documents PJ decision in writing in file and
via comment in financial aid system and gives file/paperwork
to Director to approve
Director reviews PJ decision and if approved, initials and dates
PJ decision, and enters date approved in financial aid system
Director gives paperwork back to Assistant Director for
decision to be communicated to student/parent and
award/revised award to be made.
NC State Procedures
Changes to COA
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Student requests change to cost of attendance verbally
or in writing to assistant director.
Student submits written documentation (child care letter
from provider, receipts for additional books, Computer and/or
PDA Purchase Request Form, etc.)
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Assistant director or counselor updates cost of
attendance following office policy.
Assistant director adjusts aid as needed.
Director reviews sample of these types of
professional judgments.
ECU Procedures –Changes to data
elements
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Student submits Request for Reconsideration form.
Senior Assistant Director reviews request and all
documentation.
Senior Assistant Director submits changes to
student’s ISIR.
New transaction comes to ECU
Associate Director “OK’s” the PJ and the resulting
changes
Assistant Director or Counselor adjusts aid offer
based on new EFC.
ECU Procedures – Changes to Cost
of Attendance
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Student requests change to cost of attendance by
speaking with an assistant director or counselor.
Student submits written documentation (child care letter
from provider, receipts for additional books, information about
purchasing a computer, etc.)
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Assistant director or counselor updates cost of
attendance
Assistant director adjusts aid as needed.
Senior Assistant Director for Quality Assurance
reviews sample of these types of professional
judgments.
Document Your PJ Decisions
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It is critical that you document why you made
a professional judgment – what was the basis
of your decision.
An auditor cannot question your decision, but
can question your documentation - is it
thorough and credible?
Both ECU and NCSU Document
Decisions By:
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Copy of request forms
Copy of supporting income documents
Copy of letters from student and others
Screen print of original ISIR data and changes
we made as a result of the PJ
Explanation for changes and calculations
FAA signature and date