Transcript Document 7296067

Jerry McKeen
San Juan College
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Section 479A of the Higher Education Act
No specific regulations- the US DOE is
prohibited from making regulations
Some clarification in Handbook (Application
and Verification Guide)
Dear Colleague Letters
 Some
areas to consider for
professional judgment:
◦ Dependency Override
◦ Calculation of EFC
◦ Cost of Attendance
◦ SAP Appeals
◦ Unsubsidized loan eligibility
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PJ decisions should be for individual
students or case-by-case
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Uncommon or unusual circumstances
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Should be documented
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Cannot use PJ to waive general
eligibility requirements
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Reviewed on a case-by-case basis
May be considered for students who are
removed from the parents’ home,
experienced abuse, unable to locate a parent,
incarcerated parents, etc.
Can override an automatic independent
status with documentation (like through
verification) but cannot use PJ to make an
independent student dependent
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Situation must be documented
◦ What is the reason for the override and
documentation must be maintained
◦ Supporting documentation should be obtained
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Counselors and teachers
Clergy
Government agencies
Courts or prison administration
If third party documentation cannot be
obtained then may use signed statements
from friends, relatives, and student.
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Beginning 09-10, schools may accept an
override conducted by another school
Still must review annually, as in prior years
Some reasons are strictly prohibited as a
reason to allow independent status
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Parent refuse to contribute
Parents unwilling to provide information
Parents do not claim the student on taxes
Student has resources to be self-sufficient
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Example:
Tom is 21. He got into trouble in high
school and was convicted of passing bad
checks. Now he is on probation with strict
criteria including forbidden from any
contact with his mother who works for the
probation office. He comes to you because
he does not know how to get his FAFSA
information. His father is deceased but he
has a sister who lives close by.
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Lauren lives with her grandparents. After her
mother died when she was 12 her father was
so distraught that he left Lauren with his
parents. He gave them $500,000 of
insurance money to take care of Lauren and
left town. Lauren and her grandparents hear
from him periodically. Sometimes he sends
presents or cards but sometimes months or
even years go by with no contact. They don’t
have a current address or a means to contact
him.
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May change specific data elements within
the needs formula such as AGI, untaxed
income, household size, assets, etc.
May NOT change formula itself or adjust
the EFC without a calculations
Adjustment only valid at school that
made the determination
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Situations that may be considered:
◦ Loss of job / dislocated worker
◦ Death or divorce of parents
◦ Medical and dental expenses not covered by
insurance
◦ Educational costs of other family members
◦ Homelessness
◦ Reduced work hours / loss of income
◦ Parent in college
◦ Other situations
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Situations that are not ‘unusual’
◦ Standard living expenses- having 2 car
payments or a mortgage is not unusual
◦ Other consumer debt (credit cards)
◦ Routine expenses (utilities, home repairs)
◦ Moving expenses
◦ Vacation expenses
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Remember- as with dependency
overrides
◦ Must be ‘special circumstances’
◦ Case-by-case situations
◦ Adequate documentation
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Dear Colleague Letters GEN-09-04 & GEN09-05
A letter was also sent to those getting
unemployment benefits encouraging them to
apply for Pell Grant
Encouraged financial aid offices to consider
special circumstances during the rough
economic times
◦ Fewer grant and scholarship dollars
◦ Students maxing aid eligibility sooner
◦ More people losing jobs and income
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DOE and DOL strongly urges financial
aid offices to use these letters
proactively and as documentation for
special circumstances
Letter reminded FAO’s
 Ability to make changes
 Ability to use an alternate 12 month period
 Your students may be back to school for
special job training
 Compare the verification documents with
the original FAFSA information
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To adjust the EFC:
◦ Must adjust a data element (AGI)
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May not:
◦ Change the formula itself
◦ Make an adjustment to the PC, SC, EFC
◦ Make an adjustment on the initial FAFSA
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Remember:
◦ Conflicting information must be resolved
◦ Must verify base year first, esc. if selected
for verification
◦ Adjustment is valid only at school making
the change
◦ Must use the new EFC for all federal funds
◦ Income protection allowances change with
all the changes you make
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Rob is married and has two children.
He worked almost full time until June,
then lost his job and has not been able
to find another. He is the only family
member in college. His wife earns
$750 month babysitting for a
neighbor’s child.
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Sarah’s parents own a rental home
with a net worth of $150,000. The
rental home burns down. The family
loses potential rental income but has
the potential for an upcoming
insurance settlement.
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COST OF ATTENDANCE ITEMS
Tuition and Fees
Room and Board
Books and Supplies
Transportation
Miscellaneous personal expenses
Dependent Care Allowance
Computer Allowance
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COST OF ATTENDANCE ITEMS
Loan Fees
Study Abroad Expenses
Cost of Obtaining a first professional lic. or
credential
Cooperative education expenses
Disability related expenses for reasonable
accommodations
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Must document the reason for adjusting a
COA item
Must maintain the documentation
Examples include:
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Medical bills not paid by insurance
Child care bills
Pay stubs
Documentation of unemployment
Tax returns
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Can never get enough documentation
Can ask for additional documentation
to resolve questions or conflicting
information
Can add to the suggested list
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When might it be appropriate to adjust
a data element and recalculate the
EFC?
When is it appropriate to increase the
COA?
Is one better than the other?
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If student fails SAP standards students should
be given an opportunity to appeal
Student completes an appeal and submits
documentation to support the ‘unusual’ or
‘extenuating’ circumstances
◦ Injury or illness
◦ Death of a relative
◦ Other special circumstances
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Reviewed on a case-by-case basis
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Unsubsidized loans may now be offered to
students without parental information on the
FAFSA if the FAO verifies:
Parent no longer provides or will provide in
the future, financial support
Parent refuses to file a FAFSA
FAO MUST collect a signed statement
verifying the above circumstances
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Not making a professional judgment is
making one
Be consistent; but
Your decision may differ from another’s and
that is OK
Should be exercised with discretion
Doesn’t always mean yes or no
Be sure to retain all documentation, including
the ultimate decision
Notify students of all decisions
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Matt is a 21 year old student. His parents do
not believe the federal government had the
legal right to levy income tax, so they have
not paid taxes or filed a return for the last ten
years. He has worked since he was 18 and
files a tax return each year. His parents
refuse to provide any information to sign the
FAFSA.
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Evan is a 20 year old student. Evan had lived
with his mother and two younger siblings
until his mother recently remarried. His
mother and stepfather have a prenuptial
agreement than the stepfather will cover
household expenses but no extra costs for
Evan and his siblings like tuition, music
lessons, etc. Evan asks that his stepfather’s
income not be included because his mother
and stepfather have only been married for six
months and Evan has not lived with them.
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Dory has requested an income
reduction due to the fact that her
husband’s business is not making the
same money this year as last year. He
makes and installs cabinets and has
had to drop his hourly rate from $26
to $14 to get business.