Policy Type: Administrative
Administrative Policy Type: Enrollment Services
Approval Date: November 13, 2018
Responsible Executive: Vice President for Enrollment Services
Applies to: All Students who are Recipients of Title IV Aid
Professional Judgement Policy Statement
An Office of Financial Aid professional may exercise professional judgement and change elements in the federal need analysis to account for circumstances that he/she feels have not been adequately considered in the original Free Application for Federal Student Aid. Students can submit documentation for professional judgment based on a substantial change to financial income. This policy details the actions required to guide decisions and achieve rational outcomes.
The Office of Financial Aid officially interprets this policy. The Vice President for Enrollment Services is responsible for obtaining approval for any revisions as required. Questions regarding this policy should be directed to the Vice President for Enrollment Services.
Authority: The Higher Education Act provides that professional judgment may be exercised, as Section 479 (a) states:
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. Special circumstances may include tuition expenses at an elementary or secondary school, medical, dental, or nursing home expenses not covered by insurance, unusually high child care or dependent care costs, recent unemployment of a family member or an independent student, a student or family member who is a dislocated worker (as defined in section 3102 of title 29), the number of parents enrolled at least half-time in a degree, certificate, or other program leading to a recognized educational credential at an institution with a program participation agreement under section 1094 of this title, a change in housing status that results in an individual being homeless (as defined in section 11302 of title 42), or other changes in a family’s income, a family’s assets, or a student’s status. Special circumstances shall be conditions that differentiate an individual student from a class of students rather than conditions that exist across a class of students. Adequate documentation for such adjustments shall substantiate such special circumstances of individual students. In addition, nothing in this subchapter shall be interpreted as limiting the authority of the student financial aid administrator in such cases (1) to request and use supplementary information about the financial status or personal circumstances of eligible applicants in selecting recipients and determining the amount of awards under this subchapter, or (2) to offer a dependent student financial assistance under section 1078–8 of this title or a Federal Direct Unsubsidized Stafford Loan without requiring the parents of such student to file the financial aid form prescribed under section 1090 of this title if the student financial aid administrator verifies that the parent or parents of such student have ended financial support of such student and refuse to file such form. No student or parent shall be charged a fee for collecting, processing, or delivering such supplementary information.
Professional Judgment Procedure
The Financial Aid Administrator has the authority to exercise professional judgment, both before and after a student is awarded, if a student can document an extenuating circumstance warranting a change to data elements that may impact a student’s eligibility. Professional judgment may not be used to change the needs analysis formula (Cost of Attendance – Financial Resources = Need).
The following are examples of items that may qualify for a professional judgment:
- Adjustment to cost of attendance based on documented additional expenses
- Satisfactory academic progress appeals to reinstate aid on probation
- Unusual medical or dental expenses not covered by insurance or accounted for in the need analysis formula under the Income Protection Allowance
- Unemployment or change in employment status
- Change in marital status; in some instances, the result in the loss of income due to divorce or separation may warrant a professional judgment review
- Unique circumstances that warrant an undergraduate dependent student to be considered independent for the purposes of determining financial aid eligibility (e.g., abusive relationship with parent(s), estrangement, etc.)
- Loss of untaxed income and benefits
- Loss of assets in foreclosure, natural disaster, or bankruptcy
To request that aid be reviewed due to these or similar circumstances, the student must submit the appropriate Professional Judgment form to the Office of Financial Aid, explaining in detail the reason for the request. Appropriate documentation will be required to document the student’s extenuating circumstance. For example, if a student is claiming excessive medical expenses, he/she may be required to produce a statement from their insurance company outlining claims and payments. Students will be notified of what reasonable documentation they will need to produce after the written appeal has been reviewed.
The student must be enrolled for the term in which the request for professional judgment is made. Requests must be received by the Office of Financial Aid no later than two weeks prior to the last day of classes and before finals of the current semester. All decisions are made on a case-by-case basis after reviewing the student’s individual circumstances. The student should be aware that while the college attempts to make a final decision promptly, there may be instances where additional information is required which may delay the decision.
Professional judgement decisions are noted in PowerFaids and emailed to the student. Documentation for professional judgement decisions are placed in the student’s financial aid file.
Rationale for Making a Decision:
The rationale for exercising professional judgment or rejecting a request for special consideration will be recorded on the special circumstances form in an area for office use only.
The decision to make or not make adjustments rests with the Director of Financial Aid based on understanding of federal law and regulations and cannot be appealed.
Adjustments to Need Analysis or Independent Student Status:
The following are situations in which professional judgment might be exercised. Professional judgment is not limited to these situations:
- A parent, the student, or a student’s spouse who earned money in the previous year has lost his or her job and is not presently working or is working at a substantially lower rate of pay.
- A parent, the student, or a student’s spouse who received some source of untaxed income in the previous year is no longer receiving that income or is receiving a substantially reduced amount. Examples of untaxed income include but are not limited to: Social security benefits, child support, untaxed retirement or disability benefits, welfare benefits, ADC/AFCD.
- The student has already applied for federal student aid and since that time, the student’s parents or the student and spouse have separated or divorced.
- The student has already applied for federal student aid and since that time, the student’s parent(s) or the student’s spouse has died.
- The student’s parents or the student and spouse experienced an illness or accident that led to unusually high medical expenses.
- The student’s parents or the student and spouse incurred business losses not reflected on the federal tax return (bankruptcy, etc.)
- The student does not meet the definition of independence as determined by Congress, but given family circumstances, should be treated as an independent student for the purposes of applying for federal financial aid. These family circumstances include but are not limited to physical, emotional, or sexual abuse as documented by counselors, teachers, ministers, etc. who personally know the family circumstances.
Adjustments to Cost of Attendance
If it is determined that the budget category given to a particular student is not representative of his or her true costs of attending Wiley College, adjustments may be made to the budget to reflect actual costs.
Examples of adjustments that may be required include day care costs, transportation costs if the student travels a great distance to school, medical expenses if the expense seems great in relation to family income and is not adjusted for in family income. (Documentation will be required).
Adjustments to Satisfactory Academic Progress
If it is determined that a student did not complete the required percentage of courses, did not make the required grade point average, or has exceeded the limit on the number of terms allowed for a valid reason, a second probationary term or extended terms of eligibility may be granted.
Examples of valid reasons include medical illness of the student or student’s immediate family or death of a family member. (Documentation will be required).