Professional Judgment

1
Professional Judgment

• Julie Rice Mallette North Carolina State
  University
• Rose Mary Stelma East Carolina University
• November 2006

2
What is Professional Judgment?

• 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
• Professional judgment is not regulated by the
  Department of Education

3
What Authorizes Professional Judgment?

• 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.

4
Professional Judgment . . .

• Authorizes case-by-case adjustments to
• Cost of attendance
• Values of Federal Methodology data items
• Authorizes FAA to deny or reduce eligibility for
  FFEL or Direct Loan
• Other statutory provisions allow for PJ
  regarding
• Dependency status
• Satisfactory academic progress

5
Professional Judgment . . .

• 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 students
  individual circumstances which can never be fully
  anticipated in legislation or regulation

6
How do you identify potential PJ students?

• 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?

7
Questions to ask

• Questions to ask
• Is student or students family experiencing
  unique circumstances?
• Does students unusual situation warrant special
  treatment because it affects the students or
  familys ability to contribute to the cost of
  attendance?
• What should special treatment be?
• What documentation is needed to support these
  determinations?

8
Areas you can make professional judgments about

• Statute governing the Title IV programs allows
  aid administrators to exercise discretion in
  specific areas
• Dependency status
• Need analysis calculation of Expected Family
  Contribution (EFC) and cost of attendance (COA)
• Satisfactory academic progress
• Denial or reduction of eligibility for FFEL or
  Direct Loan Program loans

9
When you CANNOT make a professional judgment

• Professional judgment may not be used to
• Change a students status from independent to
  dependent
• Devise a new category of costs
• Adjust the bottom-line EFC
• Change the EFC formula itself

10
When you CANNOT make a professional judgment

• Professional judgment may not be used to
  (contd)
• 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

11
Possible Special Circumstances

• Loss of employment of family member
• Unusual family medical or dental expenses not
  covered by insurance
• (Tuition expenses at elementary or secondary
  school for students siblings or dependents
• Extraordinary dependent care expenses
• Divorce of parent or independent student
• Death of parent or independent students spouse
• Financial losses related to a natural disaster
• Other circumstances you consider?

12
NC State ProceduresPJs for EFC Changes

• 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.

13
NC State ProceduresChanges to COA

• 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.)
• 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.

14
ECU Procedures Changes to data elements

• Student submits Request for Reconsideration form.
• Senior Assistant Director reviews request and all
  documentation.
• Senior Assistant Director submits changes to
  students ISIR.
• New transaction comes to ECU
• Associate Director OKs the PJ and the
  resulting changes
• Assistant Director or Counselor adjusts aid offer
  based on new EFC.

15
ECU Procedures Changes to Cost of Attendance

• 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.)
• 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.

16
Document Your PJ Decisions

• 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?

17
Both ECU and NCSU Document Decisions By

• 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