Professional Judgement for Special Cases

The FAFSA Simplification Act (the Act) distinguishes between different categories of professional judgment by amending section 479A of the HEA.

  • Special Circumstances refer to the financial situations (loss of a job, etc.) that justify an adjustment to data elements in the COA or in the EFC or SAI calculation.

  • Unusual Circumstances refer to the conditions that justify making an adjustment to a student’s dependency status based on a unique situation (e.g., human trafficking, refugee or asylee status, parental abuse or abandonment, incarceration), more commonly referred to as a dependency override.

A student may have both a special circumstance and an unusual circumstance. Financial aid administrators (FAAs) may make adjustments that are appropriate to each student’s situation with appropriate documentation. 

Dependency Changes / Unusual Circumstances

The FAFSA Simplification Act provides clarification for Financial Aid Administrators (FAAs) to assist applicants with unusual circumstances to change dependency status on the FAFSA form to reflect students’ situations more accurately (dependency overrides). 

An FAA may conduct dependency overrides on a case-by-case basis for students with unusual circumstances.

1. Homeless Youth Determinations

A student is considered homeless if they lack fixed, regular, and adequate housing. This is broader than just living “on the street.” It includes but is not limited to:

  • youth sharing housing with other people temporarily because they had nowhere else to go;
  • youth living in emergency or transitional shelters, for example, trailers provided by the Federal Emergency Management Agency after disasters;
  • youth living in motels, campgrounds, cars, parks, abandoned buildings, bus or train stations, substandard housing, or any public or private place not designed for humans to live in;
  • youth living in the school dormitory if they would otherwise be homeless; and
  • youth who are migrants and who qualify as experiencing homelessness because they are living in circumstances described above.

**The documentation for evaluation of your living arrangements must demonstrate that you meet the definition of an independent student. The determination may be based upon a written statement from, or a documented interview with, you that confirms that you are an unaccompanied homeless youth, or unaccompanied, at risk of homelessness, and self-supporting.

Homeless Youth Definitions

  • At risk of being homeless—when a student’s housing may cease to be fixed, regular, and adequate, for example, a student who is being evicted and has been unable to find fixed, regular, and adequate housing.
  • Homeless—lacking fixed, regular, and adequate housing.
  • Self-supporting—when a student pays for his or her own living expenses, including fixed, regular, and adequate housing.
  • Unaccompanied—when a student is not living in the physical custody of a parent or guardian.

Housing Status Definitions

  • Fixed—stationary, permanent, and not subject to change.
  • Regular—used on a predictable, routine, or consistent basis.
  • Adequate—sufficient for meeting both the physical and psychological needs typically met in the home.

2. Dependent Students without Parent Support
 

If you are a dependent student whose parents refuse to provide support, you are not eligible for a dependency override, but may be able to receive a dependent level Direct Unsubsidized Loan only. For a student to be eligible for this provision we must document the following:

  • The student’s parents refuse to complete the FAFSA; or
  • The student’s parents do not and will not provide any financial support to the student (include the date support ended).

If your parents refuse to sign and date a statement to this effect, you must get documentation from a third party, such as a teacher, counselor, cleric, or court.

3. Dependency override
 

Under HEA Sec. 480(d)(9), the FAFSA Simplification Act incorporated additional unusual circumstances to consider when you are unable to contact a parent or where contact with parents poses a risk to you.

Unusual circumstances do include (but are not limited to):

  • Human trafficking;
  • Legally granted refugee or asylum status;
  • Parental abandonment or estrangement; or
  • Student or parental incarceration.

In such cases an override might be warranted based upon your individual circumstances. These conditions would also not disqualify you from being a homeless unaccompanied youth or self-supporting and at risk of homelessness.

However, none of the conditions listed below, singly or in combination, qualify as unusual circumstances meriting a dependency override.

Unusual circumstances do not include:

  • Parents refuse to contribute to the student’s education.
  • Parents will not provide information for the FAFSA or verification.
  • Parents do not claim the student as a dependent for income tax purposes.
  • Student demonstrates total self-sufficiency

UC Forms

If you cannot provide documentation or are unsure as to which document is applicable to you, please contact our office at faidinfo@bigbend.edu or 509.793.2088

  • Homeless Youth Determination (PDF) (DOC)
  • Parent Refusal of Support (PDF) (DOC)
  • Dependency Override  (PDF) (DOC)
    *For students who have not applied for a dependency override in previous years
  • Continue Dependency Override (PDF) (DOC)
    *For students who have applied and received approval in previous year(s)

Financial Changes / Special Circumstances

 

An aid administrator may use PJ on a case-by-case basis to adjust the student’s cost of attendance or the data used to calculate his or her EFC/SAI. This adjustment is valid only at the school making the change.

The law gives some examples of special circumstances that MAY be considered:

  • Change in employment status, income, or assets

  • Change in housing status (e.g., homelessness)

  • Tuition expenses at an elementary or secondary school

  • Medical, dental, or nursing home expenses not covered by insurance

  • Child or dependent care expenses

  • Severe disability of the student or other member of the student’s household

  • Other changes or adjustments that impact the student’s costs or ability to pay for college.

This is not an exhaustive list. 

SC Forms

2023 – 2024 Academic Year (Summer 2023 – Spring 2024)

2024 – 2025 Academic Year (Summer 2024 – Spring 2025)

**Come back in January 2025 for use of 2024 income (your taxes must be done prior to completion and submission).

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