What is a Professional Judgment?

When there are special or unusual circumstances that impact your federal student aid eligibility, federal regulations give a financial aid administrator discretion or professional judgment on a case-by-case basis and with adequate documentation to make certain adjustments in the Cost of Attendance (COA), also known as the student’s budget, and/or certain data elements on the Free Application for Federal Student Aid (FAFSA®) form that impacts the Student Aid Index (also known as EFC for 2023-2024). This measure gives us a more accurate assessment of your family's ability to contribute to your cost of education.


Types of Professional Judgments

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

  • Special Circumstances refer to the financial situations (loss of a job, etc.) that justify an aid administrator adjusting data elements in the Cost of Attendance (COA) or in the Student Aid Index (also known as EFC for 2023-2024) calculation.
  • Unusual Circumstances refer to the conditions that justify an aid administrator 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.

Special circumstances refer to the financial situations that justify an aid administrator adjusting data elements in the cost of attendance (COA) or in the Student Aid Index (also known as EFC for 2023-2024).

For Student Aid Index (also known as EFC for 2023-2024) adjustments, examples of this may be (but are not limited to):

  • Loss or change of employment
  • Child support change
  • Death of parent or spouse
  • Excessive medical expenses (must exceed 11% of adjusted gross income)
  • One-time taxable income (IRA distribution, pension distribution, etc.)

For Cost of Attendance (COA) adjustments, examples of this may be (but are not limited to):

  • Costs associated with a student’s disability
  • Childcare expenses for a dependent child of student
  • One-time purchase of a computer for educational use
  • Higher than already included costs of housing or transportation

Situations not considered Special Circumstances:

  • Vacation expenses
  • Tithing expenses
  • Standard living expenses (e.g., utilities, credit card expenses, children's allowances, etc.)
  • Mortgage payments
  • Car payments
  • Lawn care
  • Credit card or other personal debt problems
  • All other discretionary expenses

Unusual circumstances refer to the conditions that justify an aid administrator making an adjustment to a student’s dependency status based on a unique situation, more commonly referred to as a dependency override.

Unusual Circumstances include (some situations, but not all, that would warrant an adjustment for dependency status):

  • Refugee or asylee status
  • Human trafficking
  • Abandonment by parents
  • An abusive family environment that threatens the student’s health or safety
  • The student's inability to locate his/her parent

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.
  • A student demonstrates total self-sufficiency

Dependent Student Without Parental Support

Dependent students whose parents refuse to support them are not eligible for a dependency override, but they may be able to receive a dependent-level Direct Unsubsidized Loan only. For a student to be eligible for this provision the following must be documented:

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

If the parents refuse to sign and date a statement to this effect, documentation from a third party is needed (the student is not sufficient), such as a teacher, counselor, cleric or court.

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 their 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:
    • 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.

Homeless Youth Determinations

A student is considered homeless if they lack fixed, regular and adequate housing.

Determining Homeless Youth:

  • 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.
  • Youth who are migrants and who qualify as experiencing homelessness because they are living in the circumstances described above.

Unaccompanied Homeless Youth

  • A student is independent if, at any time on or after July 1, 2022, the student is determined to be an unaccompanied youth who is homeless or is self-supporting and at risk of being homeless. In determining independence due to homelessness, we shall consider documentation from the following entities — provided through a documented phone call, written statement, or verifiable electronic data match — to be adequate:
  • A local educational agency homeless liaison (or designee), as designated by the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11432(g)(1)(J)(ii)).
  • The director (or designee) of an emergency or transitional shelter, street outreach program, homeless youth drop-in center or other program serving individuals who are experiencing homelessness.
  • The director (or designee) of a Federal TRIO program or a Gaining Early Awareness and Readiness for Undergraduate program (GEAR UP) grant.
  • A financial aid administrator at another institution documented the student’s circumstance in the same or a prior award year; or
  • A written statement from, or a documented interview with, the student(s) confirming they are unaccompanied homeless youth.
  • An unaccompanied youth at risk of homelessness and self-supporting.
  • Any student who is not yet 24 may qualify for a homeless youth determination, and the financial aid staff will make determinations on a case-by-case basis.

The Professional Judgment Forms are available on our Forms page and are to be submitted with your supporting documentation through our Secure Upload Link. You must submit all required documentation in order for your Professional Judgment to be reviewed.

Note: You are required to complete the verification process prior to processing your professional judgment. Please see your To-Do List for required items.

Professional Judgments for both Special and/or Unusual Circumstances may take up to 4-6 weeks to review and process. To avoid processing delays, please carefully review the information that is required and ensure that adequate and supporting documentation is provided.

Please note: Upon review, you (the student and/or parent) will be contacted via email advising that their application has been received and reviewed. If additional documentation is required, the email will include a comprehensive list of required documentation needed to complete the professional judgment.

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