The Free Application for Federal Student Aid (FAFSA) does not provide families with a place to explain special circumstances affecting their ability to pay for the student’s education. The Federal Need Analysis Methodology (FM) is a rigid formula with no provisions for exceptions. To remedy this, Congress, through The Higher Education Act (HEA) of 1992, delegated to school’s financial aid administrators to make professional judgment decisions when there are special or unusual family or student circumstances that may call for adjustments in determining a student’s eligibility for financial aid. Circumstances requiring professional judgment will be analyzed on a case-by-case basis and will be documented.
Professional judgment refers to the authority of a school’s financial aid administrator to make adjustments to the data elements on the FAFSA.
The Director for Financial Aid may exercise professional judgment and change elements in the federal need analysis to account for circumstances that he/she feels have not been adequately considered in the original FAFSA. The Director for Financial Aid has the final authority in making professional judgment decisions. There is no appeal. By law, neither the school’s president nor the U.S. Department of Education can override the financial aid administrator’s decision. (Higher Education Act of 1965, Sections 479A and 480(d) (7).
Circumstances that may warrant a professional judgment decision include, but are not limited to the following:
- Parent’s death or divorce for dependent students; death of or divorce from spouse of independent students.
- Significant loss of income/loss of employment
- Loss of untaxed income/benefits (e.g. disability, child support, or other benefits)
- Excessive medical expenses (not covered by insurance)
- One-time taxable income used for life changing event (e.g. IRA, pension distribution)
- Other special circumstances not listed
Circumstances that are NOT considered extenuating include, but are not limited to:
- Standard living expenses (e.g. utilities, credit card payments, children’s allowances, etc.)
- Mortgage payments
- Car payments
- Credit card or other personal debts
- Vacation expenses
- All other discretionary expenses
Budget adjustment for computer purchase:
The U.S. Department of Education permits institutions to include in a student’s Cost of Attendance (COA) the purchase of a computer for educational use. The Financial Aid Office will include this expense by increasing the student’s Cost of Attendance, upon request, and according to the following policy:
- The maximum allowance for purchase of a computer is $3,000, which may include the cost of a printer and maintenance contract.
- A student may receive this allowance only once as an undergraduate and once as a graduate student.
- Additional purchases of software, printer supplies, online service fees etc. will be assumed under the allowances already included in the COA for books and supplies.
- In order to have the cost of the purchase of a computer added to COA, the student must provide a dated, itemized estimate of the cost of the proposed purchase.
- A petition for this change should be submitted no later than April 1 of the academic year during which it is requested.
Students are reminded that the overall cost of a computer, which depreciates quickly, is almost prohibitive, if they intend to purchase it using student loan funds and pay for it over the course of 10 years.
Students that believe his/her circumstances may qualify for a professional judgment will need to complete the following steps. All special circumstances are evaluated on a case-by-case basis and must be documented.
- Students must complete the Free Application for Federal Student Aid (FAFSA) prior to submitting the Special Circumstance Request form. A valid FAFSA must be filed according to the instructions provided by the Department of Education. Special circumstances will be considered only after the school has received a valid Student Aid Record (SAR). If the student has been selected for verification, the school must complete the verification process before considering any special circumstances.
- Students need to download and complete all sections of the Special Circumstance Request form.
- Students must provide documentation that supports the request for a professional judgement due to special circumstances as listed on the Special Circumstance Request form. Students should make every effort to obtain all the listed documentation, missing documentation may cause the request to be rejected. Additionally, the need may arise for students to submit documentation not listed on the request form.
- Students need to submit the Special Circumstance Request form and all supporting documentation to the Financial Aid Office.
- Once a complete documentation package has been received by the University, the Director of Financial Aid will review all documentation and make a determination. The decision is final and not subject to appeal. Students will be notified in writing of the decision and will include the date of the decision and the signature of the Director of Financial Aid.
Professional judgment adjustments may increase or decrease a student’s Estimated Family Contribution (EFC). Specified adjustments may be made to data elements, but not to the formula. Any adjustments made to the FAFSA, as a result of a request for a professional judgment decision, may delay or change the financial aid package.
Federal financial aid regulations assume that a student’s family has primary responsibility for meeting educational costs. If a student is considered a dependent student according to the federal financial aid definition, then aid eligibility is determined using parent(s) income and asset information in addition to the student’s information.
Student dependency status is determined by the U.S. Department of Education, based on responses to specific questions on the FAFSA. For financial aid purposes, federal regulations have defined an independent student as one who meets AT LEAST ONE of the following conditions:
- Born before January 1, 1998
- Married as of the date FAFSA signed
- Attending graduate level program of study during the 2021-2022 academic year
- Currently serving on active duty in U.S. Armed Forces or a National Guard or Reserves (other than for training)
- Veteran of U.S. Armed Forces (or will be a veteran as of June 30, 2022), or have attended a service academy and were released under a condition other than dishonorable
- Have children who receive more than half their support from the student, OR have legal dependents, other than a spouse or children, who live with student and receive more than half their support from the student
- Orphan, ward of the court, foster care (after age 13)
- Emancipated Minor or in Legal Guardianship as determined by the court in her/his state of legal residence
- A self-supporting unaccompanied youth who is homeless or at risk of homelessness (as certified by governmental or school agency)
A student who does not meet ANY of the above conditions is classified as a dependent student.
Additionally, an individual who does not qualify as an independent student under one of the above nine categories may be considered as “independent student” under Section 480(d) (7) of the HEA. Under that provision, a student is considered to be an independent student if he or she is a “student for whom a financial aid administrator makes a documented determination of independence by reason of other unusual circumstances.”
The HUHS Director of Financial Aid can exercise professional judgment to make a dependent student as independent student; however, does not have the authority to make an independent student a dependent student.
A dependency override occurs when a financial aid administrator exercises professional judgment and overrides dependency status for a student. An override may only be granted on a case-by-case basis for students with unusual & exceptional circumstances. These circumstances must show compelling reason for a student to be considered independent rather than dependent.
Conditions that could merit a dependency override:
- Documented abandonment
- Complete alienation between parents and the student
- Parental drug use, mental incapacity or incarceration
- A verified unaccompanied youth who is homeless or who is at risk of homelessness *
Conditions that, individually or in combination with one another, do not qualify as “unusual circumstances” or that do not merit a dependency override include:
- Parents refusing to contribute to the student’s education
- Parents unwilling to provide information on the FAFSA or for verification
- Parents not claiming the student as a dependent for income tax purposes
- Parent(s) residing overseas
- Student demonstrating total self-sufficiency
- Student does not wish to communicate with parents
The law requires that a determination of unusual circumstance(s) must be made each award year. A determination of independence in one award year does not mean the student will automatically be an independent student in a subsequent award year. The financial aid administrator must confirm that the conditions for determining the student to be independent still exist. Decisions made at other institutions are not accepted.
*In order to be considered a homeless youth the student must be under the age of 22 or still in high school. If the school encounters students who fit all of the parameters of being homeless or is at risk of being homeless but are age 22 or 23, and the student is not independent for some other reason, he or she would be a dependent student since he or she no longer fits the definition of “youth.” In this case, the HUHS financial aid administrator could decide to do a dependence override and must follow all appropriate procedures for documented dependency overrides.
Students that believe his/her circumstances may qualify for a dependency override will need to complete the following steps. All dependency overrides are evaluated on a case-by-case basis and must be documented.
- Students must complete the FAFSA prior to submitting the Dependency Override Request form.
- Students need to download and complete all sections of the Dependency Override Request form.
- Students must provide documentation that supports the request for a dependency override. Students should make every effort to obtain all the listed documentation, missing documentation may cause the request to be rejected. Additionally, the need may arise for students to submit documentation not listed below.
- Notarized Third Party Statements: Provide at least two letters from third-party adult individuals who personally have knowledge of the situation and who can verify the circumstances.
- At least one letter must be from a guidance counselor, physician, social worker, clergy person, or another individual who has been involved in the circumstances in a professional capacity. This letter should be on professional letterhead.
- All letters must include details as to how the person knows the student, how long they have known the student, and how they have been involved and/or have first-hand knowledge of the situation. The individuals submitting letters cannot be related to one another, nor can they reside at the same address. A telephone number and address where the individual can be reached for follow-up questions must be included.
- All letters should be notarized
- Additional Supporting Documentation: In addition to your request form and notarized third-party statements, students need to provide the following:
- A copy of the student’s current lease, rental agreement or a signed statement from the current landlord verifying tenancy
- Tax Transcript from the IRS for tax years 2019 and 2020.
- W2’s for tax years 2019 and 2020.
- Details of monthly expenses (utility bills, car payments, etc.)
- Court documentation, police reports, arrest reports, etc. as applicable
- Independent Verification Worksheet (e-form to be completed in the HUHS Financial Aid portal)
- Copy of birth certificate; if adopted, copy of birth certificate issued after adoption proceedings.
- Notarized Third Party Statements: Provide at least two letters from third-party adult individuals who personally have knowledge of the situation and who can verify the circumstances.
4. Students need to submit the Dependency Override Request form and all supporting documentation to the Financial Aid Office. With the exception of the third-party statements, all documentation should be loaded into the HUHS Financial Aid portal. Since the documentation package should include notarized statements, copies of the third-party statements will not be accepted, submissions must be mailed to:
Huntington University of Health Sciences
Attention: Financial Aid Office
118 Legacy View Way, Knoxville, TN 37918
5. Once a complete documentation package has been received by the University, the Director of Financial Aid will review all documentation and make a determination. The decision is final and not subject to appeal. Students will be notified in writing of the decision and will include the date of the decision and the signature of the Director of Financial Aid.