Professional Judgment is the authority granted to institutions under The Higher Education Act of 1965, as amended, which provides the authority for the financial aid administrator to exercise discretion in several areas when a student has experienced special or unusual circumstances. Professional judgment decisions must be made case-by-case by examining a student's unique circumstances. All professional judgment changes apply only to data element changes and apply to all Title IV programs.
The FAFSA Simplification Act (the Act) distinguishes between different categories of professional judgment by amending section 479A of the HEA.
- Special Circumstances refer to financial situations that justify an aid administrator adjusting data elements in the COA or the EFC/SAI calculation.
- Unusual Circumstances refer to the conditions that justify an aid administrator adjusting a student’s dependency status based on a unique situation 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 adjust each student’s situation appropriately with appropriate documentation.
Potential Reasons for Exercise of Professional Judgment and Examples of Acceptable Documentation
Special Circumstance: EFC/SAI Adjustments
ICC will use professional judgment on a case-by-case basis to adjust the data used to calculate the expected family contribution/student aid index.
Must relate to the special circumstances of an individual student and not a whole class of students.
Students must document special circumstance.
ICC can adjust data elements on the FAFSA but not the formula used to calculate the expected family contribution/student aid index.
Examples of potential reasons that warrant a special circumstance review for EFC/SAI adjustment are, but not limited to: income reduction or nonrecurring income due to loss of job, divorce or death of dependent student’s parent(s) or of independent student.
Examples of acceptable documentation for EFC/SAI appeal include, but are not limited to:
- Separation of employment letter
- Most recent pay stubs. Typically, the last 3 pay periods
- Award letter from Unemployment Office
- Signed written statement from the individual appealing their EFC
- Court documentation
- Divorce papers
- Death certificate
- Additional documents as determined
Special Circumstances: Budget/COA Adjustments
ICC may use professional judgment to adjust an individual student’s cost of attendance.
A budget adjustment may be requested to cover certain additional costs above the standard cost of attendance (which includes tuition and fees, estimated costs for health insurance, books and supplies, long-distance travel, utilities/internet, rent, food, local travel, and miscellaneous/personal expenses during the academic school year).
Adjustments must be made for reasonable and allowable expenses within federal regulations.
Students must provide documentation of expenses.
Examples of potential reasons that warrant a review for a budget/COA adjustment are, but not limited to:increase in housing component for rent and/or utilities, program of study requires books/supplies over COA allowance, increase in transportation allowance.
Examples of acceptable documentation for a budget/COA (Cost of Attendance) appeal include, but are not limited to:
- Documentation associated with unusually high Costs of Attendance components
- Receipts or statements; copies of bills
Unusual Circumstances: Dependency Overrides
Federal regulations define which students are considered “dependent” on the FAFSA. Dependent students are required to provide parent information and a parent signature on the FASFA, which contributes to determining financial aid eligibility.
ICC will override the requirement to provide parent information on a case-by-case basis for students with unusual circumstances.
Student must provide a written statement detailing those circumstances and provide supporting documentation as needed.
A dependency override appeal will be reviewed as quickly as practicable, but no later than 60 days after the student has completed and turned in all documentation.
Examples of potential reasons that warrant an unusual circumstance review are, but not limited to: human trafficking, refugee or asylee status, parental abuse or abandonment, incarceration.
None of the following conditions, singly or in combination, qualify as unusual circumstances meriting a dependency override:
- Parents refuse to contribute to the student’s education.
- Parents are unwilling to provide information on the FAFSA or for verification.
- Parents do not claim the student as a dependent for income tax purposes.
- The student demonstrates total self-sufficiency.
- Parents residing in another country
Examples of acceptable documentation for an unusual circumstance (dependency override) appeal include, but are not limited to:
- Signed written statement from student
- Written statement from a third party, preferably from a professional familiar with the situation.
- Court documentation.
- Death certificate.
- Police reports.
- A documented interview between student and financial aid administrator
- Other documentation as determined
Framework and Guideline for Professional Judgments
Special or unusual circumstances will be considered on a case-by-case basis. To determine if a special or unusual circumstance may qualify, students can contact the Financial Aid Office at financialaid@icc.edu or 309-694-5600.
Students can apply for a Professional Judgment by completing the special circumstance or unusual circumstance worksheet on the ICC website and submitting it through the secure file upload or in person to the Financial Aid Office along with all supporting documentation. All professional judgment worksheets and statements must be signed and dated by the applicant submitting the appeal.
The supporting documentation may vary based on the type of Professional Judgement and reason for the Professional Judgement. Additional documentation may also be requested regarding the Financial Aid review.
A financial aid administrator will conduct and document the review as soon as practicable after all requested document(s) are provided. Students will be notified of a decision made to their ICC lab email. A financial aid administrator will submit the appropriate corrections if the appeal is approved. If the appeal is denied, the student will be notified of the reason or an opportunity to provide additional documentation.
Professional Judgment requests cannot be processed after the student is no longer enrolled for a period of enrollment; or processed by the school after the end of the period of the student’s enrollment. Therefore, ICC requires all requests be submitted as early as possible within the academic year of the student’s enrollment.
ICC’s professional judgment decisions are final and cannot be appealed to the U.S. Department of Education.