Professional Judgement

The Higher Education Act of 1965 (HEA), as amended, combined with the FAFSA Simplification Act provides the authority for administrators in the Office of Student Financial Aid (OSFA) to exercise discretion in a number of areas when a student has special or unusual circumstances. The authority is known as Professional Judgement (PJ) and may be exercised on a case-by-case basis to different categories as described below:

  • 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 Expected Family contribution (EFC) 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.

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. Providing relevant documentation, preferably from an unrelated third party, is critical to the special or unusual circumstance appeal’s success.

Below are some examples of special circumstances that may be considered:

  • Change in employment status, income, or assets
  • Change in housing status (e.g., homelessness)
  • Medical, dental, or nursing home expenses not covered by insurance
  • Child or dependent care expenses
  • Sever disability of the student or other member of the student's household
  • Other documented changes or adjustments that impact the student's costs or ability to pay for college

Unusual circumstances (dependency override) do include:

  • Human trafficking, as described in the Trafficking Victims Protection Act of 2000 (22 U.S.C. 7101 et seq.)
  • Legally granted refugee or asylum status
  • Parental abandonment or estrangement
  • Student or parental incarceration

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

Please be aware, an aid administrator may override a student from dependent to independent.

Unable to Provide Parent Data

Students who are unable to provide parent data and have a FAFSA that was rejected due to an unusual or special circumstance should also reach out to our office immediately. The reasons may be:

  • you are unaccompanied and homeless, or at risk of homelessness
  • unsure if a dependency override is warranted
  • you may have to provide parental data
  • you may be permitted to borrow only unsubsidized loans because you can document that your parents have refused support and will not provide their information on the FAFSA

If you feel that any of the mentioned circumstances apply to you, select the relevant appeal found at by selecting the “Manage Requests” icon. Correctly completed and documented appeals will be reviewed within two weeks of the submission date.