Professional Judgment

Analysis of a student's need for federal student aid is based on a standardized assessment of family financial strength relative to all other aid applicants. Sometimes, however, a student or family experiences unusual circumstances that make the standardized approach unsuitable. In such individual cases, with adequate documentation, a financial aid administrator may use his or her professional judgment to override the student’s dependency status, adjust the data used to calculate the expected family contribution, or revise the student's cost of attendance to assess that student's need more accurately. Professional judgment may also be used to deny or reduce eligibility for Direct Loans, or allow Direct Loans in cases where parents refuse to cooperate with need analysis.

Related topics in this Index: Expected Family Contribution; Cost of Attendance; Need Analysis

Synonyms: Financial aid administrator discretion

Statutory Authority
- U.S. Code, Title 20—Education Chapter 28—Higher Education Resources and Student Assistance Subchapter IV—Student Assistance > Part E—Need Analysis § 1087tt [HEA § 479A]
Regulations
The Higher Education Act prohibits ED from regulating professional judgment.
ED References
See also Subtopics for more specific references.
- 2020-21 FSA Handbook, Vol. AVG
- 2019-20 FSA Handbook, Vol. AVG
NASFAA Publications and Articles
- NASFAA AskRegs Knowledgebase
  Search or browse the Knowledgebase for answers to regulatory and compliance questions submitted by financial aid administrators.
- NASFAA Monograph #26: Professional Judgment in Eligibility Determination and Need Analysis
- NASFAA U Authorized Events
  NASFAA U Authorized Events are a comprehensive set of instructional materials for teaching financial aid concepts to groups of individuals. Materials include a study guide, instructor guide and accompanying presentation slides.
- NASFAA U Online Courses
  NASFAA U Online Courses are collaborative learning sessions bring minds and ideas together despite distances. Online courses help you become more proficient, more knowledgeable, and more valuable to your organization, to interact with your colleagues through required discussions, and offer you the option to work towards earning a professional credential from NASFAA.
Subtopics
- Applicability to all Title IV programs
  - 2020-21 FSA Handbook, Vol. AVG, Ch. 5
  - 2019-20 FSA Handbook, Vol. AVG, Ch. 5
- Case-by-case assessments
- Conflicting information
  - 2020-21 FSA Handbook, Vol. AVG, Ch. 5
  - 2019-20 FSA Handbook, Vol. AVG, Ch. 5
- Cost of attendance (COA)
  - General information
    
    2020-21 FSA Handbook, Vol. AVG, Ch. 5
    
    2019-20 FSA Handbook, Vol. AVG, Ch. 5
    
    2019-20 FSA Handbook, Vol. 3, Ch. 2
  - Dependent living expenses
    
    GEN-90-33
    
    GEN-89-49
  - Disability, less than half-time enrollment
    
    GEN-89-49
  - Telecommunications
    
    U.S. Code § 1091(l)(2) [HEA, sec. § 484(l)(2)]
    
    GEN-92-21
  - Variances to standard allowances
    
    GEN-89-49
    
    GEN-88-7
- Denial or reduction of Direct Loans
- Dependency status
  - Dependent to independent overrides
    
    2020-21 FSA Handbook, Vol. AVG, Ch. 5
    
    2019-20 FSA Handbook, Vol. AVG, Ch. 5
  - Documentation
    
    2020-21 FSA Handbook, Vol. AVG, Ch. 5
    
    2019-20 FSA Handbook, Vol. AVG, Ch. 5
  - Homelessness
    
    See top list entry for Expected Family Contribution (EFC), subtopic Dependency status/ Definition of independent student.
- Direct Loan eligibility in cases of parental refusal of support
  - 2020-21 FSA Handbook, Vol. AVG, Ch. 5
  - 2019-20 FSA Handbook, Vol. AVG, Ch. 5
- Documentation
  - 2020-21 FSA Handbook, Vol. AVG, Ch. 5
  - 2019-20 FSA Handbook, Vol. AVG, Ch. 5
- Examples
- Expected family contribution (EFC)
  - Accurate data
    
    GEN-88-7
  - Data elements only
    
    2020-21 FSA Handbook, Vol. AVG, Ch. 5
    
    2019-20 FSA Handbook, Vol. AVG, Ch. 5
  - Income protection allowance (IPA) makeup
    
    2020-21 FSA Handbook, Vol. AVG, Ch. 5
    
    2019-20 FSA Handbook, Vol. AVG, Ch. 5
- Final decision by school not subject to ED appeal
  - 2020-21 FSA Handbook, Vol. AVG, Ch. 5
  - 2019-20 FSA Handbook, Vol. AVG, Ch. 5
- General information
  - 2020-21 FSA Handbook, Vol. AVG, Ch. 5
  - 2019-20 FSA Handbook, Vol. AVG, Ch. 5
- Legal authority
  - U.S. Code § 1087tt [HEA, sec. § 479A]
  - HR Conference Report 102-630 to accompany S. 1150, p. 495
- Prohibited adjustments
- Reasonable vs. unreasonable adjustments
  - 2020-21 FSA Handbook, Vol. AVG, Ch. 5
  - 2019-20 FSA Handbook, Vol. AVG, Ch. 5
- Unemployment benefits
  - 2020-21 FSA Handbook, Vol. AVG, Ch. 5
  - 2019-20 FSA Handbook, Vol. AVG, Ch. 5
- Verification
  - 2020-21 FSA Handbook, Vol. AVG, Ch. 5
  - 2019-20 FSA Handbook, Vol. AVG, Ch. 5

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Professional Judgment

Statutory Authority

Regulations

ED References

NASFAA Publications and Articles

Subtopics

Applicability to all Title IV programs

Case-by-case assessments

Conflicting information

Cost of attendance (COA)

General information

Dependent living expenses

Disability, less than half-time enrollment

Telecommunications

Variances to standard allowances

Denial or reduction of Direct Loans

Dependency status

Dependent to independent overrides

Documentation

Homelessness

Direct Loan eligibility in cases of parental refusal of support

Documentation

Examples

Expected family contribution (EFC)

Accurate data

Data elements only

Income protection allowance (IPA) makeup

Final decision by school not subject to ED appeal

General information

Legal authority

Prohibited adjustments

Reasonable vs. unreasonable adjustments

Unemployment benefits

Verification