Prior-Prior Year and Professional Judgment

By PPY Implementation Task Force

The use of Prior-Prior Year (PPY) income and the resultant Early FAFSA change the environment in which we operate in a couple ways: base year income is further removed from the academic year, and a longer time may pass between when the student and family file for financial aid and when school begins. A lot can change in two years; special or unusual circumstances have more time to occur. The law delegates the authority, known as Professional Judgment (PJ), to the financial aid administrator to override dependency status and/or adjust the standard components of need analysis which affect the Expected Family Contribution when a particular family’s situation is no longer comparable to most other applicants.

Early FAFSA and PPY have added more decision points for schools in processing PJ/special circumstances appeals. Timing of appeals is one question—schools may want to process PJs early to get things finalized for students, while some may wish to hold off until closer to the academic year in case the change in circumstance is temporary. Schools may choose different timeframes to process appeals for new and continuing students, or for different types of scenarios. For instance, some schools wait a few months after an event like a job loss to ensure that new work is not found quickly, nullifying the change, whereas they may choose to process an appeal based on a death in the family or a divorce right away. In addition, with the change to PPY, schools may be unsure which year’s income is best to use when performing a PJ. Below please find a list with some considerations of options.

Prior Year (2016)

Considerations

  • Income from a completed year might be determined more reliably than for a partial year
  • Change in income during 2016 or earlier was permanent – e.g., change in marital status, retirement, job change
  • Other circumstances for appeal are expected to continue into or affect 2017 year
  • Able to do appeal earlier since final 2016 income would be known by early in 2017
  • Circumstances could change again in 2017 so the family’s ability to pay could be over- or under- stated
  • Using projected 2016 income for 2017-18 and actual 2016 in following year may result in conflicting information

Projected Year (2017)

Considerations

  • Change in circumstances occurs late in 2016 or in 2017 – e.g., change in marital status, loss of benefit, retirement, job changes, household size changes
  • Job loss or illness during late 2016 or 2017 is expected to continue into the academic year
  • Other one-time events occurring after 2016
  • May take into account the most recent events for student and family
  • May need to wait longer in cycle to process since projections might be available later
  • Not as much accuracy as complete 2016 income information

Other 12 month period

Considerations

  • Using 12 months including the academic year may reflect best actual ability to pay
  • Some schools use a rolling 12 months after a major event which causes the PJ request
  • Emphasizes the case-by-case nature of PJ
  • Use 2015 income but adjust it to account for permanent or continuing change, such as removal of one-time non-recurring income
  • May be more complex to administer due to collection of income documentation from two calendar years

No PJ Consideration

Considerations

  • Reasonable adjustments would not change the aid package, or not change it significantly
  • The school does not have resources to meet increased need for students who would still not be eligible for Pell and have already reached loan limit
  • Institutional policy is that the particular change in circumstances does not warrant PJ (for example, if the institution defines triggers for PJ review based on philosophy, past experience, student body characteristics, and resources
  • Can be problematic if institutional restrictions on PJ present a barrier for needy students

Each school should decide individually the best way to treat professional judgment requests at the institution following some principles of professional judgment (PJ):

PJ is a subjective process...

  • No right or wrong answer
  • Not unusual for FAAs to review the same situations and arrive at different but equally valid solution
  • FAA authorized to request and use supplemental documentation, if appropriate, to make an informed and well-reasoned PJ decision
  • No fee may be charged to do a PJ review
  • All PJ decisions must be made on an individual case-by-case basis
  • Should try to reflect the most accurate information about the ability of student and family to pay for college

Changes in income may be the result of:

  • Unemployment
  • Loss (or gain) of a benefit
  • Job Change
  • Illness
  • Retirement
  • Separation or Divorce
  • Windfall earnings in self-employment or commission-based work
  • Unusual uncompensated medical expenses

Types of documentation typically used for income adjustments:

  • For estimated income: Signed statements of estimated earnings; paycheck stubs; alimony in divorce agreement; unemployment compensation and Workforce Investment Act (WIA) benefits; disability and Social Security benefits received or to be received
  • For nonrecurring income or expenses: Federal Income Tax Return, Form 3903-Moving Expenses; Schedule D-Capital Gain and Losses

Also a reminder that any conflicting information must be resolved and verification (if applicable) must be completed before performing a PJ. Many institutions have forms to assist in collecting the appropriate figures and supporting documentation for FAA review. Any form should include the student, spouse (if appropriate) and /or parents signature and date. The student’s file should be documented with the decision (both the reason for it and the actual change that was made) and signature of the FAA. And finally, as a best practice, the student should be notified in writing of the results of the review regardless of the outcome.

 

Publication Date: 12/21/2016


Tyler B | 12/21/2016 8:19:56 AM

A very good article overall with great ideas/thoughts for this new year and PPY. However, I disagree with the assertion that "Using projected 2016 income for 2017-18 and actual 2016 in following year may result in conflicting information." As is the case currently, a PJ in on a 2016/2017 record and then using standard base year (which is 2015 income) is not considered conflicting information per the FSA conference and guidance regarding the 399 code being mistakenly put on 2017/2018 records where a PJ was completed in 2016/2017. Regardless, an assessment of the family situation in 2016/2017 and then a different assessment in 2017/2018 is reasonable per the second bullet in the PJ is a subjective process section: "Not unusual for FAAs to review the same situations and arrive at different but equally valid solution."

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