Professional Judgment Process and Appeals

Estimated Family Contribution (EFC) or Student Aid Index (SAI)

The Higher Education Act establishes the Federal methodology (FM) formula used for determining eligibility for federal student financial aid programs. However, Federal regulations provide financial aid administrators with the authority to use their discretion or professional judgment to adjust, on a case-by-case basis and with adequate documentation, the data elements used on the Free Application for Federal Student Aid (FAFSA), that impact the estimated family contribution (EFC) or student aid index (SAI) to get a better picture of a student and their family’s ability to pay for college.

Cost of Attendance (COA)

A school’s COA (also known as a student’s budget) is used to determine each student’s eligibility for financial aid, such as grants, scholarships, and loans. It is a school’s estimated total expenses for one year, that includes both direct and indirect costs.

Cost of attendance components may include tuition/fees, books, course materials, and equipment, living expenses (housing and meals), transportation, miscellaneous personal expenses, loan fees, and professional licensure, certification, or a first professional credential. Other cost of attendance components such as costs for dependent care, disability related expenses, study abroad expenses, cooperative education costs, online/study by correspondence, confined or incarcerated students, less than half-time, or those living in in military housing may be adjusted as appropriate during a professional judgment appeal.

Dependency Status

Federal student aid programs are based on the concept that it is primarily your and your family’s responsibility to pay for your education. A dependent student is assumed to have the support of parents, so the parents’ information must be assessed along with the students to get a full picture of the family’s financial strength. If you’re a dependent student, it doesn’t mean your parents are required to pay anything toward your education; this information is simply used to determine the student’s maximum eligibility for federal student aid.

It is important to understand what makes a student dependent or independent for federal aid purposes. According to the Department of Education, an independent student must meet at least one of the following criteria:

  • 24 years of age or older.
  • Married.
  • Enrolled in a master’s or doctorate program.
  • A veteran or active-duty member of the armed forces.
  • An orphan or ward of the court.
  • Supporting at least one legal dependent other than a spouse.
  • An emancipated minor, ward of the court, in foster care or under legal guardianship of someone other than a parent prior to age 18.
  • Homeless or at risk of becoming homeless.

Dependency status exceptions may be considered with a professional judgment appeal.

This type of appeal is most often utilized by undergraduate students when financial circumstances change, and those changes impact a student or their family’s ability to contribute to their education.

On a case-by-case basis and with proper documentation, Financial Aid Offices have the discretion to adjust the data elements entered on the Free Application for Federal Student Aid (FAFSA) that impacts a student’s Expected Family Contribution (EFC) or Student Aid Index (SAI). Such changes are meant to provide a more accurate assessment of a student’s family’s ability to contribute to the cost of education.

Examples for a Family Contribution Appeal Include:

  • Loss of employment.
  • Change in financial situation due to separation or divorce (changes can only be made if both parent/stepparent income was included on the FAFSA and a separation or divorce occurred after the FAFSA was submitted).
  • Death of custodial parent (if the deceased parent’s income was included on the FAFSA).
  • Death of Spouse for Independent student (if spouse’s income was included on the FAFSA).
  • Loss of child support (changes can only be made if child support was included on the FAFSA).
  • Unusual medical expenses (the FAFSA already allows for a certain percentage of income protection allowance related to medical expenses).
  • Catastrophic loss, such as a natural disaster.
  • Deduction of one-time payment (e.g., retirement, payouts, severance pay).
  • The existence of additional family members enrolled in college.
  • Severe disability of student, parent, student’s spouse, or student’s dependent.
  • Unusual amount of losses claimed on income tax return.

Example Documentation Required: (Not all inclusive)

  • Copy of termination or lay-off notice.
  • Last paystub(s).
  • W-2 form.
  • Leave and Earnings Statement(s).
  • Unemployment benefit notice.
  • Birth or death certificate.
  • Divorce decree.
  • Documented interview between student and Financial Aid Advisor.
  • Supplementary information about financial status or personal circumstances.

Examples of What DOES NOT Qualify as a Reason for an EFC/SAI Special Circumstance Review: (Not all inclusive)

  • 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.
  • Year to year fluctuations in income.
  • Credit card or other personal debts.
  • Standard living expenses.
  • Vacation expenses.
  • All other discretionary expenses
  • If the Estimated Family Contribution (EFC) calculated from the FAFSA is zero

When additional education-related expenses beyond a student’s standard COA are incurred, they may request a COA adjustment by completing a Cost of Attendance Adjustment Request. COA adjustments are evaluated on a case-by-case basis and are subject to federal and University policies.

The cost of attendance, also known as the budget, includes tuition, fees, books, supplies, housing, food, travel and estimated personal expenses.  Federal regulations only permit increases to the budget for educational-related expenses incurred during the current academic year.

Examples for a COA Appeal Include:

  • Tuition and/or fees exceeding a student’s standard COA (this generally relates to those in academic overload).
  • Course, lab, program, or fees exceeding your standard COA.
  • One-time cost for the purchase of a computer and/or mandatory course software, purchased during the aid year.
  • Childcare or dependent care costs not covered by a third party. Only expenses incurred while students are in class AND a spouse/significant other (when applicable) is unavailable to provide care will be considered.
  • Student health insurance exceeding your standard COA, if required by a student’s program/college and billed through your student account.
  • Travel costs exceeding a student’s standard COA.

Example Documentation Required: (Not all inclusive)

  • Increased Housing Costs
    • A copy of the current lease or mortgage showing all persons residing at the location and the amount of monthly rent.
    • Proof of Utilities: Utility statements should be submitted for the previous 3 months. The student’s share is then averaged to calculate expenses.
  • Food: Not currently included on the COA Appeal form. However, the student may submit documentation within the Medical Category (ex. a note from a dietitian with estimated monthly costs) if the food expenses are due to a medical condition.
  • Books & Supplies – Acceptable documentation includes itemized receipts of schoolbooks and supplies (art students purchasing software or writing utensils, etc.).
    • Confirmation of excess costs or test requirements.
    • Confirmation of textbook prices above standard COA.
  • Transportation/Travel – Documentation (such as Google Maps) of the route driven to and from school must be provided. Appeals for mileage will be approved in cases where the mileage expenditure (based on the $0.445 per mile, the # of days per week, and the number of weeks in the semester that the commute is made) exceeds the standard COA budget.
    • Flight costs to home residence.
    • Other transportation expenses – transportation passes, parking passes, etc.
    • For Study Abroad Travel expenses, proof of purchase of an airline ticket
  • Child Care
    • Current statements showing current monthly rates. The student can only include costs that accrue during the time of class.
  • Computer/Electronic Purchase
    • Receipt from purchase.
  • Licensure/Certification Allowance – The one-time direct cost of obtaining this for students enrolled in a program that requires professional licensure or certification. For example, fees charged to take licensing exam or costs to apply for license certification. Costs must be incurred during (not after) a period of enrollment. Attach receipt.
  • Other – Include a description of your circumstance and enclose supporting documentation.

Examples of What DOES NOT Qualify as a Reason for a COA Special Circumstance Review: (Not all inclusive)

  • Consumer bills (i.e., credit card debt, cell phone payments, car payments, insurance).
  • Food and on-campus meal expenses for off-campus students.
  • Expenses for extracurricular activities (i.e., conferences, sports, internships).
  • Relocation expenses.
  • Expenses for other family members.
  • Pet or hobby expenses.

Documentation for a dependency appeal is critical and must support the reason for such an appeal. Documentation should in almost all cases originate from a third party with knowledge of the unusual circumstances of the student.

Financial Aid Administrators have the authority on a case-by-case basis to change a student’s status from dependent to independent, involving unusual cases that result in the dissolution of the family unit.

The U.S. Department of Education has provided guidance regarding situations that Do or Do Not merit a dependency override.

Examples for a Dependency Appeal Include:

  • Abandonment by parents.
  • An abusive family environment that threatens a student’s health/safety.
  • Not being able to locate parents.
  • Student or parent incarceration.
  • Parents who lack the physical or mental capacity to raise the child.
  • Parents hospitalized for an extended period.
  • An unsuitable household (e.g., child removed from the household and placed in foster care).
  • A married student’s spouse dies, or student gets divorced.
  • Human trafficking.
  • Being legally granted refugee or asylum status.

Examples that Do Not Merit a Dependency Appeal Include: (Not all inclusive):

  • Parents refuse to contribute to the student’s education.
  • Parents are unwilling to complete the FAFSA and/or provide required documentation for FAFSA verification.
  • Parents do not claim the student for tax purposes.
  • Students live apart from their parents.
  • The student works and is financially self-sufficient.

Example Documentation Demonstrating Separation from Parents: (not all inclusive):

  • A letter from a high school counselor or social worker testifying to the fact that a student is independent of their parents.
  • Written explanation of how a student meets the basic necessities of life (housing, food, clothing, and transportation.
  • Police reports or court documents, such as a restraining order against one or both parents.
  • Proof of student or parent incarceration.
  • Documented phone call or written statement confirming independent status with certain authorities.

Note: If granted a dependency override appeal, HSU will presume the student will remain independent in a subsequent award year unless the student informs the institution that their circumstances have changed, or the institution has conflicting information about the student’s independence.

Please Note, requesting an appeal does not guarantee it will be granted or guarantee additional funding.

To request a Professional Judgment Appeal, follow the steps below.

  • You must have a completed FAFSA submitted to HSU before an appeal can be considered.
  • To request an appeal, please fill out this form explaining the qualifying reason you are requesting an appeal to be considered for review.
  • You will receive a response back from the Financial Aid Office within 5-7 business days informing you if your request is accepted and what the next steps shall be.
  • Appeals are typically reviewed within 2-4 weeks after submission. During busy processing times (such as the summer), it may take longer for your appeal to be evaluated.
  • If selected for FAFSA verification, you much complete verification before your appeal can be reviewed.

Submission Timeframe

  • There is no deadline for submitting a Professional Judgment Appeal. However, the U.S. Department of Education requires that you still be enrolled as a student in order for the appeal to be processed.
  • If you are only attending the Fall Semester, your appeal and all requested documentation must be accurately submitted 3-4 weeks before the end of the semester to allow time for processing.
  • If you are attending the full year (Fall and Spring semesters), your appeal and all requested documentation will need to be submitted accurately 3-4 weeks before the end of the Spring semester to allow time for processing.
  • Financial aid is awarded on a first come, first served basis.  Funding may be limited as the academic year/semester progresses. It is in the student’s best interest to file the appeal as early as possible.

Special Note: Appeals cannot be processed once you have ceased enrollment, therefore, if you fail to provide the required documentation with time to process before the end of the term, your appeal will not be processed.

The Financial Aid Office will contact you by your HSU email regarding the status of your request for an appeal. Please monitor your HSU student email account.

If granted a Family Contribution Appeal, you will be required to complete FAFSA verification first. You will receive an email from the Financial Aid Office with instructions.

Professional Judgment decisions are final. A student cannot appeal to the university president or to the U.S. Department of Education. Congress delegated the authority to make professional judgment adjustments to the data elements on the Free Application for Federal Student Aid (FAFSA) to the university financial aid office and their assigned staff.