Financial Aid Adjustments and Appeals

Filing the FAFSA, 2015-2016 Edition (Cover)
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The Free Application for Federal Student Aid (FAFSA) is a one-size fits-all form. Unlike the CSS/Financial Aid PROFILE form, there is nowhere on the form where families can describe special circumstances that affect their ability to pay for college. Instead, Congress allows college financial aid administrators to make adjustments to the data elements on the FAFSA and the college's cost of attendance, on a case-by-case basis, when supported by adequate documentation of special circumstances.

Adjustments are one of three types of changes that may be made to the FAFSA. The other two are Corrections and Updates.

Congress also granted college financial aid administrators the authority to perform dependency overrides from dependent student status to independent student status, when supported by documentation of unusual circumstances. Overrides are not normally referred to as adjustments.

Adjustments are rare, with only about one percent of undergraduate students receiving an adjustment.

Special Circumstances

Special circumstances include anything that has changed from one year to the next and anything that distinguishes the family from the typical family.

Examples of special circumstances mentioned in the Higher Education Act of 1965 include:

  • Tuition expenses at an elementary or secondary school
  • Medical or dental expenses not covered by insurance
  • Unusually high child care or dependent care including elder care costs
  • Recent unemployment of a family member or an independent student
  • A student or family member who is a dislocated worker
  • The number of parents enrolled at least half-time in a degree, certificate, or other program leading to a recognized educational credential at an institution that is eligible for Title IV federal student aid
  • A change in housing status that results in an individual being homeless
  • Other changes in a family's income, a family's assets, or a student's status that impact a family's cash flow

Special circumstances involving a sibling's elementary and secondary school tuition do not include a sibling's college tuition, as that is addressed by the number in college on the FAFSA. Some college financial aid administrators will, however, consider making an adjustment for extra costs associated with a special-needs child's education, such as the cost of support services, tutoring and other accommodations.

The Higher Education Act of 1965 also indicates that financial aid administrators may make adjustments:

  • To exclude from family income any proceeds of a sale of farm or business assets of a family if such sale results from a voluntary or involuntary foreclosure, forfeiture, or bankruptcy or involuntary liquidation
  • To take into consideration the additional costs a student with a disability incurs as a result of the student's disability

The Higher Education Relief Opportunities for Students (HEROES) Act of 2003 (P.L. 108-76) allows college financial aid administrators to waive or modify any statutory or regulatory requirement relating to federal student aid in times of war, military operation or national emergency. Affected individuals include members of the military on active duty and their families, as well as individuals who live or work in an area that is declared a disaster area by a federal, state or local official in connection with a national emergency. The authority granted by the HEROES Act was subsequently made permanent. The Federal Register mentions several waivers and modifications, including:

  • Substituting estimated award year income information (e.g., the first calendar year of the award year) for prior tax year information on the FAFSA
  • Waiving the requirement that adjustments be made on a case-by-case basis

Other common examples of adjustments granted by college financial aid administrators include:

  • Death, disability or serious illness of a wage earner
  • Incarceration or institutionalization of a wage earner
  • Mental or physical incapacitation of a wage earner
  • A loss or reduction in parent or student income, including when a student quits a job to go to school full-time
  • Exclusion of one-time events from parent or student income (but not assets), such as the exclusion of an inheritance, unusual bonus, personal injury settlement or insurance settlement from income (but not from assets), because they are not reflective of the family’s ability to pay during the award year
  • Natural disasters such as earthquakes, hurricanes, wildfires, tornadoes, floods and landslides
  • Loss or damage to the principal place of residence
  • Legal expenses
  • The end of child support when the child reaches the age of majority
  • Reductions in child support
  • Catch-up payments of child support owed from previous years
  • The end of Social Security benefit payments
  • Dependent-care costs associated with a special-needs child or an elderly parent or grandparent or other relative
  • Exclusion of the conversion of a traditional IRA to a Roth IRA from income
  • Exclusion of unusual capital gains, atypical one-time bonuses and worker's compensation buyouts
  • Exclusion of employer reimbursement of moving expenses that were included in income
  • Exclusion of hardship distributions from retirement plans, especially if used to pay for higher education expenses
  • Addressing volatile income by substituting an average of the last three years of income (e.g., taxi drivers, waitresses, commissioned sales staff and realtors all have income that may vary significantly from one year to the next)
  • U.S. Armed Forces activation of a parent or student

Most college financial aid administrators will perform a comprehensive review of the family's financial situation, not just the impact of the specific unusual circumstances. For example, if a dependent student's parent lost his job, but also won a multi-million dollar lottery, the financial aid administrator is unlikely to focus solely on the job loss.

Financial aid administrators will generally not make adjustments for vacation expenses, tithing expenses, children's allowances, car payments, lawn care, gambling losses, mortgage payments, student loan payments or credit card payments. They will also not make adjustments to exclude assets that were transferred to the parent to enable a grandparent to qualify for Medicaid.

Requesting an Adjustment

To request an adjustment, the student or the student's parents (if the student is a dependent student) should ask the college's financial aid office, not the admissions office or the president's office, about the school's process for a ""professional judgment review." Some colleges call it a special circumstances review or a financial aid appeal. Some colleges will ask the family to write a letter summarizing the special circumstances and to provide appropriate supporting documentation. Others will have a form that can be downloaded from the college's web site.

When writing a letter to request an adjustment, the letter should summarize the special circumstances affecting the family's ability to pay and discuss the financial impact of the special circumstances (including specific dollar amounts) on the family's ability to pay for college. The letter should also provide sufficient information for the financial aid administrator to identify the student, such as the student's name, student ID number (if known), and the student's date of birth.

It is important to include copies of independent third-party documentation of the special circumstances, since the process is driven by documentation. Documentation can include copies of a layoff notice, proof of the recent receipt of unemployment benefits (within the last 90 days), copies of medical or dental bills and letters from doctors, clergy, social workers, child advocates, police, teachers, guidance counselors, college financial aid administrators and anyone else who is familiar with the student's or family's situation. The documentation should ideally include information about the financial impact of the special circumstances in addition to discussing the nature of the special circumstances.

A professional judgment review should be requested from each of the colleges and universities to which the student is applying for admission and financial aid.

Each college's financial aid office will make its own decision about the request for an adjustment. Some colleges may make an adjustment while others may not. Decisions made by a financial aid administrator at one college are not binding on financial aid administrators at other colleges.

Adjustments apply only to a single award year. Financial aid administrators must review the special circumstances once a year to ensure that they still apply before making an adjustment.

Timing of Financial Aid Appeals

The appeal for more financial aid can occur at any time, even in the middle of the academic year. For example, if a parent loses his or her job in the middle of the school year, the family should ask for a professional judgment review at that time.

Not all colleges will act on an appeal in the middle of the award year, but many will. Some colleges may wait until the following year, depending on the nature of the circumstance and/or available campus funding. For example, if a college switches from prior year income to an estimate of current year income, some colleges will want to see six months of earnings before implementing a change in the student's financial aid package.

Most financial aid administrators will not make an adjustment in anticipation of a future change in the family's circumstances. Families should wait until the special circumstance has actually occurred to request a professional judgment review.

How Successful Appeals are Implemented

If the financial aid administrator feels that the unusual circumstances merit an adjustment, the amount of the adjustment will be related to the financial impact of the unusual circumstances on the family. For example, job loss will generally be implemented as a reduction in income, taking any severance pay or unemployment benefits into account. Adjustments for medical expenses may be reduced by the amount of medical expenses already considered by the federal need analysis methodology, which is 11 percent of the income protection allowance.

The changes in the data elements on the FAFSA will then result in a new expected family contribution (EFC). This, in turn, may result in a new financial aid package. (Note that even if the college allows an adjustment, the college may not be able to provide additional financial aid funds, but the financial aid administrator may be able to suggest other options.) So, the process is very formulaic.

Financial aid administrators can also adjust the cost of attendance figures, not just the data elements on the FAFSA. For example, the financial aid administrator might increase the cost of attendance to include the cost of a computer, dependent care costs for a special-needs child or disability-related expenses. Financial aid administrators are more likely to adjust the cost of attendance when the student's EFC is zero, since current financial aid formulas do not allow the EFC to go below zero. When a student's EFC is already zero, increasing the cost of attendance is the only way to increase the student's demonstrated financial need (and thus, the amount of financial aid).

Restrictions on Adjustments

There are a few restrictions on the types of adjustments that may be granted by a financial aid administrator.

Financial aid administrators cannot modify the financial aid formula, only the data elements that are part of the EFC calculation.

Financial aid administrators cannot waive eligibility requirements. For example, if a student with a learning disability is enrolled on a half-time basis, the financial aid administrator may not award financial aid as though the student is enrolled full-time. On the other hand, they may waive the requirement that such a student be making satisfactory academic progress.

Financial aid administrators cannot modify the cost of attendance figure to include expenses that occur before enrollment (e.g., application fees, test preparation) or after graduation (e.g., licensing fees).

Increasing the Odds of a Favorable Adjustment

College financial aid administrators are more likely to make an adjustment when the unusual circumstance is due to factors beyond the family's control. They are less likely to consider an adjustment when the unusual circumstances are due to a discretionary choice made by the family. For example, even though private K-12 tuition for a sibling is mentioned in the Higher Education Act of 1965 as an example of a special circumstance, some financial aid administrators feel uncomfortable making adjustments for private tuition and fees. Other financial aid administrators will grant an adjustment, but cap it at the average cost to the government to educate a public school student (e.g., about $10,000).

There is no appeal beyond the college financial aid administrator. Neither the college's president nor the U.S. Department of Education can override the financial aid administrator's decision. So, it pays to be polite. Honesty is always the best policy. If the financial aid administrator believes that the family is trying to game the system, the financial aid administrator can deny the appeal.