Professional Judgment Beyond the Numbers

1. Professional Judgment Beyond the Numbers MASFAA 2008 Linda Dagradi ldagradi@collegeboard.org

2. Can You Prevent This?

3. Need-Based Aid Family has the first responsibility to pay for college costs to the extent of its ability! Aid supplements family resources Ability may not equal willingness Challenge is to assess ability

4. Using PJ requires a good understanding of need analysis • Determining the ability to pay/EFC is often the most complex aspect of FA decision-making • Need analysis resources: • FM: FSA Handbook, FSA Coach, (www.ifap.ed.gov) • IM: College Board IM manual; institutional policies. • College Board, associations, USED training.

5. Professional Judgment: What is it? • PJ is the process that enables us to deal with unusual circumstances affecting families’ ability to pay. • PJ is our way to get around one-size-fits-all need analysis. • PJ promotes access by helping us to get aid to students in need.

6. Professional Judgment • FAA discretion • Unique family financial circumstances • Decisions vary among colleges

7. Where’s our authority to do this? • Public funds: the HEA (section 479A) gives us the authority to make “adjustments on a case-by-case basis” in “special circumstances,” with “adequate documentation.” (ref: FSA Handbook: Application & Verification Guide) • Institutional funds: institutional policies governing the scope of adjustments to standard need analysis.

8. Where do we use PJ? • Assessing ability to pay • FM ~ Federal methodology • IM ~ Institutional methodology • Determining the cost of attendance. • Making exceptions to dependency status.

9. What situations might merit use of PJ? • Loss of income • One-time income • Fluctuating income • Non-discretionary expenses • Elder care, medical, education debt, etc. • Loss of assets • Breakdown or absence of parental relationship

10. For federal aid, on a case-by-case basis, we can… • Change the value of a data element in the FM formula (e.g., AGI). • Override dependent student status. • Adjust the cost of attendance.

11. For federal aid, we can’t… • Change allowances or add new data elements to the FM formula. • Simply make a bottom-line change to the FC. • Make an independent student apply as a dependent student. • Make non-financial eligibility problems, such as loan default, go away.

12. Two important considerations • When dealing with unusual family circumstances, we need to keep in mind the difference between choice and necessity. • We should use our judgment to address a family’s inability to pay for college – not its unwillingness to pay.

13. Initiating the Process • Proactive • File review • Verification • Reactive • Appeal • Change of Circumstance

14. PJ: Process • Develop a full understanding of the situation. • Decide (in committee?) whether it merits an exception. • If it does, adjust FC, COA, or dependency status as appropriate. • Document your reasoning and adjustment. • Communicate your decision to the family.

15. Document !!!! • Audit Trail for Program Review / Audit. • Ability of another aid officer to reach the same conclusion. • Keep correspondence / notes. • Written justification. • Dates / Names / worksheets / forms

16. What’s adequate documentation? • A record that will clearly justify your decision; another aid officer (or an auditor) should be able to understand what you’ve done, why you’ve done it, and how you implemented your decision. • Standardized forms may be helpful, but aren’t necessary. • Have families provide adequate supporting documentation, but be reasonable.

17. Assess the Outcome • What do you believe the outcome of your decision should be? • Will your decision achieve the expected outcome?Can you explain your decision?….will they understand? • Are you maintaining “Equity”? • What are the consequences of making this judgment?…. Not making it???

18. Potential challenges • Are you responding to the facts, or to the people? • Can you make the same decision for every other family that presents this problem? • Are you responding only to the squeaky wheel? • Are you making so many exceptions that you’ve thrown out your usual system? • Are you reluctant? Fearful? Unsure? • Time

19. Final thoughts • Resources: • Institutional policies • Experienced colleagues • College Board PJ Tip Sheets • Don’t be afraid to use your judgment. After all, a chimp could be trained to click “Package this student” on a PC. • Be prepared to do the right thing, not just to do things right.

20. To give away money is an easy matter ... and in any man's power. But to decide to whom to give it, and how large and when, for what purpose and how, is neither in every man's power nor an easy matter. Hence it is that such excellence is rare, praiseworthy and noble."Aristotle

21. Your experience? Questions? Issues?