Chapter	5
Special	Cases
There	are	unique	situations	where	you	will	need	to	exercise	your	discretion	as	a	financial	aid	administrator:	when
modifying	data	used	to	calculate	the	Student	Aid	Index	(SAI),	adjusting	a	student9s	cost	of	attendance	(COA),	performing
dependency	overrides,	resolving	conflicting	information,	reporting	cases	of	fraud,	and	determining	a	student	to	be	an
unaccompanied	homeless	youth.
The	following	special	cases	are	discussed	in	further	detail	in	this	chapter:
You	may	choose	to	exercise	professional	judgment	(PJ)	to	adjust	components	of	a	student9s	COA	or	the	data	that
determine	a	student9s	SAI	to	account	for	a	student9s	special	circumstances.
You	might	also	choose	to	exercise	PJ	to	account	for	a	student9s	unusual	circumstances	that	warrant	making	a
dependent	student	an	independent	student.
You	may	need	to	determine	if	a	student	should	be	classified	as	an	unaccompanied	homeless	youth.
You	may	need	to	resolve	a	discrepancy	after	receiving	conflicting	information	for	a	student.
In	some	cases,	you	may	suspect	that	a	student	or	employee	has	fraudulently	obtained	federal	funds	and	you	must
report	them	to	the	Department.
Professional	Judgment
The	FAFSA	Simplification	Act	(the	Act)	distinguishes	between	different	categories	of	professional	judgment	by	amending
section	479A	of	the	HEA.
Special	Circumstances	refer	to	the	financial	situations	(loss	of	a	job,	etc.)	that	justify	an	aid	administrator	adjusting
data	elements	in	the	COA	or	in	the	SAI	calculation.
Unusual	Circumstances	refer	to	the	conditions	that	justify	an	aid	administrator	making	an	adjustment	to	a
student9s	dependency	status	based	on	a	unique	situation	(e.g.,	human	trafficking,	refugee	or	asylee	status,	parental
abuse	or	abandonment,	incarceration),	more	commonly	referred	to	as	a	dependency	override.
A	student	may	have	both	a	special	circumstance	and	an	unusual	circumstance.	Financial	aid	administrators	(FAAs)	may
make	adjustments	that	are	appropriate	to	each	student9s	situation	with	appropriate	documentation.	See	Dear	Colleague
Letter	GEN-22-15	for	additional	guidance	and	discussion	of	the	changes	made	by	the	FAFSA	Simplification	Act.
Special	Circumstances
An	FAA	may	use	PJ	on	a	case-by-case	basis	to	adjust	the	components	of	a	student9s	cost	of	attendance	or	the	data	used	to
calculate	their	SAI.	This	adjustment	is	valid	only	at	the	school	making	the	change.
The	law	gives	some	examples	of	special	circumstances	that	may	be	considered	(HEA	Sec.	479A):
Change	in	employment	status,	income,	or	assets;
Change	in	housing	status	(e.g.,	homelessness);
Tuition	expenses	at	an	elementary	or	secondary	school;
Additional	family	members	enrolled	in	college;
Medical,	dental,	or	nursing	home	expenses	not	covered	by	insurance;
Child	or	dependent	care	expenses;
Severe	disability	of	the	student	or	other	member	of	the	student9s	household;	and
Other	changes	or	adjustments	that	impact	the	student9s	costs	or	ability	to	pay	for	college.
This	is	not	an	exhaustive	list.	You	may	use	your	discretion	to	make	appropriate,	reasonable	adjustments	to	reflect	a
student9s	situation	more	accurately.	You	may	also	use	your	discretion	to	deny	a	student9s	request	for	adjustment.
However,	you	may	not	maintain	a	policy	to	deny	all	requests	for	special	circumstance	adjustments.	Your	institution	must
develop	policies	and	a	process	for	reviewing	requests	for	professional	judgment.	Additionally,	your	institution	must
publicly	disclose	that	students	may	request	an	adjustment	based	on	special	circumstances.	This	could	include	(but	is	not
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