Special circumstances refers to anything in the applicant’s financial situation that is not reflected on the FAFSA or CSS Profile. The Profile has an actual space for applicants to detail special circumstances. For FAFSA schools, applicants may have to appeal their aid award and go through the Professional Judgment (PJ) process. If this might apply to you, you should understand the decision-making criteria and process so that special circumstances you’re detailing are in fact special circumstances in the financial aid world.
The Higher Education Act and its various reauthorizations list some examples of special circumstances: “elementary or secondary school tuition, medical or dental or nursing home expenses not covered by insurance, unusually high child care costs, being homeless or a dislocated worker, recent unemployment of a family member, or other changes in the family’s income or assets.” However, there is a “judgment” element of PJ: “Use of professional judgment is neither limited to nor required for the situations mentioned.” As the FAFSA transitioned to using prior-prior income data, the Department of Education gave guidance to financial aid administrators to expect more PJ cases.
While there is some judgment involved, there are also a number of requirements for PJ:
- The reason for the adjustment must be documented, and must apply only to the student and not to a class of students. For example, in the case of a job loss, the family would need to provide documentation such as a termination letter.
- Adjustments can only be made to either the cost of attendance or values of data inputs into the EFC formula, not to the formula calculation itself. In the case of a family illness, for example, the administrator might reduce assumed income from the ill person or reduce assets based on projected medical expenses.
- Students may not be deemed independent for aid purposes based on parents’ refusal to provide financial support for education or to complete the FAFSA. However, such students may be eligible to borrow larger amounts under federal loan programs.
- Calculations may not be adjusted based on recurring vacation, tithing or other standard living expenses.
Financial aid administrators are required not only to document any adjustments they make, but to resolve any conflicting information that they receive. So the onus will be on you to document your situation. And remember that since we’re talking about the FAFSA and Profile, all of this refers to need-based awards, not merit.