professional judgment: dependency overrides & reduced income presented by paul simenson, penn...

Professional Judgment: Dependency Overrides & Reduced Income

Presented byPaul Simenson, Penn State University

Exercising Professional Judgment

Bananas, Onions, Garlic,Bananas, Onions, Garlic,

A Deck of CardsA Deck of Cards

& Other Secrets to Developing Your & Other Secrets to Developing Your Professional Judgment FrameworkProfessional Judgment Framework

First Things First:First Things First:

• Why are you here?

• What do you want from the next 40 minutes?


Student Aid 101: (Student Aid 101: (A brief history)A brief history)

• UM to CM to FM to “Simplification”

• Remains Principally Unchanged• Guidance From Department• Releasing of Monograph 26

• USDE Special Conditions Form

• HEA ’65 Reauthorized in 1992 & Finally August 14, 2008


Immutable Truths:Immutable Truths:

• Perception is Everything

• The “Reasonable Person” Standard

• Responsibility of the Authority

• Not A Rationing Device for Available Funds.


Customer Service 101:Customer Service 101:

• Courage to Challenge

• Satisfaction =

Reality ÷ Expectations

• Perception vs. Reality Thing


Counseling 101:Counseling 101:• No Talking to Crazy People

• When in Doubt, Ask for Documentation. (Paper is an unemotional advocate)

• Hurt People (pause) Hurt People


Keep in Mind:Keep in Mind:(there are differences between)(there are differences between)

• Unwilling vs. Unable

• Institutional Policy vs.

Professional Judgment

• Actionable vs. In-actionable

• Role of Choosing


And Now….And Now…. To the Nuts & Bolts: To the Nuts & Bolts:• What Meets the Measure of

an Exception?

• What Does Professional Judgment Look Like?

• Is There Documented Support from the Appropriate Parties?


More….More…. Nuts & Bolts: Nuts & Bolts:HIGHER EDUCATION ACT of 1965, As Amended

Section 479A. DISCRETION OF STUDENT FINANCIAL AID ADMINISTRATORS.

In General.- Nothing in [Part F, "Need Analysis"] shall be interpreted as limiting the authority of the financial aid administrator, on the basis of adequate documentation, to make necessary adjustments on a case-by-case basis to:

• the cost of attendance • the values of the data items required to calculate the

expected student or parent contribution (or both)• to allow for treatment of an individual eligible

applicant with special circumstances.


Nuts & Bolts… con’tNuts & Bolts… con’t

However, this authority shall not be construed to permit aid administrators to deviate from the contributions expected in the absence of special circumstances.

HIGHER EDUCATION ACT of 1965, As Amended Section 479A. DISCRETION OF STUDENT FINANCIAL AID ADMINISTRATORS.


More….More…. Nuts & Bolts: Nuts & Bolts:• How Is it Exercised?

Mitigating Circumstances (Dependency Issues)

Cost of Attendance Income / Assets (Change

of Circumstance

• How Is it Exercised?Repeatable / Reliable /

Unrelenting


• So, How Good Does Your Professional Judgment Have to Be?

• Is There a Prescribed, Document-Driven Process?

• Are Peers Involved?

More….More…. Nuts & Bolts:Nuts & Bolts:


So, What Are The Highlights?So, What Are The Highlights?

• Policy Formation (or Invoking Policy) is NOT P.J.

• P.J. Can Only Occur With The Collection of Supplemental Information

• It Is Critical You Know Your Institutional Policies & Process


• Your Decisions Must Be…

• The Tale of the Nun & The Violin…

So, What Are The Highlights?So, What Are The Highlights?


• Your Institutional Polices, Processes & Procedures

Toolbox 101:Toolbox 101:The Big three (3) “gots” to knowThe Big three (3) “gots” to know

• The Federal Law: HEA’65

CCRAA

HEOA’08• Where to Seek Guidance


Toolbox 101:Toolbox 101:Final Toolbox ThoughtsFinal Toolbox Thoughts

The financial aid administrator is expected to provide leadership in:

the development of institutional policies & guidelines for exercising professional

judgment ensuring the consistent application

of those policies. When questions arise involving professional judgment, the financial aid administrator may find it helpful to consult colleagues at similar institutions.



The financial aid administrator is expected to provide leadership in:

A continuing dialogue among financial aid administrators will prove beneficial in refining professional judgment


The objective is to serve The objective is to serve students more equitably & students more equitably & compassionately.compassionately.

Professional Judgment in Eligibility Determination And Resource Analysis

November 13, 1993, Monograph Number 10 Updated June 1997

Toolbox 101:Toolbox 101:Final toolbox ThoughtsFinal toolbox Thoughts


The aid administrator should be able to distinguish between distinguish between changes in a family’s circumstanceschanges in a family’s circumstances that are a function of choicechoice, and those that are a function of necessity.necessity.

Using this distinction distinction will help the aid administrator make better decisions….

[Professional Judgment] is not intendedis not intended to be a rationingdevice and therefore should not be tailored to availablefinancial aid funding.



Constructing Student Expense BudgetsConstructing Student Expense Budgets

April 1993, Monograph Number 9 Updated June 1997

Professional Judgment in Eligibility Professional Judgment in Eligibility Determination And Resource AnalysisDetermination And Resource Analysis

November 1993, Monograph Number 10 Updated June 1997

MonographA N A S F A A S e r i e s


Professional Judgment in Eligibility Determination And Professional Judgment in Eligibility Determination And Resource AnalysisResource Analysis

October 2007, Monograph Number 21

http://www.nasfaa.org/PDFs/2007/Monograph21.pdf

MonographA N A S F A A S e r i e s


http://www.nasfaa.org/products/monographs/Monographs.aspx

Professional Judgment in Eligibility Determination And Professional Judgment in Eligibility Determination And Need AnalysisNeed Analysis

August 2012, Monograph Number 26http://www.nasfaa.org/EntrancePDF.aspx?id=11073

Also: Dear Colleague LetterDCL ID: Gen-09-05

May 8, 2009

http://www.ifap.ed.gov/dpcletters/GEN0905.html

http://www.nasfaa.org/EntrancePDF.aspx?id=11073

One Last Thing One Last Thing As You Go…… As You Go……


Questions, Comments, Questions, Comments, Concerns?Concerns?


P.M. Simenson Senior Manager for Administrative & Constituent Services Penn State University

([email protected])

Thanks…Thanks…


professional judgment: dependency overrides & reduced income presented by paul simenson, penn...

Documents

professional judgmentmore

theexpected student

higher education act

unableinstitutional

policy formation

invoking policy

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amended section