Federal Student Aid - IFAP



From: Sally L. Stroup, Assistant Secretary for Postsecondary Education
Theresa S. Shaw, Chief Operating Officer, Federal Student Aid

Subject: Verification, Dependency Overrides, and Professional Judgment


Students Impacted by Hurricane Katrina: The Secretary will not enforce the verification requirements of the regulations for the 2005-06 award year for any student an institution determines is unable to provide requested verification information because of the impact of Hurricane Katrina. An institution must document when it does not complete verification for this reason, and should use Verification Status Code "S" when reporting a Federal Pell Grant award to the Common Origination and Disbursement (COD) System.

  • Records Lost, Destroyed, or Unobtainable: As a result of Hurricane Katrina, some students who have been selected for verification of their financial aid application, either by the U.S. Department of Education (Department) or by the institution using its own verification policy, may not be able to submit required verification documents. Consistent with guidance we previously provided (see Dear Colleague Letter GEN-04-04 on Information for Financial Aid Professionals [IFAP]), the Secretary will not enforce the verification requirements during the 2005-06 award year for students whose records were lost, destroyed, rendered illegible, or are otherwise unobtainable as a result of the impact of Hurricane Katrina.
  • Transfer Students: For the 2005-06 award year, as Institutional Student Information Records (ISIRs) are obtained for students who transfer to an institution as a result of the impact of Hurricane Katrina (see Electronic Announcement # 3 on IFAP), institutions will find that some have been selected for verification. Institutions may ignore this selection for these students.

Nothing in this guidance prohibits an institution from performing verification if it has reason to believe that information on the ISIR is incorrect.

Dependency Overrides

An institution enrolling a transferring student as a result of Hurricane Katrina who received a dependency override determination may, but is not required to, use the previous institution's dependency override determination to process the student's application. An institution may determine if a dependency override was made by the previous institution if a value of '1' is in the Dependency Override Indicator field of the 2005-06 ISIR (field #107, position 526). Before using an ISIR that was the result of the previous institution's dependency override, the enrolling institution should obtain a signed statement from the student that briefly describes the circumstances that supported the previous institution's override determination. The institution must document in the student's file that it used the Dependency Override Indicator and the student's certification as the basis for processing the student's application as independent.

Professional Judgment

Section 479A of the Higher Education Act of 1965, as amended, specifically gives the financial aid administrator the authority to use professional judgment to make adjustments to a student's cost of attendance or to the values of the items used in calculating the Expected Family Contribution (EFC) to reflect the student's special circumstances. Consistent with guidance we previously provided (see Dear Colleague Letter GEN-04-04 on IFAP), the Secretary strongly encourages institutions to consider using professional judgment in order to reflect more accurately the financial need of students and families affected by a disaster.

Because of the severity of the impact of Hurricane Katrina on many students and families, we want to reiterate our encouragement that institutions use their authority to make appropriate case-by-case professional judgment decisions when needed. Also, we want to remind institutions that any request for documentation from students and families should be made based upon a realistic assessment of the availability of a family's records as well as other critical concerns that the family may be dealing with as a result of the hurricane.

In exercising professional judgment, institutions must make their own determinations and not rely on determinations of the previous institution.

We expect, in a future announcement, to provide more information on the use of professional judgment by Financial Aid Administrators during this emergency, including guidelines on appropriate adjustments to cost of attendance.