nasfaa 2020 summer training series: professional judgment ... · professional judgment – part 2 a...

2020-21AUTHORIZED EVENTS

CREDENTIALEDTRAINING

PROFESSIONAL JUDGMENT Part 2

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June 2020

NASFAA’s 2020 Summer Training SeriesProfessional Judgment – Part 2

A NASFAA Authorized EventPresented June 23, 2020

Slide 2-1 © 2020 NASFAA

National Association of StudentFinancial Aid Administrators

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National Association of Student Financial Aid Administrators


Professional JudgmentA NASFAA Authorized Event

Presented byTonya Hsiung and Joe Massman

June 23, 2020

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© 2020 NASFAA 1 Professional Judgment 6/23/2020




Using Professional Judgment in Originating

Direct Loans

Lesson 3


Denial or Reduction of Direct Loan Eligibility• Case-by-case basis

• Document the decision

• Notify borrower, in writing

• Do not discriminate on the basis of race,national origin, religion, sex, marital status,age, disability status, or income


ApplicationApplication

• Parent is incarcerated• Parent’s only source of income is

public assistance or disability benefits

• Parent’s income/debt ratio indicates inability to repay PLUS

• Parent is incarcerated• Parent’s only source of income is

public assistance or disability benefits

• Parent’s income/debt ratio indicates inability to repay PLUS

Reasons for denying or reducing a

Direct PLUS

Reasons for denying or reducing a

Direct PLUS

Reasons for denying or reducing

loan eligibility

Reasons for denying or reducing

loan eligibility

• High debt burden • Borrower’s unwillingness to

repay the loan

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Professional Judgment 6/23/2020 2 © 2020 NASFAA




Documentation

Borrower Third-Party

Conversation with the borrower

Signed statement from borrower of

unwillingness to repay

Documentation of previous history of

unwillingness to repay

NSLDS shows high debt burden

Documentation from career services office

showing average starting salaries in

various fields


• Rachel overhears a conversation

• Michael states he is not going torepay his loans

• Michael is Rachel’s next counselingappointment

Example: Michael


If you were Rachel, would you take what you heard seriously and consider either denying or reducing Michael’s loan based upon what you overheard? Yes, I would deny or reduce Michael’s loan.

No, I would not deny or reduce Michael’sloan.

I’m not sure.

Poll

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• Rachel asks follow-up questions– Michael’s plans after college

– Michael’s intent

• Rachel’s explicitly asks Michael if he plans topay back the loans

• Michael states he does not play to pay back hisloans

Example: Michael


With this new information, would you now consider denying or reducing Michael’s loan?

Yes, I would deny or reduce Michael’s loan.

No, I would not deny or reduce Michael’sloan.

I’m not sure.

Poll


• Rachel documents conversation– Follows up with Director

• Rachel sends email to Michael– States school’s decision and why it was made

– Provides other financing options

Example: Michael

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Direct Unsubsidized Loan for Dependent Student without Parental Data• Option available to students whose parents

ended financial support and refuse to filethe FAFSA

• Parent refusal to file the FAFSA is notgrounds for a dependency override


Signed statement

from student

Signed statement from

third party

Signed statement

from parent(s)

Documentation


• Eva is a junior

• Applied as dependent for theprevious two years

• Recent argument with her parents resulted intheir refusal to provide FAFSA information

• Eva is living with a relative

• Tom meets with Eva to discuss her situation

Example: Eva

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Does Eva’s situation warrant special consideration? Yes, Eva should qualify for the Direct

Unsubsidized Loan for a dependent withoutparental data.

No, Eva should not qualify for the DirectUnsubsidized Loan for a dependent withoutparental data.

I’m not sure.

Poll


• BRMC requests documentation– Written statement

– Letter from parents

– IRS tax return or tax return transcript from Eva

• Eva’s parents respond via email

• ISIR received with parent signature

Example: Eva


• Kayleigh is a sophomore

• Last year her mother, Marguerite,was denied the Direct PLUS Loan– Kayleigh borrower the additional unsubsidized lo

• This year, Marguerite was approved the DirectPLUS Loan

• Marguerite asks you to deny the Direct PLUSLoan

Example: Kayleigh

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Would you deny it so Kayleigh could access the additional unsubsidized loan? Yes, I would deny Marguerite’s Direct PLUS

Loan.

No, I would not deny Marguerite’s Direct PLUSLoan.

I’m not sure.

Poll


• Should obtain more information

• Marguerite’s credit may have improved,but her financial situation may not have

• With additional documentation, you may beable to warrant the refusal of the Direct PLU

Example: Kayleigh


Using Professional Judgment in Satisfactory

Academic Progress

Lesson 4

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“Same as or stricter than”“Same as or stricter than”

Qualitative (grades)

Qualitative (grades)

Maximum timeframeMaximum timeframe

Quantitative (pace)

Quantitative (pace)

Frequency of

evaluation

Frequency of

evaluation

Appeal ProcessAppeal Process

SAP Standards

SAP Standards


Frequency of Evaluation

• Programs one academic year (AY) or lessmust evaluate SAP after each paymentperiod

• Programs longer than one AY may evaluate:– Annually at end of a payment period; or

– After each payment period


SAP Appeals and PJ

• Financial aid warning allows Title IV aid for onemore payment period only

– Available only to schools that monitor SAP at theend of each payment period

• Options on successful appeal:– Financial aid probation status for one payment

period if the student should be able to meet SAPstandards by the end of the payment period; or

– An academic plan under which the student cancontinue to receive Title IV aid as long as thestudent complies with the plan’s requirements

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May use PJ to waive SAP standards due to undue hardships on case-by-case basis:

Exercising PJ

Death of student’s relative

Student’s personal injury or illness

Special circumstances determined by institution


PJ Documentation for SAPCIRCUMSTANCE TYPE OF DOCUMENTATION

Death of a relative of the student

Copy of official death certificate

Statement from adult family member or physician

Personal injury or illness of the student

Signed statement from student’s physician

Accident or police report

Family difficulties, such as divorce or illness

Copies of official legal documents

Signed statement from physician

Signed statement from an involved third party (e.g., counselor, clergy, lawyer, etc.)

Interpersonal problems with friends, roommates, or others

Signed statement from an involved third party (e.g., resident advisor, school counselor, etc.)

Time management difficulties

Documentation illustrating commitments outside of school (e.g., pay stubs, etc.)

Tangible steps for improvement


PJ Documentation for SAP

Have these circumstances created an undue hardship on the student that caused the student’s inability to meet the SAP standards?

Have the barriers to academic progress been removed or sufficiently managed to permit reasonable expectations for future academic progress?

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Quick Quiz:

1. A SAP appeals process is: required by federal regulation at all institutions awarding

Title IV aid. optional at the institution’s discretion. required to be processed by an institution in groups of

students with the same situation. allowed only after a term of financial aid probation has

been completed.

Page 89


Quick Quiz:

1. A SAP appeals process is: required by federal regulation at all institutions awarding

Title IV aid. optional at the institution’s discretion. required to be processed by an institution in groups of

students with the same situation. allowed only after a term of financial aid probation has

been completed.

Page 89


Quick Quiz:

2. In cases where one payment period is not sufficient for the student to meet minimum SAP standards, an institution may consider which of the following? Using PJ to grant a SAP appeal and then placing the

student on financial aid probation Using PJ to grant a SAP appeal and then placing the

student on an academic plan with appropriate checkpoints and milestones to be achieved by the student

Using PJ to grant a SAP appeal and then placing the student on financial aid warning

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Quick Quiz:

2. In cases where one payment period is not sufficient for the student to meet minimum SAP standards, an institution may consider which of the following? Using PJ to grant a SAP appeal and then placing the

student on financial aid probation Using PJ to grant a SAP appeal and then placing the

student on an academic plan with appropriate checkpoints and milestones to be achieved by the student

Using PJ to grant a SAP appeal and then placing the student on financial aid warning

Page 89


Quick Quiz:

3. A student on financial aid probation must meet the minimum SAP standards: at the end of the next payment period. before progressing to a new grade level. at the end of the current academic year. before final approval is given for the student’s SAP

appeal.

Page 89


Quick Quiz:

3. A student on financial aid probation must meet the minimum SAP standards: at the end of the next payment period. before progressing to a new grade level. at the end of the current academic year. before final approval is given for the student’s SAP

appeal.

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Quick Quiz:

4. Each of the following are specified in the SAP regulations as conditions under which a SAP appeal may be considered, EXCEPT: Death of a relative Injury or illness of the student Other special circumstances, as determined by ED Other special circumstance, as determined by the

institution

Page 89


Quick Quiz:

4. Each of the following are specified in the SAP regulations as conditions under which a SAP appeal may be considered, EXCEPT: Death of a relative Injury or illness of the student Other special circumstances, as determined by ED Other special circumstance, as determined by the

institution

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Slide 2-44 © 2020 NASFAASlide 2-44 © 2020 NASFAA

Learning Activity

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Learning Activity: PJ Case Study 1—Aryia

• Aryia is struggling to balance school, her 30 hours/week part-time job, and raising her infant son as a single parent

• Before having her son, her cumulative GPA was just over a 3.0, although she had withdrawn from a number of courses

• Since having her son, Aryia withdrew from many of the credits for which she registered, leaving her with a cumulative pace of 64%

• Aryia has not met the required quantitative standard• Aryia would like to appeal her SAP standing• With improved performance, she could possibly regain SAP

by the end of the next payment period

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1. Does she have mitigating circumstances that may warrant a waiver of SAP standards? Yes No

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1. Does she have mitigating circumstances that may warrant a waiver of SAP standards? Yes No

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2. What type of documentation must she provide? A letter of recommendation from her instructors A certificate of approval from ED An explanation of why she failed to meet SAP, and

what has changed that will enable her to successfully meet SAP requirements going forward

Chocolate. Lots and lots of chocolate.

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2. What type of documentation must she provide? A letter of recommendation from her instructors A certificate of approval from ED An explanation of why she failed to meet SAP, and

what has changed that will enable her to successfully meet SAP requirements going forward

Chocolate. Lots and lots of chocolate.

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3. What other documentation would you request (select all that apply)? Letter of support from her job supervisor Pay stubs that document her hours worked Letter of support from her daycare provider Other

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4. Which option is NOT available as a response to the SAP appeal? She can be placed on financial aid probation for the

next payment period She can be placed immediately on an academic plan

with certain conditions The school can recommend that she take time off from

her studies to adjust to her circumstances and develop a routine with adequate time to study

The school can grant academic amnesty and not count any of the student’s past grades against future SAP

Page 91



4. Which option is NOT available as a response to the SAP appeal? She can be placed on financial aid probation for the

next payment period She can be placed immediately on an academic plan

with certain conditions The school can recommend that she take time off from

her studies to adjust to her circumstances and develop a routine with adequate time to study

The school can grant academic amnesty and not count any of the student’s past grades against future SAP

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Learning Activity

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Learning Activity: PJ Case Study 2—Tyrion

• During fall break, Tyrion had a skiing accident and encountered physical complications, which resulted in him missing quite a bit of school

• His current GPA is not consistent with graduation requirements and he no longer meets Winterfell’s SAP standards

• He has filed an appeal of his SAP determination • Tyrion’s past academic performance has not been

outstanding, and he cannot regain SAP after just one term

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1. Does he have mitigating circumstances that may warrant a waiver of SAP standards? Yes No

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1. Does he have mitigating circumstances that may warrant a waiver of SAP standards? Yes No

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2. What supporting documentation would you request (select all that apply)? Letter from his physician explaining that the medical

condition will not linger into the upcoming academic year

Police or accident report A substantial donation to the office coffee fund Other

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3. If Tyrion’s appeal is approved, can he be placed on financial aid probation? Yes No

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3. If Tyrion’s appeal is approved, can he be placed on financial aid probation? Yes No

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Credential Test Overview

• Must fully attended Part 1 and 2• Receive credential test access information email

within a week of viewing webinar– Must complete credential test within 40 days of receiving

email• Test

– 90 minutes– Open-book– 45 to 55 multiple choice– Two attempts– Printable certificate


Upcoming Courses• Fundamentals of Student Financial Aid – 7/7/2020

• Direct Loans – 9/8/2020

• Satisfactory Academic Progress – 9/22/2020

• Return of Title IV Funds – 10/27/2020

• Fundamentals of Student Financial Aid – 11/9/2020

• Verification 2021-2022 – 1/11/2021

• Federal Pell Grant & IASG – 2/9/2021

• Professional Judgment – 3/8/2021

• Consumer Information – 4/6/2021

• Fundamentals of Enrollment Management –5/3/2021

• Fundamentals of Student Financial Aid – 7/6/2021

Download Your Certificate of Attendance


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Submit Your Questions


Complete the Survey


Thank you for joining us!


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What’s next?NASFAA’s live webinars bring you the latest information, hot off the press, and allow you to actively engage with NASFAA staff and featured presenters from government, partner organizations, and fellow aid administrators.

On Demand Webinars are recordings of previously broadcasted events. The recordings are available for purchase and viewing at your convenience.

All webinars begin at 2:00 pm ET, unless otherwise noted, and last 60 to 90 minutes. Archives are usually available after the webinar for purchase; these archives are also free to webinar package purchasers.

Webinar Schedule for 2020-21 - See You Online!Topic Air Date

2021-22 Verification Basics 08/26/2020

Foundations of Academic Calendars 09/23/2020

2021-22 FAFSA Update 10/07/2020

Verification - Challenging Questions and Scenarios - Extended Edition 10/28/2020

Don’t Be Alarmed By Clock Hours! 11/18/2020

Economics of Financial Aid 12/09/2020

NASFAA Policy Update (complimentary to members) 12/15/2020

Developing Your Talents As A Financial Aid Professional 01/20/2021

Just Keep Swimming: An Aid Professional’s Experience with Mental Health Issues

02/24/2021

Graduate and Professional School Town Hall 2020-21* 03/09/2021

Panel Discussion - Data Sharing and Security 03/24/2021

NASFAA Quiz Show 04/21/2021

Consortium Agreements, Written Arrangements & Study Abroad 05/19/2021

NASFAA Policy Update (complimentary to members) 05/25/2021

Student Eligibility Spotlight 06/09/2021

* Complimentary for all Members. All other webinars are offered at the following rates: Site License:$120 members/$240 non-members/no charge for webinar package purchasers or Value Plus Members.

Please join us for the 2020-21 NASFAA Webinar Series

This listing is current as of June 14, 2020. For additions and changes to this schedule, visit www.nasfaa.org/Webinars_Live_and_On_Demand

https://www.nasfaa.org/On_Demand_Webinars

http://www.nasfaa.org/Webinar_Package_Pricing

http://www.nasfaa.org/Webinars_Live_and_On_Demand

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aid administrators; advocates for public policies that increase

student access and success;serves as a forum on student financial aid issues; and is

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