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The reason that they call it “professional judgment” and not “professional whimsy” and not “professional rubber stamp” is that they have decided to give the financial aid departments a great deal of discretion in deciding when to change things. </p>
<p>If a single low-income parent was receiving child support in an unexpectedly large amount – for example, suppose parent A earns $15,000 and receives $75,000 annually from the noncustodial parent – I believe that the financial aid department would be empowered to use professional judgment to make corrections to the FAFSA. In fact, if the FAFSA application was selected for verification, then the financial aid department would be required to obtain documentation of the true amount received as child support. </p>
<p>If parent A earns $15K and parent B pays $20K in child support, the college may think that’s not big deal – that still shows that parent A is a person of modest means. The point along the spectrum at which it becomes significant depends on — get this – the judgment of the financial aid professional. The law entrusts those college financial aid people to make that call, because it is assumed that they are smart enough to figure things out in a way consistent with the overall goals of the financial aid system. </p>
<p>Also, child support is a different category of income than interest income, because interest income usually reflects the existence of sufficient assets to generate that income. There are some exceptions, such as when interest is reported when someone cashes in a savings bond – but at least it puts the college on notice that further inquiry is warranted. </p>
<p>Also, if the interest or dividend income is tied to investment assets, it is likely to continue in the future. Child support tends to be reduced substantially just at the time the kid starts college, as the obligation to pay support usually ends when the kid turns 18. </p>
<p>So in my example above with the same numbers - a parent who earns $15K but has $20K in interest income - the parent with the interest appears to have more wealth than the parent who is relying on the ex to send a check. If that $20K turns out to reflect that the person as $400,000 in assets – the college would be more likely to exercise PJ to bring that income and asset under consideration than if the $20K turned out to be what was paid out when the parent cashed in $50K worth of savings bonds to make ends meet after being laid off from the job – because in that case it is non-recurring and the asset it represented is no longer there.</p>
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<p>No one is questioning that Steve “qualifies” for the auto 0. The point is that the qualification is NOT an “entitlement”. It’s just the first step in the process. ALL financial aid applications are subject to review by college financial aid departments; they are ALWAYS subject to the exercise of professional judgment. The college determination cannot be challenged. However, financial aid applicants can protect themselves by applying to multiple colleges. </p>
<p>As I explained above, a college would be unlikely to use PJ with a moderate amount of child support because it wouldn’t really constitute a “special circumstance”. To be a special circumstance it has to be something that makes the applicant atypical – a $10K in child support would be too common to fit that definition. </p>
<p>I honestly can’t see that any other private college considering need based aid would come to a different result in Steve’s case. Steve’s problem is that he has too much money to qualify for financial aid. The only way he even gets the possibility of aid is because his numbers happen to fit into an arbitrary category that triggers disregard of the majority of his income. But because of the way the system works, Steve’s numbers are always going to be reviewed, and I doubt that any college that sees the value of his investment portfolio is going to fail to exercise PJ to bring in the income and assets to the calculation. </p>
<p>The only way I see Steve’s son getting a Pell grant is via a college that has no intention of offering need-based grant aid to its applicants – for example, if Steve’s son applies to an out-of-state public that gives grant aid only to state residents – AND if Steve is lucky enough to avoid having his FAFSA selected for verification. The reason I say that is that if the college is not being asked to make a determination as to how to allocate its own funds, it has little incentive to scrutinize the numbers closely.</p>