Free Application for Federal Student Aid (FAFSA)

Students may pursue an adjustment based on special or unusual circumstances. A student may have both a special circumstance and an unusual circumstance. Financial Aid Administrators (FAAs) may make adjustments that are appropriate to each student’s situation with appropriate documentation.

The FAFSA Simplification Act distinguishes between different categories of professional judgment by amending section 479A of the HEA.

• Special Circumstances refer to the financial situations (loss of a job, etc.) that justify an aid administrator adjusting data elements in the COA or in the EFC calculation.
• Unusual Circumstances refer to the conditions that justify an aid administrator making an adjustment to a student’s dependency status based on a unique situation (e.g., human trafficking, refugee or asylee status, parental abandonment, incarceration), more commonly referred to as a dependency override.

1. DSDT may use a dependency override determination made by a financial aid administrator at another institution in the same or a prior award year.

2. Institutions must make and document professional judgment determinations on a case-by-case basis without regard to how broadly an event may affect its student population.

3. In making case-by-case determinations, the FAA must substantiate the student’s circumstance with supporting documentation.

4. Previous reasons for exercising professional judgment (e.g., unemployment, dislocated worker, school tuition expenses) are still allowable.

5. A dependency override for unusual circumstances is considered unique from a determination of independence for homeless youth or at-risk homeless youth.

Additional Flexibility for Assisting Students with Unusual Circumstances

The FAFSA Simplification Act provides a clearer directive for FAAs to assist applicants with unusual circumstances to adjust dependency status on the FAFSA form to reflect students’ situations more accurately. Like other types of professional judgment, institutions must make students aware of their ability to request for an adjustment for unusual circumstances by publicly posting the option on their website. For the award years, applicants must still indicate an unusual circumstance and request a determination of independence with DDBS to allow the Financial Aid Administrator to process their FAFSA form.

Starting with the 2024-2025 Award Year, both initial and renewal applicants who indicate they have an unusual circumstance on their FAFSA form will submit their application under a provisional independent status. This will allow such applicants to receive a Student Aid Index (SAI) with an estimate of their federal student aid eligibility, subject to a final determination by their school.

**As previously provided by law, if a student pursues an adjustment for unusual circumstances and the financial aid administrator does not determine that the student should be considered independent, the student will only be eligible for dependent-level Direct Unsubsidized Loans unless they subsequently complete the FAFSA form as a dependent student by providing parent information.