Can We Use the Same Documentation We Collected Last Year To Perform a Dependency Override This Year?

Award Year: 2023-24 KA-35258 Helpfulness Rating 560 page views

This guidance is specific to the 2023-24 award year and later.

A review of last year's professional judgment (PJ) documentation is no longer necessary unless the student indicates there is a change in circumstances or there is conflicting information in the student's file. Effective with the 2023-24 award year, any student determined to be independent by dependency override for a preceding award year shall be presumed to be independent for each subsequent award year at the same institution, unless the student indicates a change in circumstances or unless conflicting information exists. Schools no longer have to ask students if their circumstances have changed.

See also GEN-22-15 ISS-Q2, which reads, “Can schools ask students if their unusual circumstances or homeless situation has changed each year?

Yes. However, institutions must not maintain a practice that delays or hinders the awarding and/or disbursement of federal student aid for such students and may not require them to submit additional documentation unless there is conflicting information that the institution needs to resolve. Section 479D(d) of the HEA, as amended by the Act, will remove barriers for this vulnerable student population.”

Reference Section 479A of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087TT], GEN-23-06, and GEN-22-15.

Tools: Refer to the following tools to assist with this student population:

P&P Builder: NASFAA’s Policies & Procedures (P&P) Builder guides you step-by-step through the creation of a centralized, accessible policies and procedures manual. This is included in the cost of NASFAA Value Plus membership. There is an additional cost for other membership levels.

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