Must We Adjust Household Size For the Death Of an Unborn Child?

Scenario: A student claimed an unborn child on her Free Application for Federal Student Aid (FAFSA) and has since notified us that the child has died. Financial aid disbursements have already been made to the student.

Answer: Information on the FAFSA generally is not updated or changed if it was correct at the time the FAFSA was signed and submitted. If the student was pregnant at the time the FAFSA was filed and correctly included the unborn child in the household size, the household size would not be updated due to the death of the unborn child. There are two exceptions:

Exception 1: Under 34 CFR 668.55(b), if the student is selected for verification, either by the institution or by the Central Processing System (CPS), household size must be updated to be correct on the date of verification. If verification occurs after the death of the unborn child, the household size would be updated at the time of verification. If the student is not selected for verification by the CPS, there is no need for your institution to select the student for verification because of the knowledge of the child's death; it is not conflicting information.

Exception 2: Under 668.55(a), "If an applicant’s dependency status changes at any time during the award year, the applicant must update FAFSA information, except when the update is due to a change in his or her marital status." If the unborn child was the only reason the student was independent, then the student's dependency status will change for the entire award year. The FAFSA must be updated to include parental information and aid must be recalculated based on the new expected family contribution (EFC). The financial aid administrator could choose to exercise their professional judgment (PJ) discretion to perform a dependency override to keep the student independent if the aid administrator believes special circumstances warrant such consideration. See the Application and Verification Guide, Chapter 5, of the FSA Handbook for more information on PJ.

Bear in mind, if the student is not selected for verification either by the CPS or the institution, then the only way the financial aid office would be aware of this development is if the student provides this information to the financial aid office. Therefore, it may be possible that the student’s dependency status would not change until the subsequent award year due to the death of the unborn child.

Note: 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. For guidance changes on the carryover of the homelessness determination, reference Section 479D(d)(1) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087uu-2(d)(1)] and Dear Colleague Letter GEN-22-15.

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