Can a Dependency Override Be Reversed?

Scenario: Earlier in this award year, we approved a dependency override based on police reports and letters of testimony. Now, the student claims that he and his parents have reconciled and that he is back living with his parents. 

Answer: Yes. Although the U.S. Department of Education (ED) has indicated that a dependency override cannot be used to make an otherwise independent student dependent, that is not what would occur in this situation. Instead, your school would be choosing to reverse an allowable previous adjustment in order to make an otherwise dependent student once again dependent.

Note that the ISIR Guide specifically states that a dependency override can be cancelled: “This flag identifies a record that resulted from an application or correction on which an FAA made a dependency override request. On initial applications, overrides can be made in one direction only, from dependent to independent. Also, FAA Access enables an FAA to cancel a previous override.”

Therefore, NASFAA's understanding is that reversing the dependency override would be allowed, but not necessarily required, assuming the initial dependency override was made on the basis of information that was accurate at the time of the decision. Please note that if you choose to reverse the dependency override, parental information and signatures will be required on the FAFSA.  

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. See Section 479A(c)(2)(D)(iv) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087TT] and Dear Colleague Letter GEN-22-15 .

Student Aid Reference Desk: For additional information, try the Student Aid Reference Desk. It is a central hub of all the important financial aid resources you need with direct links to legislation, regulation, Dear Colleague Letters, and other ED and NASFAA references. It is updated on a rolling basis with the latest news and changes. Search Student Eligibility.