When Is Provisional Independent Student Status Being Implemented?

Partially for 2023-24 and partially for 2024-25. The U.S. Department of Education (ED) previously indicated that provisional independent student status would be implemented effective with the 2024-25 award year; however, that is only partially true according to Dear Colleague Letter GEN-22-15.

The FAFSA Simplification Act specifies that ED must calculate an estimated student aid index (SAI) and estimated Federal Pell Grant when students indicate on the FAFSA they have unusual circumstances that could lead to a dependency override. ED indicated it will not implement the systems changes needed on their end to accommodate this provisional independent student status until 2024-25. In the meantime, ED will provide improved help text on the FAFSA.

For the 2023-24 award year, schools are still required to comply with the institutional requirements under the law. Specifically, for 2023-24, schools must follow up with students who indicate unusual circumstances on the FAFSA, notifying them of the procedures and documentation requirements for requesting a dependency override using professional judgment (PJ). See AskRegs Knowledgebase Q&A, What Are the Requirements For Implementing Provisional Independent Student Status?

When fully implemented in 2024-25, under Section 479A(c)(2) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087TT(c)(2)], students will be granted the ability to request treatment as a provisional independent student on the FAFSA for purposes of a provisional determination of financial aid eligibility as an independent student. This will provide a new process for students with unusual circumstances who cannot provide parental information on the FAFSA. Students requesting provisional independent student status review will be able to complete the FAFSA as an independent student. Financial aid administrators (FAAs) will be required to notify students who request provisional status of the institutional process for a dependency override.

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