Must We Obtain Documentation When Accepting Another Institution's Dependency Override Determination?

Award Year: 2023-24 KA-36492 Helpfulness Rating 1,455 page views

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

Yes, but the extent of documentation it collects is entirely up to the school. The school can choose to simply document the fact that another financial aid administrator (FAA) performed a dependency override, or it can choose to collect the documents used by the other FAA to approve the dependency override at the previous school.

The FAFSA Simplification Act expanded the use of another institution's dependency override in the same or prior year. Refer to GEN-22-15 which indicates that acceptable documentation to substantiate a student's claim of unusual circumstances includes a "documented determination of independence made by a financial aid administrator at another institution in the same or a prior award year." GEN-22-15 further reads:

"ISS-Q4: What documentation is acceptable if an FAA chooses to accept a dependency override due to unusual circumstances made by an FAA at another institution?

FAAs may document the discussion from a telephone call, collect a written statement, or use a verifiable electronic data match to determine independence. For the 2023-24 year, there will not be a comment or other indicator on the ISIR. Therefore, institutions who are made aware of a determination of a student’s independence at another institution through other means (e.g., a conversation with the student) should work with the student to obtain documentation from the institution that made the determination to use it as the basis for a determination of independence. Further, FAAs who make a determination of independence at their own institution should be prepared to provide similar documentation to FAAs at other institutions."

According to clarification NASFAA received from the U.S. Department of Education (ED), "the new school has full discretion to determine what information is acceptable within their PJ [professional judgment] policy and procedures. This allows the new school flexibility when being presented with the student’s situation. The new school could ask for and accept a more limited scope of documentation supporting the prior school’s action to perform a dependency override or the new school could ask for more detailed documentation as warranted."

Remember: If the new school has any conflicting information based upon the information that is provided by the previous school, the conflicting information must be resolved under the school’s normal process for resolving conflicting information.

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