What Are the Requirements For Implementing Provisional Independent Student Status For 2024-25?

Award Year: 2024-25 KA-36499 Helpfulness Rating 3,411 page views

This guidance is specific to the 2024-25 award year and later.

Schools must reach out to all dependent students who do not provide parental data on the FAFSA (regardless of reason) and inform them about the procedures for requesting a dependency override using professional judgment (PJ).

For the 2024-25 award year, under Section 479A(c)(2) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087TT(c)(2)], when students are completing the FAFSA, they will be granted the ability to request treatment as a provisional independent student. This will provide a process for students with unusual circumstances who cannot provide parental information on the FAFSA and who demonstrate unusual circumstances that differentiate the individual student from a group of students. Students requesting provisional independent student status will be able to complete the FAFSA as an independent student and will receive an estimated student aid index (SAI) and estimated Federal Pell Grant. The financial aid office must then notify students who request provisional status of the institution's process for a dependency override. In order for the aid administrator to make a final determination, the student must then submit documentation and complete the dependency override process in accordance with changes to the law regarding dependency overrides and in accordance with required institutional procedures.

Institutional Procedures: Under HEA 479A(c) [20 USC 1087TT(c)(2)(B)] and GEN-22-15, upon receiving the accepted student's FAFSA, the aid office must:

The aid office processes the PJ request as it normally would to clear Reject Code 1 and Comment Code 003. The 2024-25 draft FAFSA Specifications Guide, Volume 6–ISIR Guide states this:

"If a student answers “Yes” to question 7 on the FAFSA form (Student Unusual Circumstances), the student will receive a provisional status as an independent student as well as a provisional SAI calculation; however, the record will still be rejected, pending further action from the student’s FAA. The student should work with the FAA to determine if they qualify for a professional judgment. If the student does qualify, the FAA will need to submit the professional judgment. Once that professional judgment is processed, the student’s status changes from “provisionally independent” to “independent,” and their SAI calculation is no longer considered provisional."

As with prior award years, you indicate the student qualifies for a dependency override either on the paper FAFSA (College Use Only section) or in the FAFSA Partner Portal (formerly FAA Access). The U.S. Department of Education (ED) has not released guidance on making FAFSA corrections using the FAFSA Partner Portal, so you'll have to find the FAA Access equivalent when the systems go live for 2024-25.

If the dependency override is approved, the school is required to carry that decision forward to future award years without collecting documentation unless the student reaches out to the school and indicates their circumstances have changed.

If a student pursues provisional independent student status and is not determined to be an independent student by a financial aid administrator, such student shall only be eligible for a Direct Unsubsidized Loan for that award year unless such student subsequently completes the FAFSA as a dependent student. See AskRegs Knowledgebase Q&A, If a Student's Parents Refuse To Provide Support, How Does the Student Complete the FAFSA To Borrow a Direct Unsubsidized Loan?

Documentation: Under HEA 479A(a)(2) [20 USC 1087TT(a)(2)], documentation must substantiate the special or unusual circumstances of an individual student and may include, but is not limited to:

For 2023-24 implementation, see AskRegs Q&A, What Are the Requirements For Implementing Provisional Independent Student Status For 2023-24?

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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