Can a School Have a Deadline For Submitting and Reviewing Professional Judgment Requests?

No. Effective with the 2023-24 award year, Section 479A of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087TT] states that schools may not have a policy that denies all professional judgment (PJ) requests. According to guidance NASFAA has received from the U.S. Department of Education (ED), this extends to implementing deadlines after which an institution will not consider a PJ request. While schools are not required to approve all PJ requests, all requests must be reviewed. Therefore, school-imposed deadlines for students submitting professional judgment (PJ) requests are not permitted.

However, longstanding guidance requiring that a PJ be processed while the student is still enrolled remains in effect. See AskRegs Q&A, Can We Process a PJ Request After a Student is No Longer Enrolled For the Award Year/Academic Year?

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.