Can We Have a Policy To Exclude Independent Siblings From Family Size?

Award Year: 2024-25 KA-36761 Helpfulness Rating 289 page views

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

The answer depends on whether you are awarding Title IV federal student aid or just institutional aid.

Title IV Federal Student Aid

No. You cannot have an institutional policy to automatically exclude an independent sibling from family size when calculating the student aid index (SAI) or awarding and disbursing any form of Title IV aid. 

Starting with the 2024-25 award year, family size is based on federal tax information (FTI) transferred directly from the IRS to the FAFSA via the FUTURE Act Direct Data Exchange (FA-DDX). This means the number of dependents in the family size is now based on the number of individuals who are claimed as dependents on either the applicant’s (if independent) or parent’s (if dependent) U.S. federal tax return. For more information about who can be claimed as a dependent on a federal tax return, see the IRS document Overview of the Rules for Claiming a Dependent.

If the FTI information pulled in has changed since the applicable tax return was filed, the FAFSA contributor has the opportunity to manually update family size if:

As a result of the definition of "dependent of the parent" in Section 480(j) of the Higher Education Act (HEA), as amended, [20 USC 1087vv(j)] it is possible for an applicant's sibling who is attending college to be considered independent for Title IV aid, but still be considered part of the dependent applicant's family size. For example, if the sibling is 24 or older, he or she would automatically be considered independent for Title IV purposes, but might still be considered dependent on the parent and included in the family size.

Professional Judgment (PJ): The only way you can exclude a legitimate family member is if you use PJ and you can document that there are exceptional circumstances that warrant removing that individual from the family size. All PJ decisions must be done on a case-by-case basis and fully documented in the student's file. Even using PJ, you cannot exclude all independent students from family size. on an across-the-board basis. And, just being an independent sibling in the family is not sufficient reason by itself to use PJ; there have to be other special circumstances to warrant a PJ decision.

For additional guidance see the Application Verification Guide volume, Chapter 2 of the FSA Handbook.

Institutional Aid Programs

Yes. You can have an institutional methodology (IM) policy to exclude an independent sibling from family size when calculating an institutional SAI or awarding and disbursing forms institutional aid. This is entirely up to the school and should be documented in its policies and procedures for awarding school funds. Such a policy cannot impact the Title IV aid eligibility.

2024-25 Award Year Note: Effective with the 2024-25 award year, number in college will still be collected on the FAFSA, but is is not a factor in federal need analysis for determining eligibility for Title IV federal student aid. Number in college can only be used in an institutional methodology for awarding institutional aid, or for state aid purposes.

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