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Return to Professional Judgment |
Cash Support from the Student's Parents
Cash support from a dependent student's parents is not reported on
Worksheet B. See, for example, the Verification Guide and Section
480(b)(7) of the Higher Education Act. Cash support
from an independent student's parents is reported on Worksheet B. Cash
support from the non-custodial parent of a dependent student is
reported as child support received on Worksheet B, even if it isn't
mandated by a child support or college support
agreement. (Technically, a non-custodial parent is not considered a
parent for Federal need analysis purposes.)
A financial aid administrator may use professional judgment to include
in-kind support from an independent student's parents as untaxed
income on Worksheet B.
Financial aid administrators should use professional judgment to
exclude from Worksheet B amounts representing payments of child
support owed from previous years, as it is not reflective of child
support likely to be received during the award year. Financial aid
administrators may also want to make an adjustment for any child
support and college support payments that go beyond the non-custodial
parent's obligations. (Otherwise, the non-custodial parent should
delay his non-required support until after the child graduates
from college, and then provide it directly to the child to help her
pay back her student loans.)
Cash support includes money, gifts, loans, housing, food, clothing,
car payments or expenses, medical and dental care, and college costs
paid to or on behalf of the student. This includes not just money
provided to the student, but money provided to others in order to
satisfy obligations of the student. If the money is not provided to
the student or used to satisfy an obligation of the student, it counts
as in-kind support. For example, if the student is provided with free
rent, it counts as cash support if the student's name is included on
the lease and in-kind support if the student's name does not appear on
the lease. (Note that housing and other allowances received as
compensation for a job are listed elsewhere on worksheet B.)
The following types of support, in addition to in-kind support, are
not reported on Worksheet B: food stamps, dependent care assistance
excluded from gross income, per capita payments to Native Americans,
rent subsidies for low-income housing, cafeteria plans (flexible
spending arrangements), and LIHEA heating/fuel assistance.
The philosophical basis for the exclusion of support received from a
dependent student's parents from the "cash received" line is that the
parent income and assets are already assessed by the need analysis
methodology, and that "internal" transfers related to parental obligations for
their children (e.g., food, clothing, shelter, medical care,
education) are not counted as part of untaxed income to the child. For
an independent student, support from parents does count, as their
income and assets are not included in EFC. Similarly, if a parent
provides more than half support for a child from a previous marriage,
he counts that child in his household size even if that child doesn't
live with him. If the child is counted in his household size, he
doesn't report the amount of child support he pays for that child in
Worksheet C, as per an example from the Verification Guide.
Or to invert this example, cash support from a non-custodial parent is
counted on Worksheet B (albeit in the child support received line
instead of the cash support line) because the non-custodial parent's
income and assets are not assessed by the need analysis formula.
Part of the philosophical basis for excluding in-kind support is that
it does not represent cash that the family has available to redirect
to other purposes, and because it is hard to assign a value to in-kind
support. In-kind support is not a resource under the control of the family.
Money received from the non-custodial parent continues to be reported
on the child support received line of Worksheet B even if the child is
beyond the age for child support. Child support normally terminates
when the child reaches the age of majority (age 18 or age 21 in most
states). But non-custodial parents sometimes continue to provide
support for the child even after their obligation has terminated.
Cash support and in-kind support received by the student's parents are
not reported on Worksheet B. Section 480(b)(7) of the Higher Education
Act specifies that untaxed income and benefits includes "cash support
or any money paid on the student’s behalf, except, for dependent
students, funds provided by the student’s parents". There is no
similar language for money paid on behalf of the parents, which is why
Worksheet B has XXX's through the parent's column on the line for
"Cash received or money paid on your behalf". It is unclear why
Congress did not want the Federal need analysis methodology to
consider cash support received by the student's parents. (As a result,
a student's grandparents, other relatives and friends can give money
to the student's parents to help pay for the student's education
without affecting the student's eligibility for need-based financial aid.)
Cash support from an adopted student's birth parents does get included
on Worksheet B. The restriction against including support from a
dependent student's parents does not apply, since adoption terminates
the parental rights and obligations of the birth parents and the birth
parents are no longer considered parents for financial aid purposes.
It is inappropriate to increase a student's cost of attendance to
include child support payments made by the student or the student's
parents, as those payments are already considered on the FAFSA. When a
student or parent makes child support payments, either the supported
children are included in household size or the payments are included
in Worksheet C, depending on whether the child support payments
represent more than half the children's support or not.
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