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Return to Professional Judgment |
Philosophical Basis of Need Analysis
It is important for financial aid administrators who perform
professional judgment adjustments to have a firm understanding of the
fundamentals of need analysis. It is not possible to make correct
professional judgment decisions without understanding how those
decisions will affect the family contribution and the extent to which
special circumstances are already considered in the design of the need
analysis formula.
The goal of need analysis is to estimate the family's ability to pay
for their children's education. The family's willingness to pay and
lifestyle choices are irrelevant. To estimate ability
to pay, the need analysis formulas assess a portion of
the parents' discretionary income and assets (referred to as available
income and discretionary net worth). Discretionary income is the
family's income after subtracting allowances for basic living
expenses, required expenses (state and federal taxes) and necessary
expenses for producing income (employment allowance).
The focus on the discretionary nature of the income and the
non-discretionary nature of the allowances is a key principle behind
evaluating whether a special circumstance merits a professional
judgment adjustment.
Family income is based on the income reported on the income tax
returns, after adding back in certain deductions that are
discretionary in nature. These deductions are added back in to total
income by including them on
Worksheets A and B. For example, the current year's deductions for
contributions to 401(k) and IRA retirement plans are counted as
untaxed income. So although money in retirement plans doesn't count as
an asset, the current year's contributions does count as income.
In addition, financial aid that was included in taxable income on the
income tax return, such as Federal Work Study earnings, is subtracted
from total income by including it on Worksheet C.
Student income and assets assumed to be primarily for paying for
college. This is why the need analysis formula assesses 20% of student
assets and 50% of student income.
The Expected Family Contribution is very heavily weighted toward
discretionary income. Parent assets are assessed at a relative low
rate (a maximum rate of 5.64% of net worth after excluding the
age-based asset protection allowance and money in retirement funds) in
order to encourage families to save. Instead, the formula emphasizes
the family's free cash flow.
Need analysis uses adjusted gross income as a departure point because
it is verifiable. Documentation of the family's financial
circumstances is an important aspect of need analysis
and professional judgment.
The Federal need analysis methodology is based on a "snapshot"
philosophy. The information used to calculate financial aid
eligibility should be accurate as of the application date. The
intention is to base estimates of the family's ability to pay on the
assets as of the application date and the income during the upcoming
award year (income during the academic year). However, since income
during the award year is not a priori verifiable, income during the
prior tax year is substituted as a proxy for award year income. This
can lead to an inaccurate estimate of the family's ability to pay if
the prior tax year income was atypical. Accordingly, financial aid
administrators can make adjustments to prior tax year income to
compensate for special circumstances such as one-time events, in
addition to special circumstances not considered by the boilerplate formula.
Because the formula focuses on a snapshot, the information on the
application form must be accurate as of the application date. If the
financial aid administrator discovers that any
of the submitted information was inaccurate as of the application
date, he or she can make a correction to that information. The financial aid
administrator may not, however, update the information
on the application form to reflect changes that occurred after
the application date, with a few notable exceptions. Those exceptions
relate to applications selected for verification. In particular,
changes in the
household size and number in
college can be updated when the application is selected for
verificiation (but only if the application is selected for
verification), if the change is due to something other
than a change in the applicant's marital status. The new information
should be accurate as of the verification date.
Professional judgment does allow a financial aid administrator to
adjust the information on the form, but only given the existence of
special circumstances. When there are no special circumstances, the
information may not be changed. A change in certain items, such as a
change in income due to job loss, is in and of itself
a special circumstance. A change in other items, such as the student's
marital status, does not on its own constitute a
special circumstance meriting an adjustment.
Thus there are three types of changes a financial aid administrator
may make to a student's application:
Nationwide, approximately 5% of Pell Grant recipients and about 1% of
undergraduate students received professional judgment adjustments.
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