Need Analysis & Professional Judgment

Need Analysis & Professional Judgment

Understanding the EFC

New Aid Officer Workshop 2013

Angelika WilliamsAssistant Director of Financial Aid

and Scholarships

Texas State University

What you will learn• Definition of Need Analysis• Factors that make up the EFC calculation

and why they are important• The various federal formulas• Types of professional judgment decisions

and how they are related to the EFC and Need Analysis

• What is Professional Judgment• Types of PJ

What is Need Analysis?• Definition: The process of

determining the student's Expected Family Contribution (EFC) based on the formula established by Congress. Also known as Federal Need Analysis Methodology and Federal Methodology, or FM.

Guiding Principles• Primary responsibility to pay for

education rests with the student and parents/family

• Family is expected to contribute to the extent it is able

• Families must be evaluated in an equitable manner

Expected Family Contribution

• Definition: Measure of how much the student and his or her family can be expected to contribute to the cost of the student’s education for the year.

• The EFC is calculated according to a formula specified in the law.

What Comprises the EFC?Basic EFC Formulas• Dependent • Independent w/no dependent(s)• Independent with dependent(s)

Factors of EFC Calculations • AGI• Eligible to file a 1040A or EZ• Federal Means Test• Dislocated Worker

Total Income• AGI• Wages Earned• Untaxed Income• Additional Financial Information

Income Protection:• Taxes Paid• Household Size• Number in college• State and other Tax

allowance

Protection of Assets• Age of Student (if

independent)• Age of Older Parent

What’s so important about the EFC?

EFC is Needed to Calculate Need

Cost of Attendance(minus)EFC

Need

• The EFC determines:– Pell eligibility– Room for need versus non-need-based

aid

Basic EFC Formulas• Formula A– For dependent students

• Formula B– For independent students without

dependents (other than a spouse)• Formula C– For independent students with

dependents other than a spouseFor 13-14 EFC worksheets, go to IFAP: http://ifap.ed.gov/fsahandbook/attachments/1314AVGCh3.pdf

EFC Calculations• There are 3 special EFC Calculations–Regular Formula: Takes BOTH

income & assets into account– Simplified Needs Test (SNT):Takes

only income into account–Auto-Zero EFC: Student’s EFC is

automatically zero

Simplified Needs Test• How does a student qualify for SNT?– Must have income (AGI/wages) of $49,999

or lessAND– Be eligible to file a 1040A or 1040EZOR– Qualify for a federal means test benefit

programOR– Be a dislocated worker

Auto-Zero EFC• How does a student qualify for Auto-Zero?–Must have income (AGI/wages) of $24,000 or

lessAND– Be eligible to file a 1040A or 1040EZOR– Qualify for a federal means test benefitOR– Be a dislocated worker

Only dependent students or independent students with dependents other than a spouse qualify for an auto-zero EFC.

Federal Means Test Benefits

• So exactly what is a federal means test benefit program?

• Supplemental Security Income (SSI)• Temporary Assistance for Needy Families

(TANF)• Special Supplemental Nutritional Program

for Women, Infants & Children (WIC)• Food Stamps/SNAP• Free Reduced-Priced School Lunches

What is a Dislocated Worker?• Was terminated or laid off from employment or received a notice of

termination or layoff;• Is unlikely to return to a previous occupation; and • Is eligible for or has exhausted unemployment compensation, or is not

eligible for compensation because, even though employed long enough to demonstrate attachment to the workforce, he or she had insufficient earnings or performed services for an employer that weren’t covered under a state’s unemployment compensation law; or

• Was terminated or laid off from employment or received a notice of termination or layoff as a result of any permanent closure of, or any substantial layoff at, a plant, facility, or enterprise;

• Is employed at a facility at which the employer made a general announcement that it will close;

• Was self-employed but is now unemployed due to economic conditions or natural disaster; or

• Is a displaced homemaker

1040, 1040A or 1040EZ?• Required to file a long form (1040) if

• Wages are $100k or more(line 7)• Alimony received (line 11)• Business or Farm (line 12 & 18)• Capital gain or loss (line 13 if schedule D is

required)• Rental property (line 17)• Itemized deductions (line 40)• Health Savings account deduction (line 25)

• Eligible to file a 1040A or EZ– If there are capital gains/losses but a Schedule

D isn’t required, then a 1040A is fine

Apply your knowledge!Which EFC Calculation?

Income Protection Allowance• FM automatically protects a set amount of

income varied by household size and number in college (called IPA)– Food 30%– Housing 22%– Transportation 9%– Clothing/Personal Care 16%– Medical 11%– Other consumption 12%

• US Taxes Paid– Also considers state & other taxes

IPA Worksheets

This example is from Worksheet A (dependent students)

Asset Protection Allowance• Asset Protection: Dept of Ed

automatically protects a set amount of assets based on the age of independent students or parents of dependent students– The older the student or parent, the

greater the amount of assets protected – due to anticipated retirement

Asset Protection Table

This example is from Worksheet A (dependent students)

Apply your knowledge!Matching Exercise of EFC Terms

Final Thoughts on Need Analysis

• A myriad of elements go into the EFC!– You can’t “guesstimate” what

someone’s EFC would be just by asking income information

• Having a strong foundation of how the EFC works will help you know if a professional judgment (coming next) will help a student

Professional JudgmentIt’s Your Decision!

What is Professional Judgment?

Section 479A in the HEA authorizes us to use PJ

Examples of PJ Situations• Adjusting Cost of Attendance components• Adjusting data elements used to calculate

EFC– Direct changes to EFC is not permitted

• Performing a Dependency Override• Establishing eligibility for a dependent

student to receive Unsubsidized Stafford if parent refuses to complete FAFSA and support student

Elements that CAN be Adjusted

• AGI• Wages Earned• Taxes Paid• Number in Household• Number in College• Additional Financial Information• Untaxed Income• Asset information • Dislocated Worker Status• Federal Benefit Programs (i.e.- SNAP, WIC, TANF, etc.)• Dependency Status

– Only for dependent to independent

First Rule of PJ is…• DOCUMENT!– Keep in mind that all special circumstances

must be verified first to ensure you start with accurate data

• Types of documents you may wish to collect– Tax returns– W2s– Last pay stubs– 3rd party documents– Legal documents– Letter from employers

Loss of Income and/or Additional Expenses

Types of Income Losses– Losses of Income– Unemployment or

income reduction– Death of parent/spouse– Divorce of

parent/student– Loss of child support– One-time lump sum

payout

• See GEN-09-04

• Additional Expenses– Extended family support

• Such as nursing home expenses

– Unusual medical/dental expenses that exceed 11% of the IPA

– Unusual non-discretionary debt that exceeds 12% of the IPA

– Private school costs for children in elementary or high school

How could some of these factors affect a student’s EFC?

Medical Expenses Example• Hands on example:• Let’s say you have a dependent student whose

parents experienced an annual medical expense totaling $5,000. The student has 4 in the household and 1 in college. How would you calculate how much of the $5,000 exceeds the 11% of the IPA?

Dependency Overrides & Unsubsidized Stafford

Eligibility

Authority given for dependency overrides HEA Section 480(d)

Dependency Overrides• Any student who answers “No” to all the

dependency questions is dependent even if student is self-supporting– Students who have extenuating circumstances

can request an FAA to consider a dependency override

– Requires documentation to the validity of the extenuating circumstances• Personal statement• Letters from professionals• Remember: DOCUMENT, DOCUMENT, DOCUMENT!

Per CCRAA, Schools have the authority to accept the dependency override that was performed and approved by another school without additional documentation.

Dependency Overrides• Factors to consider– Abandonment by parents– Unable to locate a parent after

reasonable attempts– Situations of abuse

Dependency OverridesNone of the following examples merit a

dependency override:1. Parents refuse to contribute to the

student's education 2. Parents are unwilling to provide

information on the FAFSA or for verification

3. Parents do not claim student as a dependent for income tax purposes

4. Student demonstrates total self-sufficiency

You be the Judge…• Laura is a first-time freshman living with her

grandparents. She is not under legal guardianship, but she has been living with her grandparents since she was 5 when her father left the country. Her mother died when she was 2. She has had no contact with her father since she was 5 and neither has her grandparents, although he sent a check out of the blue when she turned 18 for $5,000.

• Would you consider Laura independent?– Why or why not?

Unsubsidized Stafford Eligibility

• FAAs may use professional judgment to determine if a dependent student may be offered unsubsidized Stafford loans without parental data on the FAFSA

• To do this, FAAs must verify:– Parent no longer provides financial support– Parent refuses to file the FAFSA– FAA must collect a signed statement from the

parent affirming the above while also certifying that they will not provide support in the future (Include the date support ended.)

Cost of Attendance Adjustments

Budgets, budgets, budgets!

Standard COA Components1. Tuition & Fees 2. Books & Supplies3. Room & Board4. Transportation5. Personal Expenses

Types of Adjustments to Consider

• Additional mortgage/rent charges• Unusual car repair or transportation

costs• Dependent care costs• Computer/Laptop expenses• Unusual medical/dental expenses not

covered by insurance

What you CANNOT do in a PJ

• A PJ is award year specific and cannot carry forward from year to year unless subsequent request & documentation are received

• You cannot directly change an EFC• You cannot make changes to the EFC formula• You may not establish automatic categories of special

circumstances. All PJ must be conducted on a case by case basis.

• PJ cannot be used to circumvent the law• PJ cannot be used to waive student eligibility

requirements• PJ cannot make an Independent student dependent

Test your knowledge!Match that PJ!

Case Study

Wrapping Up• Understanding the complexity of the

EFC makes you an effective FAA!• You have the authority to use

professional judgment so use it (with proper documentation)

Resources• 2013-2014 EFC Formula Guide

http://ifap.ed.gov/ifap/byAwardYear.jsp?type=efcformulaguide

• 2013-2014 FSA Handbook, Application Verification Guide, Chapter 5, Special Cases

• DCL: GEN-09-04, GEN-09-05, GEN-11-04, GEN-11-15

• NASFAA 2010: Electronic Handout: Special Populations: Tips for Completing the FAFSA

• NASFAA 2009: Q&A from Dependency Status: It’s not the Riddle of the Sphinx Webinar

Comments/Questions?