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Special Cases | 2025-2026 Federal Student Aid Handbook
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This is not an exhaustive list. You may use your discretion to make appropriate, reasonable adjustments to reflect a student’s situation more accurately. You may also use your discretion to deny a student’s request for adjustment. However, you may not maintain a policy to deny all requests for special circumstance adjustments. Your institution must develop policies and a process for reviewing requests for professional judgment. Additionally, your institution must publicly disclose that students may request an adjustment based on special circumstances. This could include (but is not limited to) posting what may be considered a special circumstance on your website, including such information in communications to students, or adding language on award notifications. “The reason for your decision to approve or deny a request for professional judgment and any subsequent adjustments must be documented.” The law doesn’t allow you to modify either the formula or the tables used in the SAI calculation; you can only change the cost of attendance components, or the values of specific data elements used in the SAI calculation. In addition, you cannot adjust data elements or the cost of attendance solely because you believe the tables and formula are not adequate or appropriate. The data elements that are adjusted must relate to the student’s special circumstances. For example, if a family member is ill, you might modify the AGI to allow for lower earnings in the coming year or might adjust assets to indicate that family savings will be spent on medical expenses.
Financial aid administrators do not need to be tax experts, but there are some issues that even a layperson with basic tax law information can evaluate. Because conflicting data often involve such information, FAAs must have a fundamental understanding of relevant tax issues that can impact the need analysis. You are obligated to know (1) whether a person was required to file a tax return and (2) what the correct filing status for a person should be. The IRS’s online Interactive Tax Assistant can help with these and other issues by walking the user through a series of questions. IRS Publication 17 is also a useful resource. “You have resolved the matter when you have determined which data are correct; this might simply be confirming that an earlier determination was the right one.” The verification page on the FSA Assessments site has guidance to help you review your conflicting information procedures; see Activity 1.