Special Circumstances

The Higher Education Act allows an FAA to make dependency overrides on a case-by-case basis for students with special circumstances. A student may indicate on FAFSA on the Web that he or she believes that he or she has a special circumstance. If the student indicates that he or she has a special circumstance, he or she may complete and submit the FAFSA without providing parental information. However, an Expected Family Contribution (EFC) will not be calculated for the student until an FAA approves the special circumstance and performs a dependency override. Without this approval, the student must provide parental information in order to generate an EFC.

In addition to documenting a dependency override decision in the student's file, an FAA must also report the override to the CPS using FAA Access to CPS Online.

Additionally, a student may indicate on FAFSA on the Web that he or she is an unaccompanied youth who is homeless or in danger of becoming homeless. If the student does not have and cannot get verification of his/her status as an unaccompanied homeless youth from a homeless youth liaison, Runaway and Homeless Youth Act (RHYA) provider, or U.S. Department of Housing and Urban Development (HUD) provider, an FAA must make a determination of the student’s status as an unaccompanied homeless youth.

A student is considered homeless if he or she lacks fixed, regular, and adequate housing. This includes students who are living in shelters, motels, cars, or parks, or who are temporarily living with other people because they have nowhere else to go. Students are also considered homeless if they are fleeing an abusive parent(s) who would otherwise provide the student with financial support and a place to live. Homeless youth determinations are made on a case-by-case basis.

Note: Although students whose parents refuse support are not eligible for a dependency override, the Higher Education Opportunity Act of 2008 (HEOA) granted that such students may receive unsubsidized Stafford loans only. For a student to be eligible for this provision you must get documentation (1) the parents refuse to provide information on the FAFSA and (2) that they do not and will not provide any financial support to the student. Include the date support ended. If the parents refuse to sign and date a statement to this effect, you must get documentation from a third party (the student himself is not sufficient), such as a teacher, counselor, cleric, or court. As noted above, this situation does not justify a dependency override.

However, as with overrides, making this determination is up to the discretion of the financial aid administrator. If you decide that a student falls into this category, you must document your decision and ensure that the student submits a FAFSA and passes all the eligibility matches. The result will be a rejected application with no EFC. You can then award the student unsubsidized Stafford loans up to the maximum the student would normally be eligible for depending on his/her grade level (but not the amount a student can get when his/her parent is unable to get a PLUS loan). See DCL GEN-08-12 for more information.

For more information, refer to the Knowledge Center FSA Partner Connect Web site at https://fsapartners.ed.gov/sites/default/files/attachments/2021-02/2122FSAHbkAVGCh5.pdf.

When a student indicates that he or she has a special circumstance, the Special Circumstances flag is set on the resulting ISIR.

The ISIR codes and their meanings are as follows:


Special Circumstances flag is not set


Dependent record submitted without parental data


Correction made to add parental data
Dependent record submitted without parental data by an unaccompanied homeless individual
Dependent record submitted without parental data for unsubsidized loan only

If an FAA sets the Dependency Override flag on a special circumstances transaction, the Special Circumstances flag on the resulting transaction is set to blank.

Related Topic:

Dependency Override

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