Requesting a Dependency Override
Students who cannot answer "yes" to any of the dependency questions on the FAFSA can submit an appeal to Student Financial Services requesting that they be declared independent. If granted, eligibility for federal aid is then based solely on the student's income.
To have an appeal approved, there must be unusual circumstances which prevent the student from providing parental information on the FAFSA. To have the independent status carried forward into subsequent academic years, the student must submit a letter requesting that it be renewed.
Appeals granted to students by other colleges do not apply to UM. The student must go through UM's appeal process to be granted independence at UM.
Unusual Circumstances
The FAFSA Simplification Act provides a clearer directive for financial aid administrators to assist students with unusual circumstances to adjust dependency status on the FAFSA form to reflect their situations more accurately (dependency overrides).
Under HEA Sec. 480(d)(9), the FAFSA Simplification Act incorporated additional unusual circumstances to consider when a student is unable to contact a parent or where contact with parents poses a risk to such student.
Unusual circumstances may include:
- Human trafficking, as described in the Trafficking Victims Protection Act of 2000 (22 U.S.C. 7101 et seq.);
- Legally granted refugee or asylum status;
- Parental abandonment or estrangement;
- Parental abuse or neglect;
- Student or parental incarceration.
In such cases a dependency override might be warranted based upon the student’s individual circumstances.
Unusual circumstances do not include:
- Parents refuse to contribute to the student’s education.
- Parents will not provide information for the FAFSA or verification.
- Parents do not claim the student as a dependent for income tax purposes.
- Student demonstrates total self-sufficiency.
Dependency Override Procedures
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Dependency overrides can only be granted if an unusual circumstance exists.
In reviewing appeals, the committee is looking for evidence that it is not reasonable to expect the student to seek out information from their parents because it would be unsafe, unhealthy or the parents are inaccessible.
Examples of extenuating circumstances include, but are not limited to:
- Physical or sexual abuse
- Abandonment by both parents
- History of neglect due to parental alcohol or drug abuse
- Incarceration of the custodial parent
- Other circumstances which prevent the student from having contact with the parents
A parent's refusal to provide information on the FAFSA or the fact that a student is self-supporting are not reasons for which a dependency override can be granted.
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A student will start by starting the FAFSA online. The absence of parental information will result in an incomplete FAFSA, pending the approval of the dependency override.
The student then needs to submit the Special Circumstance Request for Independent Status form to Student Financial Services. Along with the form, they will need to submit a letter detailing the extenuating circumstance that prevents them from providing parental data. They will also need to submit letters from two third-party, objective adults who can confirm the student's situation. Objective adults can include but are not limited to teachers, counselors, pastors, adult relatives or the parents of friends. The letters provided must address the relationship with both parents, even if the student has not had an ongoing relationship with both parents.
A committee in Student Financial Services will then review the documentation provided and make a decision as to whether the appeal will be granted.
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If a dependency override is approved the independent status will roll forward for subsequent years.
Students still must complete their FAFSA annually and will receive a incomplete notification from the U.S. Department of Education, however, once UM receives the FAFSA we will use it to review aid eligibility for the new year.
An additional appeal may be required if the student informs us their circumstances have changed or we receive conflicting information.
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If a student is denied the appeal, they will receive a Parent Refusal to Complete FAFSA Affidavit form. If they want to receive aid for the academic year, they can update their FAFSA with parental information.
Students submitting the affidavit are limited to receiving only the Federal Direct Unsubsidized Loan at the amounts for which dependent students are eligible.