Fraud

Fraud and Abuse:

Conflicting information may cause the financial aid administrator to consider whether the student made an honest mistake or engaged in fraud. The difference is whether false information was provided with the intent to deceive.

According to the regulations, examples of fraud include:

• False claims of independent status
• False claims or citizenship
• Use of false identities
• Forgery of signatures of certifications
• False statements of income

• If the Financial Aid Administrator (FAA) suspects or can prove intent to de fraud the federal government, the information will be given to the Director of the school and he will assess the situation and make a professional judgment on whether the conflict can be resolved or if he needs to notify the Office of Inspector General (OIG).

Conflicting Information

Conflicting information is considered any information Merryfield Academy deem to be inconsistent or any information obtained or presented on behalf of a student that is different from information reported that impacts the calculation of the EFC, which also include verification. Conflicting information will be resolved whether or not a student was selected for verification and all information obtained regarding a circumstance will be utilized. This is to ensure that the student receives the correct amount of aid.

Conflicting information can be identified through the following means:

• Requested or unsolicited tax documents or schedules.
• Scholarship recipient lists
• Initial or subsequent Student Reports or Institutional Student Information Records
• C Flags or Comment Codes
• Or SAR or ISIR documents including subsequent ISIRs.
• Fafsa shows student as married, but 1040 reflects parent as single head of household.

Students are required to correct any inconsistent information on their SAR before aid can be awarded.

What is not considered conflicting information as per regulatory guidelines:

• Household size differs from number of exemptions on tax return
• Dependent under IRS rules versus ED definition of dependent
• Privacy protected information, such as information from professional counselors, chaplains, doctors, etc.
• Assumption made by the CPS
• FAFSA filed using estimated income
• Secondary confirmation match successful, but student has an expired residency document

Professional Judgment

Students and their families often experience unusual or special circumstances which can impact their ability to pay for college. The FAFSA does not always provide an option to capture such information. In this event, student or parents should contact the school’s financial aid office.

Professional judgment is a provision that allows a financial aid administrator to make an adjustment to cost of attendance or data elements on the FAFSA used to calculate EFC. Student will have to give a documented reason for adjustment and it will be placed in the student’s file. The financial aid administrators will always seek to obtain and maintain verifiable third-party documentation of changes in circumstances in order to support the decision to use professional judgment. The adjustment is only valid at the school making the adjustment and the decision of the financial aid administrator is final.

The use of professional judgment is on a case-by-case basis only and special circumstances are conditions that apply to an individual student and not a class of students.

The data elements that are adjusted must be related to the student’s special or unusual circumstances. Professional judgment cannot be used to avoid the general student eligibility requirements or to circumvent the intent of the law or regulation.

The law gives some examples of unusual or special circumstances of fraud:

• unusual child care cost
• unusually high medical expenses
• dislocated worker/recent unemployment of a family member
• change in family income/asset
• separation or divorce of student or parent(s)

The EFC resulting from the completion of professional judgment will be used for all federal student aid funds awarded.

Special Circumstances

Students will need to consult with Merryfield Academy Financial Aid Office if you feel you have any special circumstances (such as dependency status or loss of employment). But, remember, there has to be very good reasons for the financial aid office to make any adjustments, you must provide documentation to support those adjustments. Also, remember that the decision made by the Financial Aid Office is final and cannot be appealed to the U.S. Department of Education.

Dependency Override

Also, unusual or special circumstances may warrant a financial aid administrator to change the dependency status of a student, from dependent to independent, by way of a dependency override which is also done on a case-by-case basis only. Dependency override only applies to a change from dependent to independent. In this case, some examples that may be categorized as unusual or special circumstances include:

• Student’s voluntary or involuntary removal from parent’s home due to an abusive situation that threatened the student’s safety and or health.
• Incapacity of parent(s) such as incarceration, disability, mental or physical illness
• Inability of the student to locate the parent(s) after making reasonable efforts.

It is the responsibility of the student to provide substantial proof /written evidence that the situation exist and the financial aid office at Merryfield will carefully document its action. However, students must be aware that the school is not compelled to perform dependency override and that if a financial aid administrator determines that a dependency override is not appropriate, the decision is final.

Under no circumstances should the following reasons be used to exercise dependency override:

• Parent(s) refusal to contribute to student
• Parent(s) unwilling to provide information
• Parent(s) did not claim the student as an income tax dependent
• Student demonstrates total self-sufficiency