Special and Unusual Circumstances

Special and Unusual Circumstances

The Department of Education allows colleges to consider Special Circumstances and Unusual Circumstances experienced by students. Special Circumstances refer to differences or changes in financial situations that may warrant special consideration. Unusual Circumstances refer to potential adjustments to a student’s dependency status based on a unique situation, such as parental abandonment, incarceration, refugee or asylee status, or victims of human trafficking.

Unusual Circumstances

The FAFSA process defines dependence differently than the IRS, so it is possible that a person’s understanding of what it means to be independent will be different from the classification required by the FAFSA process. Kirkwood is not permitted to determine that a student is independent if the only circumstance reported is one of the following:

• Parent(s) refuse to contribute to the student’s education;
• Parent(s) did not claim the student on their taxes;
• Parent(s) are unwilling to be a contributor in the FAFSA process;
• Student demonstrates total financial self-sufficiency.

The FAFSA form identifies circumstances in which an appeal for Unusual Circumstances may be considered. A student by be experiencing Unusual Circumstances if they:

• Left home due to an abusive or threatening environment;
• Are abandoned by or estranged from their parents, and have not been adopted;
• Have refugee or asylee status and are separated from their parents, or their parents are displaced in a foreign country;
• Are a victim of human trafficking;
• Are incarcerated, or their parents are incarcerated, and contact with the parents would pose a risk to the student; or
• Are otherwise unable to contact or locate their parents, and have not been adopted.
• Became married since filing the FAFSA.

If you feel these or similar circumstances apply, you are invited to submit an appeal for Unusual Circumstances, which you may also see or hear referenced as a Dependency Override. The appeal will require a narrative to explain your circumstances, and an upload of documentation will be required. Some examples of documentation that would typically be uploaded for an Unusual Circumstances appeal include:

• Official federal or state documentation that the student’s parents or legal guardians are incarcerated;
• A written statement from:
  • an attorney; a guardian ad litem; a court-appointed special advocate (or similar); a representative of a TRIO or GEAR UP program that confirms the circumstances and the person’s relationship to the student; a state, county or tribal welfare agency; an independent living caseworker who supports current and former foster youth with the transition to adulthood; a public or private agency, facility or program servicing victims of abuse, neglect, assault or violence; a close adult family member, such as aunt, uncle, or grandparent, who has witnessed some of these circumstances and can attest to the ongoing issues
• For marriage,
  • A copy of the marriage certificate: a lease/rent agreement or mortgage statement in the student’s name to demonstrate that they are living independently of parents; copies of the most recent 1040 tax returns, including all relevant schedules, for both parties.

If such documentation is not available, please upload a document explaining why you do not have documentation. Regardless of the narrative and documentation provided, some follow-up may be required in order to determine whether a Dependency Override is appropriate for your unique circumstances. If you have questions before you get started, please reach out to your Financial Aid Advisor. If you are ready to request an appeal, you can do so here. Once an appeal has been completed, students can typically expect a response within 5-10 business days.

Special Circumstances

Sometimes, a student has unusual expenses or a change in income that impacts their ability to pay for school. Depending on the circumstances, an increase to the estimated Cost of Attendance (COA) or an adjustment to the Student Aid Index (SAI; formerly Expected Family Contribution or EFC) may be appropriate. If you feel these circumstances, described below, or similar circumstances apply, you are invited to submit an appeal for Special Circumstances.

SAI Adjustments

An SAI adjustment has the potential to increase eligibility for more beneficial types of aid, such as grants, federal work-study, and subsidized loans. These appeals are typically considered if there is a change in income and/or resources from the tax year reported on the FAFSA and now. This could be due to a job loss or other changes to employment and/or resources. In the narrative of this Special Circumstances appeal, you would tell us what changed and provide a timeline. You will need to account for the income of everyone whose income is required to be on your FAFSA. You would also describe the documentation that you will be including. Required documentation may be different depending on your circumstances, but some examples are:

• Newer 1040 tax returns and any applicable schedules
• Most-recent, current-year pay stubs
  • Must show year-to-date earnings;
  • If it is early in the calendar year, we may request to wait and resubmit pay stubs at a later date in order to more accurately and fairly project current-year income.
• Proof of job loss
  • Termination or separation letter;
  • Severance pay
  • Proof of unemployment benefits.
• Exceptional medical expenses
  • Proof of out-of-pocket payment towards medical expenses that exceeds the standard IRS deduction for medical expenses;
  • Note that it is the out-of-pocket paid amount, not the incurred or billed amount that is considered in this calculation.

If you have any questions about this, please reach out to your Financial Aid Advisor. If you are ready to request this type of appeal, you may do so here. Some follow-up may be required in order to determine whether an Unusual Circumstances appeal is appropriate for your situation. Once an appeal has been completed, students can typically expect a response within 5-10 business days.

COA Adjustments

While a COA adjustment cannot increase eligibility for grants, it can create room within a financial aid package that might not have otherwise been there for access to grants, federal work-study, and loans. COA adjustments are used to account for expenses that are above and beyond the Cost of Attendance estimates (link to COA page). Colleges’ authority to deviate from the established COA estimates is limited in some cases. Please review the types of adjustments we typically make and determine whether you feel your circumstances apply before submitting this type of appeal.

• Transportation
  • What can be considered?
    • The cost or efficiency of your vehicle is not considered;
    • If you drive an exceptional distance to and from class/clinical, you may be eligible;
    • If you drive an exceptional distance to and from work, you may be eligible.
  • What do I need?
    • Confirm your home address;
    • Confirm that your posted class schedule is correct;
    • For clinical, let us know your clinical location and schedule;
    • For work, let us know where you work and your work schedule;
    • For work, upload a pay stub showing the address of where you work; you may redact or crop out financials if you would like.
• Childcare
  • What can be considered?
    • Reasonable cost of child care on a per-child basis;
    • Typically, this will be limited by the average cost in Iowa for licensed child care programs, pro-rated to account only for the time spent in class time, a reasonable amount of study time, field work, internships, and commuting time;
    • Paying for daycare for children with additional needs that require more costly support can potentially give reason to exceed the established limit that is based on average costs.
  • What do I need?
    • Tell us the number of children you have and their age;
    • If any children have additional needs that require more costly support, please disclose relevant information;
    • Tell us if you have any internships or field work that occur outside of the regularly scheduled coursework;
    • Provide us with a billing statement that shows the cost of your childcare.
• Housing
  • What can be considered?
    • Typically, housing costs that exceed the estimate will only be considered if other circumstances exist that require a student to live in more costly housing.
    • Note that having a larger family or additional dependents is already included in the SAI calculation and therefore, by itself, cannot be considered for a COA adjustment
    • Choosing to live in a more costly area, by itself, is not a reason for a COA adjustment
  • What do I need?
    • Explain and document your special circumstance that requires greater-than-estimated housing costs;
    • Signed, dated rent/lease agreement or mortgage statement in your name;
    • A monthly bill for any utility not already included in your lease, rent, or mortgage, including: Gas; Electric; Trash; Water; Sewer; Internet.
• Personal computer or laptop for school work
  • What can be considered?
    • Personal computers or laptops purchased from the bookstore with bookstore funds are already accounted for in your COA;
    • If you purchased a laptop or personal computer for schoolwork without using bookstore funds, that cost can be added within reason.
  • What do I need?
    • Provide a dated receipt to show purchase of the computer;
    • If your program required you to purchase a computer that cost more than an average computer, please explain those requirements.

Please understand that some expenses, such as the cost of caring for dependents, is already considered in your SAI (formerly, EFC), so we are not permitted to consider those general costs here. If you have any questions about this, please reach out to your Financial Aid Advisor. If you are ready to request this type of appeal, you may do so here (The Request process for 2024-25 will be coming soon). Some follow-up may be required in order to determine whether an Unusual Circumstances appeal is appropriate for your situation. Once an appeal has been completed, students can typically expect a response within 5-10 business days.