Dependency Model Determination - Dependency Status
- Jennifer Flora Black
- Heather Smith
Overview
This page describes how Regent calculates dependency status (also called the "Dependency Model") for 2024-2025 and later FAYs. Regent's calculations mimic the dependency determinations from the FAFSA Processing Service (FPS) at the US Department of Education (ED). Dependency Status is a major input to the SAI - Student Aid Index Calculation.
Dependency Model Codes and Dependency Status:
D = Dependent
I = Independent
Z = Provisional Independent
X = Rejected Dependent (allows Unsubsidized Loans Only)
Y = Rejected Independent
Dependency Determination
Regent determines whether a student is Dependent (D), Independent (I), or Provisionally Independent (Z) for SAI calculation purposes. Regent can also apply the "X" (Unsubsidized Only) dependency status.
In summary, Regent:
Honors the Dependency Override indicator.
Regent always calculates SAI using the Independent formulas, if the student has a Dependent-to-Independent Override.
Evaluates responses to questions about the student's circumstances to determine whether the student should be Dependent or Independent.
Evaluates additional responses to additional questions to determine whether an otherwise dependent student may be considered as Provisionally Independent or marked for Unsubsidized Only.
Regent stores the Dependency Status in ISIR field #6, dependencyStatus. Note, the Dependency Status value is stored in dependencyStatusCode for some Regent Access exports. See Access - Export Files
Circumstance Question Types
Circumstances
The FAFSA has several sets of "Circumstances" questions and groupings with similar names.
Personal Circumstances: Dependency Question tests
Other Circumstances: Homelessness determination from a recognized authority
Unusual Circumstances: Student claims they cannot contact parents (unsafe); or student may be at risk of homelessness but an authority has not designated them as homeless.
Special Circumstances: Dependent student's parents are unwilling to provide information, but does not have Unusual Circumstances; used when student is applying for Unsubsidized loans only.
Dependency Override
ISIR field #282, Dependency Override Indicator (dependencyOverrideIndicator) values are:
1 = Dependent to Independent Override
If the Dependency Override Indicator has a value of 1, Regent will always consider the student as Independent for that FAY, regardless of the student's responses to the Dependency Questions.
2 = Override Canceled
3 = Failed Dependency Override
Blank = No FAA override
Personal Circumstances/Other Circumstances - Dependency Questions
If a student passes any of the Personal Circumstances tests, the student is considered to be Independent. For FAY 2024-2025 and later, students with "Other Circumstances" are also considered Independent students if a designated authority has formally determined the student is self-supporting or at risk of homelessness. Students may also be considered for Other Circumstances (i.e., homeless but not formally determined); or may have Unusual Circumstances (where it is unsafe to contact the parents). See separate sections below.
If a student does not meet any of the tests to be Independent or Provisional Independent, the student is considered Dependent (needing parent information).
From Appendix B: Dependency Status, 2025-2026 FAFSA Pell Eligibility and SAI Guide, August 13, 2024:
Dependency (independent or dependent) status determines which eligibility criteria is used to evaluate for Maximum or Minimum Pell Grant eligibility. It also drives which SAI formula to use
for a student applicant. Under HEA 480(d), a student is automatically determined to be independent for federal student aid purposes if he or she meets one or more of the following criteria:
Item# | FPS SAI Dependency Question | Regent Data Fields, Logic, and ISIR Field Numbers |
|---|---|---|
1 | For 2025-2026: The student was born before January 1, 2002. For 2024-2025: The student was born before January 1, 2001. | Regent tests whether the student was 23 years of age prior to January 1 of the ending calendar year for that FAY.
Test: ISIR field #29, studentsDateofBirth < January 1 of (calendar year 23 years ago)
Valid values: 19000101 to current date, Numeric within valid range. detailed explanation of format: Format is CCYYMMDD where:
|
2 | The student is married or remarried (but not separated or divorced) as of the date of the application. | Test: ISIR #40, studentsMaritalStatus = 2 or 3 Valid values:
|
3 | At the beginning of the [FAY] school year, the student will be enrolled in a master’s or doctoral degree program (e.g., MA, MBA, MD, JD, PhD, EdD, or graduate certificate). | Test: ISIR #41, gradeLevelInCollege = 4 Valid values:
|
4 | The student is currently serving on active duty in the U.S. Armed Forces or is a National Guard or Reserves enlistee called into federal active duty for purposes other than training. | Test: ISIR #44, areYouOnActiveDutyInUSArmedForces = 1 Valid values:
|
5 | The student is a veteran of the U.S. Armed Forces. | Test: ISIR #45, veteranofUSArmedForces = 1 Valid values:
|
6 | The student has or will have one or more children or other people who live with and receive more than half of their support from the student, now and through the last day of the award year. | Test: ISIR #46, haveChildrenYouSupport = 1 Valid values:
|
7 | At any time since the student turned age 13, both student’s parents were deceased, or the student was in foster care or was a dependent or ward of the court. | Test: ISIR #47 parentsDeceased = 1 OR #48 wardOfCourt = 1 OR #49 inFosterCare = 1 #47 parentsDeceased valid values:
#48 wardOfCourt valid values:
#49 inFosterCare valid values:
|
8 | As determined by a court in the student’s state of legal residence, the student is now, or was upon reaching the age of majority, an emancipated minor (that is, released from control by his or her parent or guardian) | Test: #50 asofTodayAnEmancipatedMinor = 1 Valid values:
|
9 | As determined by a court in the student’s state of legal residence, the student is now, or was upon reaching the age of majority, in legal guardianship. | Test: #51 asofTodayInLegalGuardianship = 1 Valid values:
|
10 | (None of these personal circumstances apply) | Test: #52 personalCircumstancesNoneOfTheAbove = 1 Valid values:
|
11 | Other Circumstances (Homelessness questions) |
|
11.1 | A student who is unaccompanied and self-supporting, or homeless or at risk of homelessness, may be determined to be an Independent or Provisional Independent. | Field #53: studentUnaccompaniedHomelessYouthUnaccompaniedAtRiskofHomelessnessAndSelfSupporting = 1
|
11.2 | On or after July 1 [of the preceding calendar year], the student was determined homeless or at risk of becoming homeless by one of the following: | Formal determination must be made on or after July 1 of the preceding calendar year. For example:
Field #53, studentUnaccompaniedHomelessYouthUnaccompaniedAtRiskofHomelessnessAndSelfSupporting
|
11a |
| #54 unaccompaniedAndHomelessGeneral
|
11b |
| #55 unaccompaniedAndHomelessHS
|
11c |
| #56 unaccompaniedAndHomelessTRIO
|
11d |
| #57 unaccompaniedAndHomelessFAA
|
11e | (Unaccompanied and Homeless: None of these other circumstances apply) | #58 otherCircumstancesNoneOfTheAbove
|
Unusual Circumstances
From Appendix B:
For students who do not meet any of the above criteria but who have documented unusual circumstances, an FAA can, by professional judgment and on a case-by-case basis, override their dependency status from dependent to independent. For information about dependency overrides, see the Application and Verification Guide, which is part of the Federal Student Aid Handbook and can be found on the Knowledge Center Web site. Additional guidance on the implementation of unusual circumstances under the FAFSA Simplification Act can be found in the Application and Verification Guide.
Regent users can set the Dependency Override indicator to mark Dependent students who should be treated as Independents.
Regent Access Applications do not automatically qualify a student for being an Independent for Unusual Circumstances. However, Access applications might meet the tests for Provisional Independent status (“Z” dependency code). A Regent user may evaluate the student's data and exercise Professional Judgment and determine whether to apply a Dependency Override.
Provisional Independent Students
Provisional Independent status (dependency status code of "Z") was introduced starting with FAY 2024-2025.
In Regent Access, a Provisional Independent student goes through the same workflow as an Independent. Regent applies the SAI calculations using only the student's information (the Independent workflow). The resulting SAI value is stored in a separate data field, provisionalSAI (ISIR field#19). The dependency status model has a value of "Z" for "Provisional Independent" and is stored in field #6, dependencyStatus.
From Appendix B:
Provisionally Independent Students
Applicants who indicate on the FAFSA form that they do not meet the above criteria to be considered an independent student but have an unusual circumstance, or who indicated that they are an unaccompanied homeless youth but do not have a determination from an authorized official, will be processed as provisionally independent. These students will receive a provisional SAI, which is calculated using the same formulas as a standard SAI but cannot be used to pay Federal student aid. Applicants who are provisionally independent will be directed to contact the financial aid office at their school for further guidance.
As a reminder, the HEA provides that unaccompanied homeless youth determinations are separate from professional judgments made under the unusual circumstances provision. These applicants are also not considered Provisionally Independent students, however, in the absence of a determination, an applicant who has indicated that they are an unaccompanied homeless youth will follow the same FAFSA flow as a Provisionally Independent student to allow them to complete a FAFSA form without parent information.
• If a FAFSA application is rejected, then no SAI will be calculated.
• If a provisionally independent student only has one FAFSA application rejected, then a provisional SAI will be calculated and returned on the ISIR. If, however, a provisionally independent student has a reject other than
REJECT 1, then a provisional SAI will not be calculated and returned on the ISIR.
Regent calculates a Provisional Independent "Z" dependency status if a Dependency Override is not already in place, and either of the following tests apply:
Student answered they were unaccompanied or at risk of homelessness, but was not determined to be such by the listed authorities:
#53, studentUnaccompaniedHomelessYouthUnaccompaniedAtRiskofHomelessnessAndSelfSupporting = 1 (Yes), AND
#58, otherCircumstancesNoneOfTheAbove = 1 (Yes)
OR
Student responded Yes that unusual circumstances prevent the student from contacting their parents, or contacting the parents would pose a risk to the student.#59, unusualCircumstance = 1 (Yes)
FAFSA Question 7, Student Unusual Circumstances (ISIR #59, unusualCircumstance)
Do unusual circumstances prevent the student from contacting their parents or would contacting their parents pose a risk to the student?
A student may be experiencing unusual circumstances if they:
• Left home due to an abusive or threatening environment;
• Are abandoned by or estranged from their parents;
• 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.If the student’s circumstances resulted in their not having a safe, stable place to live, they may be considered a homeless youth and should review the answer to question 6 about being unaccompanied and homeless.
Special Circumstances - Unsub Only
Some dependent students do not meet the tests for Independent or Provisional Independent, and may indicate their parents are unwilling to provide information. For these students, Regent calculates an "X" (Rejected Dependent) dependency status. In Regent Award, an "X" dependency status allows calculation and packaging of Unsubsidized loans only (when added manually by a user in Add Award Wizard). The Unsubsidized loans are packaged using the combined annual limits for Dependent students for the student’s grade level. The ISIR is ineligible for all other Title IV aid.
Regent Access applications that answer "Yes" to the Unsub Only question will go through the same workflow as Independent students (student-only questions and student signature only). However, Regent will not calculate any SAI value or Provisional SAI value for those students.
Data field: ISIR #60 unsubOnly = 1 (Yes)
FAFSA Question 8, Apply for a Direct Unsubsidized Loan Only (unsubOnly)
Are the student’s parents unwilling to provide their information, but the student doesn’t have an unusual circumstance, such as those listed in question 7, that prevents them from contacting the parents or obtaining their information? If the answer is “Yes,” a financial aid administrator at the student’s school will determine their eligibility for a Direct Unsubsidized Loan only. If the student is approved for this option, they will not qualify to receive other types of federal student loans (including Direct Subsidized Loans), federal grants, or Federal Work-Study programs.