Public higher education has long been unaffordable for many students, especially for Black and Latino students, who have substantially less wealth, on average, than their White peers. Unfortunately, the economic devastation caused by COVID-19 has only exacerbated these financial inequities for Black and Latino households, who have been hit hardest by unemployment and income loss amid the pandemic. The current economic downturn may not only impact how much Black and Latino families can pay for college, but how much aid they will be awarded for the upcoming year. That’s because, in the upcoming cycle, the Free Application for Federal Student Aid (FAFSA) will be based on their tax returns from 2019, i.e., two years prior, and institutions will use that information to calculate how much students can afford to pay out of pocket for college and how much to award them in aid.

This “prior-prior year” policy was put in place in 2016 to make it faster and easier to complete the FAFSA, so that more eligible students would receive financial aid and be able to attend college.

But while this policy lets students get an earlier start on the FAFSA, which usually would be a good thing, it also means that, in the case of students whose families have experienced a financial setback or job loss amid the pandemic, institutions could be using pre-COVID-19 income information that no longer reflects students’ financial reality.

One potential solution is for students to seek a professional judgment from the financial aid office, which can assign a financial aid officer to review their situation and decide whether adjustments to the FAFSA are warranted, so students can qualify for more aid. Unfortunately, many students — particularly Black and Latino students, who are more likely to be first in their families to attend college and may not have parents who know the ropes — are unaware that appealing for more aid is even an option. With these racial equity implications in mind, this brief analyzes the professional judgment process, its advantages and limitations, how financial aid officers can address racial justice, and provides recommendations on making professional judgment practices more equitable.

Download the full brief to learn more about:

  • Professional Judgment and Its Current Policies
  • The Power of Professional Judgment and Why Financial Aid Officers Need More Equity Training
  • Why Professional Judgments Have the Potential to Help Students, but Also Have Limitations, and
  • How Some Professional Judgments Are Tracked, and Why That Information Should Be Publicly Available

Recommendations for Using Professional Judgment to Advance Equity

How financial aid officers use professional judgment and their discretion could well determine whether underrepresented students of color and those from families with limited financial resources can access a higher education and go on to finish their degree, or become one of the estimated 36 million or more who drop out and miss out on the social mobility that a degree can offer. Institutions and policymakers should, therefore, do more to make these decisions transparent, and ensure that financial aid officers have the tools and the discretion to use professional judgment to advance equity rather than limit opportunity.

What Institutions and Practitioners Can Do

  • Collect data on professional judgment requests and decisions and disaggregate this data by race. Institutions should make this information available to practitioners and the public, regardless of whether the federal government requires them to do so.
  • Track and report the racial demographics of financial aid officers and make this data publicly available, since these administrators, like other key staff and faculty, have a direct impact on student opportunity and success.
  • Provide and mandate continuous education and training on racial justice and equity issues, so practitioners can be better attuned to the needs and experiences of students of color and students from low-income backgrounds and have the necessary training and tools to assist them.
  • Create student advisory groups that are representative of the student population, so administrators can collaborate with students, better understand their needs, and find more effective ways to communicate with them.
  • Consider an adjustment based on any income or job loss rather than requiring a minimum threshold for the loss of income (e.g., loss of income must be greater than 25%).
  • Explore transferring all or some of their Federal Work-Study allocation into emergency Federal Supplemental Educational Opportunity Grants, especially if the school is experiencing a decrease in on-campus employment due to majority online enrollment.

What Policymakers/Federal Government Can Do

  • Require institutions to collect and analyze data on professional judgment requests and decisions, disaggregate it by race, and make this information available to the public.
  • Collect and publish data on the racial demographics of financial aid officers.
  • Provide information, guidance, resources, and tools on implicit bias and racial justice, and require financial aid officers to meet continuous equity training benchmarks. NASFAA provides some resources and tools to financial aid officers, but ED should provide them as well.

The recommendations made here would help ensure that professional judgment is used in a way that advances equity and provides students with the resources they need to pay for college. There are some policies that could not only give students more seamless access to aid, but ensure that there is aid available for financial aid officers to distribute to those who need it most. States and institutions should prioritize need-based aid over so-called “merit” aid, which could reduce the likelihood of students having unmet need. And the federal government should:

  • Reduce the number of questions on the FAFSA
  • Remove the ban on Pell Grants for students who are incarcerated
  • Increase the Pell Grant by double or more
  • Make greater investments in historically underfunded institutions, such as community colleges, minority-serving institutions, and public regional colleges and universities that enroll larger proportions of students of color and students from low-income backgrounds, so these institutions have more aid to give


Throughout the creation of this brief, we had excellent contributions from experts and financial aid officers from the National Association of Student Financial Aid Administrators (NASFAA), who are dedicated advocates for public policies that increase student access and success. We would also like to thank the Seldin/Haring-Smith Foundation for funding this report and for their continued focus on racial justice and equity issues in higher education.