OGSLP Online News

March 5, 2009

Focus on HEOA: Unsubsidized Stafford Loans for Dependent Students

Over the past several months, OGSLP’s Online News highlighted various provisions contained in the Higher Education Opportunity Act (HEOA). This month, we’re focusing on the provision that relates to unsubsidized Stafford loans for dependent students.

HEOA permits a school to offer an unsubsidized Stafford loan to a dependent student without parental completion of the Free Application for Federal Student Aid (FAFSA) if the school verifies that the student’s parent(s) does not provide financial support and refuses to file the FAFSA. Providing financial support includes not only payment by the parent(s) of educational costs, but also providing other cash and non-cash support to the student such as room and/or board.

Dear Colleague Letter (DCL) GEN-08-12/FP-08-10 (pages 79-82) clarifies this new authority given to financial aid administrators. This provision is effective beginning with a loan for any period that includes or begins on or after Aug. 14, 2008. Additional information for implementation of this provision is summarized below.


The student must complete and submit a FAFSA that includes all of the required student information and certifications.

Verification and Documentation

The financial aid administrator must verify that the parent(s) does not provide financial support for the student and refuses to complete the parental sections of the FAFSA.

Award Amount

The maximum annual unsubsidized loan amount a dependent student may receive is the “base” annual loan limit for the student’s grade level plus the supplemental unsubsidized amount of $2,000 added to annual loan limits for dependent students by the Ensuring Continued Access to Student Loans Act (ECASLA). As outlined in ECASLA, the student does not receive the additional unsubsidized Stafford loan amounts that are available to independent undergraduate students and dependent students whose parents are willing but unable to borrow under the PLUS loan program.


If the financial aid administrator decides not to award the student the unsubsidized Stafford loan, the student must provide a correction to the FAFSA record by submitting the required parental information and signatures before any Title IV aid can be awarded. The financial aid administrator’s decision is final; students can’t appeal to ED.

For more information about the HEOA provisions related to dependency status, contact OGSLP’s Policy, Compliance, and Training department at 405.234.4432 or pct@ogslp.org. We’re here to help!