If you have not worked with this student, it would not be appropriate for the school district to provide a verification letter. However, the student can get verification from a TRIO or GEAR UP program, or a program or shelter that supports youth experiencing homelessness, if the student has been involved in such programs. Otherwise, the student would have to reach out to the financial aid administrator at the school they are applying to and ask for an unaccompanied youth determination from that office.
No. The student should not ask his mother to complete the FAFSA. He qualifies as an unaccompanied homeless youth and is independent for the FAFSA. If he cannot produce verification from a liaison or shelter, then the financial aid administrator (FAA) at his school MUST make the determination. A simple interview with the student is all the FAA needs to make the determination. This is all on page 121 of theApplication and Verification Guide.
Yes, the student can amend his FAFSA— and in fact, technically students are required to amend changes in their dependency status. There’s information on thishere. Reading your description of the student’s situation (no keys, “allowed/permitted” to stay, “for now”) it seems like the student’s situation is still unstable, and he remains at risk of homelessness, even though he is back home. He does not have to be unaccompanied and homeless now to qualify, since he was after July 1. But of course, the purpose of the policy is not for youth who leave home in a brief crisis and then return to a safe and stable home life. In this situation, it seems like he is a youth this law was designed to help.
The unaccompanied homeless youth status is not a professional judgement decision. Financial aid administrators are required to make a determination of UHY status based on the legal definition of homelessness. SeeDCL ID: GEN-15-16from the US Department of Education.
Also, per the 2018-19 FSA Handbook, page AVG-117, “If a student does not have and cannot get documentation from any of the authorities given on page 27, you (the financial aid administrator) must determine if she is an unaccompanied youth who is homeless or is self- supporting and at risk of being homeless.”
Compliance companies may not be aware of the specific provisions in the AVG that clearly state that 1) verification is not required; 2) FAAs must make determinations based on the legal definition of homelessness if youth don’t have documentation from an authorized party; 3) a documented interview suffices as documentation; and 4) a template exists for documenting interviews. In addition to informing compliance companies and institutions about these provisions andED’s DCL, it can be helpful to share the findings of the2016 GAO reportthat describes the barriers created by documentation requests. Another suggestion is to ask local homeless youth providers and/or local liaisons to meet with institutional leaders and financial aid directors, to explain the realities of youth homelessness and the ways in which financial aid practices unintentionally can retraumatize youth and stand in the way of their pursuit of higher education.
Per federal guidance, the determination process must focus only on whether a youth meets the legal definition of being unaccompanied and homeless, or at risk of being homelessness, rather than the reasons for the applicant’s homelessness.See DCL ID: GEN-15-16 from the US Department of Education. “FAAs should limit their inquiry to whether the applicant is an unaccompanied youth who is homeless, or at risk of being homeless, rather than the reasons for the applicant’s homelessness.” Commonly, youth homelessness situations are much more complex than they appear, or even than what students or families share. Students often do not want to share personal details of the situation, they may be trying to protect their parents or siblings, or they worry about stigma. This is why the law is clear that the focus is on the objective facts of the living situation and the legal definition of homelessness, rather than subjective and often incomplete understandings of the reasons behind the homelessness.
You are correct. Liaisons can provide unaccompanied homeless youth verification letters for students who have graduated if you are still in touch and still have knowledge of the information necessary to make the verification. However, you also are right that you should not write letters for former students if you are not in touch with them and aware of their current living situation. In that case, and assuming the youth is not connected to a HUD or RHYA program (as most are not), the financial aid administrator at the university has both the authority and the obligation to make the determination.
Here is a quote from the US Department of Education’s Application and Verification Guide for Financial Aid Administrators (page AVG-117):
“If a student does not have and cannot get documentation from any of the authorities given on page 27, you (the financial aid administrator) must determine if she is an unaccompanied youth who is homeless or is self-supporting and at risk of being homeless. It is important to make homeless youth determinations on a case-by-case basis.”
The AVG goes on to explain the process for FAAs to make the determination. You can access the AVGhere.
FAAs are not only authorized to make determinations of UHY status, but they are also required to do so if a student doesn’t have a determination from a party that is authorized by the HEA. A documented interview with the student can serve the purpose of documentation in these situations. You can utilize the NCHE FAA determination toolhere. So you should conduct an interview, make the UHY determination, and correct the FAFSA accordingly.
You can avoid re-traumatizing students by simply continuing their independent student status in the annual redetermination, unless you have specific information that would indicate the student is no longer unaccompanied and homeless or at risk of homelessness. You also can create a safe and comfortable environment for students. For example, some financial aid administrators host office hours with snacks for students to come in, or have counselors available to come with students for additional support. Focus solely on whether the student meets the definition of UHY, rather than asking prying questions about how or why the student is homeless. For more tips, seehere.
For students who are in college and experiencing homelessness, the financial aid administrator must make a determination of their status as an unaccompanied homeless youth.Here is a good toolthat NCHE made that financial aid administrators can use to make this determination. In addition, if the student is still in touch with a McKinney-Vento liaison or HUD or RHYA provider, those people can write letters for the youth, as long as they still have the necessary information to make a determination. The Application and Verification Guide (AVG) from the U.S. Department of Education notes, on pages 121-122, that FAAs should accept verifications from authorized parties, including liaisons. The AVG is availablehere.
If the student was never actually in foster care, she won’t qualify as independent for the FAFSA as a former foster youth. However, students who were in legal guardianship qualify as independent. Was the guardianship legal, with a court document to back it up?
If so, she should check yes to the legal guardianship question on the FAFSA. If not, she will have to talk to the financial aid office to request a dependency override. The financial aid administrator will make that decision. You could write a letter in support, describing what you know about the student. But it wouldn’t be a verification letter like you write for unaccompanied homeless youth. Given this situation, the financial aid office should grant the dependency override.
Yes, you are correct that the financial aid administrator (FAA) has to accept a liaison’sverification letter. The Application and Verification Guide (AVG) from the US Department of Education is very clear, on pages 121-122, that FAAs should accept verifications from authorized parties, including liaisons.
The AVG also states:
“It is not conflicting information if you disagree with an authority’s determination that a student is homeless.”
The AVG is availablehere.
You also should not share additional information about the student’s living situation with the admissions counselor, unless you have explicit permission from the student (if 18 or older) or the student’s parent. Information about a student’s homelessness is an educational record that is protected under the Family Educational Rights and Privacy Act (FERPA). While FERPA does allow you to share information in relation to financial aid, you should not share information that is not legally required for the student to receive the aid. You correctly provided and shared the FAFSA verification letter. Revealing additional personal information about the student’s situation would be a FERPA violation.
Yes, the student can update the FAFSA. This website has some great information, and it might be worth printing off this page and bringing it to the financial aid office, along with your unaccompanied youth verification letter:https://studentaid.ed.gov/sa/fafsa/next-steps/correct-update
The website indicates the following:
“There are certain items that you must update:
- You must update anything that changes yourdependency status(for instance, you are now pregnant or are now inlegal guardianship) except a change in your marital status.”
The UAY determination is a change in dependency status, from dependent to independent.
And:
“You can make changes in one of the following ways:
- Make changes atfafsa.gov:
- Select the “LOG IN” button and enter yourFSA ID.
- On the “My FAFSA” page, select “Make FAFSA Corrections.”
- Create a save key.
- Change your information.
- Submit your new information.
- Write in the corrections or updates on your paper SAR, sign it, and mail it to the address provided on the SAR.
- Check with the financial aid office at the school you plan to attend; the school might be able to make changes for you electronically.”
I would suggest the student change the information online and ALSO bring this webpage and your letter to the FAA to advocate for herself. It would also be helpful, if staffing permits, to have someone accompany her.
Yes. Technically, only HUD-funded and RHYA-funded shelters (and homeless liaisons) are authorized to verify homelessness for the FAFSA. However, other shelters and service providers can provide documentation to assist the Financial Aid Administrator to make the determination. Therefore, letters from such providers vouching for the youth’s homelessness are very important and helpful.
In terms of federal financial aid, there is no benefit or difference in the application for youth who are homeless with their families as compared to non-homeless youth with their families. Therefore, there would be no reason for those students to have a letter for federal financial aid. However, there may be other kinds of scholarships for which a letter like that could be very helpful. The letter could show the challenges the student has faced, it could explain any periods on the student’s transcript where grades suddenly dropped, etc. It even could be helpful with admissions. So it would be a good practice for counselors or teachers to write letters like that for all their McKinney-Vento students. It is not required.
If the student asks for copies of the FAFSA homeless verification letter, or asks a liaison/counselor to include a homeless verification letter in an application for college admission or scholarship, then it is fine for the liaison/counselor to provide it. While a student’s homelessness is an educational record subject to the privacy requirements in the Family Educational Rights and Privacy Act (FERPA), two FERPA exceptions apply. First, schools can release educational records to a postsecondary institution without consent where the student seeks or intends to enroll. Therefore, the school can share information about homelessness to be provided as part of a college entrance application. Second, schools can release educational records without consent for the purposes of financial aid. The definition of financial aid in FERPA goes beyond just the FAFSA, and includes any funds that are conditioned on a student attending any educational institution.
It always is a good practice to ensure the student wants this information shared. Usually, the student will be the one to request the homelessness verification for a college or scholarship. In that case, the school can provide the verification without parental consent.
Yes, the senior can amend her FAFSA. In fact, she must amend it. There’s some info here that explains the requirements and the process:https://studentaid.ed.gov/sa/fafsa/next-steps/correct-update. Changes in dependency status (such as becoming an unaccompanied homeless youth) are a required update. The student needs to go tofafsa.gov, log in, click on “Make FAFSA Corrections,” enter the FSA ID (username and password), and change and submit the information. This can be done on paper, too. Depending on how far along the student is in the process with her university, she also could contact the financial aid office there and ask for their help making the changes.
Also, make sure the student has the verification letter from you (regarding her status as unaccompanied and homeless), and that you also are ready to provide a copy if contacted. As you know, the process doesn’t go as smoothly for many unaccompanied youth, and things like changes in status sometimes even less so.
The student should indicate his status on the FAFSA as an unaccompanied homeless youth. If he completes the FAFSA online, there will be an option for him to indicate his homeless status, and to indicate that he doesnothave a determination from the liaison. It would look like the screenshot below:
The financial aid administrator at the schools to which he is applying will reach out to him. They may ask for some kind of other documentation of his status, so it would be good if he has any kind of note from other adults or professionals in his life who can attest to his situation. If he does not have documentation from a liaison or a shelter, then the financial aid administrator must make a determination based on the legal definition of homeless unaccompanied youth. The financial aid administrator can make a determination based on a documented interview with the student.
Yes, the determination supersedes the FAA’s disagreement. The U.S. Department of Education has made it very clear, in both the Application and Verification Guide and aDear Colleague letter, that it isnotconflicting information if a FAA disagrees with an authority’s determination. Therefore, that authority’s determination stands. “Conflicting information” would be very specific information indicating that a student isnotan unaccompanied homeless youth. You can hear more about the FAFSA and homelessness directly from U.S. Department of Education staff in thewebinarthey did with SchoolHouse Connection in June.
No. The student should insert all zeros for the parents’ Social Security numbers. More information on this topic is available athttps://studentaid.ed.gov/sa/sites/default/files/financial-aid-and-undocumented-students.pdf.
At this time, the student should use his legal name. The name on the FAFSA must match with the student’s Social Security number on record with the Social Security Administration.
The issue of tax claims is completely separate from the FAFSA independent student status. The FAFSA status is based on the student’s living situation. As long as the student is determined to be unaccompanied and homeless in the year in which he is submitting the application, he is considered an independent student for the FAFSA, regardless of whether someone else is fraudulently claiming him as a dependent on their taxes.
A parent or another person’s decision to claim a youth as a dependent on their taxes reflects on the parent or on the person making the claim; that person may be subject to penalties for unlawfully claiming a youth as a dependent. The key point is that the parent or other person’s actions should not subject the youth to penalties or make them ineligible for independent student status on the FAFSA, as long as the youth is abiding by the tax laws applicable to his own income and does not personally benefit from the parent or other person’s unlawful actions.
I know it is confusing because both the FAFSA and the IRS use the term “dependent,” but they are different matters.
Hereis the latest letter from the U.S. Department of Education on this. There is some new information on page 116 of the latest AVG that specifically allows liaisons to provide verifications for students after high school, if the liaison has the information necessary to verify the student’s status. “Also, local liaisons may write subsequent year letters of verification for unaccompanied homeless youth through age 23 for whom they have the necessary information to write such letters.”
https://ifap.ed.gov/fsahandbook/attachments/1718AVG.pdf
However, if the liaison does not have the necessary information, and the youth is not connected to a HUD or RHYA program (as most are not), the Financial Aid Administrator at the college/university has both the authority and the obligation to make the determination.
We have some information on this, as well as a sample verification form, on our website: https://schoolhouseconnection.org/key-issues/higher-education
Here is the latest letter from ED on this:https://ifap.ed.gov/dpcletters/attachments/GEN1516Attach.pdf
There is some new information on page 116 of the latest AVG about liaisons providing verifications for students after high school. That IS allowed, if the liaison has the information necessary to verify the student’s status. “Also, local liaisons may write subsequent year letters of verification for unaccompanied homeless youth through age 23 for whom they have the necessary information to write such letters.”
https://ifap.ed.gov/fsahandbook/attachments/1718AVG.pdf
However, if the liaison does not have the information, and the youth is not connected to a HUD or RHYA program (as most are not), the FAA at the university has both the authority and the obligation to make the determination.
We have some information on this, as well as a sample verification form, on our website:
Here is the latest letter from ED on this:https://ifap.ed.gov/dpcletters/attachments/GEN1516Attach.pdf
There is some new information on page 116 of the latest AVG about liaisons providing verifications for students after high school. That IS allowed, if the liaison has the information necessary to verify the student’s status. “Also, local liaisons may write subsequent year letters of verification for unaccompanied homeless youth through age 23 for whom they have the necessary information to write such letters.”
https://ifap.ed.gov/fsahandbook/attachments/1718AVG.pdf
However, if the liaison does not have the information, and the youth is not connected to a HUD or RHYA program (as most are not), the FAA at the university has both the authority and the obligation to make the determination.
We have some information on this, as well as a sample verification form, on our website:https://schoolhouseconnection.org/higher-education/
The issue of tax claims is completely separate from the FAFSA independent student status. The FAFSA status is based on the youth’s living situation. As long as the student is determined to be unaccompanied and homeless in the year in which he is submitting the application, he is considered an independent student for the FAFSA, regardless of whether or not he is fraudulently claimed by someone as a dependent on their taxes.
A parent or another person’s decision to claim a youth as a dependent on their taxes reflects on the parent or on the person making the claim; that person may be subject to penalties for unlawfully claiming a youth as a dependent. The key point is that the parent or other person’s actions should not subject the youth to penalties or make them ineligible for independent student status on the FAFSA, as long as the youth is abiding by the tax laws applicable to his own income and does not personally benefit from the parent or other person’s unlawful actions.
I know it is confusing because both the FAFSA and the IRS use the term “dependent,” but they are different matters.
She cannot complete the FAFSA as an unaccompanied homeless youth, because she would’ve had to have been in that status after July 1, 2017. However, she still qualifies as independent because of the guardianship. See:https://studentaid.ed.gov/sa/fafsa/filling-out/dependency. “Has it been determined by a court in your state of legal residence that you are anemancipated minoror that someone other than your parent or stepparent haslegal guardianshipof you? (You also should answer “Yes” if you are now an adult but were in legal guardianship or were an emancipated minor immediately before you reached the age of being an adult in your state. Answer “No” if the court papers say “custody” rather than “guardianship.”)”
She can check that box, and then fill out the FAFSA just like your unaccompanied youth— using only her information.
If the grandparent is not the legal guardian, then the student is neither independent nor should provide the grandparent’s information. The parents’ information would still be required. The way to navigate this situation is to seek a “dependency override” from the financial aid office of the school she wishes to attend. This involves explaining the situation and asking the financial aid administrator to make a discretionary determination of independence.
A good summary of independent students is available here:https://studentaid.ed.gov/sa/fafsa/filling-out/dependency#dependency-questions
Yes, the liaison definitely can document independent student status for the FAFSA, because this student is and has been an unaccompanied homeless youth. I would argue she is homeless now, since her housing with her father is not stable and likely will end at some time soon. But regardless, under the Higher Education Act, she only has to have experienced homelessness at some point in the year in which the application is submitted. She definitely meets that criterion, so the liaison can write the verification letter for her. If she needs a sample letter, she can downloadour template.
The U.S. Department of Education has changed their guidance to financial aid administrators (FAAs), and also to liaisons. ED now specifically says that liaisons may continue to submit letters of verification for unaccompanied homeless youth in subsequent years, up to age 23, as long as liaisons have the information that is necessary to make the determination of their homeless and unaccompanied status, or their status as at risk of homelessness, unaccompanied, and self-supporting.
Please see the sidebar on Application and Verification Guide (AVG)-118 for the instruction to FAAs (you can just search for “liaison”). Also, see pp. 48-49, Q-2, for the same information provided to liaisons.
I think you could let the school know about this new guidance, and then provide them with an updated letter (as long as you have the information needed to verify that she is homeless and unaccompanied, OR that she is at risk of homelessness, unaccompanied, and self-supporting).
If you don’t have the information to make the determination, the FAA must make the determination. They should not be sending students back to the high school. AVG-117 makes that really clear.
No. The federal guidance for financial aid, called the Application and Verification Guide (https://ifap.ed.gov/fsahandbook/attachments/1819FSAHbkAVG.pdf) states that the financial aid administrator must make the determination of unaccompanied homeless youth status if the student does not have a determination from another authority. (AVG-117). The financial aid administrator should not send a student back to you when that student graduated in 2015. It’s not reasonable to expect the school to have information about the student’s situation 3 years after graduation, or to require the student to return to her high school for this assistance. If you do have enough information to provide the student with the determination, you MAY do that. (AVG-118) But you are not required to do it. This really is the financial aid administrator’s role.
The short answer is that the college financial aid office is wrong. The federal guidance for financial aid, called the Application and Verification Guide (https://ifap.ed.gov/fsahandbook/attachments/1819FSAHbkAVG.pdf) states: “Unaccompanied homeless youth (56–58). A student is independent if at any time on or after July 1, 2017 (irrespective of whether he is currently homeless or at risk thereof) he is determined to be an unaccompanied youth who is homeless or is self-supporting and at risk of being homeless.” (Page 31 of the document, or page AVG-27). Neither the student’s current status nor his intermittent stays with his mother matter – the student simply needs to have been determined to be an unaccompanied homeless youth after July 1. Elsewhere in this document, on pp. 121-122, or AVG-117-118, the guidance makes clear that financial aid administrators must use the McKinney-Vento definition, and must accept determinations from liaisons.
Yes. Any institution that offers federal financial aid has to follow the same FAFSA rules. So they have to accept a liaison’s verification of unaccompanied youth status and treat the student as independent for the FAFSA.
No. Here is a quote from the current Application and Verification Guide, which is the Dept. of Education guidance that financial aid administrators must follow: “You are not required to confirm the answers to the homeless youth questions unless you have conflicting information. A documented phone call with, or a written statement from, one of the relevant authorities is sufficient verification when needed… It is not conflicting information if you disagree with an authority’s determination that a student is homeless.” This information is found on the very last page of this document:https://ifap.ed.gov/fsahandbook/attachments/1819FSAHbkAVG.pdf. Since the liaison has provided appropriate verification of the student’s situation, the financial aid office should not request any additional information regarding his independent student status. Certainly, the office should not request anything that requires a parent’s signature, since the very nature of being an unaccompanied homeless youth means the youth does not have support from parents or access to parental information or signatures.
