Reminder – Unaccompanied Homeless Youth Determinations (2024)

Section 480(d)(8) of the Higher Education Act of 1965, as amended (HEA), provides that an applicant for Title IV federal student aid is an independent student—that is, an applicant who does not need to provide parental information on the Free Application for Federal Student Aid (FAFSA^®) form—if the applicant is an unaccompanied homeless youth or unaccompanied and self-supporting youth at risk of homelessness. This announcement reminds institutions of their roles and responsibilities related to dependency determinations for unaccompanied homeless youth for Title IV federal student aid as provided by the FAFSA Simplification Act and described in Dear Colleague Letter GEN-23-06.

For the 2024-25 award year, a student is independent if, at any time on or after July 1, 2023, the student was determined to be an unaccompanied youth who is homeless or is self-supporting and at risk of being homeless. The student may self-report their independence due to homelessness by indicating on the FAFSA form that they have a determination from one of the following entities:

If a student indicates that they have a determination from one of the above entities on their FAFSA form, your institution is not required to request documentation from the student. If your institution chooses to request documentation, you must accept documentation from one of the above entities—provided through a documented phone call, written statement, or verifiable electronic data match. As noted in Dear Colleague Letter GEN-23-06, if the student has received a documented determination from one of these authorities, the institution must not request additional documentation, proof, or statements unless it has conflicting information about the student’s status.

As a reminder, the HEA provides that unaccompanied homeless youth determinations are separate from professional judgments made under the unusual circ*mstances provision. These applicants are also not considered Provisionally Independent students. FAFSA applicants who indicate that they have a determination by one of the above entities can complete the FAFSA form without parent information as a fully independent student.

In the absence of a determination by the entities above, 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. However, because an unaccompanied homeless youth determination is not a professional judgment under the unusual circ*mstances provision, the applicant will see unique comment code messaging on the FAFSA Submission Summary that indicates the need for further action by their college or career school’s financial aid office to determine their eligibility.

In these cases, a financial aid administrator at your institution must review the student’s circ*mstances and make a case-by-case determination of homeless youth status based upon a written statement from or a documented interview with the student that confirms that they are an unaccompanied homeless youth, or unaccompanied, at risk of homelessness, and self-supporting. Your determination must be made without regard to the reasons that the student is unaccompanied and/or homeless, or the circ*mstances that lead to the student’s unaccompanied homeless youth status.

As a reminder, if a student is determined to be independent due to their unaccompanied homeless youth status, the institution shall presume the student to be independent for each subsequent award year at the same institution, and is not required to request affirming documentation unless the institution has conflicting information about the student’s status or the student informs the institution that their circ*mstances have changed.

In all situations, institutions should be able to show that their policies and procedures for reviewing and making homeless youth determinations are compliant with statutory requirements.

For more information on the issue of homeless youth, please review “Dependency Status” in Chapter 2 and Chapter 5, “Special Cases,” of the Application and Verification Guide (AVG) in the Federal Student Aid Handbook.

You may refer additional questions to the Department using the Contact Customer Support form in FSA’s Partner Connect Help Center. To submit a question, please enter your name, email address, topic, and question. When submitting a question related to this Electronic Announcement, please select the topic “Policy Guidance”.

We thank you for your cooperation in ensuring that unaccompanied homeless youth receive the resources they need to succeed in their pursuit of higher education.