Making Determinations of Unaccompanied Homeless Youth Status

A NASFAA conference interest session and a recent Dear Colleague Letter (DCL) from the Department of Education (ED) remind schools of the statutory requirements related to homeless youth, clarify the roles and responsibilities of financial aid administrators, and offer guidance on best practices when working with this vulnerable population.

Dear Colleague Letter

DCL GEN-15-16 does not include any changes in guidance. Because of concerns that some institutions are unnecessarily restricting applicants’ access to aid, the DCL provides the following reminders:

  • Institutions are not required to verify the answers to the unaccompanied homeless youth questions.
  • In instances where the institution has conflicting information, a documented phone call or a written statement from the relevant authority is sufficient.
  • It is not conflicting information if an FAA disagrees with an authority’s determination that a student is homeless. If an FAA believes the authority is incorrect or abusing the process, the FAA should contact the relevant oversight party to evaluate the determination.
  • If an applicant believes that he or she is homeless or at risk of being homeless but is unable to answer “yes” to any of the relevant FAFSA questions, the applicant is directed to contact his or her financial aid office to request that an unaccompanied homeless youth determination be made. Upon such a request, the FAA is required to make an unaccompanied homeless youth determination.
  • In all cases, the institution should limit any inquiry to whether the applicant has been determined to be an unaccompanied youth who is homeless, or at risk of being homeless, rather than the reasons for the applicant’s homelessness.

NASFAA Conference Session

At NASFAA’s conference in New Orleans, attendees had the option to participate in an interest session on making determinations of unaccompanied homeless youth status; unaccompanied homeless youth are independent for Title IV purposes.

After sharing statistics, the linkage between youth homelessness and foster care, the barriers to accessing higher education, definitions, and which professionals are authorized to make determinations, presenters reviewed the determination process. While making determinations of this status shares some characteristics with professional judgment – the need for documentation and making decisions on a case-by-case basis – this process is not an exercise of professional judgment authority, nor is it verification. By making a determination of unaccompanied homeless youth status, a financial aid administrator is confirming a student meets the three-part definition of an unaccompanied homeless youth.

Presenters reminded attendees that school district liaisons cannot make determinations for continuing students since these students are no longer in high school and not receiving services under the McKinney-Vento Act. However, information from school district liaisons may be used as supporting documentation when a financial aid administrator makes a determination. Attendees learned about best practices for conducting a documented interview. Richard Heath, Director of Financial Aid at Anne Arundel Community College, shared the process his school uses to make determinations, and how other campus offices are involved.

The session also provided resources to help participants with the determination process, including an interactive determination tool and how to identify state coordinators for homeless education and school district liaisons. Resources include the:

For highlights and summaries of key events and other sessions that were held at the 2015 National Conference in New Orleans, see our summaries page.


Publication Date: 7/31/2015

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