NASFAA AskRegs: What Documentation Should a Student Submit To Prove He Or She is Homeless Or At Risk Of Homelessness?

Effective with the 2023-24 award year, in making a determination of independence based on homelessness (homeless or at risk of homelessness) under Section 479D of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087uu-2(a)], and further clarified in Dear Colleague Letter GEN-23-06, a financial aid administrator (FAA) shall accept documentation from the following designated authorities--provided through a documented phone call, written statement, or verifiable electronic data match:

A local educational agency homeless liaison, as designated by the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11432(g)(1)(J)(ii))), or a designee of the liaison;
The director or designee of an emergency or transitional shelter, street outreach program, homeless youth drop-in center, or other program serving individuals who are experiencing homelessness;
The director or designee of a program funded under subtitle B of title IV of McKinney-Vento (relating to emergency shelter grants) (42 U.S.C. 11371 et seq.);
The director or designee of a Federal TRIO program or a Gaining Early Awareness and Readiness for Undergraduate program (GEAR UP) grant; or
An FAA at another institution who documented the student’s circumstance in the same or a prior award year.

The HEA, as amended, provides that documentation from one of the above authorities is sufficient for establishing a student’s unaccompanied homeless youth status. Therefore, 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.

In the absence of a designated authority's determination, the FAA must review the student's circumstances and make the determination. If you are uncertain how to make the determination, you can contact the homeless liaison in the school district or one of the other authorities listed above to get help on how to apply the McKinney-Vento definition; however, you must still make the determination. You can find more information at The National Center for Homeless Education (NCHE).

You would need to collect any documentation you deem necessary to validate the living arrangements of the student who claims to meet the definition of homeless or at risk of being homelessness in accordance with the FSA Handbook, Application and Verification Guide (AVG), Chapter 5, "Homeless youth determinations" which states:

"A student is considered homeless if he lacks fixed, regular, and adequate housing. This is broader than just living “on the street.” It includes but is not limited to:

youth sharing housing with other people temporarily because they had nowhere else to go;
youth living in emergency or transitional shelters, for example, trailers provided by the Federal Emergency Management Agency after disasters;
youth living in motels, campgrounds, cars, parks, abandoned buildings, bus or train stations, substandard housing, or any public or private place not designed for humans to live in;
youth living in the school dormitory if they would otherwise be homeless; and
youth who are migrants and who qualify as experiencing homeless because they are living in circumstances described above.

The documentation for an FAA’s evaluation of the living arrangements of a student must demonstrate that he or she meets the definition of this category of independent student. The determination may be 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. The FAA might consider using the SchoolHouse Connection template below. In any case, such determinations should be made without regard to the reasons that the student is unaccompanied and/or homeless.

Remember the following when you are making a homelessness determination:

Ask for help with determining eligibility from local school district homeless liaisons, state homeless education coordinators, the National Center for Homeless Education (https://nche.ed.gov/higher-education/), or the National Association for the Education of Homeless Children and Youth (https://naehcy.org/higher-education/). Search for “Making Student Status Determinations for Unaccompanied Homeless Youth” to find worksheets and tools to help make your determination.
Relevant information can come from recognized third parties such as private or publicly funded homeless shelters and service providers, financial aid administrators from another college, college access programs such as TRIO and GEAR UP, college or high school counselors, other mental health professionals, social workers, mentors, doctors, and clergy.
Use discretion when gathering information and respect the student’s privacy. Some information, such as that protected by doctor-patient privilege, is confidential. Also, documents such as police or Child Protective Services reports are not necessary. Don’t focus on why the student is homeless or unaccompanied but on whether the evidence shows he or she is an unaccompanied homeless youth.
Determine eligibility based on the legal definitions provided (see “Homeless youth definitions” below).
Recall that unaccompanied homeless youth may use the address of your school as their own on the FAFSA form.

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Finally, if you do not have conflicting information at your institution, you must use documentation from an FAA at another institution that made a documented determination that a student was an unaccompanied homeless youth in the same or prior award year. You should also presume that a student for whom your institution has made a determination of homelessness continues to be independent in each subsequent year at your institution unless the student tells you their circumstances have changed, or you have conflicting information."

See the FSA Handbook for the procedures to follow when updating the FAFSA and/or Institutional Student Information Record (ISIR) after making a homelessness determination.

An example of someone who may be considered "at risk of homelessness" might include a student who has been living with someone else and does not receive any parental support. The student states she has been at risk of being homeless on many occasions because her living conditions have not been stable, as she has been staying with people who allow her to stay with them. The student at one point did have an apartment; however, she had to break that lease due to financial hardship. She has documented proof of breaking the lease. She has not yet gone to a shelter because she does not want to go that route if it can be avoided. She has not gone to see any homeless counselors/liaisons.

Remember: A homelessness determination is not professional judgment (PJ). See AskRegs Knowledgebase Q&A, Is an Unaccompanied Homeless Youth Determination a Professional Judgment Adjustment?

Tools: Refer to the following tools to assist with this student population:

What Documentation Should a Student Submit To Prove He Or She is Homeless Or At Risk Of Homelessness?

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