Can a Student Be Considered Homeless Or At Risk Of Homelessness If They Have a Relationship Or Contact With Their Parents?

Award Year: 2023-24 KA-33003 Helpfulness Rating 6,945 page views

This guidance is specific to the 2023-24 award year and later.

Scenario: A student moved into a homeless shelter when the dorms closed for spring break because they missed the deadline to stay on campus. They used that documentation to complete the FAFSA as an independent student even though they have a good relationship with their parents.

Answer: Having a relationship with one’s parents does not disqualify a student from being 1) an unaccompanied homeless youth; or (2) unaccompanied, self-supporting, and at risk of being homeless. In fact, the following circumstances do not disqualify a student from being homeless or at risk of homelessness:

Regardless of their age and the reason, applicants who are homeless or at risk of homelessness qualify for a homeless youth determination and will be considered independent students on the FAFSA. It does not matter why the student is homeless or at risk of homelessness, so schools should not ask why the student is homeless or at risk of homelessness. While we certainly understand the desire to question why the student does not live with their parents, the U.S. Department of Education (ED) has indicated that it is not appropriate for the financial aid administrator (FAA) to question why the student is homeless or does not live with their parents. In other words, it does not matter that the student may be choosing not to live with their parents. It also does not matter if the student is still using the parent's address as their mailing address. It also doesn't matter if the student does not want to go to a homeless shelter or receive help from any source related to homelessness.

The fact that the student has contact with their parent does not necessarily mean that the student would not meet the homeless or at risk of homelessness criterion. For example, a student fleeing an abusive parent and without fixed, regular, and adequate housing may be considered homeless even though the student’s parent would otherwise provide support and a place to live. On the other hand, let's say for example a family lost their home in a house fire and the entire family is homeless. This does not make the student homeless because the student is still accompanied by the parents; the student must also be unaccompanied to be considered homeless or at risk of homelessness for Title IV purposes. The same is true even if the parents still have legal (but not physical) custody of the student.

An FAA should only question the student’s status if conflicting information is present. Otherwise, the FAA should only document the fact that the student is homeless or at risk of homelessness for Title IV purposes according to the following definitions: 

If the student does not have a determination from one of the entities listed below, you, the FAA, must make the determination. The FAA must use their best judgment to determine only whether the student is homeless or an unaccompanied youth at risk of being homeless. NASFAA cannot make this determination on the FAA's behalf, so they should follow the guidance under "Unaccompanied Homeless Youth" in Chapter 5 of the Application and Verification Guide (AVG) volume of the FSA Handbook, as well as in and Dear Colleague Letter GEN-23-06.

Remember that, if the student already has a determination of homelessness or at risk of homelessness from one of the following authorities, the school must accept that determination and cannot request additional documentation or statements unless there is conflicting information in the information that is provided to the school:

Note: Effective with the 2023-24 award year, any student determined to be independent due to homelessness for a preceding award year shall be presumed to be independent for each subsequent award year at the same institution, unless the student indicates a change in circumstances or unless conflicting information exists in the student's file. Reference Section 479A(c)(2)(D)(iv) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087TT]. Given these new provisions, FAAs should not need to obtain documentation to confirm a student’s status from year to year.

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

Student Aid Reference Desk: For additional information, try the Student Aid Reference Desk. It is a central hub of all the important financial aid resources you need with direct links to legislation, regulation, Dear Colleague Letters, and other ED and NASFAA references. It is updated on a rolling basis with the latest news and changes.

AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.