NASFAA AskRegs: If a Student Cannot Receive a Determination Of Homeless Youth Status From a District Liaison, Must She Submit a Dependency Appeal?

No. In cases when 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 related FAFSA dependency status questions, the financial aid administrator (FAA) is required to make the determination as to whether the student is homeless or at risk of homelessness. Effective with the 2023-24 award year, in making a determination of independence based on homelessness, an FAA must 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, per the McKinney-Vento Homeless Assistance Act;
The director (or designee) of an emergency/transitional shelter, street outreach program, homeless youth drop-in center, or other program serving individuals 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 project supported by a Federal TRIO or GEAR-UP grant; or
An FAA at another institution who documented the student's circumstance in a prior award year.

If the student cannot provide any of the above mentioned documentation, the FAA must make a determination:

On a case-by-case basis;
Based on a written statement from or a documented interview with the student which confirms the student is an unaccompanied homeless youth, or unaccompanied, at risk of homelessness, and self-supporting; and
Without regard to the reason that the student is unaccompanied and/or homeless.

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 provides information that his, her, or their circumstances have changed or if the institution has conflicting information. [HEA Section 479A, 20 USC 1087TT(c)(2)(B)(iv)]

Additional questions on making your determination should be directed to your ED School Participation Division.

Reference Section 479D of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087uu-2(a)] and Dear Colleague Letters GEN-23-06 and GEN-22-15. Also see guidance under "Unaccompanied Homeless Youth" in Chapter 5 of the Application and Verification Guide (AVG) volume of the FSA Handbook. See also the FAFSA Simplification--NASFAA Conference Presentation July 2022.

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

P&P Builder: NASFAA’s Policies & Procedures (P&P) Builder guides you step-by-step through the creation of a centralized, accessible policies and procedures manual. This is included in the cost of NASFAA Value Plus membership. There is an additional cost for other membership levels.

If a Student Cannot Receive a Determination Of Homeless Youth Status From a District Liaison, Must She Submit a Dependency Appeal?

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