Is a Documented Phone Conversation With an Out-of-State Student Sufficient To Make a Homeless Youth Determination?

Scenario: We have a lot of students from other states and we conduct phone interviews with students to document their unaccompanied homeless youth (UHY) status.

Answer: Yes, you can conduct a documented phone conversation with the student to make the unaccompanied homeless youth determination for students coming from another state using guidance in GEN-23-06 and under "Unaccompanied Homeless Youth" in Chapter 5 of the Application and Verification Guide (AVG) volume of the FSA Handbook.

Effective with the 2023-24 award year, 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.

If the student is unable to provide documentation from any of the entities listed above, the FAA must make a determination under this guidance:

• On a case-by-case basis;
• Based on a written statement from or a documented interview with the student that confirms the student is an unaccompanied homeless youth or at risk of homelessness; and
• Without regard to the reason for the student's situation.

Additionally, 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 student indicates a change or conflicting information exists).

See also the Higher Education Act of 1965 (HEA), as amended [20 USC 1087TT], FAFSA Simplification--NASFAA Conference Presentation July 2022 and GEN-23-06.

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

• Tip Sheet for Unaccompanied Homeless Youth (UHY)
• Homelessness--Unaccompanied Homeless Youth Determinations: 2023-24 Template
• Homelessness--Unaccompanied Homeless Youth Determinations: 2024-25 Template

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