NASFAA AskRegs: Can We Use Self-Declaration Letters To Make a Determination That a Student Is an Unaccompanied Homeless Youth?

Yes, in certain circumstances. Effective with the 2023-24 award year, in making a determination of independence based on homelessness or at risk of homelessness under Section 479D of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087uu-2(a)], 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 USC 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 USC 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 a student does not have the above listed documentation, the FAA must make a determination:

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

If an institution has no conflicting information about the status of the student, and has documentation from one of the above entities, the institution cannot request additional documentation, proof, or statements. Doing so may appear as if the FAA is asking applicants to explain, clarify, or justify their circumstances, instead of simply providing documentation of their homeless status. The FAA is required to make a homeless youth determination in the cases when a request is made by a student.

In the event of conflicting information, the school may request any documentation it deems necessary to resolve the conflict.

For assistance in making such determinations, see Chapter 5 of the Application and Verification Guide (AVG) volume of the FSA Handbook and Dear Colleague Letter GEN-23-06.

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. For guidance changes on the carryover of the homelessness determination, reference Section 479D(d)(1) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087uu-2(d)(1)]. See also AskRegs Q&A, Can We Ask Students To Inform the School If Their Unusual Circumstances Or Homelessness Status Has Changed From the Previous Year?

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.

Can We Use Self-Declaration Letters To Make a Determination That a Student Is an Unaccompanied Homeless Youth?

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