NASFAA AskRegs: Can a High School Or School District Liaison Make a Determination Of Unaccompanied Homeless Youth Status For Continuing Students?

Yes, it is possible in some cases; however, it may not be necessary.

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. 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)] and Dear Colleague Letter GEN-22-15. Additionally, student responses to the unaccompanied homeless youth/at risk of homelessness questions will carry forward, beginning with 2023-24 renewal FAFSA filers. The student must update the response if his or her circumstances change.

Given these new provisions, financial aid administrators (FAAs) should not need to obtain documentation to confirm a student’s status from year to year (except as noted above). In a case where documentation is necessary (i.e., the student does not have a determination from one of the designated authorities or there is conflicting information), because of district restrictions, these authorities may choose to make this determination only if the student is still receiving their program's services or if, in the case of a school district homeless liaison, the student is in high school. However, based on their knowledge of the student’s current status, local liaisons (including high school liaisons) can make a determination of unaccompanied homeless youth status for continuing students. Guidance found under "Homeless youth determinations in the Application and Verification Guide (AVG) volume of the FSA Handbook states:

“In most cases the officials authorized to make an unaccompanied homeless youth determination (those listed under the “Unaccompanied homeless youth” section in Chapter 2) will only provide documentation of that status for persons they are directly providing services to. However, there may be a few case-by-case instances where such an official will provide documentation for a person who is no longer officially receiving services. Also, local liaisons may write subsequent-year letters of verification for unaccompanied homeless youth through age 23 for whom they have the necessary information to write such letters. This documentation is acceptable for verifying unaccompanied homelessness.”

In GEN-23-06, the U.S. Department of Education (ED) states:

"HEA section 479D(a)(1), as amended, requires FAAs to consider a student to be independent if the applicant’s status as an (1) unaccompanied and homeless youth or (2) unaccompanied and self-supporting youth at risk of homelessness is verified by one of the following authorities through a documented phone call, written statement, or a 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 documentation from any of the individuals described above, the FAA must make a case-by-case determination:

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; and
Made without regard to the reasons that the student is unaccompanied and/or homeless.

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.

Can a High School Or School District Liaison Make a Determination Of Unaccompanied Homeless Youth Status For Continuing Students?

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