When Can We Accept Another School's Determination Of a Student's Independent Status?

Award Year: 2023-24 KA-36440 Helpfulness Rating 504 page views

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

Effective with the 2023-24 award year, a school may accept another school's determination of a student's independent status. Section 479D(d)(2) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1087uu-2(d)(2)], states "A financial aid administrator may make a determination of independence pursuant to section 1087tt(c) of this title, this section, or paragraph (2), (8), or (9) of section 1087vv(d) of this title, based upon a documented determination of independence that was previously made by another financial aid administrator under such provisions in the same or a prior award year."

Schools may accept another institution's determination of independent status for a student as defined in Section 480(d)(2), (8), and (9) of the HEA, [20 USC 1087vv(d)(2),(8),(9)] who: 

See Dear Colleague Letters GEN-23-06 and GEN-22-15 for more information.

Note: The HEA does not specify whether or not the aforementioned authority would apply in the case of documenting the dependency status of a person in a legal guardianship or an emancipated minor. The Dear Colleague Letter repeats the circumstances in the HEA, but then says "all requests for a determination of independence"--language that seems to contradict itself. We are seeking clarification and will update this Q&A when we receive additional information.

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