1. Session # 38
Understanding Federal Aid Policy and Practice for Unaccompanied Homeless Youth
Cyekeia Lee (NAEHCY) | Dec National Association for the Education of Homeless Children and Youth 2014 FSA Training Conference for Financial Aid Professionals

2. Homeless Children and Youth
Children or youth who lack a fixed, regular, and adequate nighttime residence, including
Sharing the housing of other persons due to loss of housing, economic hardship, or a similar reason
Living in motels, hotels, trailer parks, or camping grounds due to the lack of alternative adequate accommodations
Living in emergency or transitional shelters
Awaiting foster care placement

3. Homeless Children and Youth
Living in a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings
Living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings
Migratory children living in the above circumstances
Unaccompanied youth living in the above circumstances
Visit for more information

4. Family and Youth Homelessness
Shelters are not an option for all families and/or youth experiencing homelessness
Shelter demand often exceeds supply
Many communities don’t have shelters
Shelters may have stay limits
Families don’t want to be separated
Safety can be a concern

5. Number of Homeless Children and Youth
national numbers
1,258,182 homeless children and youth enrolled in public schools
8% increase over the previous year
85% increase since recession
34 states reported an increase
75,940 unaccompanied homeless youth
37,598 children ages 3-5

6. Causes of Family Homelessness
A lack of affordable housing
Unemployment or underemployment
Physical or mental health challenges
The challenges of single parenting
Domestic violence

7. Causes of Youth Homelessness
Sexual, physical, or emotional abuse
Parental mental illness, incarceration, or drug use
Conflict related to blended family issues
Conflict related to the student’s sexual orientation, pregnancy, or drug use
Financial strain

8. Foster Care and Homelessness
Correlation between child welfare involvement and experiences of homelessness
For school-age youth
Foster care placements often are short-term or may be unstable
Some students leave foster care placements due to feeling unsafe and/or isolated
For youth aging out of care
Exit the foster care system without sufficient preparation and/or support to be successful living independently

9. Foster Care and Homelessness
By age 24, 29% of youth who aged out of foster care had been homeless for at least one night
28% reported having couch-surfed since exiting care
In total, nearly 40% of youth had experienced homelessness or had couch-surfed since exiting care
Dworksy, A.& Courtney, M. (2011). Assessing the impact of extending care beyond age 18 on homelessness: Emerging findings from the Midwest study, Washington, DC: The Urban Institute. Retrieved from

10. Foster Care and Homelessness
6% became homeless within the first month after exiting care
14 % within the first year
20% within the first 2 years
22 % within the first 30 months
63% of the young people who became homeless within the first 30 months post-exit did so during the first year
Dworksy, A.& Courtney, M. (2011). Assessing the impact of extending care beyond age 18 on homelessness: Emerging findings from the Midwest study, Washington, DC: The Urban Institute. Retrieved from

11. Barriers to Higher Education Access
Lack of parental income and support
Barriers accessing financial aid
Barriers receiving subsequent year determinations of homeless status
Lack of housing during holiday and summer breaks
Food insecurities on campus
Lack of information about available support systems
Struggle to balance school and other responsibilities 11

12. Single Point of Contact (SPOC) Model
“Single Point of Contact” – a supportive college administrator on each campus who is committed to helping homeless youth (and often foster youth) successfully navigate the college-going process on campuses
Assist students with the following
Admissions
Financial aid
Academic advising
Student life
Community resources

13. Where Are SPOC’s Located ?
SPOCs are found in the Financial Aid, Counseling, Dean of Students, Ombudsmen, or Student Support Services offices on campus
In place in CO, NC, MI, and GA
In progress in AL, FL, NH, NV, MA, NJ, IN, PA
Kennesaw State University
Social Worker staffs C.A.R.E Center
Food Bank
Clothing Closet
Housing Support
Scholarship Assistance

14. SPOC Model Benefits of having a SPOC on campus
Allow unaccompanied homeless youth to have support finding campus and community resources
Reduces the number of times student have to repeat, or relive, situations that led to them becoming homeless
Having a staff member on campus that is knowledgeable of federal guidance, and state laws impacting higher education access and success for unaccompanied homeless youth

15. State Networks
Convene a meeting with local stakeholders from McKinney-Vento K-12, Higher Education, RHYA/HUD shelter communities as well as other local service providers and advocates
Allow each to share knowledge about their area of expertise
UHY and independent student definitions
Financial aid
Campus and community resources
Build an action plan for serving UHY that makes sense for your community

16. State Networks
Networks are formed by having homeless education or homeless policy professionals partner with higher education professionals
Members collaborate to identify and address barriers to higher education access, retention, and success for youth experiencing homelessness
Current states include: CO, NC, NH, KY, FL, GA, IL, MI, MA, and OK
In development: NY, NJ, VA, IN, and MT

17. State Networks Best practices include Establishing SPOCs on campuses
Establishing food or clothing pantries on campus
Establishing emergency funding to obtain IDs, bed sheets, toiletry items, etc.
Establishing scholarships for homeless youth on campus
Providing housing during breaks

18. Session # 38
Understanding Federal Aid Policy and Practice for Unaccompanied Homeless Youth
Aaron Washington (ED) | Dec U.S. Department of Education 2014 FSA Training Conference for Financial Aid Professionals
-Hello Everyone my name is Aaron Washington and I will be discussing Title IV aid as it relates to unaccompanied youth who are homeless. You may have heard many terms such as “unaccompanied youth”, “homeless youth” and “unaccompanied homeless youth” please note that all of the variations that you may hear are referred to as an “unaccompanied youth who was homeless” on the FAFSA.
-Also be sure to reference the original law or guidance source discussed in this presentation to ensure that you are following the guidelines, this presentation is meant to be a high level overview

19. Student Eligibility for Title IV Aid
Our most basic eligibility requirements are that a student must:
Be a U.S. citizen or eligible noncitizen
Have a valid SSN
Register with the Selective Service if you’re a male between the ages of 18 and 25
Maintain SAP
Have a H.S. diploma/equivalent or home-school
Demonstrate financial need (for most programs)
Before we begin I would like to note that unaccompanied youth who are homeless must satisfy all of eligibility requirements in order to receive Title IV, federal student aid, you can find more detail in the FSA handbook on eligibility in Volume 1

20. Title IV Aid & Unaccompanied Homeless Youth
Statute
Higher Education Act
McKinney-Vento Homeless Assistance Improvements Act
Runaway and Homeless Youth Act
Free Application for Federal Student Aid (FAFSA)
Dependency Questions
Federal Student Aid (FSA) Handbook
Application and Verification Guide

21. McKinney-Vento Act Section 725 definition of homeless youth:
means individuals who lack a fixed, regular, and adequate nighttime residence, this includes-
Fixed—stationary, permanent, and not subject to change.
Regular—used on a predictable, routine, or consistent basis.
Adequate—sufficient for meeting both the physical and psychological needs typically met in the home.

22. McKinney-Vento (cont’d)
children and youths who are sharing the housing of other persons due to loss of housing, economic hardship, or a similar reason
children and youths who have a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings
children and youths who are living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings;
migratory children (as such term is defined in section 1309 of the Elementary and Secondary Education Act of 1965) who qualify as homeless for the purposes of this subtitle because the children are living in circumstances described in the first three bullets
Bullet 4 MIGRATORY CHILD- The term migratory child' means a child who is, or whose parent or spouse is, a migratory agricultural worker, including a migratory dairy worker, or a migratory fisher, and who, in the preceding 36 months, in order to obtain, or accompany such parent or spouse, in order to obtain, temporary or seasonal employment in agricultural or fishing work —
(A) has moved from one school district to another;
(B) in a State that is comprised of a single school district, has moved from one administrative area to another within such district; or
(C) resides in a school district of more than 15,000 square miles, and migrates a distance of 20 miles or more to a temporary residence to engage in a fishing activity.

23. HEA Section 480(d)(1)(H)-Definition of independent student:
Has been verified during the school year in which the application is submitted as either an unaccompanied youth who is a homeless child or youth (as such terms are defined in section 725 of the McKinney-Vento Homeless Assistance Act), or as unaccompanied, at risk of homelessness, and self- supporting, by-

24. HEA (cont’d) a local educational agency homeless liaison
the director of a program funded under the Runaway and Homeless Youth Act or a designee of the director;
the director of a program funded under the McKinney-Vento Homeless Assistance Act or a designee of the director; or
a financial aid administrator
Bullet 1 local educational agencies will designate an appropriate staff person, who may also be a coordinator for other Federal programs, as a local educational agency liaison for homeless children and youths, to carry out the duties described in paragraph
Bullet 2 The Runaway and Homeless Youth Act has enacted to develop accurate national reporting system, and an effective system of care including preventive and aftercare services, emergency shelter services, extended residential shelter, and street outreach services
Runaway and Homeless Youth Act program- Street Outreach Program-provides shelter, community services and prevention education for youth, adults and families
Bullet 3 McKinney Vento Act grant programs- plethora of local, regional and state homeless assistance programs

25. 2014-15 FAFSA-Dependency Questions
-Now that we have looked at the Statute, how does that translate to applying for federal aid?
-Note there are 3 questions relating to homeless youth on the FAFSA, these questions correspond to the HEAs definition of ways in which an unaccompanied homeless youth can be verified during the school year in which the application is submitted as either an unaccompanied youth who is a homeless child or youth
-If a student answers yes to any of the questions they are considered independent for the purposes of Title IV aid. Questions specifically refer to unaccompanied youth who are homeless. Dependency effects the need analysis calculation for Federal Student Aid.
-Please note that applicants who qualify as an independent may not necessarily have a lower EFC than if they were a dependent student.

26. FAFSA (cont’d)
An applicant should answer yes or no to questions based on the guidance provided on page 9 of the FAFSA. If they believe they should qualify but can not answer yes, they should contact their Financial Aid office to have a homeless youth determination made.

27. AVG-FSA Handbook
You are not required to verify the answers to the homeless youth questions unless you have conflicting information
A documented phone call with, or a written statement from, one of the relevant authorities is sufficient verification when needed
It is not conflicting information if you disagree with an authority’s determination that a student is homeless
-After the student has completed the FAFSA and the data is sent to the school FSA handbook provides guidance about unaccompanied homeless youth
-if the student answers yes to 56, 57, or 58 of the dependency questions, you are not required to confirm the answer unless you have conflicting information.
-If you believe the authority is incorrect or abusing the process, accept his determination but contact the following relevant oversight party, to evaluate the authority’s determinations; see the margin note on page 128 of the AVG. [The AVG explains who the oversight parties are.]

28. AVG-FSA Handbook (cont’d)
If the student claims to be homeless and cannot answer yes to question 56, 57, or 58 on the FAFSA, you are required to make a homeless youth determination
You can get assistance with making case-by-case determinations by contacting:
College access programs (TRIO, GEAR UP, etc.)
Doctors
Social Workers
Mental Health Professionals
The determination may be based on a documented interview with the student if there is no written documentation available
You are not required to verify answers on the FAFSA, but if an application requires an FAA homeless youth determination, by the FAA you are required to make it based on legal definitions.
You can use the listed examples of resources to confirm a student. This list is not exhaustive.
Because this is a sensitive area, use discretion and respect for the students when making inquiries about a student’s status.

29. AVG-FSA Handbook (cont’d)
A Homeless Youth Determination is not a dependency override or a case of professional judgment

30. AVG-FSA Handbook (cont’d)
Students determined to be unaccompanied homeless youth
You should select option 4 in the dependency override field in FAA Access to CPS Online or Electronic Data Exchange (EDE)
You may also rely on a determination by another school that on or after July 1, 2013, a student was homeless
Students who would be homeless unaccompanied youth but are over 21 (and not yet 24) qualify for a dependency override
-To cancel a homeless youth determination, you use the same method as when canceling a dependency override: change the dependency override value to “2—FAA override canceled” in FAA Access or EDE.
-The definition of youth is a student who is 21 years old or younger or still enrolled in high school as of the date he signs the application. In some cases there are the students that were able to be certified one year but not the other.

31. NAEHCY Case Study & FAQ’s

32. Case Study
Shannon is a 19-year old sophomore. For her freshman year, she filed her FAFSA as a dependent student and her parents helped pay her tuition and included her on their health insurance. This year, Shannon filed her FAFSA much later then she did the previous year, on August 15th. Her Institutional Student Information Record (ISIR) has a Special Circumstances Flag of 3, indicating Shannon believes she meets the definition of an unaccompanied homeless youth but does not have a determination from a homeless professional.

33. Case Study Continued
Per office policies and procedures, you schedule an appointment with Shannon to discuss her situation and conduct the interview required for the institution’s determination process. During the appointment, Shannon explains that her mom is seriously ill and her father has left due to the stress of the situation. Her mom’s behavior has become increasingly erratic, and she threatened Shannon with a knife during an argument. As a result, Shannon stayed with her best friend’s family for a few weeks in the summer. When her best friend left to return to her college in another state, Shannon was told she could no longer stay with the family. Shannon couch surfed for a couple of weeks until she was able to move into on-campus housing. Shannon has no idea where she will stay when on-campus housing closes between the fall and spring semesters.
Does Shannon meet the definition of being an unaccompanied homeless youth?

34. FAQ #1
Subsequent Year Determination: If a McKinney-Vento Liaison is only able to make a determination of student’s unaccompanied homeless youth status for one academic year, and a student has not stayed at an RHYA or HUD funded shelter, what steps can an FAA take to make a determination of a student’s unaccompanied homeless youth status?

35. FAQ # 1 Answer
Answer: A documented interview can be conducted. Many schools have created their own determination form; however NAEHCY’s FAA Determination tool can be used to help make a determination. FAA’s can consult with NCHE, McKinney-Vento Liaison, or State Coordinator. Relevant third parties can provide information McKinney-Vento Liaison, School Counselor, TRIO or GEAR-UP staff, college or high school counselor. FAA’s can contact NAEHCY Higher Education Helpline.

36. FAQ #2
First Year Determination: If a school district McKinney-Vento Liaison provides a letter confirming that a student meets the definition of being an unaccompanied homeless youth, do you need supplemental documentation from other authorities in order to make the student independent?

37. FAQ #2 Answer
Answer: Verification Not Required. See Chapter 5 of the of the Application and Verification Guide page 128.
You are not required to verify the answers to the homeless youth questions unless you have conflicting information. A documented phone call with, or a written statement from, one of the relevant authorities is sufficient verification when needed.

38. FAQ #3
Dependency Status Appeal: If a 22 year old student had previously received determinations of their unaccompanied homeless youth status their freshman, sophomore, and junior year, how can you assist the student with completing a Dependency Status Appeal if they are still unaccompanied and homeless, but no longer considered a youth?

39. FAQ #3 Answer
Answer: Explain the difference between making a determination of an unaccompanied homeless youth status, and making a Professional Judgment of Dependency Status Appeal. Discuss the forms and documentation needed for the appeal process (Personal Statement, third party letters, verification documentation). Assist student with questions about the appeal process.

40. Available Resources NAEHCY Higher Education Initiative:
National Center for Homeless Education:
FSA Handbook, Application and Verification Guide:
TRIO Programs:

41. Contact Us Barbara Duffield, bduffield@naehcy.org
Cyekeia Lee,
Aaron Washington,

42. QUESTIONS?