1. Homelessness, DACA, And The Financial Aid Student Carrie Bishop Dir. of Fin. Aid Training & Compliance, Ivy Tech CC IACAC Congress March 2016

2. Agenda The McKinney-Vento Act Title IV Aid Implications Definitions Dependency Status ISIR Corrections What we can & cannot do DACA Recommendations and Resources

3. McKinney-Vento Homeless Assistance Act Enacted in 1987 –Defined homeless children as those who “lack a fixed, regular, and adequate nighttime residence” and provided examples*. –Established programs and services (including grants for homeless shelters) to better meet the needs of homeless people. *examples include living in motels, camp grounds, emergency shelters, cars, abandoned buildings, bus/train stations; sleeping on park benches; awaiting foster care placement

4. McKinney-Vento Homeless Assistance Act There have been several Reauthorizations –“Improvements Act of 2001” Homeless students must be given equal access to public education. School districts must appoint a homeless liaison. States must review/revise certain documentation requirements (birth certificate, residency, immunization records, etc.).

5. Implications for Title IV Aid Unaccompanied homeless youth (56–58). A student is independent if at any time on or after July 1, 2014 (irrespective of whether he is currently homeless or at risk thereof), he is determined to be an unaccompanied youth who is homeless or is self-supporting and at risk of being homeless. This determination can be made by: a school district homeless liaison, the director (or designee) of an emergency shelter or transitional housing program funded by the U.S. Department of Housing and Urban Development, or the director (or designee) of a runaway or homeless youth basic center or transitional living program. These authorities make this determination if the student is receiving their programs’ services or if, in the case of a school district homeless liaison, the student is in high school. An FAA may also determine this; see Chapter 5. From 2015-16 FSA Handbook, AVG p. 26

6. Implications for Title IV Aid “Unaccompanied Youth” means: –Student is not in the physical custody of a parent or guardian. –“Youth” applies up to age 21. Under McKinney-Vento: up to age 24 still qualifies for Homeless status. “At risk of being homeless” means: –Student is self-supporting and –Has been evicted, is unable to find “fixed, regular, and adequate housing”. Definitions

7. Implications for Title IV Aid “Fixed, Regular, and Adequate Housing” –Fixed: stationary, permanent –Regular: predictable, routine, consistent –Adequate: meets “physical & psychological needs typically met in the home” Definitions

8. Implications for Title IV Aid Student may be “voluntarily homeless” due to abuse in the family. May be homeless even if living in campus housing (if they are otherwise homeless). Definitions

9. Implications for Title IV Aid Homelessness can be certified by school district liaison, director of HUD-funded shelter, or director of runaway center. Homelessness can be determined by a college/university Financial Aid Officer (FAO). Determination

10. Implications for Title IV Aid In determining student’s homeless status, we must be discrete. –Respect student’s privacy. Some information is protected by confidentiality; student may offer it but we cannot require it. –Police or CPS reports are not required. Determination

11. Implications for Title IV Aid In determining student’s homeless status, we use checklist/interview form to ensure: –consistency between students, and –that the documentation requirements are met. Documentation must at least include FAO’s determination, such as interview form, that student meets the homeless definition. Other documentation can include information obtained by another school and FAO documentation of phone calls with a relevant authority. Determination

12. BOTTOM LINE for Title IV Aid Homeless/Unaccompanied Youth are independent for Title IV aid purposes. –This is not a dependency override or professional judgment. –We don’t select for verification unless we have conflicting information. –Homeless students may use college’s address on FAFSA. Dependency Status

13. Financial Aid Officers DO DO Do get to know the local high school homeless liaison; work in partnership as needed. Do process ISIR corrections for students who submit a certified homeless form after filing a FAFSA. Homelessness

14. Financial Aid Officers DON’T If student submits a certified homeless form: Don’t require additional documentation or ask probing questions. Don’t question student about the certification form if you think it is fraudulent (accept form and contact the oversight party – see links at end of slides). Don’t Homelessness

15. Recommendations FAOs update local school district homeless liaison annually re: FAFSA process and deadlines Build on-campus awareness of homelessness issues (advisors, student affairs, health center) Identify an on-campus point of service for homeless students Homelessness

16. Poster by NCHE and NASFAA – it may be displayed on your campus and in your local high schools!

17. Resources Federal Student Aid Handbook Application/Verification Guide http://ifap.ed.gov/fsahandbook/ attachments/1516AVG.pdf Homelessness

18. Resources National Center for Homeless Education http://center.serve.org/nche/ http://center.serve.org/nche/ –Map: find state-specific contact info –Homeless Liaison Toolkit: 17 Informational Chapters Dozens of Appendices –Publications, videos, training Homelessness

19. Resources If we question the authenticity of a certification form, I follow up –School District Liaison: find state contact information at http://center.serve.org/nche/states/state_resources.php. http://center.serve.org/nche/states/state_resources.php –Director of Emergency Shelter: find state HUD contact info at http://www.hudhre.info/index.cfm?do=viewCocContacts. http://www.hudhre.info/index.cfm?do=viewCocContacts –Director of Runaway/Homeless/Youth Shelter: e-mail ncfy@acf.hhs.gov or call (301) 608-8098. ncfy@acf.hhs.gov Homelessness

20. Deferred Action for Childhood Arrivals (DACA) is a U. S. immigration policy that allows certain undocumented immigrants who entered the country before their 16th birthday and before June 2007 to receive a renewable two-year work permit and exemption from deportation. Deferred Action for Childhood Arrivals (DACA)

21. DACA: What It Is Were under the age of 31 as of June 15, 2012; Came to the United States before reaching their 16th birthday; Have continuously resided in the United States since June 15, 2007, up to the present time; Were physically present in the United States on June 15, 2012, and at the time of making their request for consideration of deferred action with USCIS; Had no lawful status on June 15, 2012; Are currently in school, have graduated or obtained a certificate of completion from high school, have obtained a general education development (GED) certificate, or are an honorably discharged veteran of the Coast Guard or Armed Forces of the United States; and Have not been convicted of a felony, significant misdemeanor, or three or more other misdemeanors, and do not otherwise pose a threat to national security or public safety. Available to those who: https://www.uscis.gov/humanitarian/consideration- deferred-action-childhood-arrivals-daca

22. DACA is NOT the DREAM Act –DACA is about a work permit and deferred deportation Immigration policy created in 2012 Provides “legal presence” –DREAM Act is the Development, Relief, and Education for Alien Minors Act Federal legislation introduced level in 2001; has not passed –Would create a path to citizenship (“legal status”) Many states have their own version of Dream Act DACA: What It Is NOT

23. DACA: What Else It Is NOT Does not grant citizenship or naturalization Does not grant eligible non-citizenship status Does not qualify a student for federal or Indiana student financial aid programs Does not qualify a student for in-state tuition rates (Indiana)

24. Discussion Contact Information: –Carrie Bishop –317-968-1530 –cbishop39@ivytech.edu