1. Dependency Status Issues
April 4, 2019

2. Financial Aid Counselor
Tony Babits
Financial Aid Counselor
Marquette University

3. What is Going to be Covered
Flagging Students for Review
Dependency Questions on the FAFSA
Students Without Parent Support
Dependency Overrides
Homeless Youth Determination
Overview
What is Going to be Covered

4. Flagging Students for Review
Student answers ‘Yes’ to any of the questions 53 thru 58
Follow up occurs where necessary
Documentation is received and reviewed
If approved, appropriate changes made to budget and awards
If denied, notify student to make changes and add appropriate signatures

5. FAFSA Dependency Questions
53. At any time since you turned age 13, were both your parents deceased, were you in foster care or were you a dependent or ward of the court?
Both parents must be deceased to qualify
Foster care and ward of the court paperwork must come from court, state/county child welfare agency or private provider that delivers child welfare services
Adoption paperwork does not prove foster care or ward of the court status on its own

6. FAFSA Dependency Questions Q53 continued
Both Parents Deceased
FSA Handbook does not provide specific guidelines on paperwork to collect
Acceptable Documentation for both parents:
Death Certificates?
Obituaries?
Student Statement?

7. Foster Care Examples

8. FAFSA Dependency Questions
54. As determined by a court in your state of legal residence, are you or were you an emancipated minor?
States that recognize Emancipation of Minor: AL, CA, FL, IL, MI, NC, OR, VT, WV.
Age of majority in all the above is 18, except AL; which is 19.
Court of student’s residing state must issue order for emancipation.

9. Emancipation Example

10. FAFSA Dependency Questions
55. Does someone other than your parent or stepparent have legal guardianship of you, as determined by a court in your state of legal residence?
Legal custody and Power of Attorney do not directly qualify.
Temporary and Plenary Guardianships need clarification.
Legal Guardian – an individual appointed by a court to be a “guardian” of a person and specifically required by the court to use his or her financial resources for the support of that person (FSA Handbook A-45).

11. Legal Guardianship Examples

12. Plenary Guardians
Plenary Guardianship: a guardianship in which the court gives the guardian the power to exercise all legal rights and duties on behalf of a ward, after the court makes a finding of incapacity. A court may appoint a plenary guardian only upon a finding that the ward lacks the capacity to perform all of the tasks necessary to care for his/her person or property and is in need of plenary guardianship services.
Send file to University’s Office of Inspector General (OIG)
Request Student and Guardian to sign add’l document:
Include who is paying for student’s Cell Phone Bill & who is providing student with Health Insurance

13. FAFSA Dependency Questions
56. At any time on or after July 1, 2018, did your high school or school district homeless liaison determine that you were an unaccompanied youth who was homeless or were self-supporting and at risk of being homeless?
The National Center for Homeless Education,
The National Association for the Education of Homeless Children and Youth,

14. McKinney-Vento Liaison Example

15. FAFSA Dependency Questions
57. At any time on or after July 1, 2018, did the director of an emergency shelter or transitional housing program funded by the U.S. Department of Housing and Urban Development determine that you were an unaccompanied youth who was homeless or were self- supporting and at risk of being homeless?
HUD EXCHANGE, Continuum of Care (C.o.C) Program, Click on “Contact a C.o.C”

16. FAFSA Dependency Questions
58. At any time on or after July 1, 2018, did the director of a runaway or homeless youth basic center or transitional living program determine that you were an unaccompanied youth who was homeless or were self-supporting and at risk of being homeless?
The National Clearinghouse on Families and Youth, phone number or by at

17. Honorable Mention – FAFSA Dep. Question
50. Are you a veteran of the U.S. Armed Forces?
Answer “Yes” if you (1) have engaged in active duty (including basic training) in the U.S. Armed Forces
Even just 1 day of Active Duty will suffice so long as the student was in an Active Duty Component of the military
Members of the National Guard or Reserves are only considered veterans for FSA purposes if they were called up for active federal duty by presidential order
State Active Duty missions do not satisfy this requirement
FSA Handbook: AVG-26,

18. Students Without Parent Support
Parents refusal to support them does not grant Dependency Override
Need documentation confirming situation
Preferably signed statement from parent refusing support
Can accept 3rd party payment as last resort, cannot just be a student statement
Student’s FAFSA will reject, but we can award Unsubsidized Loan only
Max award is the Dependent Undergrad annual limit, NOT like a Parent PLUS Denial
Example: First Year Freshman could be awarded $5,500 Unsubsidized Loan with rejected FAFSA
Student must meet all other eligibility requirements

19. Dependency Overrides Case-by-case basis with unusual circumstances
Abandonment
Abuse
Inability to locate parents
Thorough documentation
Include your reasoning and/or rationale for override
Override must be renewed every award year
Signed student statement sufficient
FSA Handbook: AVG-113,

20. Dependency Overrides Do not consider:
Parents refuse to contribute to student’s education
Parents unwilling to provide information on the FAFSA or for Verification.
Parents do not claim the student as a dependent for income tax purposes.
Student demonstrates total self-sufficiency.
FSA Handbook: AVG-113,

21. Dependency Override Documentation
Crucial for compliance
Include professional/personal input
Strong third party documentation
Teacher, therapist, medical authority, clergy member, prison administrator, government agency or court
If third party documentation not possible, signed and dated statement from student and/or family is acceptable – as a last resort only
Administrator may, without gathering documentation, use an override that another school granted in the same award year
Per FSA Handbook

22. Continuing Dependency Overrides
Student files next year FAFSA without parent information
FAFSA will reject
Student must confirm Dependency Override situation is unchanged
Signed and dated statement
FAA must confirm Dependency Override still valid
Recollecting documentation not required

23. Homeless Youth Determination
Student is at risk of being homeless
Housing is no longer fixed, regular or adequate
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
Student is self-supporting, unaccompanied youth.
Self-supporting – student pays for own living expenses
Unaccompanied – not living in the physical custody of a parent/guardian
Youth – 21 years old or younger or still enrolled in high school

24. Homeless Youth Determination
Per FSA Handbook –
Use discretion when gathering information
Respect the student’s privacy
Police reports nor Child Protective Services documentation not necessary
Do not focus on why the student is homeless or unaccompanied
Determine eligibility based on the legal definitions

25. Homeless Youth Determination - Confirmation
Per FSA Handbook –
FAA not required to confirm the answers to the homelessness of the youth unless you have conflicting information
Documented phone call with, or a written statement from, a relevant authority is sufficient verification when needed
FAA may use decision made by prior school within same award year

26. Homeless Youth Determination
Dependency Override
Don’t focus on “why”
Need to know “why”
3rd party docs helpful
Professional
Judgment Needed
Renewal
Required
Parents might be involved &
also considered homeless
Parents typically disassociated
with student entirely
Rare & Unusual
Need to be
thoroughly documented
Fairly
Loose Regulations
3rd party docs required

27. Questions?