MASFAA 2013

October 6th – 9th, 2013

Indianapolis, Indiana

What You Need to Know to Comply with Federal Policies for

Unaccompanied Homeless Youth

Presenters

Ginger Arvin, Homeless Liaison, Indianapolis Public Schools

Mark Delorey, Director of Financial Aid, Western Michigan University

Barbara Duffield, Policy Director, NAEHCY Crystal Haslett, Homeless Liaison,

Metropolitan School District of Washington Township

Cyekeia Lee, National Higher Education Liaison, NAEHCY

How Many Youth Experience Homelessness?

1.6 to 1.7 million youth run from home each year

Public schools enrolled 1,166,339 homeless children and youth in 2011-12◊ 10% increase over the previous year◊ 71% increase since 2006-2007

(recession)

Why Are Youth Homeless andOn Their Own?

Physical and sexual abuse Parental drug and alcohol abuse Abandoned or neglected Kicked out due to sexual

orientation or pregnancy

Homeless Youth and Foster Care

Youth in foster care returned to unstable/unsafe arrangements

Youth adopted from foster care, but kicked out after age 18

Youth exit foster care without adequate housing and/or supports

Youth fear foster care and hide from it

Definitions

• HEA contains definitions of “unaccompanied” and “homeless”

• These definitions match the education subtitle of the McKinney-Vento Homeless Assistance Act

• McKinney-Vento Act: a federal law that provides protections and services for homeless children and youth in the K-12 education system

Definitions, Continued

• Unaccompanied: not living in the physical custody of a parent or guardian

• Homeless: lacking fixed, regular, and adequate housing.

• Specifically includes sharing the housing of others due to loss of housing, economic hardship, or similar reason; motels; shelters; transitional housing

Why So Broad a Definition?

Shelters do not exist in suburban and rural areas

Existing shelters are full Shelters have restrictive rules Motels unavailable, or too expensive Unaccompanied youth fear adult shelters Shelters often have time limits Youth may be unaware of alternatives,

fleeing in crisis

Where Do Most Homeless Youth Live?

ED collects data annually from all public school districts

• In the 2011-2012 School Year:• 75% were sharing the housing of

others due to loss of housing, economic hardship, or similar reason

• 15% were in shelters• 5% were in motels• 3% were unsheltered

Definition of Youth

• The McKinney-Vento Act, the Higher Education Act, and HUD’s Homeless Programs do not define “youth.”

• However, the U.S. Department of Education has defined “youth” in the notes of the FAFSA to mean age 21 or younger.

Independent Student Status

Youth who are determined to be unaccompanied and homeless in the year in which they are submitting their FAFSA are independent students.

Who Makes Determinations?

School District homeless liaison RHYA-funded shelter director or

designee HUD-funded shelter director or

designee College financial aid

administrator

Application and Verification Guide

◊ Verification is not required unless there is conflicting information

◊ If a student does not have, and cannot get, documentation from a local liaison, RHYA provider, or HUD provider, a FAA must make a determination of homeless/unaccompanied status based on the legal definitionsA documented interview (even via phone) is acceptable

◊ Should be done with discretion and sensitivity

Determination Process for FAAs

◊ This is not professional judgment or a dependency override; a determination must be made

◊ Two Step Process:• Does the student meet the legal

definition of homeless?• Does the student meet the

definition of unaccompanied?

NAEHCY Survey: Liaisons

No barri-ers en-

countered

After a student’s first year, financial aid office required burden-

some documen-

tation

Financial aid office unaware of policies for unac-

com-panied

homeless youth

Financial aid office insensi-

tive/intim-idating to students/providers

Financial aid office required

student to obtain

additional documen-

tation

Don’t know who to contact for help at

ED

Financial aid office would not accept a

statement from a

school li-aison

No appeal process if financial aid office refuses to

accept youth’s

homeless status

22 and 23 year old

homeless students must ask

for de-pendency override

Financial aid office would not accept a

statement from other

agency/person

Financial aid office would not accept a

statement from a

homeless provider

When we contacted ED, they did not help re-

solve the situation

Series1 45.7% 29.6% 18.4% 15.2% 15.2% 12.6% 9.4% 9.4% 9.0% 8.1% 0.9% 0.0%

2.5%

7.5%

12.5%

17.5%

22.5%

27.5%

32.5%

37.5%

42.5%

47.5% 45.7%

29.6%

18.4%

15.2% 15.2%12.6%

9.4% 9.4% 9.0% 8.1%

0.9% 0.0%

Barriers Reported by LEA Homeless Liaisons

Perspective: Complexity

• Application & Verification Guide is clear

• Definitions are WAY easier than what we had for year-round Pell, Borrower-Based, UEH

• Verification is NOT required• Conflicting information rules apply• If the student has documentation from

their district homeless liaison, or the director of a shelter for homeless or runaways, they are eligible

Perspective: Complexity

• If there is no documentation, FAO must determine based on the definition already covered

• UHY is not a PJ – Dependency Override

• Determine if the student meets the criteria

• We don’t Decide if the student should be independent

• Don’t ask Why “Didn’t get along vs. ….”

Perspective: False Positives

• All statuses have false positives• Establish dialogue with the

student • If not UHY, then what?• Would PJ be appropriate?• Instruct them to apply as

dependent!

Resources

NAEHCY Higher Education Hotline:855-446-2673

Website:http://naehcy.org/educational-resources/higher-ed

Cyekeia Lee, Higher Education Liaison, clee@naehcy.org

FAFSA Tips for Unaccompanied Youth Without Stable Housing

Eligibility Tool/Questions for FAAs Determination Template/Form Helping Unaccompanied Homeless Youth Access

College Toolkit