April 20, 2023

In advance of changes to take effect on July 1, new guidance has been issued clarifying the roles and responsibilities in determining the dependency status for unaccompanied homeless youth.

In an April 14 Dear College Letter (DCL), the Department of Education provided updated guidance on the institutional and applicants' roles and responsibilities related to Title IV dependency determinations for unaccompanied homeless youth. The updated guidance is a result of changes under the FAFSA Simplification Act.

According to the guidance in the letter, financial aid administrators are to consider a student to be independent if the applicant’s status as an (1) unaccompanied and homeless youth or (2) unaccompanied and self-supporting youth at risk of homelessness is verified by one of the following authorities through a documented phone call, written statement, or a verifiable electronic data match:

• A local educational agency homeless liaison, as designated by the McKinney-Vento Homeless Assistance Act (42 U.S.C. 11432(g)(1)(J)(ii)), or a designee of the liaison
• The director or designee of an emergency or transitional shelter, street outreach program, homeless youth drop-in center, or other program serving individuals who are experiencing homelessness
• The director or designee of a program funded under subtitle B of title IV of McKinney-Vento (relating to emergency shelter grants) (42 U.S.C. 11371 et seq.)
• The director or designee of a Federal TRIO program or a Gaining Early Awareness and Readiness for Undergraduate program (GEAR UP) grant
• A financial aid administrator (FAA) at another institution who documented the student’s circumstance in the same or a prior award year

According to the Department, the law provides that documentation from one of the above authorities is sufficient for establishing a student’s unaccompanied homeless youth status.

The Department also added that if the student has received a documented determination from one of these authorities, the institution must not request additional documentation, proof, or statements unless it has conflicting information about the student’s status.

The letter outlines further steps the financial aid administrator must take in carrying out these new procedures.

For more information or to ask specific questions, financial aid professionals should use the Contact Customer Support form in FSA’s Partner Connect Help Center.