Recent guidance from the Department of Education on the FAFSA Simplification changes has shed new light on the problem of basic-needs insecurity among college students in the United States. According to the latest research findings, around 12.5% of households in the U.S. with young adults between the ages of 18-25 years of age are currently experiencing issues of housing insecurity (Morton et al., 2018). These odds are even greater for youth who are young parents, Black, Hispanic, or members of the LGBTQ+ community. In response to this issue, regulatory changes have been made to empower financial aid administrators to assist these students by lifting some of the regulatory burdens related to their eligibility to receive aid as independent students. This article briefly discusses some of the concerns related to the updated guidance.
As a reminder—and according to the U.S. Department of Education— “homeless youth determinations are not considered professional judgement” (PJ). They do, however, have some similarities with PJ determinations in that schools are allowed to update the ‘homeless youth determination’ mark on a student’s Institutional Student Information Record (ISIR) upon request by the student, on a case-by-case basis, with proper documentation on file justifying the change. GEN-23-06 expanded on this by affirming that FAA’s have the authority to make these determinations by documenting a conversation with the student experiencing housing insecurity issues by uploading a written statement or through a documented interview with the student that confirms that they are an unaccompanied homeless youth, or unaccompanied, at risk of homelessness, and self-supporting— WITHOUT regard to the reasons that the student is unaccompanied and/or homeless.
Moreover, and according to a recent NASFAA AskRegs article on the matter, the HEA, as amended, provides that documentation from any one of the designated authorities listed in the regulations (including FAAs) is “sufficient for establishing a student’s unaccompanied homeless youth status.” Therefore, 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.”
Affirming that the office has conflicting information regarding the student’s homelessness or at-risk-of-homelessness status might be difficult since none of the following circumstances disqualify a student from being homeless or at risk of homelessness: (a) being in contact with their parent(s); (b) being in the custody of their parent(s); (c) providing parental data on the FAFSA; or (d) listing the parent’s address on the FAFSA or other documents. (Additional AskRegs article on the matter can be found: here.)
Before making these determinations, FAA’s are therefore encouraged to brush up on the definition provided in the FSA Handbook, Application and Verification Guide (AVG), Chapter 5, ‘Homeless youth determinations’ which states that “A student is considered homeless if he or she lacks fixed, regular, and adequate housing.” This is broader than just living ‘on the street.’ It includes but is not limited to:
- Youth sharing housing with other people temporarily because they have nowhere else to go
- Youth living in emergency or transitional shelters, for example, trailers provided by the Federal Emergency Management Agency after a disaster
- Youth living in motels, campgrounds, cars, parks, abandoned buildings, bus or train stations, substandard housing, or any public or private place not designed for humans to live in
- Youth living in the school dormitory if they would otherwise be homeless
- Youth who are migrants and who qualify as experiencing homelessness because they are living in the circumstances described above
Ultimately, colleges and universities have an opportunity to plan an active role assisting students through these difficult circumstances. That being said, it is now more important than ever to ensure that these decisions are being made in accordance with the dictates and stipulations of the published guidelines listed. As always, if you have questions about this issue, or if you require further assistance completing these types of reviews, email firstname.lastname@example.org to connect with one of our compliance experts for further guidance.