Refugee and asylee students face unique challenges in accessing higher education, but financial aid administrators can play a crucial role in supporting them. These students are eligible for federal financial aid, yet navigating the documentation and verification processes can be complex. Below are key considerations and best practices to ensure that refugee and asylee students receive the aid they are entitled to.
Understanding Eligibility
Refugee and asylee students, along with other eligible noncitizen groups, qualify for federal student aid under Title IV. Eligible noncitizen categories include:
- Refugees and asylees
- Lawful permanent residents
- Conditional residents
- Parolees (Parolee-Indefinite or Parolee-Expires)
- Cuban-Haitian Entrants
- Victims of human trafficking (T-visa holders)
- Battered immigrants under the Violence Against Women Act (VAWA)
- American Indians born in Canada (Jay Treaty students)
Financial aid offices should refer to the Federal Student Aid (FSA) Handbook for up-to-date guidance on verifying eligibility and required documentation.
Key Documentation and Verification Processes
- I-94 Forms
- The expiration date on an I-94 form refers to the form itself, not the student’s immigration status, so if a student has an I-94 form, this can still be used for verification purposes, even if the form appears to be expired, since refugee status does not expire unless revoked by the Department of Homeland Security (DHS), even if the student later obtains Lawful Permanent Resident (LPR) status.
- Similarly, asylum status remains valid unless revoked or until permanent residency is granted.
- Conflicting Information on Bachelor’s Degree Status
- A student who originally reported having a bachelor’s degree but later changed the response to qualify for a Federal Pell Grant must provide written documentation proving that their foreign credential is not equivalent to a U.S. bachelor’s degree.
- Institutions can use foreign transcript evaluation services to verify credentials.
- Non-English High School Diplomas
- Schools may use foreign diploma evaluation services to verify the validity of a high school diploma.
- Institutions cannot require students to provide translated diplomas unless it is part of a standard admissions policy for all students with foreign diplomas.
SAVE System and Third-Step Verification
Schools must complete third-step verification through the Systematic Alien Verification for Entitlements (SAVE) system when:
- The student’s documentation supports their noncitizen status but was not confirmed during the secondary match process.
- The student’s status was confirmed, but conflicting information exists.
If third-step verification takes longer than 15 business days and no conflicting information is present, aid administrators may determine eligibility and disburse aid. If a response later reveals ineligibility, no further aid can be disbursed, and the student must return previously disbursed funds (excluding Federal Work-Study earnings).
Distinctions Between Refugees, Asylees, and DACA Students
While refugee and asylee students qualify for the same federal financial aid programs as U.S. citizens, Deferred Action for Childhood Arrivals (DACA) students do not. DACA students remain ineligible for federal aid but may qualify for state or institutional aid depending on individual state policies.
Best Practices for Financial Aid Offices
- Stay Informed: Regularly review FSA and DHS updates to stay current on policies affecting refugee and asylee students.
- Streamline Verification: Train staff to recognize valid documentation and ensure a smooth verification process to prevent unnecessary delays in awarding aid.
- Provide Clear Guidance: Offer multilingual resources and workshops to help students understand their eligibility and documentation requirements.
- Collaborate with Campus Partners: Work with admissions, international student services, and academic advising offices to provide holistic support to refugee and asylee students.
By proactively addressing these challenges, financial aid administrators can help refugee and asylee students successfully access higher education and achieve their academic goals. HEAG is committed to helping schools and financial aid administrators navigate these policies through these challenging times. For further assistance, don’t hesitate to reach out to us at info@heag.us. Our team of qualified experts is ready to assist you by sharing regulatory guidance and best-practices.