Christina Dukes, Program Specialist,cdukes@serve.orgJennifer Martin, Senior Content Development Specialist, martinj@nasfaa.org

SUPPORTING UNACCOMPANIED

HOMELESS YOUTH IN ACCESSING HIGHER

EDUCATION

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The McKinney-Vento Act and Policy Guidance, available at http://center.serve.org/nche/m-v.php

The Application and Verification Guide (AVG), available at http://center.serve.org/nche/ibt/higher_ed.php

FOUNDATIONAL DOCUMENTSFOUNDATIONAL DOCUMENTS

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2-step process1. Does the student’s living arrangement meet the

McKinney-Vento Act’s definition of homeless?2. Once homelessness is determined, is the student

unaccompanied?Unaccompanied = “not in the physical custody of a

parent or guardian”Students can be eligible regardless of whether they

were forced from the home or left the homeYouth or parents may or may not disclose the full

nature of the family issues; these are often very personal discussions

WHO ARE UNACCOMPANIED WHO ARE UNACCOMPANIED STUDENTS?STUDENTS?

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College Cost Reduction and Access Act (CCRAA)FAFSA = Free Application for Federal Student AidEFC = Expected Family ContributionDependent Student

Must report parent information on FAFSA EFC is calculated based on parents’ and student’s income

and assetsIndependent Student

Does NOT report parent information on FAFSA EFC is calculated based on student’s income and assets

Youth = age 21 or younger; age 22-23 can be independent by dependency override

HIGHER EDUCATION BASICSHIGHER EDUCATION BASICS

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Independent if ANY of these are true:Married24 Years OldVeteran Or On Active DutyGraduate StudentHas a Legal Dependent (child/other)Orphan/Ward of the Court/In a Legal Guardianship

Legally Emancipated Minor In foster care at age 13 or olderUnaccompanied Homeless Youth Independent by Professional Judgment

CLASSIFICATION AS “INDEPENDENT”CLASSIFICATION AS “INDEPENDENT”

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Determinations can be made by:Local liaison (graduating high school seniors)Runaway and Homeless Youth Act funded shelter director or designee (where youth received services)

U.S. Department of Housing and Urban Development funded shelter director or designee (where youth received services)

College Financial Aid AdministratorLocal Liaisons and State Coordinators can play

an advocacy role in cases where they are not making the official determination

DETERMINING INDEPENDENT STUDENT DETERMINING INDEPENDENT STUDENT STATUS FOR UHYSTATUS FOR UHY

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CCRAA uses the McKinney-Vento definition of homeless

Includes a student living in the dorms if he/she would otherwise be homeless

Includes a homeless student fleeing an abusive parent, even if the parent would provide housing and support

INDEPENDENT STATUS FOR INDEPENDENT STATUS FOR UNACCOMPANIED STUDENTSUNACCOMPANIED STUDENTS

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2012-2013 2012-2013 ONLINEONLINE FAFSA FAFSA

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2012-2013 2012-2013 ONLINEONLINE FAFSA FAFSA

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2012-13 2012-13 PDFPDF FAFSA FAFSA

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NOTES FROM THE 2012-13 PDF FAFSANOTES FROM THE 2012-13 PDF FAFSA

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Guidance on verification by FAAsVerification of “yes” answers on the FAFSA is not required unless there is conflicting information

FAA may verify the status with a documented interview with the student

Encourages discretion and sensitivity when gathering informationSome information may be confidential (e.g., protected by doctor-patient privilege)

Child welfare or police reports are not necessaryRecommends consulting with local liaisons, State Coordinators, NCHE, school counselors, clergy, etc.

Eligibility determinations may be appealed to the school or the U.S. Department of Education

2011-12 2011-12 APPLICATION AND APPLICATION AND VERIFICATION GUIDEVERIFICATION GUIDE

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Determination refers to making the original decision that a student meets the definition of unaccompanied homeless youth and, therefore, qualifies as an independent student

Verification has a specific meaning in the “FAA world”: Verification is the process of checking, through the submission of

documentation, that an applicant correctly reported information on the FAFSA. If a student has been selected for verification, it is generally because either ED or the school thinks that information has been reported inaccurately

Other useful terms: Confirmation Documentation

DETERMINATION VS. VERIFICATION

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Tax issues and FAFSA issues operate in separate domainsThe IRS’ definition of “dependent” for tax purposes is

different that the FAFSA’s definition of “dependent” for financial aid purposes

A youth should file a tax return if they are required by the tax code to do so

It is possible for a student to meet the definition of “independent” for financial aid purposes but meet the definition of “dependent” for tax purposes, thereby enabling the parent to claim the student as a dependent legally

If a parent commits tax fraud in any way, the student is not liable for this; they would only be held liable if they participated actively and knowingly in the fraud

TAX ISSUES

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Connect with “team members”: Higher education, homeless education, other educators (guidance counselors, social workers, etc.), pre-collegiate associations (GEAR UP, TRIO, etc.)

Have an updated list of local liaisons available to share with team members

Have a list of HUD and RHYA shelters availableHave the UHY excerpt of the AVG “at the ready”

FIRST STEPS

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Use available templates: NAEHCY determination documentation template and NCHE FAA Documentation Tool

When talking with a higher education audience, team up with a higher education member so they can “talk the talk”

Homeless education issues may be very new to FAAs and other team members; be prepared to be patient and help them “learn the ropes” – you’ll catch more flies with honey…

Want to get involved in NAEHCY Higher Education Committee efforts? Let us know!

FIRST STEPS (CONT)

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When using the determination documentation template with service providers, address HIPPA concerns by having students sign giving consent to share information with institutions of higher education

Fill out a template for all graduating seniors, even if they aren’t sure if they’ll continue on to higher education; give a copy to the student, the local liaison, and the guidance counselor working with the student

Ensure students have e-mail addresses; can get free accounts through yahoo.com or gmail.com, if needed

Ensure students use their legal names that appear on vital documents, not their “street names”, on all financial aid paperwork

TIPS

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NCHE website:http://center.serve.org/nche/ibt/higher_ed.php

http://center.serve.org/nche/best/higher_ed.phpNational Association for the Education of

Homeless Children and Youth:http://www.naehcy.org/higher_ed.html

http://www.naehcy.org/tk/tk.html National Association of Student Financial Aid

Administrators:http://www.nasfaa.org/

MORE INFORMATIONMORE INFORMATION

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Regional and State Associations of Student Financial Aid Administratorshttp://www.nasfaa.org/States/Directory_of_Associations.aspx

NACAC (National Association of College Admission Counselors) Affiliateshttp://www.nacacnet.org/AboutNACAC/Governance/sra/Pages/default.aspx

Council for Opportunities in Education Member Associationshttp://www.coenet.us/ecm/AM/Template.cfm?Section=Member_Associations

State College Goal Sunday Associationshttp://www.collegegoalsundayusa.org/studentsFamilies/where.htm

REGIONAL AND LOCAL CONTACTS

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NCHE Higher Education Briefwww.serve.org/nche/briefs.php

NCHE/NASFAA Higher Education Posterwww.serve.org/nche/pr/he_poster.php

NAEHCY Determination Template: Unaccompanied Homeless Youth Verification For the Purposes of Federal Financial Aidwww.naehcy.org/higher_ed.html

NAEHCY: Income Tax and the FAFSA for Unaccompanied Homeless Youthwww.naehcy.org/higher_ed.html

NCHE/NAEHCY FAA Tool: Available soon

RESOURCES