Supporting Unaccompanied Homeless Youth in Accessing Higher Education

1. Supporting Unaccompanied Homeless Youth in Accessing Higher Education Christina Dukes, Program Specialist,cdukes@serve.org Jennifer Martin, Senior Content Development Specialist, martinj@nasfaa.org

2. Foundational Documents • 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

3. Who are Unaccompanied Students? • 2-step process • Does the student’s living arrangement meet the McKinney-Vento Act’s definition of homeless? • 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 home • Youth or parents may or may not disclose the full nature of the family issues; these are often very personal discussions

4. Higher Education Basics • College Cost Reduction and Access Act (CCRAA) • FAFSA = Free Application for Federal Student Aid • EFC = Expected Family Contribution • Dependent Student • Must report parent information on FAFSA • EFC is calculated based on parents’ and student’s income and assets • Independent 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 TheBasics

5. Classification as “INDEPENDENT” • Independent if ANY of these are true: • Married • 24 Years Old • Veteran Or On Active Duty • Graduate Student • Has a Legal Dependent (child/other) • Orphan/Ward of the Court/In a Legal Guardianship • Legally Emancipated Minor • In foster care at age 13 or older • Unaccompanied Homeless Youth • Independent by Professional Judgment

6. Determining Independent Student Status for UHY • 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 Administrator • Local Liaisons and State Coordinators can play an advocacy role in cases where they are not making the official determination

7. Independent Status for Unaccompanied Students • 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

8. 2012-2013 Online FAFSA

9. 2012-2013 Online FAFSA Encourage students to complete the FAFSA online.

10. 2012-13 PDF FAFSA

11. Notes from the 2012-13 PDF FAFSA No “general 4th question” included in the PDF FAFSA.

12. 2011-12 Application and Verification Guide • Guidance on verification by FAAs • Verification 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 information • Some information may be confidential (e.g., protected by doctor-patient privilege) • Child welfare or police reports are not necessary • Recommends 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

13. Determination vs. Verification • 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

14. Tax Issues • Tax issues and FAFSA issues operate in separate domains • The 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

15. First Steps • 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 available • Have the UHY excerpt of the AVG “at the ready”

16. First Steps (cont) • 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!

17. Tips • 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

18. More Information NCHE website:http://center.serve.org/nche/ibt/higher_ed.phphttp://center.serve.org/nche/best/higher_ed.php National 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/

19. Regional and Local Contacts • 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

20. Resources • 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