Homeless Youth & Federal Financial Aid

1. Homeless Youth & Federal Financial Aid Mark Delorey, Director of Financial Aid Western Michigan University

2. Our Role in Assisting/Enforcing

3. What is theMcKinney-Vento Act?

4. Eligibility for McKinney-Vento Rights and Services • Children or youth who lack a fixed, regular, and adequate nighttime residence, including: • Sharing the housing of others due to loss of housing, economic hardship, or similar reason (“doubling up”) • Living in motels, hotels, trailer parks, camping grounds due to the lack of adequate alternative accommodations • Living in emergency or transitional shelters

5. Eligibility for McKinney-Vento Rights and Services • Awaiting foster care placement • Living in a public or private place not designed for humans to live • Living in cars, parks, abandoned buildings, substandard housing, bus or train stations, or a similar setting • Migratory children living in the above circumstances • Unaccompanied youth living in the above circumstances

6. Homeless?...Really? • Set aside preconceived notions of what homelessness “looks like” • Pay close attention to the legislative definition and its wording • Consider “relative permanence” of the living arrangement • Consider practical implications of high mobility and/or estrangement from parents and their effects on a student’s education • Reference NCHE’s Determining Eligibility brief at www.serve.org/nche/briefs.php

7. Fixed, Regular, and Adequate • Fixed: Stationary, permanent, and not subject to change • Regular: Used on a predictable, routine, or consistent basis (e.g. nightly) • Adequate: Sufficient for meeting both the physical and psychological needs typically met in home environments Can the student go to the SAME PLACE (fixed) EVERY NIGHT (regular) to sleep in a SAFE AND SUFFICIENT SPACE (adequate)?

8. Why the“Broad Definition”? • Shelters are often full, turning youth away • There are no shelters in many suburban and rural areas • Eligibility rules of shelters often exclude unaccompanied minors • Youth may fear adult shelters • Shelters often have 30-, 60-, or 90-day time limits • Youth may be unaware of alternatives, fleeing in crisis, living in over-crowded, temporary, and sometimes unsafe environments

9. Rights McKinney-Vento K-12 • Immediate enrollment, even if lacking paperwork • Choice of schools • School of origin (if feasible) • School of residence • Transportation to school of origin, if requested by parent or guardian • Academic support (Title I, removal of barriers, etc.) • Comparable services

10. 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”; in practical terms, this means the youth does not live with the parent or guardian

11. Barriers to Education • Lack of financial means to live independently and safely • Inability to be financially self-sufficient once enrolled in college • Limited housing options, especially in small towns or rural areas • Struggling to balance school and other responsibilities • Lack of adult guidance and support • Lack of access to parental financial information and support • Failure to access available support systems

12. Demographics Source: Homeless Youth in the United States: Recent Research Findings and Intervention Approaches, http://aspe.hhs.gov/hsp/homelessness/symposium07/toro/index.htm • Multiple studies estimate that 1+ million youth ages 12-17 will become homeless unaccompanied youth each year • A disproportionate representation of minority ethnic groups, LGBTQ youth, and pregnant/parenting teens • Generally aged 13 or older, but can be younger

13. Paths to Being“On Your Own” • Longstanding patterns of family conflict: blended family issues, pregnancy, sexual activity or orientation, school problems, alcohol/drug use • Abuse and/or neglect within the home • Parental incarceration, substance abuse, mental illness, hospitalization, or death

14. Paths to Being“On Your Own” (cont) • Foster care issues: running away from a foster care placement, aging out of the foster care system; significant correlation between involvement with the child welfare system and experiencing homelessness as an adult • Foster care placement MISSES youth • Standards to terminate parental rights leads some youth to take matters into their own hands

15. Paths to Being“On Your Own” (cont) #Some students become homeless with their families, but end up on their own due to lack of space in temporary accommodations or shelter policies that prohibit adolescent boys

16. “But, the student chose to leave…” • A youth can be eligible regardless of whether he/she was asked to leave the home or “chose” to leave • Sometimes there is “more than meets the eye” for youth’s home life situations • “I left because I didn’t get along with my step-father”….Often means…..

17. Would You? If your home life was turbulent and/or problematic, would you disclose this information in detail to a person you are just meeting? Unaccompanied homeless students and/or parents may or may not wish to discuss or feel comfortable sharing issues occurring in their home life.

18. The School’s Charge • Schools first and foremost are educational agencies • The school’s primary responsibility and goal is to enroll and educate in accordance with federal law, which supersedes state and local law • Schools do not need to understand and/or agree with all aspects of a student’s home life to educate him/her and comply with federal educational mandates

19. Independent Status for Unaccompanied Students • College Cost Reduction and Access Act • Independent student status on the FAFSA for unaccompanied homeless youth and self-supporting youth at risk of homelessness • Can apply for aid without parental signature or consideration of parental income • Must be determined by: • Local liaison • RHYA-funded shelter director or designee • HUD-funded shelter director or designee • College Financial Aid Administrator

20. Independent Status for Unaccompanied Students • CCRAA uses the McKinney-Vento definition of homeless; also includes a student living in the dorms if he/she would otherwise be homeless • At risk of homelessness: “when a student’s housing may cease to be fixed, regular, and adequate” • Includes a homeless student fleeing an abusive parent, even if the parent would provide housing and support

21. 2011-12 FAFSA

22. 2011-12 FAFSA

23. The Role of the FAA • According to the Application and Verification Guide, if a student does not have, and cannot get, documentation from a Local Liaison, RHYA provider, or HUD provider, a financial aid administrator must make a determination of homeless/unaccompanied status • This is not an “exercise of professional judgment” or a “dependency override” for youth 21 and younger; this is determining the independent student status of an unaccompanied homeless youth

24. 2009-2010 Numbers • Numbers for January 1, 2009 through June 30, 2010, FAFSA application period • Total Number of Applicants for Independent Status - 19,490,665 • Total Number of  Applicants who indicated a homeless circumstance - 47,204 (.24% of total independent applicants) • Determined by Local Liaisons: 15,190 applicants – (.08% of total independent, 32% of homeless) • Determined by HUD provider: 11,950 applicants – (.06% of total independent, 25% of homeless) • Determined by RHYA provider: 20,064 applicants – (.10% of total independent, 43% of homeless)

25. Determining Who Qualifies to be Independent Based on the Definition

26. Federal Homeless Youth Definitions • Youth – 21 or Younger* • Fixed Housing • Regular Housing • Adequate Housing • At Risk of Being Homeless • Homeless • Self-Supporting • Unaccompanied *Students who are older than 21 but not yet 24 and who are unaccompanied and homeless or self-supporting and at risk of being homeless may qualify as “independent by professional judgment” but they do not qualify to be independent as “homeless”.

27. Additional Federal Guidance “A financial aid administrator can also determine if a student is an unaccompanied youth who is either homeless or is self-supporting and at risk of being homeless. It is important that you examine students’ living situations and claims on a case-by-case basis.”

28. Verification Not Required?! “You are not required to verify the answers to the homeless youth questions unless you have conflicting information.”

29. BUT!!! 2010-11 Federal Student Aid Handbook, Application and Verification Guide, Chapter 2, Step 3, Pages 28 &29 has two pages of qualifying language. Definition of conflicting information is very broad and covers the entire institution.

30. 2010-11 Federal Student Aid Handbook

31. Financial Aid Office Communication and Processing Concerns • The questions on the FAFSA are confusing • Having the age distinction (21 and younger, 22-23) creates MUCH confusion • Many applicants who claim the status are NOT homeless • Many who “should” qualify have NOT been in shelters so the questions do not apply

32. Financial Aid Office Audit Concerns • Paid consultants are telling dependent applicants to claim the status • Some fraudulent documentation is being submitted • There is not always clear, verifiable, recognizable, consistent documentation • Possibility of a standard certification??

33. Acceptable Documentation • Letters on official letterhead from • Homeless liaison • Counselor/teacher/coach/priest-minister-rabbi-etc. • Shelter director • Case worker • Interview with student and written statement • Letters from anyone supporting case

34. Supporting Unaccompanied Students in Your School • Refer unaccompanied students to campus and community support services upon admission • Establish coordination between financial aid offices, student support services, and campus housing • Establish a food and clothing bank on campus • Plan housing for homeless students when dormitories close; ideas include leaving one residence hall open or establishing a list of “host homes” in the community • Establish a mentoring program for unaccompanied homeless youth

35. Supporting Unaccompanied Students in Your School • Become familiar with the Application and Verification Guide • Become familiar with the McKinney-Vento Act’s definition of homeless and apply it to students’ circumstances on a case-by-case basis • Consult with Local Liaisons, State Coordinators, or NCHE • Be reasonable and sensitive when requesting information from students • Advocate!

36. ABC News 20/20 last Friday • Put on a bus to San Francisco • Found a much older man willing to “help” • Couch surfing • Parents can no longer afford kids

37. Real Life Alternatives to School • Prostitution • Drug trafficking • Stealing • Suicide • If very lucky, a minimum wage job

38. Questions? Mark Delorey Director of Financial Aid Western Michigan University 1903 West Michigan Ave. Kalamazoo, MI 49008 269-387-6037 mark.delorey@wmich.edu