Understanding Federal Aid Policy and Practice for Unaccompanied Homeless Youth

1. Session # 38 Understanding Federal Aid Policy and Practice for Unaccompanied Homeless Youth Cyekeia Lee (NAEHCY) | Dec. 2014 National Association for the Education of Homeless Children and Youth 2014 FSA Training Conference for Financial Aid Professionals

2. Homeless Children and Youth Children or youth who lack a fixed, regular, and adequate nighttime residence, including • Sharing the housing of other persons due to loss of housing, economic hardship, or a similar reason • Living in motels, hotels, trailer parks, or camping grounds due to the lack of alternative adequate accommodations • Living in emergency or transitional shelters • Awaiting foster care placement

3. Homeless Children and Youth • Living in a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings • Living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings • Migratory children living in the above circumstances • Unaccompanied youth living in the above circumstances Visit http://center.serve.org/nche/legis/mv-def.php for more information

4. Family and Youth Homelessness Shelters are not an option for all families and/or youth experiencing homelessness • Shelter demand often exceeds supply • Many communities don’t have shelters • Shelters may have stay limits • Families don’t want to be separated • Safety can be a concern

5. Number of Homeless Children and Youth 2012-13 national numbers • 1,258,182 homeless children and youth enrolled in public schools • 8% increase over the previous year • 85% increase since 2006-07 recession • 34 states reported an increase • 75,940 unaccompanied homeless youth • 37,598 children ages 3-5

6. Causes of Family Homelessness • A lack of affordable housing • Unemployment or underemployment • Physical or mental health challenges • The challenges of single parenting • Domestic violence

7. Causes of Youth Homelessness • Sexual, physical, or emotional abuse • Parental mental illness, incarceration, or drug use • Conflict related to blended family issues • Conflict related to the student’s sexual orientation, pregnancy, or drug use • Financial strain

8. Foster Care and Homelessness Correlation between child welfare involvement and experiences of homelessness • For school-age youth • Foster care placements often are short-term or may be unstable • Some students leave foster care placements due to feeling unsafe and/or isolated • For youth aging out of care • Exit the foster care system without sufficient preparation and/or support to be successful living independently

9. Foster Care and Homelessness • By age 24, 29% of youth who aged out of foster care had been homeless for at least one night • 28% reported having couch-surfed since exiting care • In total, nearly 40% of youth had experienced homelessness or had couch-surfed since exiting care Dworksy, A.& Courtney, M. (2011). Assessing the impact of extending care beyond age 18 on homelessness: Emerging findings from the Midwest study, Washington, DC: The Urban Institute. Retrieved from http://www.chapinhall.org/sites/default/files/publications/Midwest_IB2_Homelessness.pdf

10. Foster Care and Homelessness • 6% became homeless within the first month after exiting care • 14 % within the first year • 20% within the first 2 years • 22 % within the first 30 months • 63% of the young people who became homeless within the first 30 months post-exit did so during the first year Dworksy, A.& Courtney, M. (2011). Assessing the impact of extending care beyond age 18 on homelessness: Emerging findings from the Midwest study, Washington, DC: The Urban Institute. Retrieved from http://www.chapinhall.org/sites/default/files/publications/Midwest_IB2_Homelessness.pdf

11. Barriers to Higher Education Access • Lack of parental income and support • Barriers accessing financial aid • Barriers receiving subsequent year determinations of homeless status • Lack of housing during holiday and summer breaks • Food insecurities on campus • Lack of information about available support systems • Struggle to balance school and other responsibilities 11

12. Single Point of Contact (SPOC) Model “Single Point of Contact”– a supportive college administrator on each campus who is committed to helping homeless youth (and often foster youth) successfully navigate the college-going process on campuses Assist students with the following • Admissions • Financial aid • Academic advising • Student life • Community resources

13. Where Are SPOC’s Located ? SPOCs are found in the Financial Aid, Counseling, Dean of Students, Ombudsmen, or Student Support Services offices on campus • In place in CO, NC, MI, and GA • In progress in AL, FL, NH, NV, MA, NJ, IN, PA • Kennesaw State University • Social Worker staffs C.A.R.E Center • Food Bank • Clothing Closet • Housing Support • Scholarship Assistance http://www.kennesaw.edu/studentsuccessservices/care/

14. SPOC Model Benefits of having a SPOC on campus • Allow unaccompanied homeless youth to have support finding campus and community resources • Reduces the number of times student have to repeat, or relive, situations that led to them becoming homeless • Having a staff member on campus that is knowledgeable of federal guidance, and state laws impacting higher education access and success for unaccompanied homeless youth

15. State Networks • Convene a meeting with local stakeholders from McKinney-Vento K-12, Higher Education, RHYA/HUD shelter communities as well as other local service providers and advocates • Allow each to share knowledge about their area of expertise • UHY and independent student definitions • Financial aid • Campus and community resources • Build an action plan for serving UHY that makes sense for your community

16. State Networks • Networks are formed by having homeless education or homeless policy professionals partner with higher education professionals • Members collaborate to identify and address barriers to higher education access, retention, and success for youth experiencing homelessness • Current states include: CO, NC, NH, KY, FL, GA, IL, MI, MA, and OK • In development: NY, NJ, VA, IN, and MT

17. State Networks Best practices include • Establishing SPOCs on campuses • Establishing food or clothing pantries on campus • Establishing emergency funding to obtain IDs, bed sheets, toiletry items, etc. • Establishing scholarships for homeless youth on campus • Providing housing during breaks

18. Session # 38 Understanding Federal Aid Policy and Practice for Unaccompanied Homeless Youth Aaron Washington (ED) | Dec. 2014 U.S. Department of Education 2014 FSA Training Conference for Financial Aid Professionals

19. Student Eligibility for Title IV Aid • Our most basic eligibility requirements are that a student must: • Be a U.S. citizen or eligible noncitizen • Have a valid SSN • Register with the Selective Service if you’re a male between the ages of 18 and 25 • Maintain SAP • Have a H.S. diploma/equivalent or home-school • Demonstrate financial need (for most programs)

20. Title IV Aid & Unaccompanied Homeless Youth • Statute • Higher Education Act • McKinney-Vento Homeless Assistance Improvements Act • Runaway and Homeless Youth Act • Free Application for Federal Student Aid (FAFSA) • Dependency Questions • Federal Student Aid (FSA) Handbook • Application and Verification Guide

21. McKinney-Vento Act • Section 725 definition of homeless youth: • means individuals who lack a fixed, regular, and adequate nighttime residence, this includes-

22. McKinney-Vento (cont’d) • children and youths who are sharing the housing of other persons due to loss of housing, economic hardship, or a similar reason • children and youths who have a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings • children and youths who are living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings; • migratory children (as such term is defined in section 1309 of the Elementary and Secondary Education Act of 1965) who qualify as homeless for the purposes of this subtitle because the children are living in circumstances described in the first three bullets

23. HEA • Section 480(d)(1)(H)-Definition of independent student: • Has been verified during the school year in which the application is submitted as either an unaccompanied youth who is a homeless child or youth (as such terms are defined in section 725 of the McKinney-Vento Homeless Assistance Act), or as unaccompanied, at risk of homelessness, and self- supporting, by-

24. HEA (cont’d) • a local educational agency homeless liaison • the director of a program funded under the Runaway and Homeless Youth Act or a designee of the director; • the director of a program funded under the McKinney-Vento Homeless Assistance Act or a designee of the director; or • a financial aid administrator

25. 2014-15 FAFSA-Dependency Questions

26. FAFSA (cont’d)

27. AVG-FSA Handbook • You are not required to verify the answers to the homeless youth questions unless you have conflicting information • A documented phone call with, or a written statement from, one of the relevant authorities is sufficient verification when needed • It is not conflicting information if you disagree with an authority’s determination that a student is homeless

28. AVG-FSA Handbook (cont’d) • If the student claims to be homeless and cannot answer yes to question 56, 57, or 58 on the 2014-15 FAFSA, you are required to make a homeless youth determination • You can get assistance with making case-by-case determinations by contacting: • College access programs (TRIO, GEAR UP, etc.) • Doctors • Social Workers • Mental Health Professionals • The determination may be based on a documented interview with the student if there is no written documentation available

29. AVG-FSA Handbook (cont’d) • A Homeless Youth Determination is not a dependency override or a case of professional judgment

30. AVG-FSA Handbook (cont’d) • Students determined to be unaccompanied homeless youth • You should select option 4 in the dependency override field in FAA Access to CPS Online or Electronic Data Exchange (EDE) • You may also rely on a determination by another school that on or after July 1, 2013, a student was homeless • Students who would be homeless unaccompanied youth but are over 21 (and not yet 24) qualify for a dependency override

31. NAEHCY Case Study & FAQ’s

32. Case Study Shannon is a 19-year old sophomore. For her freshman year, she filed her FAFSA as a dependent student and her parents helped pay her tuition and included her on their health insurance. This year, Shannon filed her FAFSA much later then she did the previous year, on August 15th. Her Institutional Student Information Record (ISIR) has a Special Circumstances Flag of 3, indicating Shannon believes she meets the definition of an unaccompanied homeless youth but does not have a determination from a homeless professional.

33. Case Study Continued Per office policies and procedures, you schedule an appointment with Shannon to discuss her situation and conduct the interview required for the institution’s determination process. During the appointment, Shannon explains that her mom is seriously ill and her father has left due to the stress of the situation. Her mom’s behavior has become increasingly erratic, and she threatened Shannon with a knife during an argument. As a result, Shannon stayed with her best friend’s family for a few weeks in the summer. When her best friend left to return to her college in another state, Shannon was told she could no longer stay with the family. Shannon couch surfed for a couple of weeks until she was able to move into on-campus housing. Shannon has no idea where she will stay when on-campus housing closes between the fall and spring semesters. Does Shannon meet the definition of being an unaccompanied homeless youth?

34. FAQ #1 Subsequent Year Determination: If a McKinney-Vento Liaison is only able to make a determination of student’s unaccompanied homeless youth status for one academic year, and a student has not stayed at an RHYA or HUD funded shelter, what steps can an FAA take to make a determination of a student’s unaccompanied homeless youth status?

35. FAQ # 1 Answer Answer: A documented interview can be conducted. Many schools have created their own determination form; however NAEHCY’s FAA Determination tool can be used to help make a determination. FAA’s can consult with NCHE, McKinney-Vento Liaison, or State Coordinator. Relevant third parties can provide information McKinney-Vento Liaison, School Counselor, TRIO or GEAR-UP staff, college or high school counselor. FAA’s can contact NAEHCY Higher Education Helpline.

36. FAQ #2 First Year Determination: If a school district McKinney-Vento Liaison provides a letter confirming that a student meets the definition of being an unaccompanied homeless youth, do you need supplemental documentation from other authorities in order to make the student independent?

37. FAQ #2 Answer Answer: Verification Not Required. See Chapter 5 of the of the 2014-15 Application and Verification Guide page 128. You are not required to verify the answers to the homeless youth questions unless you have conflicting information. A documented phone call with, or a written statement from, one of the relevant authorities is sufficient verification when needed.

38. FAQ #3 Dependency Status Appeal: If a 22 year old student had previously received determinations of their unaccompanied homeless youth status their freshman, sophomore, and junior year, how can you assist the student with completing a Dependency Status Appeal if they are still unaccompanied and homeless, but no longer considered a youth?

39. FAQ #3 Answer Answer: Explain the difference between making a determination of an unaccompanied homeless youth status, and making a Professional Judgment of Dependency Status Appeal. Discuss the forms and documentation needed for the appeal process (Personal Statement, third party letters, verification documentation). Assist student with questions about the appeal process.

40. Available Resources • NAEHCY Higher Education Initiative: http://www.naehcy.org/educational-resources/higher-ed • National Center for Homeless Education: http://center.serve.org/nche/ • 2014-15 FSA Handbook, Application and Verification Guide: http://ifap.ed.gov/fsahandbook/attachments/1415AVG.pdf • TRIO Programs: http://www2.ed.gov/about/offices/list/ope/trio/index.html

41. Contact Us • Barbara Duffield, bduffield@naehcy.org • Cyekeia Lee, clee@naehcy.org • Aaron Washington, aaron.washington@ed.gov

42. QUESTIONS?