Unaccompanied Homeless Youth Determinations – Update (2024)

Dear Colleague:

Section 480(d)(8) of the Higher Education Act of 1965, as amended (HEA), provides that an applicant for Title IV federal student aid is an independent student—that is, an applicant who does not need to provide parental information on the Free Application for Federal Student Aid (FAFSA^®) form—if the applicant is an unaccompanied homeless youth or unaccompanied and self-supporting youth at risk of homelessness. This guidance supplements Dear Colleague Letter GEN-22-15, which pertains to general changes that will be in effect July 1, 2023, for the 2023-24 award year. It supersedes our previous DCL GEN-15-16 on unaccompanied homeless youth.

To be considered an unaccompanied homeless youth on the FAFSA^® form, an individual must be a youth who is (1) unaccompanied and homeless or (2) unaccompanied, self-supporting, and at risk of being homeless. Outlined below are some initial terms that support a homeless youth determination, as defined in section 725 of the McKinney-Vento Homeless Assistance Act (McKinney-Vento) (42 U.S.C. 11434a). Note that the last two definitions do not appear in McKinney-Vento. Also, institutions should refer to Chapter 5, “Special Cases,” of the Application and Verification Guide in the Federal Student Aid Handbook for additional components of the definition for homeless children and youths.

Regardless of their age, applicants who are unaccompanied and homeless, or self-supporting and at risk of being homeless, qualify for a homeless youth determination and will be considered independent students on the FAFSA^® form.

Starting with the 2024-25 FAFSA^® form, applicants under the age of 24 will be presented with a single question to determine if they are a youth who is (1) unaccompanied and homeless or (2) unaccompanied, self-supporting, and at risk of becoming homeless. If they answer “Yes” to the homeless question, they will be asked if they have a documented determination from one of the eligible authorities listed below. Applicants who affirm they are an unaccompanied homeless youth will be able to submit their application as an independent student.

First-time applicants will need to follow up with their institution to submit documentation supporting their homeless determination. Renewal applicants who had their 2023-24 FAFSA^® form processed as an independent student due to a homeless youth determination are eligible to have their status carried forward if their circumstances remain unchanged and they are enrolled at the same institution for 2024-25. Institutions will need to manually adjust 2024-25 FAFSA^® forms for students in these situations.

Beginning with the 2024-25 FAFSA^® form, applicants with an unaccompanied and homeless determination or unaccompanied, self-supporting, and at risk of homelessness youth determination will have their answer to the homeless question carried over to subsequent award years. For the 2025-26 FAFSA^® form and all applications moving forward, applicants with a previous homeless youth determination will be provided the opportunity to review the pre-populated answer to the homeless question and make a correction, if necessary, prior to submitting their form as an independent student.

In addition, homeless youth should use a mailing address on the FAFSA^® form where they can reliably receive mail. This can be, for example, the address of a relative, friend, or social service agency that has given the applicant permission to use that address. It also can be the applicant’s institution’s address, if they have contacted the institution for permission and instructions are in place to ensure that mail they receive at the institution reaches them. Applicants should update their address on the FAFSA^® form once they have more stable housing.

HEA section 479D(a)(1), as amended, requires FAAs to consider a student to be independent if the applicant’s status as an (1) unaccompanied and homeless youth or (2) unaccompanied and self-supporting youth at risk of homelessness is verified by one of the following authorities through a documented phone call, written statement, or a verifiable electronic data match:

The HEA, as amended, provides that documentation from one of the above authorities is sufficient for establishing a student’s unaccompanied homeless youth status. Therefore, if the student has received a documented determination from one of these authorities, the institution must not request additional documentation, proof, or statements unless it has conflicting information about the student’s status.

As provided in section 479D(a)(2) of the HEA, as amended, if a student indicates that they are an unaccompanied homeless youth—or unaccompanied and self-supporting youth at-risk of homelessness—and the student is unable to provide documentation from at least one of the entities listed above, FAAs must review the student’s circumstances and make the determination themselves. If FAAs are uncertain how to make the homeless determination, they can contact the local homeless liaison in their school district or one of the other authorities listed above to discuss the McKinney-Vento definition and how it applies, but the FAAs must still make the determination. To contact the state coordinator or to request contact information for the local liaison, FAAs should visit https://nche.ed.gov/data/.

Additionally, if an applicant believes they are an unaccompanied homeless youth—or unaccompanied and self-supporting youth at-risk of homelessness—but are unable to answer or are uncertain of their answer to the homeless question on the FAFSA^® form, the applicant should contact their financial aid office to request that an FAA make a homeless youth determination.

In these situations, FAAs must make a case-by-case decision that is:

FAAs should keep in mind that a student may be considered homeless if they had to flee an abusive or threatening home environment, or had other unusual circumstances, that resulted in them not having a safe, stable place to live. Even if the parent(s) in such a situation would otherwise provide housing, the student may still meet the definition for unaccompanied, self-supporting, and at-risk of becoming homeless.

In all situations, institutions should be able to show that their policies and procedures for reviewing and making homeless youth determinations are compliant with statutory requirements.

FAAs shall review the eligible authority’s documented determination or make their own determination that the student was an unaccompanied homeless youth, or at risk of being homeless, at any time on or after July 1st of the FAFSA^® “base year” (e.g., July 1, 2023, for the 2024-2025 FAFSA^® form).

Starting with the 2023-24 Award Year, institutions must review all requests for a determination of independence (including homeless youth) as quickly as possible, and as early as the year before the applicable award year, but no later than 60 days after the student enrolls. If the student is determined to be independent due to their unaccompanied homeless youth status, the institution shall presume the student to be independent for each subsequent award year at the same institution, unless the institution has conflicting information about the student’s status or the student informs the institution that their circumstances have changed.

If the FAA determines that the applicant is an unaccompanied youth who is homeless or at risk of being homeless, the FAA must submit a FAFSA^® correction using the “Homeless Youth Determination” flag. Additional information for correcting a student’s dependency status is outlined in the Application and Verification Guide in the Federal Student Aid Handbook.

Institutions must retain all documents related to unaccompanied homeless youth determinations for at least 3 years after the end of the award year which the student last attended.

For more information on the issue of homeless youth, please review “Dependency Status” in Chapter 2 and Chapter 5, “Special Cases,” of the Application and Verification Guide in the Federal Student Aid Handbook at https://fsapartners.ed.gov/knowledge-center/fsa-handbook.

You may refer additional questions to the Department using the Contact Customer Support form in FSA’s Partner Connect Help Center. To submit a question, please enter your name, email address, topic, and question. When submitting a question related to this Dear Colleague Letter, please select the topic “FSA Ask-A-FED/Policy.”

We thank you for your cooperation in ensuring that unaccompanied homeless youth receive the resources they need to succeed in their pursuit of higher education.

Sincerely,

Annmarie Weisman
Deputy Assistant Secretary for Policy, Planning, and Innovation
Office of Postsecondary Education