Federal Student Aid stated that some institutions are unnecessarily restricting applicants’ access to aid by asking applicants to provide justification as to why they are homeless or unaccompanied rather than evidence that they have been determined to be homeless or at risk of being homeless. Institutions should limit any inquiry to whether the applicant has been determined to be an unaccompanied youth who is homeless, or at risk of being homeless, rather than the reasons for the applicant’s homelessness.
They also published a reminder to schools about the guidance in GEN-15-16, reiterating that institutions are not required to verify the answers to the homeless youth questions on the FAFSA. However, in instances where the institution does request documentation to verify a student’s homeless youth status, verification documentation may include a documented phone call or a written statement from the student or documentation from the relevant authority that provided the student’s homeless youth determination. A relevant authority may be:
- A school district homeless liaison (often referred to as a McKinney Vento Liaison),
- The director (or their designee) of a program funded under subtitle B of title IV of McKinney-Vento (relating to emergency shelter grants), or
- A Housing and Urban Development homeless assistance program director funded under McKinney-Vento or RHYA.
Generally an FAA may not override, ignore, or reject a determination made by one of the above relevant authorities. However, if an FAA has questions about the submitted documentation, he or she should contact the relevant authority.