mark delorey, director of financial aid western michigan university
TRANSCRIPT
Homeless Youth & Federal Financial AidMark Delorey, Director of Financial Aid
Western Michigan University
Our Role in Assisting/Enforcing
What is theMcKinney-Vento Act?
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
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
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
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 environmentsCan the student go to the SAME
PLACE (fixed) EVERY NIGHT (regular) to sleep in a SAFE AND SUFFICIENT
SPACE (adequate)?
Fixed, Regular, and Adequate
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
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
Rights McKinney-Vento K-12
Who are Unaccompanied Students? 2-step process
1)Does the student’s living arrangement meet the McKinney-Vento Act’s definition of homeless?
2)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
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
DemographicsSource: 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
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
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
#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
Paths to Being“On Your Own” (cont)
“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…..
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.
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
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
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
2011-12 FAFSA
2011-12 FAFSA
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
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)
Determining Who Qualifies to be Independent Based
on the Definition
At Risk of Being Homeless
Homeless Self-Supporting Unaccompanied
Federal Homeless Youth Definitions
Youth – 21 or Younger*
Fixed Housing Regular Housing Adequate Housing
*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”.
“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.”
Additional Federal Guidance
“You are not required to verify the answers to the homeless youth questions unless you
have conflicting information.”
Verification Not Required?!
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.
BUT!!!
2010-11 Federal Student Aid Handbook
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
Financial Aid Office Communication and Processing 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??
Financial Aid Office Audit Concerns
• 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
Acceptable Documentation
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
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!
Put on a bus to San Francisco Found a much older man willing to “help” Couch surfing Parents can no longer afford kids
ABC News 20/20 last Friday
Prostitution Drug trafficking Stealing Suicide If very lucky, a minimum wage job
Real Life Alternatives to School
Mark DeloreyDirector of Financial AidWestern Michigan University1903 West Michigan Ave.Kalamazoo, MI 49008
269-387-6037
Questions?