Postsecondary attainment is increasingly necessary to move out of poverty, and live a healthy life. Yet youth experiencing homelessness and youth from foster care face unique barriers in transitioning to and completing postsecondary education. One of the most significant barriers is access to financial aid; without financial aid, they cannot transition to and complete their college education, and remain at higher risk of continued homelessness and hardship as adults. 

Unaccompanied youth experiencing homelessness are not living with, or supported by, a parent or guardian. Therefore, under the Higher Education Act, they are considered independent students and do not need to provide a parent’s signature or information about parents’ income on the FAFSA. Similarly, youth who were in foster care after age 13 are considered independent students. Despite these policies, a 2016 Government Accountability Office report found that burdensome financial aid program rules make it more difficult for both unaccompanied homeless youth and youth from foster care to obtain federal financial assistance for college.

The FAFSA Simplification Act (enacted as part of the Consolidated Appropriations Act, 2021 and updated by the Consolidated Appropriations Act, 2022) aims to remove many of the barriers faced by youth experiencing homelessness or with experience in foster care. The U.S. Department of Education (ED) started implementing the FAFSA Simplification Act in phases with the 2023-2024 FAFSA and released further guidance in April 2023. The changes for homeless and foster youth are summarized below.

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1. Homeless or foster care status does not need to be redetermined every year.

Under the FAFSA Simplification Act, any student who is determined to be an unaccompanied homeless youth, or a former foster youth, for a preceding award year is presumed to be independent for each subsequent year at the same institution, unless the student informs the institution that circumstances have changed, or the institution has specific conflicting information about the student’s independence, and has informed the student of this information. According to guidance issued by ED in April 2023, 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. While schools may ask students if their homeless situation has changed, they may not maintain a practice that delays or hinders the awarding and/or disbursement of federal student aid, nor require them to submit additional documentation unless there is conflicting information that the institution needs to resolve.

2. Determinations of unaccompanied homeless youth and foster youth status must be made as quickly as practicable.

In the past, delays in determinations have caused delays in aid, exacerbating financial hardship and basic needs challenges. Under FAFSA Simplification, determinations must be made as quickly as possible, may be made as early as the year before the award year for which the student submits the application, and must not be made later than during the award year for which the student initially submits the application.

3. More officials and programs are authorized to verify that an applicant is an unaccompanied homeless youth (and therefore an independent student).

Homeless youth receive services from an array of providers and educators. Under the FAFSA Simplification Act, additional individuals are authorized to verify this status. Authorized entities include:

• School district homeless liaisons or their designee;
• The director or a designee of a director of an emergency or transitional shelter, street outreach program, homeless youth drop-in center, or other program serving individuals who are experiencing homelessness;
• The director or a designee of a director of a program funded under a TRIO or Gaining Early Awareness and Readiness for an Undergraduate program (“GEAR UP”) grant;
• A financial aid administrator at the current institution or at another institution who previously made a determination.

These entities can use this sample form letter to provide unaccompanied homeless youth with a determination.

4. Financial aid administrators must consider and accept documentation from one of the entities who are authorized to verify a youth’s status as an unaccompanied homeless youth, unless there is “documented conflicting information.”

For unaccompanied youth experiencing homelessness, documentation from one of the authorized entities may include a documented phone call, written statement, or verifiable electronic data match.

5. If an institution requires documentation that a student was in foster care when the student was age 13 or older, the financial aid administrator must accept any of the following documents (in the absence of documented conflicting information):

• A court order or official State documentation that the student received Federal or State support in foster care
• A documented phone call, written statement, or verifiable electronic data match, which confirms the student was in foster care at an applicable age
• A documented phone call or a written statement from an attorney, a guardian ad litem, or a Court Appointed Special Advocate that confirms that the student was in foster care at an applicable age, and documents the person’s relationship to the student, or 
• Verification of the student’s eligibility for an education and training voucher under the John H. Chafee Foster Care Program.

6. Financial aid administrators must make a determination of unaccompanied homeless youth status for youth who cannot get determinations from other authorities.

Public schools are required to proactively identify unaccompanied homeless youth, inform them of their status as independent students, and help them get documentation. However, many unaccompanied homeless youth still are not identified in high school — and many youth become homeless after high school. In addition, there are very few shelters or other services for homeless youth. This means that financial aid administrators will continue to have a large role in making determinations of unaccompanied homeless youth status. Under the FAFSA Simplification Act:

• Financial aid administrators must make determinations for unaccompanied homeless youth who are unable to get determinations from other entities.
• These determinations must be based on a written statement from, or a documented interview with, a student that confirms that a student is an unaccompanied homeless youth (or unaccompanied, at risk, and self-supporting). 
• The determination must be made based on the legal definitions of homeless and unaccompanied contained in the education subtitle of the McKinney-Vento Act, and independently from the reasons that the student is an unaccompanied homeless youth, or is a youth who is unaccompanied, at risk of homelessness, and self-supporting.
• Financial aid administrators can watch this role-playing video and use this template to see how to conduct an unaccompanied homeless youth documented interview. Alternatively, financial aid administrators can request students to fill out this written statement. Both of these examples are acceptable forms of documentation for unaccompanied homeless youth determinations.

7. Simplified FAFSA Question on Homelessness

The FAFSA Simplification Act requires the U.S. Department of Education to ensure that the 2024-2025 FAFSA will have a single question on homelessness status.

• The question must be an “easily understood screening question” to identify an applicant who is an unaccompanied homeless youth, or unaccompanied, at risk of homelessness, and self-supporting.
• The question must be “distinct from those relating to an individual who does not have access to parental income due to an unusual circumstance.”

8. Provisional Independent Student Status

The FAFSA Simplification Act also permits students to complete the FAFSA as a “provisional” independent student if they believe they may qualify for independent status due to unusual situations such as parental abandonment, abuse, neglect, legally granted asylum, or student or parental incarceration. While these situations are frequently the cause of, or contributing factors to, youth homelessness, it is important to note that the new homeless and foster youth provisions are different and distinct from the new provisional independent student status. Unlike the provisional independent student status provision, financial aid administrators must make determinations for unaccompanied homeless youth and foster youth, following the processes outlined in the law – it is not a matter of their professional judgment. However, the provisional independent provisions may be helpful for youth who are neither homeless nor former foster youth, but who nonetheless have extenuating circumstances that preclude being able to obtain parental information.

Applicants must still indicate an unusual circumstance and request a determination of independence with their school. Starting in the 2024-25 FAFSA, students can submit their application under a provisional independent status until the financial aid office makes a  determination. This will allow such applicants to receive a Student Aid Index (SAI) with an estimate of their Federal student aid eligibility, subject to a final determination by their school. Financial aid administrators must:

• Notify students of the school’s process, requirements, and reasonable timeline to review adjustment requests after their FAFSA form is submitted;
• Provide students with a final determination of their dependency status and financial aid award as soon as practicable after reviewing all requested documentation;
• Retain all documentation, including documented interviews, related to the adjustment for at least 3 years after the student’s last term of enrollment; and
• Presume that any student who has obtained an adjustment for unusual circumstances and a final determination of independence to be independent for each subsequent award year at the same institution unless the student informs the institution that their circumstances have changed or the institution has conflicting information about the student’s independence.