Free Application for Federal Student Aid (FAFSA) completion is an important indicator of college enrollment and completion, particularly for marginalized and vulnerable students. Compared to last year, FAFSA numbers are down about 9% for all students, providing cause for concern. Now, recently released FAFSA numbers for unaccompanied homeless youth provide early indications of the impact of the pandemic on the higher education prospects of youth experiencing homelessness. These findings demand attention and action: youth experiencing homelessness need additional support now more than ever if they are to access financial aid and obtain the education that is the key to overcoming homelessness.

To school district homeless liaisons, homeless service providers, and financial aid administrators:

We urge school district homeless liaisons, homeless service providers, and financial aid administrators to use these resources to remove barriers and support youth in their pursuit of higher education.

To the U.S. Department of Education:

We also urge the U.S. Department of Education both to update and re-issue guidance to financial aid administrators on homeless youth determinations and to increase oversight and monitoring of institutions.

1. For the first time in seven years of data collection, the number of FAFSA homeless youth determinations made by high schools decreased, most likely due to school closures during the pandemic. This worrisome trend threatens the progress made over the previous years.

Unaccompanied homeless youth (UHY) FAFSA determinations made by high schools make up a large majority of all UHY FAFSA determinations. In 2016, amendments to the McKinney-Vento Act went into effect requiring local educational agency (LEA) homeless liaisons to inform unaccompanied homeless youth of their status as independent students for financial aid and assist them to obtain verification of their status as unaccompanied youth experiencing homelessness. Additionally, state McKinney-Vento plans must describe how homeless youth will receive assistance from school counselors to advise and prepare them, and improve their readiness for college. FAFSA UHY data show the impact of these policy changes, as the number of high school UHY FAFSA determinations increased significantly between 2016 and 2018.

In March 2020, many schools closed abruptly due to the pandemic; as a result, many homeless liaisons and counselors lost contact with students experiencing homelessness, or faced difficulties identifying and staying in touch with them. This worrisome trend continued into the current year: survey data indicate a 28% decrease in the number of identified homeless students in the fall of 2020 compared to the fall of 2019, which translates to an estimated 420,000 fewer children and youth experiencing homelessness who have been identified and enrolled by schools so far this school year.

The decrease in UHY FAFSA determinations made by high schools threatens the progress made over the past few years. Nearly three quarters of the increase in UHY FAFSA determinations over the past seven years occurred between the 2016-2017 and 2018-2019 academic years, after enactment and implementation of amendments to federal K-12 education law to improve homeless youth’s access to financial aid. While there was a small overall increase in UHY FAFSA determinations in 2019-2020, it is less than a 1% and is mostly the result of an increase in determinations made by Runaway and Homeless Youth Act (RHYA) providers.

2. The number of FAFSA determinations for unaccompanied homeless youth decreased in 26 states between the 2018-2019 and 2019-2020 school year, also likely as a result of the pandemic.

While trends vary among states, the overall trend among states has been steady increases in UHY FAFSA determinations, with only a few states showing decreases. However, in the 2019-2020 school year, more than half of all states (26) had a drop in UHY FAFSA determinations. This trend is also a great cause for concern, and likely reflects the impact of the pandemic on the ability of unaccompanied youth experiencing homelessness to obtain the financial aid they need to pursue higher education.

3. While the number of financial aid administrator (FAA) UHY FAFSA determinations increased between 2018-2019 and 2019-2020, FAAs continue to make the fewest UHY determinations of all authorized entities.

Of all authorized entities, financial aid administrators (FAAs) continue to make the fewest UHY FAFSA determinations. It would be expected that, of all the parties authorized to make youth homelessness determinations, FAAs would make the greatest number of determinations, not the fewest. Most youth experiencing homelessness do not stay in shelters due to lack of shelter availability or limited capacity, and thus are not able to obtain verifications from HUD or RHYA providers. Moreover, only younger students who are transitioning from high school to postsecondary education are likely to have determinations from high schools or school districts. This means that FAAs are often the only parties who are able to make determinations for the vast majority of unaccompanied homeless youth. The role of FAAs in making UHY determinations takes on even greater significance during the pandemic, as homeless programs have reduced capacity due to social distancing, and youth fear seeking shelter due to the virus.

SchoolHouse Connection’s direct experience with young people and with FAAs indicates that FAAs continue to be reluctant to make UHY FAFSA determinations. We continue to witness incidents where FAAs ask youth to obtain documentation from other authorized parties, do not accept determinations from authorized parties, or steer homeless youth to a professional judgment process that essentially bases their access to financial aid up on the subjective discretion of the FAA, rather than on whether or not youth meet the legal definition of unaccompanied homeless youth. 

The reluctance of financial aid administrators to make UHY FAFSA determinations creates tremendous barriers for some of our most marginalized young people. The pandemic has created many strains on students and families, causing greater numbers of college students to experience homelessness, and creating new barriers for those already experiencing homelessness. According to the most recent report from the Hope Center, 14% of students experienced homelessness in the Fall of 2020. Many of these students will be relying on FAAs to continue their education, making appropriate and supportive practices by FAAs even more important.