Answer: Here is the latest letter from ED on this:
There is some new information on page 116 of the latest AVG about liaisons providing verifications for students after high school. That IS allowed, if the liaison has the information necessary to verify the student’s status. “Also, local liaisons may write subsequent year letters of verification for unaccompanied homeless youth through age 23 for whom they have the necessary information to write such letters.”
However, if the liaison does not have the information, and the youth is not connected to a HUD or RHYA program (as most are not), the FAA at the university has both the authority and the obligation to make the determination.
We have some information on this, as well as a sample verification form, on our website: https://schoolhouseconnection.org/higher-education/