Answer: Compliance companies may not be aware of the specific provisions in the AVG that clearly state that 1) verification is not required; 2) FAAs must make determinations based on the legal definition of homelessness if youth don’t have documentation from an authorized party; 3) a documented interview suffices as documentation; and 4) a template exists for documenting interviews. In addition to informing compliance companies and institutions about these provisions and ED’s DCL, it can be helpful to share the findings of the 2016 GAO report that describes the barriers created by documentation requests. Another suggestion is to ask local homeless youth providers and/or local liaisons to meet with institutional leaders and financial aid directors, to explain the realities of youth homelessness and the ways in which financial aid practices unintentionally can retraumatize youth and stand in the way of their pursuit of higher education.

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