“Answer: The U.S. Department of Education has changed their guidance to financial aid administrators (FAAs), and also to liaisons. ED now specifically says that liaisons may continue to submit letters of verification for unaccompanied homeless youth in subsequent years, up to age 23, as long as liaisons have the information that is necessary to make the determination of their homeless and unaccompanied status, or their status as at risk of homelessness, unaccompanied, and self-supporting.

Please see the sidebar on Application and Verification Guide (AVG)-118 for the instruction to FAAs (you can just search for “liaison”). Also, see pp. 48-49, Q-2, for the same information provided to liaisons.

I think you could let the school know about this new guidance, and then provide them with an updated letter (as long as you have the information needed to verify that she is homeless and unaccompanied, OR that she is at risk of homelessness, unaccompanied, and self-supporting).

If you don’t have the information to make the determination, the FAA must make the determination. They should not be sending students back to the high school. AVG-117 makes that really clear.”

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