HIGHER EDUCATION

Actions Needed to 

Improve Access to 

Federal Financial 

Assistance for 

Homeless and Foster 

Youth

Report to the Ranking Member, Senate 

Committee on Health, Education, Labor, 

and Pensions

May 2016

GAO-16-343

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-343, a Report to the 

Ranking Member, Senate Committee on 

Health, Education, Labor, and Pensions

May 2016

HIGHER EDUCATION

Actions Needed to Improve Access to Federal 

Financial Assistance for Homeless and Foster Youth

Why GAO Did This Study

Homeless youth and youth in foster 

care are often unprepared for the 

transition to adulthood. Given the 

economic benefits of college, GAO 

was asked to examine the college 

experiences of these vulnerable youth.

GAO examined (1) college enrollment 

and completion for foster and 

homeless youth, (2) the extent to which 

challenges these youth face affect their 

ability to pursue college, and (3) the 

extent to which program barriers hinder 

these youth from obtaining federal

financial assistance for college. GAO 

analyzed the most recently available 

Education data—two enrollment data

sets, for 2011-2012 and 2013-2014, 

and data on college completion from 

2009; reviewed relevant federal laws

and guidance; interviewed officials 

from Education and HHS, as well as 

external groups knowledgeable about 

higher education, foster youth, and 

homelessness; and held discussion 

groups with foster and homeless youth. 

What GAO Recommends

GAO is making six recommendations 

to Education and HHS to improve 

homeless and foster youth access to 

financial assistance for college, 

including centralizing college 

information for these youth on 

Education’s website, clarifying 

Education guidance, and considering 

legislative proposals to simplify federal 

requirements for homeless and foster 

youth. HHS agreed with these 

recommendations while Education 

generally did not agree or disagree, but 

described actions it was taking in 

response to the recommendations.

What GAO Found

Available research suggests that a lower percentage of youth who have been in 

foster care enroll in and complete college compared to other youth, but little is 

known about homeless youth. While the Departments of Education (Education) 

and Health and Human Services (HHS) administer programs that can help them 

with college, Education data from 2009 (the latest available) indicate that a lower 

percentage of foster youth complete a bachelor’s degree within 6 years (14 

percent) compared to other students (31 percent). Education has begun to collect

data on homeless youth and plans to have some college completion information 

by 2017. Education data also show that homeless and foster youth who attend 

college pursue an associate’s degree to a greater extent than other students.

Homeless and foster youth experience challenges, such as weak academic 

foundations, limited family support, and lack of awareness of available financial 

resources, making it harder for them to pursue college, according to stakeholders 

GAO interviewed. With few adults in their lives, homeless and foster youth in 

GAO discussion groups said it is hard to navigate complex college application 

and financial aid processes. Education officials and other stakeholders told GAO 

that these youth are often not aware of financial resources for college. Federal 

law requires Education to provide accessible information on financial aid, but its

website has limited information on college resources directed towards homeless 

and foster youth. The lack of easily accessible and tailored information can make 

it difficult for these youth to learn about and obtain federal assistance for college.

Burdensome program rules can make it more difficult for unaccompanied 

homeless youth (those not in the physical custody of a parent or guardian) and 

older foster youth to obtain federal financial assistance for college.

 Homeless youth: Unaccompanied homeless youth are required by law to 

have their status verified by either an official of specified federal homeless 

programs or a college financial aid administrator each time they apply for 

federal grants and loans. Obtaining documentation from specified program 

officials after the first year of college can be difficult because these programs 

generally do not serve homeless youth throughout college and because 

Education guidance on the role of these officials is unclear. Further,

according to Education officials and other stakeholders, financial aid staff are 

often reluctant to determine that a student is unaccompanied and homeless 

without making extensive documentation requests, yet homeless youth living 

in a car or tent can find it difficult to document these tenuous living situations.

 Foster youth: Age criteria in federal law can hinder access to an HHS 

program that provides a voucher for college expenses to foster youth up to 

age 23, but only if they were receiving the voucher at age 21. Foster youth

who start college after age 21 are not eligible for the voucher.

These barriers to accessing financial assistance contribute to the challenges 

these youth face trying to attend and complete college, but Education and HHS 

have not developed legislative proposals to address them.

View GAO-16-343. For more information, 

contact Melissa Emrey-Arras at (617) 788-

0534 or emreyarrasm@gao.gov.
Page i GAO-16-343 College Outcomes for Homeless and Foster Youth 

Letter 1

Background 4

Foster Youth Complete College to a Lesser Extent than Other 

Students, while Little Is Known about College Outcomes for 

Homeless Youth 10

Limited Academic Preparation, Family Support, and Awareness of 

Resources Make It Harder for Homeless and Foster Youth to 

Pursue College 19

Burdensome Program Rules Can Hinder the Ability of Homeless 

and Foster Youth to Access Federal Supports 30

Conclusions 42

Recommendations for Executive Action 44

Agency Comments and Our Evaluation 45

Appendix I Objectives, Scope, and Methodology 48

Overview 48

Data Sources and Analysis 49

Laws and Policies 51

Review of Studies 51

Interviews with Federal and Selected State Officials and Officials 

from Knowledgeable Organizations 52

Discussion Groups with Homeless and Foster Youth 53

Appendix II College Enrollment and Completion of Foster Youth and 

Unaccompanied Homeless Youth Compared to Dependent 

Students 55

Appendix III Comments from the U.S. Department of Education 58

Appendix IV Comments from the U.S. Department of Health and Human

Services 62

Appendix V GAO Contact and Staff Acknowledgments 65

Contents
Page ii GAO-16-343 College Outcomes for Homeless and Foster Youth 

Table

Table 1: Key College Challenges for Homeless and Foster Youth 20

Figures

Figure 1: Federal Student Aid Application Process for 

Unaccompanied Homeless Youth 8

Figure 2: Types of Colleges Attended by Foster Youth and All 

Other Undergraduates, Free Application for Federal 

Student Aid Award Year, 2013-2014 12

Figure 3: Comparison of Enrollment of Foster Youth and Other 

Students in College Degree Programs, by Estimated 

Percent of Students Enrolled, School Year 2011-2012 13

Figure 4: Comparison of Estimated College Degree Completion 

Rates within 6 Years of First Enrollment, for Foster Youth 

and Other Students, as of 2009 15

Figure 5: Types of Colleges Attended by Unaccompanied 

Homeless Youth and All Other Undergraduates, Free 

Application for Federal Student Aid Award Year, 2013-

2014 17

Figure 6: Comparison of Degree Program Enrollment for 

Unaccompanied Homeless Youth and Other Students, By 

Estimated Percent Enrolled, School Year 2011-2012 18

Figure 7: Comparison of Enrollment of Foster Youth to Dependent 

Students in College Degree Programs, by Estimated 

Percent of Students Enrolled, School Year 2011-2012 55

Figure 8: Comparison of Estimated College Degree Completion 

Rates within 6 Years of First Enrollment, for Foster Youth 

and Dependent Students, as of 2009 56

Figure 9: Comparison of Degree Program Enrollment for 

Unaccompanied Homeless Youth and Dependent 

Students, By Estimated Percent Enrolled, School Year 

2011-2012 57
Page iii GAO-16-343 College Outcomes for Homeless and Foster Youth 

Abbreviations

BPS Beginning Postsecondary Students 

Longitudinal Study

Chafee ETV Voucher Chafee Education and Training Voucher 

 Program

COD Common Origination and Disbursement 

System

CRS Congressional Research Service

Education Department of Education

FAFSA Free Application for Federal Student Aid

GED General Education Development

HHS Department of Health and Human Services

HUD Department of Housing and Urban 

 Development

NPSAS National Postsecondary Student Aid Study

SPOC Single Point of Contact 

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Page 1 GAO-16-343 College Outcomes for Homeless and Foster Youth 

441 G St. N.W.

Washington, DC 20548

May 19, 2016

The Honorable Patty Murray

Ranking Member

Committee on Health, Education, Labor, and Pensions

United States Senate

Dear Senator Murray:

An estimated 32,000 unaccompanied youth ages 18 through 24 were 

homeless on a single night in 2015, and more than 22,000 youth aged out 

of the foster care system in fiscal year 2014, reaching college age without 

having the support of relatives or adoptive parents.1 These two vulnerable 

populations have similar experiences. For example, homeless youth, like 

youth who have been in foster care, may have experienced parental 

abuse and neglect. Similarly, youth who are no longer in foster care can 

end up homeless or without other services. Advocates and others 

knowledgeable about homeless and foster youth have expressed 

concerns that these youth lag far behind their peers when it comes to 

attending and graduating from college. The economic benefits of a 

college education are well documented—for homeless and foster youth, 

earning a degree can mean more financial stability when transitioning to 

adulthood so that they can establish independent, productive lives. 

However, to the extent that homeless and foster youth are unable to 

attend college, they may be unprepared for the transition to adulthood, 

unable to support themselves, or experience continued homelessness.

The Department of Education (Education) is responsible for administering 

federal student aid programs—such as Pell Grants and federal loans—

 

1Numbers of homeless and foster youth were the most recent data available during our 

review. Information on the number of homeless youth is from the U.S. Department of 

Housing and Urban Development’s (HUD) 2015 Annual Homeless Assessment Report to 

Congress. HUD’s point-in-time estimate is for a single night in January 2015 and 

represents unaccompanied homeless youth from ages 18 to 24 who were by themselves. 

An additional 20,700 homeless youth ages 18-24 were with their families on that date.

Information on the number of youth aging out of foster care is from the U.S. Department of 

Health and Human Services, Administration on Children, Youth and Families, 

Administration for Children and Families, Children’s Bureau, The AFCARS Report, #22, 

http://www.acf.hhs.gov/sites/default/files/cb/afcarsreport22.pdf. Data on foster youth 

represents preliminary fiscal year 2014 estimates as of July 2015.

Letter
Page 2 GAO-16-343 College Outcomes for Homeless and Foster Youth 

that help low- and middle-income students cover the cost of attending 

college.2 The Department of Health and Human Services (HHS) 

administers the Chafee Education and Training Voucher Program to help 

older foster youth pay for college and the Runaway and Homeless Youth 

Transitional Living Program, which funds shelters and services to help

homeless youth become self-sufficient, including assistance with college 

planning.

In light of the economic benefits of college, you asked us to examine the 

challenges and barriers affecting the ability of foster and homeless youth 

to pursue a college education.3 Specifically, we analyzed (1) What is 

known about college enrollment and completion for youth who have been 

in foster care or who are homeless?(2) To what extent do challenges 

identified by researchers and stakeholders affect the ability of foster and 

homeless youth to pursue college? (3) To what extent do program 

barriers exist that could hinder these youth from obtaining federal 

financial assistance for college?

For the first objective, we analyzed available data from three federal 

databases: (1) administrative data from Education’s Common Origination 

and Disbursement System for 2013-2014, as well as (2) data from the 

nationally representative National Postsecondary Student Aid Study 

(NPSAS) for 2011-2012 and (3) the Beginning Postsecondary Students 

Longitudinal Study (BPS) for 2009. These were the most recent data 

available for each database at the time of our review. We assessed the 

reliability of these data by reviewing existing information about the data 

and the systems that produced them and interviewing agency officials 

knowledgeable about the data. We determined that the data were 

sufficiently reliable for the purposes of this report. To supplement our data 

analyses, we also reviewed available studies on college enrollment and 

completion for foster and homeless youth. We assessed the quality of 

these studies by evaluating the methods used in the research and 

identifying any limitations. In analyzing college outcomes for homeless 

youth, we focused on unaccompanied homeless youth—those who are 

not in the physical custody of their parents or guardians—rather than all 

 

2For this report, we define federal student aid programs as financial aid programs 

authorized under Title IV of the Higher Education Act of 1965, as amended. 

3

In this report, we use the term college to refer to a variety of postsecondary programs, 

including certificate and associate degree programs. 
Page 3 GAO-16-343 College Outcomes for Homeless and Foster Youth 

homeless youth because data are available only for this group of 

homeless students. Available data report on youth who have been in 

foster care any time since they turned age 13.

For our second and third objectives, we interviewed officials from 

Education, HHS, and the Department of Housing and Urban Development 

(HUD), as well as officials from numerous organizations knowledgeable 

about child welfare, homelessness, and higher education issues. We also 

reviewed relevant federal laws and guidance on federal student aid and 

relevant foster care and homeless youth programs to understand the 

context for any barriers to program access.4 To obtain information and 

perspectives on program access for homeless and foster youth, we also 

interviewed state education and other officials in California, Colorado, 

Michigan, and Virginia. We selected these states based on several 

criteria, including the number of foster youth ages 16 to 21 in the state, 

the number of homeless applicants for federal student aid, and 

geographic distribution. We also interviewed college financial aid 

administrators at three colleges in other states, based on the 

recommendation of a national organization of financial aid 

administrators.5 The views of these state officials and college financial aid 

administrators are nongeneralizable. Further, we convened two 

discussion groups with homeless youth and two discussion groups with 

foster youth to obtain nongeneralizable information directly from them on 

any challenges and access issues they faced in enrolling in and 

completing college. We assessed Education’s efforts to provide 

information on federal student aid and access to these programs with 

related provisions in the Higher Education Act as amended by the College 

Cost Reduction and Access Act and with Education’s strategic plan and 

federal standards for internal controls (see app. I for more information on 

our methodology).

We conducted this performance audit from October 2014 to May 2016 in

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

 

4

In analyzing program access, we focused primarily on unaccompanied homeless youth 

because they identify themselves as such when they apply for federal student aid, while 

homeless youth living with their families are not distinguishable from other students.

5We also interviewed another college financial aid administrator in Michigan who 

participated in the state interview. The three other financial aid administrators were from 

colleges located in Maryland, North Carolina, and Ohio.
Page 4 GAO-16-343 College Outcomes for Homeless and Foster Youth 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Education is responsible for administering federal student aid programs 

that provide grants and loans to students to attend college, managing the 

application process for these programs, and administering support 

services for homeless children and youth in elementary and secondary 

schools.

Education administers federal student aid programs that provided $128.7 

billion in assistance to almost 12 million eligible college students and their 

families in fiscal year 2015.6 The main federal grant and loan programs 

that Education administers are:

 Federal Pell Grant Program: Pell grants are awarded to low-income 

undergraduate students who have not earned a bachelor’s or a

professional degree. These grants do not need to be repaid. Students 

may be eligible to receive a Pell Grant award for up to the maximum 

lifetime limit of 12 semesters or their equivalent. The maximum award 

amount for the 2015-2016 award year is $5,775. In fiscal year 2015, 

Education distributed $29.9 billion in Pell Grants to eligible low-income 

students.

 William D. Ford Federal Direct Loan Program: To help cover the 

cost of college, eligible students may receive federal student loans, 

which must be repaid with interest. For the purposes of federal 

student aid eligibility, a student is considered to be either financially 

dependent on his or her parents or financially independent. 

Undergraduate students who are independent of their parents may 

 

6Title IV of the Higher Education Act of 1965, as amended, authorizes the federal 

government’s major student aid programs, which are the primary source of direct federal 

support to low and middle-income students pursuing postsecondary education. 20 U.S.C. 

§ 1070-1099d and 42 U.S.C. §§ 2751-2756b.

Background

Education Programs That 

Support Homeless and 

Foster Youth

Federal Student Aid Programs
Page 5 GAO-16-343 College Outcomes for Homeless and Foster Youth 

qualify to borrow up to $9,500 during their first year, while dependent 

undergraduate students may borrow a maximum of $5,500.

Education also provides support services for homeless children and youth 

in school up through grade 12.7 The key federal education program for 

these youth is the McKinney-Vento Education for Homeless Children and 

Youth Program, which requires all school districts to designate a 

McKinney-Vento homeless liaison to help homeless students succeed in 

school.8 For unaccompanied homeless youth who apply for federal 

student aid, McKinney-Vento homeless liaisons may verify that a student 

is an unaccompanied homeless youth. For fiscal year 2015, Congress 

appropriated about $65 million for Education to administer this program, 

and about 1.3 million homeless children and youth were served during the 

2013-2014 school year, the most recent year for which data are available.

To apply for federal student aid programs, students must submit the Free 

Application for Federal Student Aid (FAFSA), which asks for financial and 

other information from the student. Information from the FAFSA 

determines whether a student is considered either financially dependent 

on his or her parents or financially independent for the purpose of 

determining federal student aid eligibility. Most college students attending 

an undergraduate school are considered dependent students and must 

provide parental income information on the FAFSA.9If a dependent 

 

7Education also provides support services through several of its Federal TRIO programs 

to help disadvantaged students (such as low-income and first-generation college students) 

prepare for and enroll in college. For example, the Student Support Services program 

aims to improve the undergraduate student retention and graduation rates of its 

participants by providing support services, such as academic tutoring and assistance in 

completing college financial aid applications. While foster and homeless youth are eligible 

for TRIO services, Education does not track the number of homeless and foster youth 

participating in TRIO programs, according to agency officials.

8Under the Education for Homeless Children and Youth grant program, states and their 

school districts are required to identify homeless children and provide them with needed 

services and support. The Education for Homeless Children and Youth Program was 

initially authorized by Title VII-B of the Stewart B. McKinney Homeless Assistance Act, 

Pub. L. No. 100-77, 101 Stat. 482, 525 (1987), codified as amended at 42 U.S.C. §§ 

11431-11435. The Education for Homeless Children and Youth Program was most 

recently amended and reauthorized by the Every Student Succeeds Act, Pub. L. No. 114-

95, §§ 9101-9107, 129 Stat. 1802, 2124 - 2137 (2015).

9For dependent students, eligibility for the type and amount of federal student aid is based 

on such factors as the student’s and parents’ income and assets, as well as family size 

and whether the family has other children enrolled in college. 20 U.S.C. § 1087oo.

Support Services Provided by 

Education

Applying for Federal Student 

Aid
Page 6 GAO-16-343 College Outcomes for Homeless and Foster Youth 

student does not provide information on parental income, the FAFSA will 

be considered incomplete and the student will not be eligible for federal 

student aid. Certain students—such as those who are married, are 

veterans, are age 24 and older, or those attending a graduate or 

professional school—are defined as independent students for the 

purpose of federal student aid and do not need to provide parental 

financial information on the FAFSA.10 By law, students who have been in 

foster care after the age of 13 or who are verified as unaccompanied 

homeless youth are also considered independent.11 The terms 

“unaccompanied youth” and “homeless child and youth” are defined in the 

McKinney-Vento Homeless Assistance Act.12

The FAFSA asks a series of questions to identify unaccompanied 

homeless youth. For students who are not already determined to be 

independent, the online FAFSA asks all students a general screening

question about whether they are homeless or self-supporting and at risk 

 

1020 U.S.C. § 1087vv(d)(1). For independent students, eligibility for the type and amount 

of federal student aid is based on such factors as the student’s and, if married, spouse’s 

income and assets and whether the student has any dependents other than a spouse, as 

well as the number of family members enrolled in college. 20 U.S.C. §§ 1087pp and 

1087qq.

11Specifically, students who are in foster care or who have been in foster care at any time 

since they turned 13 years of age are defined in the Higher Education Act as independent 

students. 20 U.S.C. § 1087vv(d)(1)(B). In addition, students who are verified during the 

school year in which the FAFSA is submitted as an unaccompanied youth who is a 

homeless youth or is at risk of homelessness and is self-supporting are defined in the act 

as independent students. 20 U.S.C. § 1087vv(d)(1)(H). For the purpose of this report, we 

will refer to these students as homeless youth or unaccompanied homeless youth. In 

addition, foster youth refers to both current and former foster youth in this report. These 

categories of individuals were added to the definition of independent students by the 

College Cost Reduction and Access Act, Pub. L. No. 110-84, § 604(a), 121 Stat. 784, 806 

(2007). 

12According to the McKinney-Vento Homeless Assistance Act, being homeless means

lacking fixed, regular and adequate housing and includes those living in shelters, parks, 

motels or cars, as well as those temporarily living with other people. 42 U.S.C. § 11434a.

According to the 2016-2017 FAFSA, “homeless means lacking fixed, regular and 

adequate housing. You may be homeless if you are living in shelters, parks, motels or 

cars, or temporarily living with other people because you have nowhere else to go. Also, if 

you are living in any of these situations and fleeing an abusive parent you may be 

considered homeless even if your parent would provide support and a place to live.” Being 

homeless also includes living in a college dormitory if a student would otherwise be 

homeless, according to Education guidance.
Page 7 GAO-16-343 College Outcomes for Homeless and Foster Youth 

of being homeless.13 Students who answer “yes” to this screening 

question must then indicate whether they have been determined to be an 

unaccompanied homeless youth by a McKinney-Vento homeless liaison 

or a director of specific programs sponsored by HUD or HHS who are 

authorized under the Higher Education Act to verify homelessness for 

student aid purposes.14 If these youth answer “yes” to any of these 

questions, they are deemed independent.15 Education does not require 

financial aid administrators to obtain documentation from unaccompanied 

homeless students to prove their circumstances if they answer yes, 

unless the college has conflicting information.

Students who do not have determinations of homelessness from these 

federal programs can still qualify as an unaccompanied homeless youth 

by contacting a financial aid administrator at each school to which they 

apply to request an unaccompanied homeless youth determination.16

Education requires financial aid administrators to determine whether 

these students are unaccompanied homeless youth and therefore 

 

13 For the online FAFSA, unaccompanied homeless youth questions are only presented to 

applicants who have not been deemed independent by a prior question. For example, 

students who previously responded that they were married or were veterans would be 

considered independent and would not see questions about homelessness. 

14These include directors of HUD-funded emergency shelters or transitional housing 

programs or directors of runaway or homeless youth programs funded by HHS. 20 U.S.C. 

§ 1087vv(d)(1)(H)(i)-(iii). In addition, financial aid administrators are authorized to verify a 

student as an unaccompanied homeless youth. 20 U.S.C. § 1087vv(d)(1)(H)(iv). Because 

Education defines youth as age 21 or under in the FAFSA, unaccompanied homeless 

youth ages 22 and 23 are not asked these specific follow-up questions in the online 

FAFSA.

15Education guides homeless and other students through the FAFSA, for example by 

providing online “help text” to explain technical terms and to help students answer 

questions most appropriate for their situation. About 99 percent of all applicants use the 

online version of the FAFSA, according to Education data.

16Although unaccompanied homeless youth ages 22 and 23 do not meet Education’s 

definition of “youth” in the FAFSA. Education issued guidance in July 2015 instructing 

financial aid administrators that these students qualify as unaccompanied homeless youth 

if they otherwise meet the definition. The July guidance on the status of 22- and 23-year 

old homeless youth was incorporated into Education’s September 2015 Application and 

Verification Guide.
Page 8 GAO-16-343 College Outcomes for Homeless and Foster Youth 

considered financially independent for federal student aid purposes.17

(See fig. 1 for a description of the full process.)

Figure 1: Federal Student Aid Application Process for Unaccompanied Homeless Youth

Note: For the online FAFSA, the unaccompanied homeless youth screening questions are only 

presented to online FAFSA applicants who were not deemed independent by a prior question. For 

example, students who previously responded that they were married, were veterans, were age 24 or 

older, were attending a graduate or professional school, or had been in foster care, among other 

things, would be considered independent and would not see questions about homelessness.

 

17According to the Application and Verification Guide, if a student does not have and 

cannot obtain documentation from any of the authorities cited on the FAFSA, financial aid 

administrators must determine if the student is an unaccompanied youth who is homeless 

or is self-supporting and at risk of being homeless.
Page 9 GAO-16-343 College Outcomes for Homeless and Foster Youth 

HHS provides support services for older foster youth and youth 

transitioning out of foster care through the John H. Chafee Foster Care 

Independence Program and the related Chafee Education and Training 

Voucher Program (Chafee ETV Voucher Program).18 HHS also provides 

support services for homeless youth through its Runaway and Homeless 

Youth Program.

 The John H. Chafee Foster Care Independence Program: This 

program provides funding to states for support services, including 

employment and educational assistance, to prepare foster youth for 

adulthood. Foster youth up to age 18 and former foster youth up to 

age 21 are eligible for this program.19 The program was funded at 

about $140 million in fiscal year 2015.

 Chafee ETV Voucher Program: Youth who qualify for the Chafee 

Independence Program are eligible for the Chafee ETV Voucher 

Program, which authorizes funding to states to help eligible foster 

youth pay for college.20 A youth who has aged out of foster care may 

be eligible for vouchers worth up to $5,000 annually to help pay for 

college costs. Eligible youth receiving a voucher before they turn 21 

 

18The federal foster care program, authorized by title IV-E of the Social Security Act as 

amended, helps to provide safe and stable out-of-home care for children who have 

experienced abuse or neglect until the children are safely returned home, placed 

permanently with adoptive families or placed in other planned arrangements for 

permanency. HHS also provides additional support services in states that have extended 

foster care for youth up to age 21. As provided for by the Fostering Connections to 

Success and Increasing Adoptions Act of 2008, Pub. L. No 110-351, § 201, 122 Stat. 

3949, 3957, codified at 42 U.S.C. § 675, states have the option to seek federal 

reimbursement for part of the cost of providing foster care to eligible youth until age 19, 

20, or 21. As of September 2015, HHS had approved plans for 21 states and Washington, 

D.C. to extend foster care and services up to age 21. 

19The program was authorized by the Foster Care Independence Act of 1999, Pub. L. No. 

106-169, § 101, 113 Stat. 1822, 1823, codified at 42 U.S.C. § 677. 

20The Chafee ETV Voucher Program was authorized by the Promoting Safe and Stable 

Families Amendments of 2001, Pub. L. No. 107-133, § 201(b), 115 Stat. 2413, 2422, 

codified at 42 U.S.C. § 677(i). 

HHS Programs to Support 

Foster and Homeless 

Youth
Page 10 GAO-16-343 College Outcomes for Homeless and Foster Youth 

may continue to participate in the program through age 22.21 The 

program was funded at about $43 million in fiscal year 2015.

 Runaway and Homeless Youth/Transitional Living Grant 

Program: The Runaway and Homeless Youth Program has several 

grant programs. The Transitional Living Program provides grants to 

local entities that provide residential support services to homeless 

youth ages 16 through 21.22 Grantees are required to provide 

homeless youth with safe living accommodations and services to help 

them prepare for adulthood, including college planning. In fiscal year 

2015, the program was funded at about $44 million.23

 

21States may allow youth participating in the voucher program on the date they turn 21 to 

continue to participate in the program until they reach 23 years of age as long as they are 

enrolled and making satisfactory progress in a postsecondary education or training 

program. 42 U.S.C. § 677(i)(3). Foster youth are generally eligible for both the Chafee 

Independence Program and the Chafee ETV Voucher Program if they are expected to age 

out of foster care without being placed in a permanent family or if they left foster care for a 

permanent placement after age 16. Receipt of a Chafee ETV voucher does not affect 

foster youths’ eligibility for Pell Grants and other federal aid except that the total amount of 

educational assistance cannot exceed the total cost of attendance. 42 U.S.C. § 677(i)(5).

22The Transitional Living Program—established as an amendment to The Runaway and 

Homeless Youth Act in 1988—was most recently reauthorized and amended by the 

Reconnecting Homeless Youth Act of 2008, Pub. L. No. 110-378, § 4, 122 Stat. 4068, 

4069, codified at 42 U.S.C. §§ 5714-1 - 5714-2. Under certain circumstances, a 22- or 23-

year-old homeless youth can participate in the program. 42 U.S.C. § 5732a(3)(A)(ii).

23For fiscal year 2015, Congress appropriated $97 million for the Transitional Living 

Program together with another shorter term program for runaway and homeless youth. 

HHS allocated $44 million of these funds to the Transitional Living Program. 

Foster Youth 

Complete College to 

a Lesser Extent than 

Other Students, while 

Little Is Known about 

College Outcomes for 

Homeless Youth
Page 11 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Little information is available on the percentage of foster youth who enroll 

in college. One major three-state study of foster youth in 2011 found a 

gap in college experience between foster youth and other youth. 

Specifically, 40 percent of former foster youth in the study reported 

completing at least 1 year of college, compared to an estimated 68 

percent of youth in the general population.24 According to our analysis of 

Education administrative data, about 72,000 foster youth received federal 

student aid in 2013-2014 (less than 1 percent of all undergraduates 

receiving aid).25 However, this may be an undercount of foster youth 

because of how the FAFSA collects information from applicants.26

Foster youth who do attend college enrolled at public 2-year colleges to a 

greater extent than other youth. According to our analysis of Education 

data, 43 percent of the foster youth who received federal student aid in 

2013-2014 attended public 2-year colleges, compared to 29 percent of 

other undergraduates receiving federal student aid (see fig. 2). Further, 

based on our analysis of Education’s nationally representative National 

Postsecondary Student Aid Survey (NPSAS) data from 2011-2012, we 

estimated that foster youth attended public 2-year colleges at higher 

 

24M. Courtney, A. Dworsky, A. Brown, C. Cary, K. Love, & V. Vorhies, Midwest Evaluation 

of the Adult Functioning of Former Foster Youth: Outcomes at Age 26 (Chicago, IL: 

Chapin Hall at the University of Chicago, 2011). See appendix I for more information on 

this analysis.

25These data are from Education’s Common Origination and Disbursement System, which 

contains information on students who receive federal student aid. Data on foster youth 

come from the “foster care, ward of the court, or orphaned” question on the FAFSA. For 

FAFSA purposes, a student who was in foster care at any time after they turned age 13 is 

considered a foster youth. In our report, foster youth refers to both current and former 

foster youth. Based on data from Education’s nationally representative National 

Postsecondary Student Aid Survey, we developed an estimate of the total number of 

foster youth enrolled in college, including those who did not receive federal student aid. 

For the 2011-2012 school year, NPSAS estimates that approximately 286,000 foster youth 

(about 1 percent of all students) were enrolled in college as undergraduates nationwide. 

The data on foster youth from NPSAS and the Common Origination and Disbursement 

system vary due to differences in the data sources, such as the specific student 

population and timeframes. For more information on our NPSAS analyses, see 

appendixes I and II.

26Data on foster youth based on FAFSA responses may represent an undercount of foster 

youth because of how the FAFSA screens applicants to determine whether they are 

dependent or independent students. Students who are considered financially independent 

because they are 24 years of age or older, serve or served in the military, or are married, 

among other things, do not answer the FAFSA questions about whether they were in 

foster care. 

One Study Suggests That 

a Lower Percentage of 

Foster Youth Attend 

College and Education 

Data Show Many Attend 

Public 2-Year Colleges
Page 12 GAO-16-343 College Outcomes for Homeless and Foster Youth 

percentages (estimated 49 percent) than other low-income youth (41 

percent).27 Two studies we reviewed also found that a high percentage of 

college-enrolled foster youth attended 2-year colleges.28

Figure 2: Types of Colleges Attended by Foster Youth and All Other Undergraduates, Free Application for Federal Student Aid 

Award Year, 2013-2014

Notes: Figures and subtotals may not add to 100 due to rounding. The non-profit category refers to 

private non-profit colleges. Data on 2-year colleges also include some certificate programs that are up 

to 3 years in length.

Consistent with attending 2-year colleges, foster youth who enrolled in 

college also pursued an associate’s degree to a greater extent than other 

students. Specifically, an estimated 53 percent of foster youth enrolled in 

college in 2011-2012 pursued an associate’s degree compared to 48 

 

27All foster youth comparisons from NPSAS are statistically significant at the 95 percent 

confidence level unless otherwise indicated. NPSAS collects data on a large, nationally 

representative sample of students and colleges to examine how students and their

families pay for college. Data on foster youth comes from the “foster, orphan, and ward of 

the court” question on the FAFSA. We use low-income students as a comparison group 

for our analyses of NPSAS data because most foster and homeless youth have incomes 

within the lowest income quartile of all college-enrolled youth. We defined “low-income” as 

students in the lowest income quartile for our analyses. All estimates have margins of 

error within plus or minus 10 percentage points, unless otherwise noted.

28Courtney, et al., Midwest Evaluation; J. Merdinger, A. Hines, K. Osterling, & P. Wyatt, 

“Pathways to College for Former Foster Youth: Understanding Factors That Contribute to 

Educational Success,” Child Welfare, vol. 84, no. 6 (2005).
Page 13 GAO-16-343 College Outcomes for Homeless and Foster Youth 

percent of low-income students, according to our analysis of NPSAS 

data. Conversely, foster youth pursued a bachelor’s degree to a lesser 

extent than all other students.29 For example, about 48 percent of all other 

students enrolled in bachelor’s degree programs, compared to 38 percent 

of foster youth (see fig. 3).30

Figure 3: Comparison of Enrollment of Foster Youth and Other Students in College Degree Programs, by Estimated Percent of 

Students Enrolled, School Year 2011-2012

aPercentage estimate is not statistically different from the foster youth estimate at the 95 percent 

confidence level.

Notes: Percentages may not add to 100 due to rounding. All foster youth comparisons are statistically 

significant at the 95 percent confidence level, unless otherwise indicated. The percentage estimates 

for all populations have margins of error of within plus or minus 10 percentage points. We compared 

foster youth to low-income students because most foster youth have incomes within the lowest 

income quartile of all college-enrolled youth. The “all other students” category includes all students 

who are not foster youth, regardless of income level.

 

29The difference between foster youth and low-income youth enrolled in bachelor’s degree 

programs was not statistically significant at the 95 percent confidence level, according to 

our NPSAS analysis. 

30We also used dependent students as a comparison group because they are similar in 

age (under 24) to foster and homeless youth. These results were largely similar to the 

comparisons of foster youth with low-income youth and all other youth (see app. II).
Page 14 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Available data suggest that a smaller percentage of foster youth who 

begin college ultimately finish with a degree compared to other students. 

According to our analysis of Education’s Beginning Postsecondary 

Students (BPS) data, a smaller percentage of foster youth who began 

college for the first time in the 2003-2004 school year (an estimated 14 

percent) graduated with a bachelor’s degree as of June 2009—the latest 

data available at the time of our analysis—than all other students (31 

percent).31 Further, BPS data indicate that a high percentage of foster 

youth who enroll in college do not earn a degree compared to other lowincome students. Specifically, 72 percent of foster youth had no degree or 

certificate within 6 years of first enrolling in college—a far greater 

percentage than for low-income students (57 percent), as well as for all 

other students (49 percent) (see fig. 4).32

 

31BPS surveys a sample of first-time students at three points in time: at the end of their 

first year, and then 3 and 6 years after first starting college. It collects data on a variety of 

topics, including student demographic characteristics, school and work experiences, 

persistence, transfer, and degree attainment. BPS draws its initial cohorts from the 

NPSAS data set. We analyzed BPS data for the student cohort that began college in 

2003-2004, and compared foster youth to other low-income students and all other 

students. We also compared foster youth to dependent students because they are similar 

in age (under 24) to foster and homeless youth. These results were largely similar to the 

comparisons with low-income youth and all other youth (see app. II). All foster youth 

comparisons from BPS are statistically significant at the 95 percent confidence level, 

unless otherwise indicated. 

32Some smaller studies involving a few states or schools also indicate that a relatively low 

percentage of foster youth graduate from college. For example, a study of adults who had 

been in foster care in the Pacific Northwest found that 43 percent of foster youth who 

participated in the study received some education beyond high school, but only 2 percent 

completed a bachelor’s degree or higher. P. Pecora, R. Kessler, K. O’Brien, C. Roller 

White, J. Williams, M. Herrick, “Educational and Employment Outcomes of Adults 

Formerly Placed in Foster Care: Results from the Northwest Foster Care Alumni Study,”

Children and Youth Services Review, vol. 28 (2006).

A Lower Percentage of 

Foster Youth Graduate 

from College Compared to 

Other Low-Income 

Students
Page 15 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Figure 4: Comparison of Estimated College Degree Completion Rates within 6 Years of First Enrollment, for Foster Youth and 

Other Students, as of 2009

aPercentage estimate is not statistically different from the foster youth estimate at the 95 percent 

confidence level.

Notes: Percentages may not add to 100 due to rounding. All foster youth comparisons are statistically 

significant at the 95 percent confidence level, unless otherwise indicated. All estimates have margins 

of error of within plus or minus 10 percentage points, with the exception of the foster youth estimates:

The confidence intervals for these estimates are: 58 to 82 percent for no degree, 7 to 26 percent for 

certificate or associate’s degree, and 6 to 25 percent for bachelor’s degree. We compared foster 

youth to low-income students because most foster youth have incomes within the lowest income 

quartile of all college-enrolled youth. The “all other students” category includes all students who are 

not foster youth, regardless of income level.
Page 16 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Unaccompanied homeless youth have college enrollment patterns similar 

to those of foster youth, but the percentage of all homeless youth who 

enroll in college is not generally known, partly due to definitional and 

other issues that make it difficult to count these youth.33 According to our 

analysis of Education administrative data, about 15,000 unaccompanied 

homeless youth received federal student aid in the FAFSA award year 

2013-2014 (less than 1 percent of all undergraduates receiving aid).34

Again, this number may represent an undercount because of how FAFSA 

collects information.35

Like foster youth, unaccompanied homeless youth enrolled at public 2-

year colleges to a greater extent than other students. Specifically, 

Education’s administrative data show that 46 percent of homeless 

students who received federal student aid in 2013-2014 attended public 

 

33GAO, Homelessness: A Common Vocabulary Could Help Agencies Collaborate and 

Collect More Consistent Data, GAO-10-702 (Washington, D.C.: June 30, 2010) and GAO, 

Education of Homeless Students: Improved Program Oversight Needed, GAO-14-465 

(Washington, D.C.: July 31, 2014). 

34Data on homeless youth are for students who are unaccompanied homeless youth and 

are considered independent for federal student aid purposes. In analyzing college 

outcomes for homeless youth, we focused on unaccompanied homeless youth (those who 

are not in the physical custody of their parents or guardians) rather than all homeless 

youth because data are available only for unaccompanied homeless youth. Administrative 

data cited are from Education’s Common Origination and Disbursement System, which 

contains information on students who receive federal student aid. Further, our analysis of 

NPSAS data showed that about 21,000 of the approximately 23 million students enrolled 

in college during the 2011-2012 school year were unaccompanied homeless youth (less 

than 1 percent of all college students). The data on homeless youth from NPSAS and the 

Common Origination and Disbursement system vary due to differences in the data 

sources, such as the specific student population and timeframes.

35Data on unaccompanied homeless youth based on FAFSA responses may represent an 

undercount of homeless youth because of how FAFSA screens applicants to determine 

whether they are dependent or independent students. Students who are considered 

independent because they are 24 years of age or older, served in the military, or are 

married, among other things, do not answer the FAFSA questions about whether they are 

unaccompanied homeless youth.

Unaccompanied 

Homeless Youth Have 

College Enrollment 

Patterns Similar to Foster 

Youth but Little Is Known 

about Completion
Page 17 GAO-16-343 College Outcomes for Homeless and Foster Youth 

2-year schools, compared to 30 percent of all other undergraduates 

receiving federal student aid (see fig. 5).36

Figure 5: Types of Colleges Attended by Unaccompanied Homeless Youth and All Other Undergraduates, Free Application for 

Federal Student Aid Award Year, 2013-2014

Notes: Figures and subtotals may not add to 100 due to rounding. The non-profit category refers to 

private non-profit colleges. Data on 2-year colleges also include some certificate programs that are up 

to 3 years in length.

Like foster youth, unaccompanied homeless youth enrolled in college also 

pursued an associate’s degree to a greater extent than other students.

Specifically, an estimated 59 percent of unaccompanied homeless youth 

enrolled in 2011-2012 pursued an associate’s degree program compared 

to 44 percent of all other students, according to our analysis of NPSAS 

data.37 Conversely, unaccompanied homeless youth enrolled in a 

 

36All unaccompanied homeless youth comparisons from NPSAS are statistically 

significant at the 95 percent confidence level unless otherwise indicated. While our 

analysis of NPSAS data also indicated that a higher percentage of unaccompanied 

homeless students attended public, two-year colleges than other students, in this 

instance, the results of this additional analysis were not statistically significant. The small 

sample size for unaccompanied homeless youth in the NPSAS data may not be sufficient 

for detecting statistical significance.

37We compared unaccompanied homeless youth to other low-income students and all 

other students for our NPSAS analyses. We compared low-income students and 

unaccompanied homeless youth because most unaccompanied homeless youth have 

incomes within the lowest income quartile of all college-enrolled youth. 
Page 18 GAO-16-343 College Outcomes for Homeless and Foster Youth 

bachelor’s degree program to a lesser extent than all other students (see 

fig. 6).38

Figure 6: Comparison of Degree Program Enrollment for Unaccompanied Homeless Youth and Other Students, By Estimated 

Percent Enrolled, School Year 2011-2012

aPercentage estimate is not statistically different from the unaccompanied homeless youth estimate at 

the 95 percent confidence level.

Notes: All unaccompanied homeless youth comparisons are statistically significant at the 95 percent 

confidence level, unless otherwise indicated. All estimates have margins of error of within plus or 

minus 10 percentage points, with the exception of the unaccompanied homeless youth estimates for 

associate’s and bachelor’s degrees: The confidence intervals for these estimates are 45 to 72 percent 

for associate’s degree and 20 to 47 percent for bachelor’s degree. We compared unaccompanied 

homeless youth to low-income students because most unaccompanied homeless youth have 

incomes within the lowest income quartile of all college-enrolled youth. The “all other students”

category includes all students who are not unaccompanied homeless youth, regardless of income 

level.

While some information is available on the college enrollment patterns of 

unaccompanied homeless youth, little is known about their completion 

rates. Our literature review found no rigorous studies on the college 

graduation rates of homeless youth. In our past work, we found that 

information on homeless youth can be limited because of data collection 

challenges such as the stigma associated with homelessness and the 

existence of multiple federal definitions of homelessness.39 An official at a 

 

38We also compared unaccompanied homeless youth to dependent students because 

they are similar in age (under 24) to foster and homeless youth. The results were largely 

similar to the comparisons with low-income youth and all other youth (see app. II).

39GAO-14-465 and GAO-10-702.
Page 19 GAO-16-343 College Outcomes for Homeless and Foster Youth 

national homeless organization said that she was not aware of any 

colleges or universities that were tracking graduation rates for 

unaccompanied homeless youth. Further, federal data on college 

completion for homeless youth are limited because Education did not 

collect information on homeless youth for either the NPSAS or BPS data 

sets prior to 2011-2012. However, more should be known about 

graduation rates for unaccompanied homeless youth in upcoming years. 

In 2011-2012, Education included a question to identify homeless youth 

for the first time in the BPS. Starting in 2017, when Education will have 6 

years of data on homeless youth attending college, it will be possible to 

begin assessing college completion rates for unaccompanied homeless 

youth.40

From elementary school through high school, many homeless and foster 

youth face common challenges that can leave them unprepared and illequipped for college, according to stakeholders we interviewed and 

studies and reports we reviewed (see table 1 for a summary of these 

challenges). Many homeless and foster youth have weak academic 

foundations for college because of their frequent moves from school to 

school. They also typically have few supportive family members or other 

adults they can turn to for help and advice about how to apply for, enroll, 

and stay in college. Lastly, because they typically have low incomes, their 

financial resources for college are limited. These challenges can also be 

exacerbated by the extent to which homeless and foster youth lack 

awareness about federal financial resources that are available to help 

them pursue a college education.

 

40The current student cohort for the BPS began college in 2012, was surveyed in 2014, 

and will be contacted again in 2017.

Limited Academic 

Preparation, Family 

Support, and 

Awareness of 

Resources Make It 

Harder for Homeless 

and Foster Youth to 

Pursue College
Page 20 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Table 1: Key College Challenges for Homeless and Foster Youth

Source: GAO analysis of challenges and effects based on stakeholder views and reports and studies we reviewed. | GAO-16-343

While many homeless and foster youth deal with academic issues 

associated with other low-income and disadvantaged students, these 

youth can experience additional academic and other challenges that can 

hinder their ability to attend and succeed in college. For many homeless 

and foster youth, their early academic development is often disrupted by 

frequent changes in living arrangements and subsequent transitions into 

different schools. As we have previously reported, research suggests that 

student mobility has a negative effect on students’ academic 

achievement.41 Specifically, research has found that students who 

changed schools more frequently than other students tended to have 

lower scores on standardized reading and math tests and drop out of 

school at higher rates than their less mobile peers. Many homeless and 

foster youth change schools multiple times, according to officials from 

foster care and homelessness organizations we interviewed. A study we 

reviewed of more than 650 former foster youth indicated that 65 percent 

had changed schools seven or more times from elementary through high 

 

41GAO, K-12 Education: Many Challenges Arise in Educating Students Who Change 

Schools Frequently, GAO-11-40 (Washington, D.C.: Nov 18, 2010).

Common characteristics of 

homeless and foster youth

Effect on college 

enrollment

Effect on college 

persistence and attainment

Academic preparation

Frequent school changes 

lead to lower academic 

performance

Take few or no college 

preparation courses

Difficulty meeting college 

admissions requirements

Unprepared for college-level 

courses (stuck in remedial 

classes)

Family supports

Lack strong family support 

systems or other adult 

mentors

Less access to high school 

counselors and college 

advisors

Difficulty navigating 

complex college 

application and financial 

aid processes

Lack emotional support

Lack adult mentors

Financial

Predominately from lowincome backgrounds 

Financial aid does not 

fully cover students’

needs

Trouble balancing financial 

obligations of school and life

Lack of stable housing

Weak Academic 

Foundations Can Hinder 

College Progress and 

Success
Page 21 GAO-16-343 College Outcomes for Homeless and Foster Youth 

school.42 Similarly, a homeless youth in one of our discussion groups said 

she and her family had lived out of a car in 11 different states, and she 

often spent just a few weeks or months at each new school. Frequent 

school changes can be disruptive for students’ academic progress 

because they must adjust to new curriculums, classmates, and teachers.

The lack of sufficient academic preparation can make it difficult for some 

homeless and foster youth to qualify for college enrollment. College 

admission standards generally require students to have completed a high 

school degree or a recognized equivalent; however, homeless and foster 

youth generally have lower rates of high school completion than their 

peers, according to federal officials and studies we reviewed. For 

example, Education officials told us that available data from states 

indicate that a lower percentage of homeless students graduate from high 

school compared to non-homeless students. Foster and homeless youth 

also tend to be absent from classes more than other students, which 

impedes their academic progress.43 In addition, homeless and foster 

youth who do graduate from high school may not have sufficient grades 

or may not have taken the necessary college preparatory courses to meet 

college admissions standards. For example, a homeless youth in one of 

our discussion groups said her high school grade point average was not 

high enough to be accepted into college. Similarly, many homeless youth 

acquire a General Education Development (GED) credential rather than a 

high school diploma, which HHS officials said can make it more difficult to 

get into college.

Weak academic foundations can continue to hinder these students when 

they are enrolled in college. Many homeless and foster youth are not 

sufficiently prepared for college-level classes, so they must enroll in 

remedial education courses during their first year in college, according to 

federal and state officials we interviewed. A foster youth in one of our 

discussion groups said she was not academically prepared for college so 

she had to take remedial English and other summer classes to catch up. 

As we have previously reported, students in remedial education have 

 

42P.J. Pecora, et al., “Results from the Northwest Foster Care Alumni Study.”

43Thomas R. Wolanin, Higher Education Opportunities for Foster Youth: A Primer for 

Policy Makers, The Institute for Higher Education Policy (Washington, D.C.: December 

2005), and National Center for Homeless Education, Best Practices in Homeless 

Education: Increasing Access to Higher Education for Unaccompanied Homeless Youth: 

Information for Colleges and Universities (Washington, D.C.).
Page 22 GAO-16-343 College Outcomes for Homeless and Foster Youth 

relatively low chances of completing their degrees or certificates within 8 

years.44 Education officials also said these students are using portions of 

their available student aid on remedial classes, which do not count toward 

a degree.45 The cumulative effect of these academic challenges can 

make it more difficult for homeless and foster youth to achieve successful 

college outcomes.

Without the support of family members or mentors, homeless youth and 

youth in foster care may lack the impetus to pursue college or the 

knowledge to navigate the complex enrollment process. Homeless and 

foster youth may be less inclined to think of college as a viable option 

when they do not have relationships with supportive adults to convey the 

value of education or provide models of academic success, according to 

several reports and a homeless organization we interviewed.46 A college 

financial aid administrator we interviewed told us that lack of 

encouragement and support from a caring adult and the generally low 

expectations of homeless and foster youth keep these students from 

applying to college. In addition, homeless and foster youth often lack the 

support of knowledgeable adults to help guide them through the complex 

processes of applying to and selecting a college, according to several 

officials from foster care and homelessness organizations we interviewed. 

As a result, homeless and foster youth who are interested in going to 

college often do not know how to start the process and lack information 

on different types of colleges and programs, according to federal and 

state officials we interviewed, as well as officials from foster care and 

homelessness organizations. For example, a representative for college 

admission counselors explained that it can be extremely challenging for 

homeless and foster youth to complete the numerous college admission 

requirements on their own, such as signing up for college admissions 

tests and completing the FAFSA.

 

44GAO, Community Colleges: New Federal Research Center May Enhance Current 

Understanding of Developmental Education, GAO-13-656 (Washington, D.C.: September 

2013).

45Students are eligible to receive Pell Grants for up to 12 semesters.

46Wolanin, Higher Education Opportunities for Foster Youth: A Primer for Policy Makers; 

A. Dworsky and A. Pérez, Helping former foster youth graduate from college: Campus 

support programs in California and Washington State. (Chicago: Chapin Hall at the 

University of Chicago, 2009).

Limited Family Support 

Can Make It Difficult to 

Enroll in and Succeed in 

College
Page 23 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Although many foster and homeless youth can turn to certain 

professionals to help them with college applications and planning, these 

professionals may not have the time or knowledge to provide the full 

extent of college guidance that some homeless and foster youth need, 

according to relevant reports we reviewed and interviews with officials 

from higher education organizations. High school counselors are often 

tasked with many responsibilities in addition to college counseling, and 

also have high caseloads, especially those who serve low-income 

students.47 McKinney-Vento homeless liaisons in particular are often 

more focused on helping homeless students with fundamental needs, 

such as obtaining food and shelter and staying in high school, rather than 

helping them apply to college, according to Education officials and federal 

researchers we interviewed. Similarly, child welfare caseworkers are 

often more focused on helping foster youth transition to independence as 

they age out of the foster care system, according to foster care experts 

we interviewed. 

Further, according to federal and other officials, some of these 

professionals are not fully aware of federal student aid or college 

application processes because these are not their areas of expertise. Yet 

child welfare systems are required to help youth aging out of foster care 

prepare to transition to adulthood, and this transition means going to 

college for many young people.48 Similarly, under the McKinney-Vento 

Homeless Assistance Act, school districts are required to coordinate with 

social services agencies and other programs to help meet homeless 

 

47School counselors’ responsibilities also include administrative duties (monitoring special 

education compliance), academic counseling (ensuring students are taking the right 

courses, counseling struggling students), and even social work (addressing student 

discipline and mental health issues). According to the National Association of College 

Admission Counseling, public high school counselors spend only about a quarter of their 

time on college admission counseling. M. Clindinst, et al., State of College Admission 

2012: National Association of College Admission Counseling. Further, although the 

American School Counselors Association recommends a student-to-counselor ratio of 

250:1, the ratio for counselors serving low-income students averages 1,000:1, according 

to a survey by the National Association of College Admission Counseling.

48State child welfare agencies are required to help youth aging out of foster care to 

develop a transition plan that must be implemented during a 90-day period prior to a 

youth’s 18th birthday (or up to a youth’s 21st birthday in states that offer extended foster 

care). The plan is to be directed by the youth and must include specific options on 

education, housing, and other matters. 42 U.S.C. § 675(5)(H).
Page 24 GAO-16-343 College Outcomes for Homeless and Foster Youth 

students’ academic and other needs.49 Under the most recent change to 

the law, McKinney-Vento homeless liaisons are responsible for informing 

unaccompanied homeless youth that they may obtain help from them to 

verify their status as an unaccompanied homeless youth.50

These professionals from different fields are important resources for 

homeless and foster youth, who often lack any family support to help 

them navigate the college application and financial aid processes. 

However, these professionals work in different, complex systems with 

competing priorities, and the primary purpose of these systems is not to 

facilitate college planning and admissions. Further, these professionals 

have multiple responsibilities that make it challenging to provide this type 

of assistance. These systems may be able to take steps to more 

effectively encourage and enable these professionals to provide more 

active college planning. Given the complexities of these different systems, 

any effort to do so would need to carefully consider current workloads, 

responsibilities, and training needs of these professionals, as well as 

program goals, priorities, and incentives. Education and HHS are 

responsible for administering the McKinney-Vento program and child 

welfare programs, and as such would be well positioned to consider 

available options for encouraging college planning efforts among 

professionals in these programs who work with homeless and foster 

youth. Officials from Education and HHS agreed that it would be helpful to 

explore such options. Without additional support from professionals they 

encounter in school or through the child welfare system, homeless and 

foster youth may not receive the assistance they need to attend college 

and may struggle to establish independent, productive lives.

The lack of emotional support from caring adults can also make it more 

difficult for homeless and foster youth to be successful once enrolled in 

college. Youth in our discussion groups and officials from national 

organizations that work with homeless youth discussed how homeless 

and foster youth often feel alone and isolated on campus. For example, 

an official from an organization involved with homelessness issues 

shared a story of a homeless youth who felt depressed on college move-

 

4942 U.S.C. § 11432(g)(5). Also, under the GPRA Modernization Act of 2010, federal 

agencies should collaborate on similar goals. Pub. L. No. 111-352, 124 Stat. 3866 (2011). 

50Pub. L. No. 114-95, § 9102(5), 129 Stat. 1802, 2126 (2015), codified at 42 U.S.C. § 

11432(g)(6)(A)(x)(III).
Page 25 GAO-16-343 College Outcomes for Homeless and Foster Youth 

in day when her classmates brought personal belongings in U-Hauls and 

had parents helping them, but she had only two suitcases and had to 

move in by herself. A homeless youth in one of our discussion groups 

said she continued to face difficulties after she enrolled in college 

because she did not have anyone to provide emotional support or help 

validate that she was making the right decisions. Homeless students in 

both of our discussion groups said either that they had mentors who 

proved critical to their success at school or that they wished they had a 

mentor. To help such students, colleges in nine states have instituted 

Single Points of Contact (known as SPOCs) to offer guidance and 

counseling services to vulnerable populations such as homeless and 

foster youth, according to a national homelessness organization. The 

SPOC is a supportive college administrator who helps these youth 

address barriers by providing referrals to admissions, financial aid, and 

academic advising staff. A national homelessness organization is working 

to establish SPOCs at colleges in other states. Similarly, Virginia higher 

education officials told us the state has established coaches and case 

management support programs for foster youth at 18 of its community 

colleges.

The vast majority of homeless and foster youth come from low-income 

backgrounds with limited access to financial supports. Foster youth are 

much more likely than their peers to be poor before, during, and after they 

are in foster care, and the lack of a stable income is common among 

homeless families, according to some studies.51 Among college-enrolled 

foster youth, an estimated 95 percent had annual incomes of less than 

$25,000, along with 100 percent of college-enrolled homeless youth, 

according to our analysis of NPSAS data for 2011-2012.52

These financial challenges can create numerous obstacles to college 

enrollment for homeless and foster youth. The upfront cost of college 

entrance exams, transcripts, and application fees creates an immediate 

barrier that may deter some homeless and foster youth from considering 

 

51For example, see Peter J. Pecora, et al., Improving Foster Family Care: Findings from 

the Northwest Foster Care Alumni Study, Casey Family Programs (Seattle, WA: 2005).

52These data are based on students who self-identify as having been in foster care or as 

unaccompanied homeless youth on the FAFSA and who would therefore be considered 

financially independent.

Financial Challenges Can 

Be Exacerbated by 

Limited Awareness of 

Available Federal 

Resources
Page 26 GAO-16-343 College Outcomes for Homeless and Foster Youth 

college as an option, according to experts and students with whom we 

spoke. For example, one homeless youth said it was challenging on a 

limited budget to cover the cost of college application fees, some of which 

are as much as $150. Eligible youth can apply to obtain fee waivers for 

college entrance exams and application fees, although the extent to 

which students are aware of these waivers likely varies.53 The financial 

challenges often persist after these students are accepted into schools 

because available federal grants are rarely sufficient to fully cover their 

tuition and living expenses.54 In some cases, homeless and foster youth 

take out federal or private student loans to pay for college. A homeless 

youth in one of our discussion groups said her school provided some 

financial aid but she had to take out an additional $12,000 in loans her 

first year of college to cover expenses.

This financial stress can affect the ability of homeless and foster youth to 

complete college. In one three-state study, the need to work was the most 

common reason given by foster youth for why they dropped out of 

college.55 While many students work during college, foster youth in our 

discussion groups also described having to work one or more jobs, often 

to the detriment of their classes. For example, one former foster youth 

told us she worked up to 60 hours a week to support herself while 

attending college part-time.56 A particular financial concern for homeless 

and foster youth is finding affordable housing while in college, according 

 

53For example, homeless youth automatically qualify for the College Board’s college 

application waiver. Some colleges also establish their own individual waiver policies. 

54According to our analysis of NPSAS data, although college-enrolled foster youth 

received an estimated average of $7,175 in total federal grants and loans in 2011-12, they 

still needed to cover an estimated average of $8,099 in expenses out-of-pocket after all 

their financial aid was accounted for that year. According to the College Board, the 

average cost of tuition, fees, room and board at a public 4-year college for the 2014-15 

school year was $18,943. College Board (2015). Trends in higher education: Tuition and 

fees and room and board over time. Retrieved from http://trends.collegeboard.org/collegepricing/figures-tables/tuition-fees-room-board-time

55Courtney, et al., Midwest Evaluation.

56The lack of a family safety net can be compounded for unaccompanied homeless youth, 

who worked full-time while in school to a greater extent than low-income students, 

according to our analysis of 2011-2012 NPSAS data. For example, about 32 percent of 

homeless youth were working full-time while enrolled in college, compared to 17 percent 

of low-income youth. The difference between unaccompanied homeless youth and all 

other youth working full-time while in college was not statistically significant, according to 

our NPSAS analysis. 
Page 27 GAO-16-343 College Outcomes for Homeless and Foster Youth 

to multiple experts and federal officials we interviewed. Students in our 

discussion groups talked about the stress of finding and affording stable 

housing, and a student in one discussion group expressed fear over 

becoming homeless again. Homeless and foster youth can face particular 

difficulty securing housing during school holidays and summer breaks 

when campus dorms are often closed, according to federal and other 

officials. According to a national homelessness organization, homeless 

students often focus on finding summer housing in May instead of 

concentrating on studying for final examinations.

Despite their financial and housing needs and without knowledgeable 

adults in their lives, many homeless and foster youth are not aware of 

federal programs that could help them, such as Pell Grants and Chafee 

ETV vouchers, according to federal officials and other stakeholders. 

Some research suggests that low-income and first-generation students—

which may include many homeless and foster youth—lack general 

knowledge about how financial aid works and often do not realize that 

financial aid, including need-based aid, is available. For example, lower 

income respondents in a survey of prospective and recently-enrolled 

students reported less familiarity with Pell Grants than with scholarships 

from colleges or loans.57 In addition, former foster youth in one of our 

discussion groups told us they were initially unaware that they were 

eligible for Chafee ETV vouchers. One of these students did not receive a 

Chafee ETV voucher until her junior year of college because she and 

administrators at her college were unfamiliar with the program. 

Because they are commonly on their own, many homeless and foster 

youth must generally independently identify potential sources of funding 

or other financial support provided by government and other entities. 

While specialized resources are available for homeless and foster youth, 

such as Chafee ETV vouchers, test fee waivers, waivers for college 

application fees, and state tuition waivers for foster youth, there is no 

centralized federal online location for these youth to learn about existing 

resources.58 While homeless or foster youth may not have access to the 

 

57Rachel Fishman, 2015 College Decisions Survey Part III, Familiarity with Financial Aid,

New America Foundation, August 2015, and unpublished data obtained from the author. 

This survey was based on a nonprobability sample of prospective and recently enrolled 

students who were participants in an online respondent panel that was designed to be 

representative of the general population.

58At least 22 states have passed tuition waivers to help former foster youth attend college, 

according to an organization knowledgeable about foster youth issues.
Page 28 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Internet where they live, they may have other ways to access online 

information, such as public library computers or cellphones. For example, 

students in two discussion groups told us that they were able to access 

the Internet at their school libraries during lunch hours, and one of them 

said Internet access was not an issue because everyone had a device.

Although Education provides federal student aid information on its 

website, little information on financial aid and college planning is readily 

available or tailored for homeless and foster youth. Education is required 

under the Higher Education Act to provide students and their families with 

information to help them make informed college decisions, including 

information about aid available from Education and other federal 

departments.59 Further, Education is required to continue to improve the 

usefulness and accessibility of the information provided on college

planning and student financial aid.60 Education provides webpages with 

specialized information for certain types of students, including those with 

criminal convictions, intellectual disabilities, or parents killed in Iraq and 

Afghanistan. Education does have a webpage about foster youth that 

offers limited information about financial resources, but that information is 

generally not directed towards foster youth and is difficult to find. For 

example, Education’s webpage about foster youth is largely targeted to 

policymakers and practitioners, such as financial aid administrators or 

grant applicants, and contains relatively little information to help foster 

youth seeking to enroll in college. It provides legal and technical 

information mostly about foster youth in elementary and secondary 

school. The webpage does contain a link to an easily understandable 

document on Chafee ETV vouchers explaining who is eligible, how they 

can apply, and how much funding they could receive. However, the other 

items related to college include a technical explanation of dependent 

versus independent students and a Dear Colleague Letter directed at 

college officials about how to treat foster care payments made directly to 

older youth. Finally, the webpage is not easy to find from the main 

 

5920 U.S.C. § 1015(b), (d) and (g).

6020 U.S.C. § 1015(e)(1).
Page 29 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Education webpage for students looking for college information: we were 

unable to locate the webpage without searching the website.61

Similarly, Education had little information for unaccompanied homeless 

youth until recently on its federal student aid website other than the 

FAFSA instructions for filling out the questions for unaccompanied 

homeless youth. During the course of our work, an Education official 

responsible for homeless issues for elementary and high school students 

said Education was planning a webpage about homeless students that 

would include some college information, but did not know when it would 

be finalized or what kind of college information would be included. In its 

technical comments, Education noted that it had just launched a new 

webpage that consolidates information on its resources for homeless 

children and youth from pre-kindergarten through higher education. While 

this new webpage provides important information on independent student 

status and federal resources for unaccompanied homeless youth, the 

webpage is directed to the public and practitioners, such as McKinneyVento liaisons, not homeless students seeking to enroll in college. 

Furthermore, the page is not easily accessible and students need to click 

on multiple indirect links about the agency and its initiatives to find it. In 

addition, Education said that it was working to complete a factsheet for 

unaccompanied homeless youth that will consolidate resources from 

several places. In developing this factsheet, it will be important for 

Education to include easy-to-understand information that is relevant to 

unaccompanied homeless youth and post it in a place easy for students 

to find. 

Tailoring financial aid information to unaccompanied homeless youth and 

foster youth would continue to improve the usefulness and accessibility of 

the information provided on college planning and student financial aid, as 

required under the Higher Education Act. While Education is developing 

more online information, the relative lack of readily available information 

about college resources directed towards homeless and foster youth 

makes it difficult for these highly vulnerable youth with limited adult 

 

61 In addition, when foster youth report on the online FAFSA that they are or have been in 

foster care, the FAFSA online confirmation page provides a link to an HHS webpage. 

However, that information is not prominently displayed on the confirmation page. Further, 

the college-related information on the HHS webpage is not readily apparent—in addition 

to providing links to state coordinators for Chafee ETV vouchers, it lists a broad range of 

child welfare resources, such as hotlines, adoption information, and complaint offices that 

are unrelated to potential college applicants.
Page 30 GAO-16-343 College Outcomes for Homeless and Foster Youth 

support to learn about programs to help them attend college. It also

makes it difficult for professionals, such as child welfare caseworkers, 

who may be trying to help these youth but who lack the expertise to do so 

effectively without further information. As a result, foster and homeless 

youth, or the professionals who assist them, cannot easily locate clear 

information on available resources and may miss opportunities to obtain 

financial assistance for which they are eligible and which they need to 

successfully complete college.

When unaccompanied homeless youth cannot obtain verification of their 

status from the specific federal program officials cited on the FAFSA, they 

must rely on financial aid administrators at individual colleges to 

determine if they are unaccompanied and homeless and therefore meet 

the definition of an independent student.62 However, according to officials 

from organizations that work with homeless youth and homeless youth in 

our discussion groups, financial aid administrators have been reluctant to 

make these determinations without burdensome documentation requests. 

If a student does not have a homeless youth determination from one of 

the officials cited on the FAFSA, Education requires a financial aid 

administrator to evaluate the student’s situation and determine if the 

student qualifies as an unaccompanied homeless youth.63 According to 

 

62In discussing the barriers that homeless youth face for college, we focused primarily on 

unaccompanied homeless youth because they are asked to identify themselves as such 

when they apply for federal student aid on the FAFSA, while homeless youth living with 

their families are not distinguishable from other students. 

63The authorized program directors cited in the FAFSA include school homeless liaisons 

or directors of HUD-funded emergency shelters or transitional housing programs or 

directors of runaway or homeless youth centers or programs funded by HHS. 20 U.S.C.A. 

§ 1087vv(d)(1)(H)(i)-(iii).

Burdensome Program 

Rules Can Hinder the 

Ability of Homeless 

and Foster Youth to 

Access Federal 

Supports

Extensive Documentation 

Requests Can Impede 

Access to Aid for 

Homeless Youth
Page 31 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Education’s guidance, the financial aid administrator should document 

that a student meets the definition of an unaccompanied homeless 

youth—either with documentation from a third-party source provided by 

the student or, if the student does not have such documentation, the 

financial aid administrator can interview the student about his or her living 

situation and document the interview.64 There are no specific 

requirements in law or Education’s guidance about what kind or how 

much documentation is needed to demonstrate a student’s status. 

Financial aid administrators can accept documentation of homelessness 

from recognized third-parties, such as high school counselors, social 

workers, mentors, doctors, and clergy, according to Education’s 

guidance. Although these other professionals cannot directly make the 

determination of homelessness, financial aid administrators can use 

information from these professionals to support and document their own 

determinations.65

As noted in Education’s most recent guidance, some colleges were 

unnecessarily restricting applicants’ access to student aid by asking them 

to justify why they are homeless or unaccompanied rather than 

requesting evidence to demonstrate that they are homeless or at risk of 

being homeless. Similarly, homeless students in both of our discussion 

groups told us they were asked multiple times to explain why they were 

homeless and not living with their families, and one was asked to produce 

a copy of a police report to explain her family situation. Asking personal 

and intrusive questions often causes unaccompanied homeless students 

to walk away before completing the financial aid process, according to 

officials from higher education organizations. For example, homeless 

youth who are estranged from family because of parental sexual or other 

kinds of abuse do not want to repeatedly share these personal details and 

choose not to complete the process to obtain federal student aid, 

according to an official from a higher education organization and financial 

aid administrator we spoke with. To address this issue, Education issued 

guidance in July 2015 that institutions should limit any inquiries to 

 

64Application and Verification Guide from Education’s 2015-2016 Federal Student Aid 

Handbook.

65Financial aid administrators’ decisions cannot be appealed to Education, according to 

Education guidance. Data on administrators’ denials of unaccompanied homeless youth 

status are not available, according to a national homeless youth organization we 

contacted. 
Page 32 GAO-16-343 College Outcomes for Homeless and Foster Youth 

whether—not why—an applicant meets the criteria for being an 

unaccompanied homeless youth.66

In addition, financial aid administrators frequently ask homeless youth to 

provide extensive documentation about their situations, some of which 

can be difficult to obtain, according to officials from homelessness and 

higher education organizations and homeless youth we spoke to. For 

example, an unaccompanied homeless youth in one of our discussion 

groups told us that she had to submit many documents, including 

documentation for a group home that she had lived in 3 years earlier that 

kept such records at an off-site storage facility. Financial aid 

administrators at two colleges told us that documentation is hard for 

homeless students who are not in a situation where there is a third party 

to substantiate their living circumstances, such as those who are 

temporarily sleeping on a friend’s or relative’s couch because they have 

nowhere else to go and who have never connected with a formal social 

service organization. A college official in Michigan said that some 

financial aid administrators require an unaccompanied homeless youth to 

submit three pieces of documentation about his or her situation and do 

not understand how difficult these are for students to obtain. Education’s 

July 2015 guidance states that, if a college has no conflicting information 

about the student’s status, the college should not request additional 

documentation, proof, or statements because of the sensitive nature of 

these situations. Officials from two homeless organizations noted that 

some youth feel a stigma associated with being homeless and feel 

uncomfortable asking multiple parties for documentation. Furthermore,

many financial aid administrators often do not exercise the option to 

interview students to determine whether they are unaccompanied 

homeless youth, and then document that interview for their records, 

according to higher education and homelessness officials we interviewed.

Having to obtain extensive documentation can make it difficult for 

homeless youth to complete the financial aid process on time. Until a 

financial aid administrator signs off that a student is unaccompanied and 

homeless, the student’s FAFSA application is considered incomplete. 

Students in this situation can miss deadlines for getting federal student 

 

66This guidance was issued first in a July 2015 Dear Colleague Letter (DCL-GEN-15-16).

The most recent Application and Verification Guide from September 2015 further notes 

that financial aid administrators should respect students’ privacy, that some information is 

confidential, and that police or child protective services reports are not necessary.
Page 33 GAO-16-343 College Outcomes for Homeless and Foster Youth 

aid and consequently may have to pay upfront costs themselves. For 

example, a homeless youth in one of our discussion groups said that the 

process took so long that she had to pay tuition upfront to hold her 

classes and then wait for reimbursement after providing the requested 

documentation. Another homeless youth in one of our discussion groups

had no financial aid for an entire quarter because the application took 

more than 6 weeks to process.

The reluctance by financial aid administrators to make an unaccompanied 

homeless youth determination without considerable documentation may 

stem from a number of factors, according to financial aid administrators 

we spoke with and officials from higher education organizations. First, 

financial aid administrators at schools that assist few homeless students 

each year are likely to be less accustomed to assessing a student’s 

homeless status and less familiar with the process. According to two 

financial aid administrators and officials from a higher education and a 

homelessness organization, financial aid offices may not typically work 

with a lot of homeless youth. Second, financial aid administrators work in 

a particularly risk-averse culture, according to Education officials, and 

higher education and homelessness officials we interviewed—many are 

concerned that future audits and oversight activities by Education could 

cite them for not complying with agency requirements for documentation, 

even though administrators are allowed to make determinations on the 

basis of their own interviews. For example, financial aid administrators at 

several colleges told us they are concerned that Education could question 

their determinations if they did not have documentation from other parties. 

Education officials said they have heard similar concerns, even though 

administrators are authorized under the Higher Education Act to make 

unaccompanied homeless youth determinations. Lastly, according to 

higher education and homelessness officials, financial aid administrators 

are accustomed to receiving official documentation, such as a marriage 

license or military papers from veterans, as primary support for their 

decisions when they change a student’s status from dependent to 

independent. One college financial aid administrator we spoke to said that 

financial aid administrators are trained “from day one” that they need 

documentation for these types of decisions. However, administrators 
Page 34 GAO-16-343 College Outcomes for Homeless and Foster Youth 

have had the option to interview homeless students and document that 

interview since at least 2009, according to Education guidance.67

A national higher education organization and several financial aid 

administrators suggested that making a form available to help determine 

and document whether students are unaccompanied and homeless could 

make the process easier for both students and financial aid 

administrators. While such a form has been developed by two homeless 

organizations, Education has not adopted or encouraged the use of such 

a form. These officials told us that having Education adopt or encourage 

the use of such a form would be more effective in promoting its use.68

Such an optional form could offer financial aid administrators a tool to 

document homeless students’ situations, especially during interviews, as 

well as provide just-in-time guidance on federal requirements to help 

them recognize when they have enough documentation. It could also be 

particularly helpful for administrators who do not see many homeless 

student applicants and who may be less comfortable with interviews or 

some third-party documentation, such as letters from mentors, doctors, or 

clergy. Similarly, a worksheet or form could also help students navigate 

this complicated process and let them know what kind of documentation 

they may need to prepare for meetings with financial aid staff, according 

to financial aid administrators we interviewed. 

In discussing this possibility, an Education official said that the agency 

could highlight the availability and usefulness of such a form in future 

guidance. According to Education officials, the agency cannot require 

financial aid administrators to use a standard form for documenting a 

student’s status as an unaccompanied homeless youth because the 

agency is prohibited from regulating in this area.69 Making a voluntary 

worksheet or form available for administrators to use to document an 

 

67This guidance was issued in response to changes made by the College Cost Reduction 

and Access Act, which expanded the definition of independent students to include 

students verified as unaccompanied homeless youth. Application and Verification Guide, 

2009-2010.

68The National Association for the Education for Homeless Children and Youth in 

collaboration with the National Center for Homeless Education developed a two-page form 

that financial aid administrators can use when evaluating whether a student meets the 

definition of an unaccompanied homeless youth.

69Education is prohibited from regulating any part of the process that determines a 

student’s eligibility for federal student aid. 20 U.S.C. § 1087rr(a).
Page 35 GAO-16-343 College Outcomes for Homeless and Foster Youth 

interview or third-party information would be consistent with Education’s 

strategic plan goal to make federal student aid information easily 

accessible.70 Such a worksheet or form would also help financial aid 

administrators document their homeless youth determinations and would 

also help unaccompanied homeless youth better understand the financial 

aid process, demonstrate their status, and obtain the federal student aid 

for which they are eligible.

The requirements and process for identifying unaccompanied homeless 

youth can pose a barrier to these students obtaining federal student aid. 

By law, to be considered independent students, they must have their 

status as an unaccompanied homeless youth in the aid year verified by a 

McKinney-Vento homeless liaison, a program director cited in the FAFSA, 

or a financial aid administrator. Further, the Higher Education Act requires 

homeless students seeking independent status to have their 

circumstances re-verified by an authorized program official or a financial 

aid administrator each school year.71 The same requirements apply to a 

student’s initial verification and any re-verification in subsequent years—if 

a student cannot obtain a determination from one of the authorized 

program officials, a financial aid administrator must evaluate the student’s 

situation and document the student’s eligibility as an unaccompanied 

homeless youth with documentation from a third-party or a documented 

interview.

Officials from homelessness and higher education organizations that work 

with homeless youth told us that having a McKinney-Vento homeless 

liaison or other authorized program official verify a student’s status as an 

 

70In its fiscal year 2012-2016 Strategic Plan, Education’s Office of Federal Student Aid 

outlines a goal of ensuring that all participants in the system of postsecondary education 

funding, such as college financial aid administrators, serve the interests of students, from 

policy to delivery. One of Education’s objectives under this goal is to work to ensure that 

all participants in the postsecondary education funding system can easily access the 

information they need to support their role. U.S. Department of Education, Office of 

Federal Student Aid, Federal Student Aid Strategic Plan, Fiscal Years 2012-2016

(December 2011).

7120 U.S.C. § 1087vv(d)(1)(H). All students applying for federal student aid as 

independent students have to annually attest to their current or past circumstances. The 

FAFSA form requires all students applying for aid to certify that all of the information they 

provided is true and complete and cites fines and other penalties for false or misleading 

information.

Annual Re-Verification of 

Homelessness Poses 

Barrier for 

Unaccompanied 

Homeless Youth
Page 36 GAO-16-343 College Outcomes for Homeless and Foster Youth 

unaccompanied homeless youth can be increasingly difficult after a 

student’s first year of college. Information these organizations provide to 

students and other stakeholders on how to complete the FAFSA note that 

a student cannot obtain a homeless youth determination from a 

McKinney-Vento homeless liaison or the other authorized program 

officials if the student is not in high school or is not receiving services 

from one of the authorized programs. McKinney-Vento liaisons do not 

provide services to students who have left high school, and the other 

authorized programs either do not serve college-age students or do not 

serve them for extended periods of time.72 As a result, it may be difficult 

for youth to obtain a homeless determination from officials of these 

programs in multiple years. For example, officials from homelessness and 

higher education organizations told us that once homeless youth are out 

of high school and no longer receiving services from the McKinney-Vento 

homeless program, the McKinney-Vento liaison cannot provide an 

unaccompanied homeless youth determination in subsequent years when 

youth are already in college. Instead, students are told that college 

financial aid offices can make that determination.

Education’s policy on the authority of these program officials to make a 

homeless youth determination if a student is not receiving program 

services is unclear. Education’s written guidance to financial aid 

administrators says that authorized program officials make a homeless 

youth determination if the student is receiving services from their program 

or, in the case of a McKinney-Vento homeless liaison, if the student is in 

high school.73 Similarly, its student guide for completing the FAFSA says 

that authorized program officials “only make these determinations if you 

are in high school or receiving their services” and tells students that they 

should seek a determination from their financial aid officer if they are no 

longer in high school or not receiving the services of these programs.74

However, Education officials told us that McKinney-Vento homeless 

liaisons and other authorized program officials can make a homeless 

 

72For example, HHS’s Basic Centers provide up to 21 days of shelter for runaway and 

homeless youth under 18 years old, while the Transitional Living Program supports 

projects that provide residential and other services to runaway and homeless youth ages 

16 to 22, for up to 21 months.

73Education’s September 2015 Application and Verification Guide.

74Department of Education, Federal Student Aid, Guide for Completing the FAFSA 2016–

17 (Washington, D.C).
Page 37 GAO-16-343 College Outcomes for Homeless and Foster Youth 

youth determination even if a student is no longer in high school or is not 

receiving program services. Education officials said that some school 

districts allow McKinney-Vento liaisons to make homeless youth 

determinations for youth no longer in high school, while others do not. 

Education officials pointed out that Education guidance acknowledges the 

existing practice of some McKinney-Vento liaisons to not make 

determinations for students when they are no longer in high school, not 

that McKinney-Vento liaisons cannot make these determinations. Further, 

an Education official said the agency expects financial aid administrators 

to accept determinations from authorized program officials even if the 

student is not receiving program services; however, the official 

acknowledged that Education’s guidance does not explicitly say this.

Education’s views on this issue are not fully and clearly stated in its 

written guidance. As a result, students who keep in touch with a 

McKinney-Vento liaison after high school may not be aware that they can 

seek a homeless youth determination from that individual. Similarly, 

homelessness and higher education organizations may continue to 

provide information on federal student aid to homeless students that does 

not fully reflect Education’s policy. Officials from a higher education 

organization said that some students do maintain contact with McKinneyVento liaisons and that not being able to obtain a determination from 

them after high school creates a barrier to having their situation reverified. Authorized program officials are also sometimes in a position to 

verify a student’s situation even if he or she is not receiving program 

services. For example, an Education official described a situation in which 

the director of an authorized homeless shelter could verify that a student 

was eligible for services, but was not receiving services because the 

program was full. If students and financial aid administrators do not 

realize that these are options, it can make a difficult process even more 

challenging. Education officials acknowledged that their written guidance 

may not be as clear as it could be and said they were planning to update 

it but did not provide a timeframe for when changes would be made. 

Federal internal controls require agencies to use relevant and reliable 

communications. Without clear guidance from Education, students 

seeking federal student aid may not be aware that they can request a 

homeless youth determination from authorized program officials even if 
Page 38 GAO-16-343 College Outcomes for Homeless and Foster Youth 

they are not receiving program services, and financial aid administrators 

may not know that they should accept these determinations.75

In addition, unaccompanied homeless youth who must rely on a financial 

aid administrator to make a homelessness determination find it 

challenging to provide documentation of their circumstances, if, for 

example, they live in a car or tent or are temporarily sleeping on 

someone’s couch, according to officials from homeless and higher 

education organizations we interviewed. Providing documentation of 

these circumstances for multiple years is even more challenging. While 

data are not available on the number of homeless youth who are unable 

to obtain a determination after their first year, officials from organizations 

who work with homeless youth told us that obtaining a determination in 

subsequent application years was a common problem. For example, an 

official from a national homeless organization said that the organization 

has received multiple calls on its hotline in the past 2 years from students 

who were having difficulty obtaining a subsequent FAFSA homeless 

determination even though their status had not changed while in college. 

In one example, a student experienced delays that led to her losing workstudy funding and other financial aid. According to officials at this 

homeless organization, other students have had to skip a semester or 

have been dropped from their classes after not receiving aid by the 

college’s deadline. Because of these issues, the homeless organization 

has recommended the elimination of the requirement for these students 

to be re-verified each year as unaccompanied and homeless, unless 

there is information suggesting a change of status.76

An Education official told us that eliminating the re-verification 

requirement for unaccompanied homeless youth seemed reasonable, and 

noted that Education is exploring administrative options to reduce the 

burden on FAFSA applicants who are homeless and that a legislative 

 

75According to federal internal controls, for an entity to run and control its operations, it 

must have relevant, reliable, and timely communications relating to internal as well as 

external events. Information is needed throughout the agency to achieve all of its 

objectives. Effective communications should occur in a broad sense with information 

flowing down, across, and up the organization. GAO, Standards for Internal Control in the 

Federal Government. GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999).

76National Association for the Education of Homeless Children and Youth, Financial Aid 

for Unaccompanied Homeless Youth: A Survey Report (Minneapolis, MN: 2014). The 

National Association of Financial Aid Administrators cosponsored the survey for this 

report.
Page 39 GAO-16-343 College Outcomes for Homeless and Foster Youth 

solution could be helpful. To date, however, the agency has not sent a 

legislative proposal to Congress on this specific issue. Federal student 

aid policies, such as the annual re-verification requirement, seek to 

encourage access to funds for eligible students while also ensuring 

program integrity. Their purpose is to ensure that students are 

appropriately classified as dependent or independent so that federal 

student aid funds are appropriately provided for students who have a 

financial need. For unaccompanied homeless youth, however, an annual 

re-verification requirement may keep otherwise eligible students from 

accessing federal student aid.

While it is possible that a student could be unaccompanied and homeless 

one year but reunite with a parent in a subsequent year and no longer 

qualify as an independent student, several federal and state officials and 

officials from a national homelessness organization told us that students 

who receive a homeless youth determination are unlikely to experience a 

change in their living situation in subsequent years.77 Homeless youth 

who have been subject to parental abuse may be unable to return home, 

for example, and homeless youth whose parents have died or are 

incarcerated may not have other family members to support them. 

According to an official at a national homeless organization, one 

unaccompanied homeless youth had to track down her homeless, 

abusive, and addicted mother in an attempt to obtain family income 

information when the student could not obtain a homelessness 

determination for a subsequent year. Colorado officials said that in some 

cases it can be dangerous for unaccompanied homeless youth to return 

and that they are aware of situations in which homeless youth have been 

physically attacked by their parents when they try to obtain signatures for 

the FAFSA.

As noted earlier, many foster and homeless youth have similar life 

experiences, including chaotic, unstable living situations and experiences 

with abuse and neglect. However, the financial aid process is more 

complicated and presents more barriers for unaccompanied homeless 

youth, according to officials we interviewed from a national homelessness 

 

77See also National Center for Homeless Education, Best Practices in Homeless 

Education: Increasing Access to Higher Education for Unaccompanied Homeless Youth: 

Information for Colleges and Universities (Washington, D.C.) 
Page 40 GAO-16-343 College Outcomes for Homeless and Foster Youth 

organization.78 Specifically, while foster youth must also attest to their 

status each year on the FAFSA, they only have to indicate that they have 

been in foster care at any time since they were 13 years old.79 In addition, 

the FAFSA also instructs foster youth to answer “yes” even if their 

situation has changed and they are no longer in foster care. For foster 

youth, it does not matter whether they were in foster care for 1 week or 8 

years. This is different for unaccompanied homeless youth who have to 

typically document their continued homelessness each year in order to be 

re-verified.

This difference between foster youth and unaccompanied homeless youth 

places an additional burden on unaccompanied homeless youth, whose 

many challenges make them no better equipped to effectively navigate 

complex financial aid application processes. In 2007, the College Cost 

Reduction and Access Act expanded the definition of “independent 

students” to include unaccompanied homeless youth and enabled them to 

apply for federal student aid without reporting parental income. As noted 

during debate prior to enactment of the law, these provisions were 

designed to address the barriers these vulnerable students face in 

pursuing their education and simplify the process for applying for federal 

student aid.80 However, the statutory requirement that a student’s status 

as an unaccompanied homeless youth be verified each year can pose a 

barrier to their obtaining federal student aid. By developing a legislative 

proposal to change this requirement, Education could help address this 

barrier.

 

78Runaway and homeless youth have described abuse and neglect as common 

experiences. Youth who run away often have a history of involvement in the foster care 

system. On the last day of fiscal year 2013, states reported 4,450 foster children (1% of all 

foster children) as “runaways.” Adrienne L. Fernandes-Alcantara, Congressional Research 

Service, Runaway and Homeless Youth: Demographics and Programs. (Washington, 

D.C.: January 20, 2015). See also Courtney et al., Midwest Evaluation.

79The FAFSA notes that financial aid administrators may request proof that a student has 

been in foster care. If financial aid administrators request proof that a youth has previously 

been in foster care, these youth can request documentation from their child welfare 

agency. Officials in Michigan told us that, to make it easier for foster youth, they created a 

standard form that youth can use to document their foster care status for the FAFSA and 

noted that another state has created a data exchange to allow colleges to verify a 

student’s foster care status. Such proof is easier for foster youth to obtain than the 

process unaccompanied homeless youth have to go through to prove their homelessness.

80Statement of Senator Murray, 153 Cong. Rec. S. 11241, 11252 (Sept. 7, 2007).
Page 41 GAO-16-343 College Outcomes for Homeless and Foster Youth 

While HHS offers Chafee ETV vouchers to help foster youth pay for 

college, this program also has age eligibility requirements that can make 

it harder for them to use these vouchers. Chafee ETV vouchers offer an 

important financial support that supplements other federal grants for 

which foster youth are eligible. However, the program has age eligibility 

rules that limit participation, according to foster youth in one discussion 

group and officials from organizations familiar with foster youth issues 

with whom we spoke. Under current law, former foster youth must be 

receiving Chafee ETV funds before they turn 21 in order to continue 

eligibility for the voucher through age 22. Specifically, the law introduces 

a two-part rule for ETV eligibility whereby, at states’ discretion, former 

foster youth ages 20 and under who begin receiving Chafee ETV 

vouchers may continue receiving ETV vouchers until they turn age 23.81

In contrast, former foster youth ages 21 and 22 who did not previously 

receive a Chafee ETV voucher are not eligible to receive a voucher.

One of the voucher program’s key purposes is to make funds available for 

education to students who have aged out of foster care to help them 

achieve self-sufficiency.82 This two-part eligibility rule can undermine that 

program goal and can be confusing to foster youth seeking support for 

college. Foster youth in one discussion group said they did not know 

about Chafee ETV vouchers until after they turned 21, when they were no 

longer eligible to receive funds. According to Congressional Research 

Service (CRS) and state officials, many foster youth start college at older 

ages than traditional students. If they start college at age 21, however, 

they may miss an opportunity to obtain a voucher for 2 years for which 

they would otherwise be eligible. Some state officials we spoke with said 

this rule creates an unnecessary barrier for foster youth. State officials in 

Colorado and foster youth told us that foster youth find it difficult to begin 

their college education without these funds. A foster youth in one of our 

discussion groups told us that he did not find out about the Chafee ETV 

voucher until after age 21 and had to leave college when he could not 

afford to pay for it. According to one major study of three Midwest states, 

35 percent of former foster youth reported that they had dropped out of a 

 

8142 U.S.C. § 677(i)(3). To continue receiving the ETV vouchers through age 22, foster 

youth must be enrolled in a postsecondary education or training program and be making 

satisfactory progress toward completion of the program Currently, every state and the 

District of Columbia has extended their Chafee ETV programs through age 22.

8242 U.S.C. § 677(a)(5)-(6).

Age Eligibility Rule 

Hinders Some Foster 

Youths’ Access to Chafee 

Education and Training 

Vouchers
Page 42 GAO-16-343 College Outcomes for Homeless and Foster Youth 

college program and the most commonly cited barrier to continuing their 

education, by a large margin, was being unable to pay for school.83

According to HHS, 16 states returned more than $1.2 million in unused 

Chafee ETV voucher funds to the federal Treasury in 2012, the latest 

date for which we have data.84 Allowing students to enter the Chafee ETV 

voucher program at an older age could allow more foster youth to benefit 

from this program without necessarily affecting program funding. HHS 

officials noted that simplifying the age eligibility requirements could help 

states provide these vouchers seamlessly to foster youth through age 23; 

however, the agency has not developed a legislative proposal to

encourage congressional action on this issue. Doing so could help ensure 

that foster youth who start college after they turn 21 are able to take 

advantage of available Chafee ETV funds meant to help them go to 

college and achieve self-sufficiency, as the program intended.

Lacking a stable family home and support from parents, homeless youth 

and foster youth are a particularly vulnerable group of young people who 

face significant challenges in pursuing college. Federal program 

requirements call for child welfare caseworkers and McKinney-Vento 

homeless liaisons to have some role in helping these students plan for 

college. In practice, however, these professionals are often focused on 

helping these youth find housing and graduate from high school, and their 

expertise with college planning and federal student aid is often limited. 

School homeless programs and child welfare systems have different 

purposes and competing priorities that do not necessarily focus on 

college planning, and it is important that any effort to encourage these 

professionals to more effectively provide college planning for homeless 

and foster youth consider program goals, priorities, workload, and 

 

83Courtney, et al., Midwest Evaluation.

84CRS issued a 2013 memorandum on unused Chafee funds. In discussing policy 

options, the CRS report suggests that allowing entry into the ETV voucher program at an 

older age may enable more youth to benefit from the program and more states to expend 

their unused funds. CRS found that funds were returned for a variety of reasons, including 

a lack of financial aid knowledge on the part of child welfare workers and foster youth’s 

lack of preparedness for college. Stakeholders CRS contacted emphasized that ETV 

funds are essential to provide supportive services for youth aging out of foster care, and 

that the unused funds should not suggest that the state has excessive resources for these 

services. CRS, Memorandum, Chafee Foster Care Independence Program and Education 

and Training Voucher Program: Unused Funds and Program Evaluations (Washington, 

D.C.: Aug. 21, 2013).

Conclusions
Page 43 GAO-16-343 College Outcomes for Homeless and Foster Youth 

responsibilities. Education and HHS administer these programs, making 

them well positioned to study available options for encouraging better 

college planning efforts. Further, in the absence of knowledgeable adults 

to help navigate the complex college admissions and financial aid 

processes, it is important for these students to have easy access to 

information on federal student aid and other federal support programs to 

help them pursue college. However, Education’s website has little 

centralized information on federal student aid and other college-related 

resources directed specifically to homeless and foster youth, even though

the Higher Education Act requires Education to provide students with 

information to help make college decisions and to continually improve the 

usefulness and accessibility of this information.

Federal supports, such as federal student aid and HHS’s Chafee 

Education and Training vouchers, are available to help pay for college, 

yet eligible homeless and foster youth face program barriers to accessing 

them. When college financial aid officers require homeless students to 

provide burdensome documentation beyond what is needed or are 

reluctant to verify students’ homelessness, some homeless students may 

not apply for federal student aid for which they are eligible and would be 

unable to afford college. Making a voluntary worksheet or form available 

to guide and document homeless youth determinations could make the 

process easier for both students and financial aid administrators. 

Homeless youth can find it especially difficult to obtain verification of 

homelessness from the specific program directors authorized by law after 

their first year of college, when they may no longer be served by these 

programs. While Education officials stated that program officials 

authorized by law can make homeless youth determinations for students 

not receiving program services, this is not clearly communicated in 

Education’s written guidance, making it harder for these students to 

obtain a homeless youth determination. Homeless youth also find it 

difficult to document their circumstances when they are in tenuous living 

arrangements not served by formal programs. Homeless youth who need 

a college financial aid administrator to verify their homelessness typically 

have to provide documentation of their continued homelessness each 

year—unlike foster youth who only need to attest on the FAFSA that they 

have previously been in foster care. This requirement, and the additional 

burden it can create, does not promote the goal of the College Cost 

Reduction and Access Act to improve college access for homeless youth. 

A legislative proposal from Education to change this requirement could 

help address this barrier. Finally, for some foster youth, the age eligibility 

requirements for HHS’s Chafee Education and Training Vouchers can 

create a barrier to available financial assistance. The voucher program 
Page 44 GAO-16-343 College Outcomes for Homeless and Foster Youth 

provides funds to help foster youth go to college and achieve selfsufficiency, but when foster youth begin college at a later age or do not 

apply for these vouchers until they are 21, they are unable to use a key 

financial support that can help them pay for college for 2 additional years. 

A legislative proposal from HHS could help address this age restriction for 

foster youth who are otherwise eligible to use this support to attend and 

complete college.

1. To help foster and unaccompanied homeless youth better navigate 

the college admissions and federal student aid processes, the 

Secretaries of Education and HHS should jointly study potential 

options for encouraging and enabling child welfare caseworkers, 

McKinney-Vento homeless youth liaisons, and other adults who work 

with these youth to more actively assist them with college planning.

2. To help foster and unaccompanied homeless youth, as well as adults 

who assist these youth, better navigate the federal student aid 

process and obtain information about college resources, the Secretary 

of Education, in consultation with the Secretary of HHS, should create 

webpages directed to homeless and foster youth so they can more 

easily find tailored and centralized information about available federal 

and other resources, such as Pell Grants, Chafee ETV Vouchers, and 

waivers for college admission tests.

3. To help college financial aid administrators more effectively implement 

eligibility rules for unaccompanied homeless youth, the Secretary of 

Education should make available an optional worksheet or form that 

college financial aid administrators can voluntarily use to document 

unaccompanied homeless youth status or encourage the use of 

existing forms that are available.

4. To help homeless youth more easily access federal student aid, the 

Secretary of Education should clarify its guidance to financial aid 

administrators and students about whether financial aid administrators 

should accept any unaccompanied homeless youth determination 

provided by McKinney-Vento homeless liaisons or other authorized 

officials even if a student is not in high school or receiving program 

services.

5. To enhance access to federal student aid for unaccompanied 

homeless youth, the Secretary of Education should consider 

developing a legislative proposal for congressional action to simplify 

the application process so that once a student has received an initial 

determination as an unaccompanied homeless youth, the student will 

not be required to have that status re-verified in subsequent years but 

Recommendations for 

Executive Action
Page 45 GAO-16-343 College Outcomes for Homeless and Foster Youth 

attest to their current status on the FAFSA, unless a financial aid 

administrator has conflicting information.

6. To simplify program rules for Chafee ETV vouchers and improve 

access to these vouchers for former foster youth ages 21 and 22, the 

Secretary of HHS should consider developing a legislative proposal 

for congressional action to allow foster youth to be eligible for the 

Chafee ETV voucher until age 23 without also requiring that they start 

using the voucher before they turn 21.

We provided a draft of the report to the Department of Education and the 

Department of Health and Human Services for review and comment. 

Education and HHS provided written comments, which are reproduced in 

appendixes III and IV, as well as technical comments, which we 

incorporated as appropriate.

In its written comments, Education agreed with one of our 

recommendations and did not specifically agree or disagree with the other 

recommendations; however, the agency generally noted actions it was 

taking to address the recommendations. 

 In response to our recommendation for Education and HHS to jointly 

study options for encouraging professionals to more actively help 

homeless and foster youth with college planning, Education referred 

to its work with HHS and a national homelessness organization on 

federal student aid issues and said that the agency will continue to 

encourage more active assistance in college planning. It also 

mentioned that its grantees in Education’s higher education programs 

work with disenfranchised youth, including unaccompanied homeless 

youth, and assist them with college planning. 

 In its response to our recommendation that Education create 

webpages directed to homeless and foster youth, Education noted 

that it has a webpage about foster youth and that it had just created a 

new webpage with resources for homeless children and youth in midApril, after we provided our draft report to Education for comment. 

Making more information available online is an encouraging step in 

the right direction. However, much of the information on these 

webpages is about programs unrelated to college and is not directed 

at foster or homeless youth who want to apply to college. Instead, 

they contain technical information largely directed to policymakers, 

practitioners, and the general public, rather than providing information 

homeless and foster youth can easily use to help plan for and apply to 

Agency Comments 

and Our Evaluation
Page 46 GAO-16-343 College Outcomes for Homeless and Foster Youth 

college. In addition, these webpages are not easy to find from the 

main Education webpage for students looking for college information. 

As a result, we continue to believe that Education, in consultation with 

HHS, should create webpages tailored to the needs of homeless and 

foster youth that students can find without extensive searching. 

Education also said that it is working to complete a factsheet of 

resources for unaccompanied homeless youth. In completing this 

factsheet, it will be important for Education to make sure that the 

factsheet is directed towards these youth, contains information 

relevant to planning for and applying to college, and is located in such 

a place that students can easily find it.

 In response to our recommendation that Education make available an 

optional form that financial aid administrators can use for documenting 

the status of unaccompanied homeless youth, Education agreed that 

it would be helpful to make forms developed by outside organizations 

available for financial aid administrators. Education also said that it 

plans to highlight the availability of these forms and provide guidance 

at its annual conference and in updates to the Federal Student Aid 

Handbook. 

 In response to our recommendation that Education clarify its guidance 

on unaccompanied homeless youth determinations, Education said 

that it will continue to issue guidance through conference 

presentations and publications, including the Federal Student Aid 

Handbook. In its technical comments, Education acknowledged that it 

could broaden its guidance and technical assistance to clarify that 

Runaway and Homeless Youth program directors and shelter 

directors funded by HUD can write these letters of verification even 

when their shelters are full and they turn the youth away. Given the 

lack of clarity, however, we continue to believe Education should 

revise its guidance to clarify when financial aid administrators should 

accept unaccompanied homeless youth determinations from 

authorized officials. 

 Lastly, in response to our recommendation for Education to consider 

developing a legislative proposal so that youth with an initial 

unaccompanied homeless youth determination are no longer required 

to have their status re-verified in future years, Education noted that it 

will consider our recommendation within the context of its proposal for 

further FAFSA simplification contained in the agency’s fiscal year 

2017 budget. 
Page 47 GAO-16-343 College Outcomes for Homeless and Foster Youth 

In its written comments, HHS agreed with our recommendations.

 In response to our recommendation that Education and HHS jointly 

study options for encouraging professionals to more actively help 

homeless and foster youth with college planning, HHS said that it 

agreed. HHS further noted that both agencies were working together 

to develop a transition guide for youth in foster care that would 

provide foster youth, and the adults working with them, with more 

information about the range of federal and state educational 

resources available. 

 In response to our recommendation that Education, in consultation 

with HHS, create webpages directed to homeless and foster youth, 

HHS agreed and said that the agency would continue to partner with 

Education on these webpages and other efforts to assist homeless 

and foster youth with college planning.

 HHS also agreed with our recommendation to consider a legislative 

proposal to simplify program rules for Chafee ETV vouchers.

We are sending copies of this report to the Secretaries of Education and 

HHS, relevant congressional committees, and other interested parties. In 

addition, the report is available at no charge on the GAO website at 

http://www.gao.gov.If you or your staff have any questions about this 

report, please contact me at (617) 788-0534 or emreyarrasm@gao.gov.

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this report. GAO staff who made 

key contributions to this report are listed in appendix V.

Sincerely yours,

Melissa Emrey-Arras

Director, Education, Workforce, and Income Security
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-16-343 College Outcomes for Homeless and Foster Youth 

This report examines: (1) What is known about college enrollment and 

completion for youth who have been in foster care or who are homeless? 

(2) To what extent do the challenges identified by researchers and 

stakeholders affect the ability of foster and homeless youth to pursue 

college? (3) To what extent do program barriers exist that could hinder 

these youth from obtaining federal financial assistance for college?

We used multiple methodologies to conduct this study. To analyze federal 

postsecondary education data on foster care and homeless youth, 

including available data about financial assistance programs, we used 

data from three federal databases. These included (1) administrative data 

on recipients of federal student aid from the Department of Education’s 

(Education) Common Origination and Disbursement System (COD); (2) 

data on college enrollment and degree program characteristics from the 

nationally representative National Postsecondary Student Aid Study 

(NPSAS); and (3) data on graduation rates from the Beginning 

Postsecondary Students Longitudinal Study (BPS). We assessed the 

reliability of COD, NPSAS, and BPS data by reviewing existing 

information about the data and the system that produced them and 

interviewing agency officials knowledgeable about the data. We 

determined that the data were sufficiently reliable for the purposes of 

describing enrollment and completion information for homeless and foster 

youth.

We also conducted a review of academic studies that were based on 

original research to determine what is known about foster and homeless 

youths’ college enrollment and completion. We assessed the quality of 

these studies by evaluating their research methods and determined that 

the studies we selected were sufficiently reliable for our use. We also 

conducted an additional analysis of the comparison group used in one 

study—for this analysis, we obtained data from the National Longitudinal 

Study of Adolescent to Adult Health (Add Health).1 We also reviewed 

relevant federal laws and guidance on federal student aid and other 

college support programs for homeless and foster youth. In addition, we 

conducted interviews with officials from Education, HHS, and the 

Department of Housing and Urban Development (HUD); state officials 

from selected states; and officials and experts from eight organizations 

 

1Kathleen Mullan Harris, Wave IV, 2007-2009, The National Longitudinal Study of 

Adolescent to Adult Health (Add Health), accessed November 24, 2015, 

http://www.cpc.unc.edu/projects/addhealth/data. 

Appendix I: Objectives, Scope, and 

Methodology

Overview
Appendix I: Objectives, Scope, and 

Methodology

Page 49 GAO-16-343 College Outcomes for Homeless and Foster Youth 

knowledgeable about child welfare, homelessness, or higher education 

issues. We selected these states based on the number of foster youth 

ages 16-21 in the state, the number of homeless applicants for federal 

student aid, promising postsecondary initiatives for homeless or foster 

youth, state approaches to the federal option to expand foster care up to 

age 21 instead of 18, and geographic distribution. Lastly, we convened 

two discussion groups with homeless youth and two discussion groups 

with foster youth in the greater Washington DC area to discuss any 

challenges they faced in enrolling in and completing college. We 

assessed Education’s efforts to provide information on federal student aid 

and access to these programs with related provisions in the Higher 

Education Act as amended by the College Cost Reduction and Access 

Act as well as with Education’s strategic plan and federal standards for 

internal controls. We also reviewed the college planning responsibilities of 

child welfare caseworkers and McKinney-Vento homeless liaisons as 

described in the Social Security Act and the McKinney-Vento Homeless 

Assistance Act.

We conducted this performance audit from October 2014 to May 2016 in

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

COD: To provide information on the homeless and foster youth 

enrollment in college, as well as the types of schools they attended, we 

analyzed data on financial aid recipients for the 2013-2014 federal 

student aid award year from Education’s Common Origination and 

Disbursement System. We chose this time period because it was the 

most recent and complete financial data available, according to Education 

officials. The Common Origination and Disbursement system provides a 

common student record reporting system for disbursements from federal 

student aid programs, including both Pell Grants and Direct Loans.

NPSAS: We used NPSAS data to analyze foster and homeless youth’s 

enrollment in higher education. NPSAS compiles student-level records on 

college enrollment and financial aid provided by the federal government, 

states, colleges, employers, and private organizations. NPSAS data are 

collected every 3-4 years from a variety of sources for a large, nationally 

representative sample of all students, regardless of enrollment type, who 

Data Sources and 

Analysis
Appendix I: Objectives, Scope, and 

Methodology

Page 50 GAO-16-343 College Outcomes for Homeless and Foster Youth 

are enrolled in a Title IV eligible program during the relevant school year. 

Student data are collected through web-based self-administered and 

computer-assisted telephone interviews. NPSAS contains historical 

information on foster care students, but data on homeless students are 

only available for its most recent year—2011-2012—as of the date of this 

report.

BPS: We used BPS data to analyze the extent to which foster youth who 

began college completed a postsecondary degree. BPS tracks a cohort of 

students over a 6-year period. The most recently completed BPS cohort 

first enrolled in postsecondary education in the 2003-2004 school year. 

The final follow-up with the group was the 2008-2009 school year. For our 

analysis, we used the BPS variable for highest degree attained anywhere 

through June 2009. We chose this variable because it allowed us to track 

completion for students even if they transferred from their original 

institution.

Add Health: We obtained Wave IV data from the National Longitudinal 

Study of Adolescent to Adult Health (Add Health) to calculate estimates 

and 95 percent confidence intervals of college experience, i.e. completion 

of at least 1 year of college, of the general U.S. population for comparison 

to those of foster youth in one academic study.2 The Add Health 

percentage estimates of educational attainment levels cited in this report 

have a 95 percent confidence interval of within plus or minus 10 

percentage points. Add Health is a longitudinal study of a nationally 

representative sample of adolescents in the United States. The Add 

Health study cohort has been followed from middle school into young 

adulthood through in-home interviews, the most recent of which took 

place in 2008.

Because the NPSAS and BPS data are based on probability samples, 

estimates are formed using the appropriate estimation weights provided 

with each survey’s data. Because each of these samples follows a 

probability procedure based on random selection, they represent only one 

of a large number of samples that could have been drawn. Since each 

sample could have provided different estimates, we express our 

confidence in the precision of our particular sample’s results as a 95 

percent confidence interval (e.g., plus or minus 7 percentage points). This 

 

2Courtney, et al., Midwest Evaluation. 
Appendix I: Objectives, Scope, and 

Methodology

Page 51 GAO-16-343 College Outcomes for Homeless and Foster Youth 

is the interval that would contain the actual population value for 95 

percent of the samples we could have drawn. Unless otherwise noted, all 

percentage estimates cited in this report from NPSAS and BPS have 95 

percent confidence intervals within +/- 10 percentage points, and are 

within +/- 10 percent of the estimate itself for other numerical estimates. 

We conducted t-tests and compared confidence intervals to identify 

statistically significant differences between foster/homeless youth and the 

comparison groups.

To determine the extent to which program barriers exist that can hinder 

homeless students and foster youth from obtaining federal financial 

assistance for college, we reviewed relevant federal laws, including the 

Higher Education Act of 1965, provisions of the Social Security Act 

governing the John H. Chafee Foster Care Independence Program and 

the Chafee ETV Voucher Program, provisions of the McKinney-Vento 

Homeless Assistance Act governing the Education for Homeless Children 

and Youth Program, and provisions of the Runaway and Homeless Youth 

Act governing the Transitional Living Grant Program We also reviewed 

relevant Education and HHS policies and guidance related to these 

federal programs that provide financial assistance to homeless students 

and foster youth for college.

To determine what is known about college outcomes for homeless and 

foster youth, we conducted a literature search for quantitative studies that 

provided outcome data (e.g., enrollment and completion). To identify 

existing studies, we conducted searches of various databases, such as 

ERIC, ProQuest Education Journals, and WorldCat. Through these 

databases, we identified 76 studies that were published between 2005 

and 2015 and were relevant to our research objectives on college 

outcomes for homeless and foster youth. We then identified 17 studies 

that met the following criteria: conducted original research and included a 

quantitative methodology. We assessed the quality and methodological 

rigor of each of the 17 studies that met our inclusion criteria according to 

generally accepted social science research standards. Each study was 

evaluated by a GAO analyst with specialized expertise in research 

methodology or statistics, and was reviewed by a second GAO analyst 

with similar expertise. Our review considered results from the 12 studies 

that we found were acceptable through this review process.

Laws and Policies

Review of Studies
Appendix I: Objectives, Scope, and 

Methodology

Page 52 GAO-16-343 College Outcomes for Homeless and Foster Youth 

To understand any challenges and barriers homeless students and foster 

youth face in accessing federal financial aid and pursuing college, we 

interviewed officials at the Department of Education, the Department of 

Health and Human Services (HHS), Department of Housing and Urban 

Development (HUD), and the Congressional Research Service (CRS).

More specifically, at Education, we interviewed officials from the Office of 

Elementary and Secondary Education, the Office of Postsecondary 

Education, the Office of Federal Student Aid, the Budget Office, and the 

National Center for Education Statistics. At HHS, we interviewed officials 

from the Children’s Bureau and the Family and Youth Services Bureau. At 

HUD, we interviewed officials from the Office of Special Needs 

Assistance Programs. At CRS, we interviewed officials knowledgeable 

about homeless students and foster youth seeking college.

To gather more in-depth information on any challenges and barriers 

homeless students and foster youth face in accessing federal student aid, 

we conducted interviews with officials in four states—California, Colorado, 

Michigan, and Virginia. We selected these states based on the number of 

foster youth ages 16-21 in the state, the number of homeless youth 

seeking college education, promising college initiatives for homeless or 

foster youth in that state, state approaches to the Title IV-E option to 

expand foster care up to age 21, and geographic distribution. Findings 

associated with our outreach to these selected states cannot be 

generalized to all states’ homeless student and foster youth populations; 

rather, they provide insight into a range of views and experiences with 

federal programs that provide financial support to homeless and foster 

youth.

We also interviewed representatives from a broad range of organizations 

knowledgeable about homeless students and foster youth as well as 

programs that serve these populations, including: the American Bar 

Association’s Center for Children and the Law’s Legal Center for Foster 

Care and Education, Casey Family Programs, Foster Care to Success, 

the National Association of College Admissions Counseling, the National 

Association for the Education of Homeless Children and Youth, the 

Interviews with 

Federal and Selected 

State Officials and 

Officials from 

Knowledgeable 

Organizations 
Appendix I: Objectives, Scope, and 

Methodology

Page 53 GAO-16-343 College Outcomes for Homeless and Foster Youth 

National Association of Student Financial Aid Administrators, and the 

National Center for Homeless Education.3

To further understand how easily homeless students and foster youth can 

access federal student aid and other support programs for college, we 

interviewed financial aid directors at three community colleges located in 

three states.4 We focused on community colleges for these interviews 

because our data analyses showed that the largest percentage of foster 

and homeless youth attend this type of college. We identified these 

financial aid directors with assistance from the National Association of

Student Financial Aid Administrators. We also interviewed a college 

financial aid director as part of the Michigan state interview with higher 

education officials. While financial aid directors we interviewed provide 

some insight into the programmatic barriers of homeless students and 

foster youth, their responses are not generalizable to all financial aid 

directors.

To describe any challenges that homeless and foster youth face in 

applying to and enrolling in college, and to illustrate issues raised by 

experts and available studies and data, we held four discussion groups—

two with youth who had experienced homelessness and two with youth 

previously or currently enrolled in foster care. To organize these 

discussion groups, we identified organizations or programs through 

interviews and other contacts with federal agencies and organizations 

that support homeless or foster youth. The number of homeless or foster 

youth participating in the discussion groups ranged from 7 to 12.

All four discussion groups took place in the greater Washington, D.C.

area; however, two of the four groups drew upon students from across 

the United States. One discussion group was composed of homeless 

youth at an HHS-funded shelter for runaway and homeless youth. 

Another discussion group was composed of homeless, or formerly 

homeless, youth from across the country who participated in a national 

 

3We also attended congressional briefings on foster or homeless youths’ challenges and 

barriers to higher education organized by the Congressional Coalition on Adoption 

Institute and the National Association for the Education of Homeless Children and Youth 

as well as policy presentations and discussions on these issues for foster youth organized 

by the American Youth Policy Forum.

4The community colleges were located in Maryland, North Carolina, and Ohio.

Discussion Groups 

with Homeless and 

Foster Youth
Appendix I: Objectives, Scope, and 

Methodology

Page 54 GAO-16-343 College Outcomes for Homeless and Foster Youth 

homeless organization’s student scholars program located in Washington, 

D.C. Similarly, one foster youth discussion group was made up of 

students selected for a national program who represented a diverse 

number of states. The other discussion group of foster youth was made 

up of local students participating in a state-run program for foster youth at 

a community college in Virginia.

Each discussion group was led by a trained facilitator using an interview 

protocol designed for either the homeless youth or foster youth population 

and specifically tailored for each program or site. In addition, we used a 

short questionnaire to capture basic background information on the 

discussion group members. Information and views obtained from these 

discussion groups are not generalizable to any other homeless or foster 

youth.
Appendix II: College Enrollment and 

Completion of Foster Youth and 

Unaccompanied Homeless Youth Compared to 

Dependent Students

Page 55 GAO-16-343 College Outcomes for Homeless and Foster Youth 

In addition to comparing foster youth and unaccompanied homeless 

youth to low-income and all other students, we also compared foster 

youth and unaccompanied homeless youth to low-income dependent 

students and all other dependent students (see figures 7, 8, and 9). We 

used dependent students as a comparison group for our analyses 

because the ages of these students (under 24) are similar to those of 

college-enrolled foster and homeless youth. We also used low-income 

dependent students as a comparison group because both the ages and 

incomes of these students are more similar to those of college-enrolled 

foster youth and homeless youth. The results of these analyses were 

largely similar to comparisons made to all low-income youth and all other 

youth presented in the report.

Figure 7: Comparison of Enrollment of Foster Youth to Dependent Students in College Degree Programs, by Estimated 

Percent of Students Enrolled, School Year 2011-2012

Notes: Percentages may not add to 100 due to rounding. All foster youth comparisons are statistically 

significant at the 95 percent confidence level. All estimates have margins of error within plus or minus 

10 percentage points. “Dependent students” refers to students who are considered financially 

dependent on their parents for the purposes of federal student aid programs and who must therefore 

report parental income to determine their eligibility for federal student aid. Foster youth are 

considered financially independent for the purposes of federal student aid programs and therefore 

report only their own income.

Appendix II: College Enrollment and 

Completion of Foster Youth and 

Unaccompanied Homeless Youth Compared 

to Dependent Students
Appendix II: College Enrollment and 

Completion of Foster Youth and 

Unaccompanied Homeless Youth Compared to 

Dependent Students

Page 56 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Figure 8: Comparison of Estimated College Degree Completion Rates within 6 Years of First Enrollment, for Foster Youth and 

Dependent Students, as of 2009

aPercentage estimate is not statistically different from the foster youth estimate at the 95 percent 

confidence level.

Notes: Percentages may not add to 100 due to rounding. All foster youth comparisons are statistically 

significant at the 95 percent confidence level, unless otherwise indicated. All estimates have margins 

of error within plus or minus 10 percentage points, with the exception of the foster youth estimates: 

Confidence intervals for these estimates are 58 to 82 percent for no degree, 7 to 26 percent for 

certificate or associate’s degree, and 6 to 25 percent for bachelor’s degree. “Dependent students”

refers to students who are considered financially dependent on their parents for the purposes of 

federal student aid programs and who must therefore report parental income to determine their 

eligibility for federal student aid. Foster youth are considered financially independent for the purposes 

of federal student aid programs and therefore report only their own income.
Appendix II: College Enrollment and 

Completion of Foster Youth and 

Unaccompanied Homeless Youth Compared to 

Dependent Students

Page 57 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Figure 9: Comparison of Degree Program Enrollment for Unaccompanied Homeless Youth and Dependent Students, By 

Estimated Percent Enrolled, School Year 2011-2012

aPercentage estimate is not statistically different from the foster youth estimate at the 95 percent 

confidence level.

Notes: Percentages may not add to 100 due to rounding. All unaccompanied homeless youth 

comparisons are statistically significant at the 95 percent confidence level, except for the low-income 

dependent certificate category. All estimates have margins of error within plus or minus 10 

percentage points, with the exception of unaccompanied homeless youth estimates in the associate’s 

and bachelor’s categories: Confidence intervals for these estimates are 45 to 73 percent for 

associate’s and 20 to 48 percent for bachelor’s degrees. “Dependent students” refers to students who 

are considered financially dependent on their parents for the purposes of federal student aid 

programs and who must therefore report parental income to determine their eligibility for federal 

student aid. Unaccompanied homeless youth are considered financially independent for the purposes 

of federal student aid programs and therefore report only their own income.
Appendix III: Comments from the U.S. 

Department of Education

Page 58 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Appendix III: Comments from the U.S. 

Department of Education
Appendix III: Comments from the U.S. 

Department of Education

Page 59 GAO-16-343 College Outcomes for Homeless and Foster Youth 
Appendix III: Comments from the U.S. 

Department of Education

Page 60 GAO-16-343 College Outcomes for Homeless and Foster Youth 
Appendix III: Comments from the U.S. 

Department of Education

Page 61 GAO-16-343 College Outcomes for Homeless and Foster Youth 
Appendix IV: Comments from the U.S. 

Department of Health and Human Services

Page 62 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Appendix IV: Comments from the U.S. 

Department of Health and Human Services
Appendix IV: Comments from the U.S. 

Department of Health and Human Services

Page 63 GAO-16-343 College Outcomes for Homeless and Foster Youth 
Appendix IV: Comments from the U.S. 

Department of Health and Human Services

Page 64 GAO-16-343 College Outcomes for Homeless and Foster Youth 
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 65 GAO-16-343 College Outcomes for Homeless and Foster Youth 

Melissa H. Emrey-Arras, (617) 788-0534 or emreyarrasm@gao.gov

In addition to the contact named above, Michelle St. Pierre (Assistant 

Director), Deborah A. Signer (Analyst-in-Charge), Jessica Botsford, 

Nancy Cosentino, Maria Gaona, Ricky Harrison, Jean McSween, John W. 

Mingus, Jr., Amber Sinclair, Jeff Tessin, Shana Wallace, and Najeema 

Davis Washington made key contributions to this report. Also contributing 

to this report were Susan Aschoff, Rachel Beers, James Bennett, 

Deborah Bland, Will Colvin, Julia C. DiPonio, David M. Reed, Charlie 

Willson, and Paul C. Wright.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(131328)
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