TURNING POLICY INTO PRACTICE:

EFFECTIVE SUPPORT FOR UNACCOMPANIED YOUTH

S

LUNCH + LEARN

MARCH 26, 2026

Session 1�Core Overview

Number of Children & Youth Experiencing Homelessness, 2024-2025

52,000+

Pennsylvania

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13,000+

Region 2

19+%

Unaccompanied Youth in Region 2

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PA Department of Education

Unaccompanied Homeless Youth

1. Lack a fixed, regular, or adequate nighttime residence
2. Not residing in the physical custody of a legal parent/guardian.

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No age requirement

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Unaccompanied Youth Rights

UHY have the same rights as students experiencing homelessness with their parents plus the right to:

• Enroll with or without parental involvement
• Have their wishes prioritized regarding school placement
• Dispute eligibility and best interest determinations
• Verification of their independent status for FAFSA

Approximate Number of Children �Experiencing Homelessness by County�2024-25��

County

Berks

Chester

Dauphin

Lancaster

Lebanon

Schuylkill

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Number

2,590

2,640

3,610

3,160

830

530

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Unaccompanied Homeless Youth At a Glance�Approximate Data in Region 2 – 2024-25

Category

Doubled-up�Unsheltered

Economically disadvantaged

Special education

Enrolled in 2 or more schools

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Percentage

85%

3%

85%

33%

19%

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Unaccompanied Homeless Youth State Testing�Approximate Data in Region 2 – 2024-25�

77% Scored basic or below basic on state testing for Reading/Literature

87% Scored basic or below basic on state testing for Math/Algebra I

UHY Truancy in Region 2�2024-25

51% Of identified UHY were chronically absent.

9% Of identified 9-12^th grade UHY dropped out of school.

16% Of identified 12^th grade UHY did not graduate on their originally anticipated graduation date.

From Data to Practice

Myth Busters:

Accuracy matters -Which statement is fully true?

Myth Busters Directions

1. Review each statement and find the truth among two myths.

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• Choose the most accurate statement and hold up the corresponding number card at your seat.

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Myth #1�1302 Guardianship Affidavit vs UHY

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• Option 1: If the caregiver claims the youth as a dependent on their taxes, the youth is no longer unaccompanied or experiencing homelessness, and the student would not be eligible for MKV services.
• Option 2: If a caregiver signs a 1302 guardianship affidavit, the student is no longer considered an unaccompanied youth under MKV because the caregiver now has legal authority.
• Option 3: Eligibility under MKV depends on whether the living arrangement is fixed, regular, and adequate — not on whether a caregiver affidavit exists.

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Myth #1�Answer

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• Option 1: If the caregiver claims the youth as a dependent on their taxes, the youth is no longer unaccompanied or experiencing homelessness, and the student would not be eligible for MKV services.
• Option 2: If a caregiver signs a 1302 guardianship affidavit, the student is no longer considered an unaccompanied youth under MKV because the caregiver now has legal authority.
• Option 3: Eligibility under MKV depends on whether the living arrangement is fixed, regular, and adequate — not on whether a caregiver affidavit exists.

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Myth Buster #1: Compliance Gaps

Compliance gaps happen when:

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• A 1302 is viewed as legal guardianship
• Caregiver signs a 1302 ending review of MKV eligibility

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Gaps lead to:

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• Improper denial or exit from services
• Loss of provisions and supports
• Failure to identify UHY
• Decisions not being based on housing status

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Myth Buster #1: Tip and Tools

Tips:

• 1302 Guardianship Affidavit speaks to who can make certain educational decisions
• 1302 does not determine legal custody or housing stability.
• Handle the MKV eligibility determination separately.

Tools:

• UHY Flow Chart: Workbook (WB) pg. 3 (print), pg. 7 (digital)
• UHY Enrollment Questionnaire: WB pg. 7 (print), pg. 11 (digital)
• Quick Reference and Tips Guide for School Administrators: WB pg. 10 (print), pg. 14 (digital)

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Myth Buster #1: Legal Citation/Federal Guidance

42 U.S.C. §11434a(2) Defines “homeless children and youths” as individuals who lack a fixed, regular, and adequate nighttime residence, including those who are living in shelters, motels, cars, or doubled-up with others due to loss of housing.

Regulatory Guidance: 34 C.F.R. § 200.2 emphasizes that eligibility is based on the living arrangement, not on documentation or caregiver affidavits.

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Myth #2�Best Interest Disagreements

If an UHY disagrees with a best interest determination…

• Option 1: …the liaison can meet the requirement by verbally explaining the decision and describing how to appeal.
• Option 2: ...UHY must be informed of their right to appeal. Written notice is required any time eligibility, school selection, or enrollment is disputed.
• Option 3: …the liaison must provide written notice to the youth’s parent or guardian, even if the youth is unaccompanied.

Myth #2�Answer

If an UHY disagrees with a best interest determination…

• Option 1: …the liaison can meet the requirement by verbally explaining the decision and describing how to appeal.
• Option 2: ...UHY must be informed of their right to appeal. Written notice is required any time eligibility, school selection, or enrollment is disputed.
• Option 3: …the liaison must provide written notice to the youth’s parent or guardian, even if the youth is unaccompanied.

Myth Buster #2: Compliance Gaps

Compliance gaps happen when:

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• Youth is not informed of their right to dispute
• Failure to issue written notice when disagreement occurs.

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Gaps lead to:

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• Loss of right to dispute
• School placement decisions may go unchallenged
• Risk to school stability
• UHY’s wishes not being prioritized

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Myth Buster #2: Tip and Tools

Tip:

• Include the youth in the BID process.
• If there is a disagreement on school placement, follow PDE’s dispute process.
• Provide an advocate, such as the regional office, to assist the youth in navigating the dispute process.

Tools:

• Best Interest Determination Checklist: WB pgs. 18-21 (print), pgs. 22-25 (digital)
• Best Practices for UHY Checklist: WB pgs. 24-25 (print), pgs. 28-29 (digital)

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Myth Buster #2: Legal Citation

42 U.S.C. § 11432(g)(3)(E) If there is a dispute over school selection or enrollment, the child or youth shall be immediately enrolled in the school in which enrollment is sought, pending resolution of the dispute. The local educational agency must provide the child or youth with a written explanation of the enrollment decision and notice of the right to appeal the decision.

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Myth # 3�Special Education for Unaccompanied Homeless Youth

• Option 1: IDEA requires immediate appointment of a surrogate if no parent is available, but services cannot be withheld while waiting. LEAs must have a process to ensure rights are protected without delay.
• Option 2: An UHY may be referred for special education, but services cannot begin until a surrogate parent is appointed to provide consent.
• Option 3: An administrator can sign consent for special education for as long as it takes the district to find a surrogate parent in order to avoid a delay in services.

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Myth # 3�Answer

• Option 1: IDEA requires immediate appointment of a surrogate if no parent is available, but services cannot be withheld while waiting. LEAs must have a process to ensure rights are protected without delay.
• Option 2: An UHY may be referred for special education, but services cannot begin until a surrogate parent is appointed to provide consent.
• Option 3: An administrator can sign consent for special education for as long as it takes the district to find a surrogate parent in order to avoid a delay in services.

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Myth Buster #3: Compliance Gaps

Compliance gaps happen when:

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• Delayed evaluations or services due to a lack of parent or guardian
• Treating surrogate appointment as a prerequisite to moving forward
• Failure to initiate assigning a surrogate immediately
• Child Find responsibilities are paused due to lack of a parent

Gaps lead to:

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• Missed or delayed identification of disabilities
• Delay or denial of special education services
• Barriers to full participation in school
• Loss of educational progress and school success

Myth Buster #3: Tip and Tools

Tips:

• Start processes immediately, don’t wait for a surrogate
• Run processes in parallel
• If needed, appoint a temporary surrogate until a permanent one can be found.

Tools:

• UHY: Requirements and Best Practices Concerning IDEA and FERPA: WB pgs. 28-34 (print), pgs. 32-38 (digital)
• Surrogate Parents and Unaccompanied Homeless Youth Under the Individuals with Disabilities Act, NAEHCY (PDF)

Myth Buster #3: Legal Citation

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20 U.S.C. §1415(b)(2) and 34 C.F.R. §300.519(f). A surrogate must be appointed promptly (within 30 days), but the child’s right to services cannot be delayed or denied while waiting for that appointment.

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Myth #4�Financial Aid Determinations for UHY

• Option 1: The homeless liaison may provide the verification letter confirming UHY status, and that letter must be accepted by colleges for financial aid purposes if it meets FAFSA requirements.
• Option 2: The homeless liaison can provide a verification letter, but the college’s financial aid administrator has the final decision.
• Option 3: The student can only qualify if they are currently in a UHY situation and self-report to the college’s financial aid administrator.

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Myth #4�Answer

• Option 1: The homeless liaison may provide the verification letter confirming UHY status, and that letter must be accepted by colleges for financial aid purposes if it meets FAFSA requirements.
• Option 2: The homeless liaison can provide a verification letter, but the college’s financial aid administrator has the final decision.
• Option 3: The student can only qualify if they are currently in a UHY situation and self-report to the college’s financial aid administrator.

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Myth Buster #4: Compliance Gaps

Compliance gaps happen when:

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• Districts fail to provide UHY verification for FAFSA resulting in a barrier to postsecondary access
• Verification is deferred to colleges’ financial aid offices
• Verification is delayed, incomplete or doesn’t meet FAFSA requirements

Gaps lead to:

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• Students incorrectly treated as dependent
• Delays or loss of financial aid eligibility
• Missed enrollment deadlines
• Barriers to post secondary access and success

Myth Buster #4: Tip and Tools

Tips:

• Have graduation plans in place early
• Provide all UHY seniors with a verification letter and advise them to keep a copy. Also keep the letter on file for the student.
• Ensure letter meets FAFSA requirements

Tools:

• Access Post Secondary Education: WB pgs. 40-42 (print), pgs. 44-46 (digital)
• Independent Student Verification Letter: WB pg. 45 (print), pg. 49 (digital)
• Sample Job Description for Homeless Liaisons: WB pgs. 48-50 (print), pgs. 52-53 (digital)

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Myth Buster #4: Legal Citation

20 U.S.C. § 1087vv(d)(2)(I), referencing 42 U.S.C. § 11432(g)(1)(J)(ii) “The term ‘independent student’ means an individual who is determined to be an unaccompanied youth who is homeless… and such determination is made by a local educational agency liaison for homeless children and youths designated pursuant to section”

Myth #5�UHY and Parental Involvement

• Option 1: If a previously uninvolved parent returns, the school must consider the parent’s preference and follow it when making a best interest determination on school placement.
• Option 2: The UHY’s best interest, including the youth’s wishes, must be prioritized, and the liaison must ensure the youth is able to participate in the decision-making process. Parental input is considered but does not automatically override the youth’s position.
• Option 3: Once a parent is involved, the youth can no longer make future decisions about school enrollment, but they would be allowed to continue in their current school for the remainder of the year.

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Myth #5�Answer

• Option 1: If a previously uninvolved parent returns, the school must consider the parent’s preference and follow it when making a best interest determination on school placement.
• Option 2: The UHY’s best interest, including the youth’s wishes, must be prioritized, and the liaison must ensure the youth is able to participate in the decision-making process. Parental input is considered but does not automatically override the youth’s position.
• Option 3: Once a parent is involved, the youth can no longer make future decisions about school enrollment, but they would be allowed to continue in their current school for the remainder of the year.

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Myth Buster #5: Compliance Gaps

Compliance gaps happen when:

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• District automatically defers to a parent’s preference without a best interest determination
• Student is excluded from school selection discussions
• Dispute rights are not explained or offered to the student

Gaps lead to:

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• Inappropriate school placement decisions
• Possible loss of school stability and continuity
• Youth excluded from process
• Failure to follow dispute procedures

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Myth Buster #5: Tip and Tools

Tips:

• Ensure both the parents and student are fully aware of MKV and FERPA rights for UHY.
• Include youth in decision making process. Consider parent input, but don’t make it determinative
• Avoid making immediate placement changes when parent reenters

Tools:

• Informational Flyer for Unaccompanied Youth (PDF)
• UHY: Requirements and Best Practices Concerning IDEA and FERPA: WB pgs. 28-34 (print), pgs. 32-38 (digital)

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Myth Buster #5: Legal Citation

42 U.S.C. §11432(g)(3)(B)(iv). 

“In the case of an unaccompanied homeless youth, the local educational agency shall ensure that the liaison assists in placement or enrollment decisions, gives priority to the views of such unaccompanied homeless youth, and provides notice to such youth of the right to appeal under paragraph (3)(E).”

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Myth #6�UHY, FERPA, and Support Referrals

• Option 1: FERPA allows schools to share information with community partners about an UHY if the youth verbally agrees to the sharing.
• Option 2: Because McKinney-Vento prioritizes supporting UHY, schools may share relevant student information with community partners and/or temporary caregivers when it is in the youth’s best interest.
• Option 3: FERPA does restrict disclosure of education records without written consent, but schools can share directory information if policies allow. Schools may also share information with individuals acting as parents in the absence of a parent/guardian.

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Myth #6�Answer

• Option 1: FERPA allows schools to share information with community partners about an UHY if the youth verbally agrees to the sharing.
• Option 2: Because McKinney-Vento prioritizes supporting UHY, schools may share relevant student information with community partners and/or temporary caregivers when it is in the youth’s best interest.
• Option 3: FERPA does restrict disclosure of education records without written consent, but schools can share directory information if policies allow. Schools may also share information with individuals acting as parents in the absence of a parent/guardian.

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Myth Buster #6: Compliance Gaps

Compliance gaps happen when:

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• Student information is shared without proper consent or a FERPA exception
• Verbal consent is considered enough for disclosure
• Assuming best interest allows for information sharing
• FERPA confusion leads to over or under sharing of information

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Gaps lead to:

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• FERPA violations from over sharing
• Missed support from under sharing
• Loss of trust
• Barriers to services

Myth Buster #6: Tips and Tools

Tips:

• Obtain written consent when possible
• Explain what will be shared with whom. Don’t overshare
• Apply FERPA exceptions appropriately

Tools:

• UHY: Requirements and Best Practices Concerning IDEA and FERPA: WB pgs. 28-34 (print), pgs. 32-38 (digital)
• MKV Temporary Caregiver Form: WB pg. 37 (print), pg. 41 (digital)
• Quick Reference and Tip Guide for Counselors and Social Workers: WB pg. 11 (print), pg. 15 (digital)

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Myth Buster #6: Legal Citations

20 U.S.C. § 1232g(a)(5)(A) and 34 C.F.R. § 99.37:

• Schools may designate certain information as directory information (e.g., name, address, phone, participation in activities).
• Schools may disclose directory information without consent if they have notified parents/eligible students and provided an opt-out opportunity.

34 C.F.R. § 99.3 and 34 C.F.R. § 99.31(a)(8) Definition of parent includes an individual acting as a parent in absence of a parent/guardian. Schools may disclose education records without consent to these individuals, as they are considered to have parental rights under FERPA.

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Myth Buster #6: Legal Citation

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20 U.S.C. § 1232g(b)(1) Schools may not disclose personally identifiable information (PII) from education records without written consent from the parent or eligible student (18+), except as otherwise provided by law.

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Myth #7�UHY Eligibility

• Option 1: If a youth leaves home voluntarily, the district may determine the youth is not eligible because the situation is a family conflict rather than homelessness.
• Option 2: A student can only be eligible if they have nowhere else to live full-time; if living with a parent is an option, they are automatically ineligible.
• Option 3: Eligibility is based on the youth’s current living situation, not on why they are unaccompanied. If their living arrangement is not fixed, regular and adequate, they qualify under McKinney-Vento.

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Myth #7�Answer

• Option 1: If a youth leaves home voluntarily, the district may determine the youth is not eligible because the situation is a family conflict rather than homelessness.
• Option 2: A student can only be eligible if they have nowhere else to live full-time; if living with a parent is an option, they are automatically ineligible.
• Option 3: Eligibility is based on the youth’s current living situation, not on why they are unaccompanied. If their living arrangement is not fixed, regular and adequate, they qualify under McKinney-Vento.

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Myth Buster #7: Compliance Barriers

Compliance gaps happen when:

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• Assuming parental availability determines eligibility
• Eligibility based on perceived choice or motivation of the youth
• Eligibility not based on current nighttime status
• Lack of understanding of UHY criteria

Gaps lead to:

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• Misidentifying UHY status
• Delays in enrollment or access to services
• Denied supports
• Increased risk of truancy

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Myth Buster #7: Tip and Tools

Tips:

• Base UHY eligibility on current nighttime status: fixed, regular and adequate
• Do not determine eligibility on whether the student can return home
• Accept youth’s self report of living situation

Tools:

• Quick Reference and Tips Guide for Enrollment Staff: WB pg. 12 (print), pg. 16 (digital)
• UHY Enrollment Questionnaire: WB pg. 7 (print), pg. 11 (digital)

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Myth Buster #7: Legal Citation/Federal Guidance

42 U.S.C. §11434a(2)(A) …definition of homeless children and youth includes those lacking a fixed, regular, and adequate nighttime residence, regardless of parental involvement.

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U.S. Department of Education’s McKinney-Vento guidance (2016, Non-Regulatory Guidance) “Eligibility for unaccompanied youth is determined by the nature of their nighttime residence, not by the cause of their unaccompanied status.”

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Session 2�Building School Based Supports

Panel Topics

• Enrollment challenges

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• Ongoing supports

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• Building partnerships

Panelists

• Jacy Clugston Hess: Assistant Superintendent for Ephrata Area School District

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• Cathy Koenig: Director of Student Services for Pequea Valley School District

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• Emily Snisky: Families in Transition Social Worker for Reading School District

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• Amber Stine: Manager of McKinney-Vento Support for Reach Cyber Charter School

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McKinney-Vento Program Checklist�Best Practices for UHY

Pgs. 24-25

Session 3�Action Planning

Theory of Change Activity – Process (Pg.52)

Step 1: Define the issue

• Choose one relevant and solvable problem
• Be specific – avoid broad, abstract issues

Step 2: Clarify the desired impact for students

• If this problem were solved, what would be different for students
• Write a clear end statement

Step 3: Identify outcomes

• What short term changes must happen first
• What long term results should follow

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Theory of Change Activity - Process

Step 4: Identify Activities and Outputs

• What concrete activities will drive those outcomes
• What deliverables will exist as evidence of action

Step 5: Identify Inputs and Risks

• What resources are needed
• What barriers could slow or block progress

Step 6: Define Indicators of Progress

• How will you measure if this is working
• Identify at least 2 measurable indicators

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Action Planning Topics

• Improving Identification of UHY
• Behavior and Discipline Systems
• Supporting Highly Mobile Youth
• Post Secondary Transitions
• Engaging Community Partners
• Supporting UHY with Disabilities

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Instructions

1. With your group, choose 1-2 topics from the list on your table.
2. Each topic has possible focus areas. You may use those focus areas or develop your own. 
3. Using the blank Theory of Change template in your workbook, outline a manageable plan, including action steps, for your district to follow to reach your goals. (A sample is included in the workbook.) 
4. Share out at the end of the session with the larger group on:
1. One concrete first action step
2. One anticipated barrier
3. One indicator of progress

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Large Group Discussion

• What is one concrete first action step?
• What is one anticipated barrier?
• What is one indicator of progress?

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Jeopardy

Spring Regional Meeting

Scenario - Disputes

• Elena is in 3^rd grade in District A.
• In 2024, Elena and her mother are evicted from their apartment and move into a friend’s house temporarily, which is located in District B.
• Elena is identified as McKinney-Vento and remains in her school of origin (District A) and receives transportation to this school.
• It is now 2026 and Elena and her mother have been with their friend in District B for over a year.
• District A meets with the family to review the housing situation. While the family says this is still a temporary situation, District A believes the family has established permanent residency.

What should happen next?

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Dispute Procedure - Level 1

• A dispute may be raised with the LEA
• Homeless Liaison contacted for review of situation
• Homeless Liaison must provide written notice to parent/student which includes:
• What they are denying and the basis for that decision
• A timeline for next steps
• Information on their right to appeal

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Dispute Procedure – Level 2

• A complaint may be filed with a regional or state coordinator
• A parent may appeal the decision
• Regional office gathers information
• PDE offers resolution within 20 business days
• Student remains enrolled pending dispute outcome

Things to Remember

• Maintain documentation
• If providing a denial of enrollment to a family, include a tentative date of withdrawal
• Communicate with your regional office about possible disputes before sending denial letters
• Ensure timely communication with regional and state ECYEH offices
• Do not withdraw students without following this process
• The burden of proof to prove non-homelessness is on the district

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Recent Trends in Disputes

• Eligibility (time limit on homelessness)
• Adequacy of living arrangements
• Residency verification challenges (online systems “proving” residency)
• Parents using AI (ChatGPT) to prove/cite MKV
• Transportation
• Graduation plans
• Truancy

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End of Year Reminders

• Data entered and exported by June 30
• Don’t forget to include younger siblings (birth-5)
• Summer reverification
• Make a plan to reverify MKV status before start of school year
• Regional Survey
• Please complete this before the end of the year!
• Region 2 Highlights
• Liaison Mentorship Program, Office Hours, Internship Program

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Access Today’s Resources�(website)

Kristen Hoffa, Regional Coordinator

Melissa DeMotta, Supervisor

Tabitha Kramer, Supervisor

Lauren Hammond, Training &

Projects Coordinator

Stacey Kilgore, Site Coordinator

Rachel Wright, Intern

Alyson Hoffa, Intern

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