Parent-Guardian Information Question

This is a change management planning worksheet.

Purpose of the Parent Guardian Information Question

The Parent/Guardian Information question determines whether an applicant under 19 years of age on the residency determination date (RDD) is either subject to care and control of a parent or guardian for purposes of determining residency, or Independent because of one of the approved exceptions.

The Parent/Guardian Information question only appears in the CCCApply Standard & Noncredit Application IF the applicant is UNDER 19 years of age. If the question is displayed, a response is required. For residency purposes (unlike in general law), a minor is defined as someone under 19 years of age. This is specified in the SAAM, which cites the CA Ed Code 68062 (see below).

The data field behind this question is “Dependency Status” = <dependent_status> and the values are defined in the DED.

Additional Information - Data

In FY 2018-2019, over 2.6 million CCCApply applications were submitted. For the purposes of this breakdown, spam applications were not removed from the total = 2,647,615. Of the this total submitted:

MINORS = 730,716 (27.6% of all apps submitted)
- DEPENDENT Minors = 679,566 (93% of minors) and 25.6% of all apps were from DEPENDENT minors.
- INDEPENDENT Minors = 51,150 (7% of minors) self-reported as having one or more special circumstances (either married, emancipated, do not have a living parent, or were in foster youth any time after age 13 or - as of the RDD are in active military, or are self-supporting. (2% of all apps submitted.)
ADULTS = 1,916,899 (72.4% of apps submitted by Independent adults, 19 yrs or older)

In FY2018-19, only 7% of all minors self-identified as “independent minors”. all the rest are “dependent” and must provide their Parent or Guardian’s name and relationship.

College Meeting Discussion Notes - December 2019

Immigrants Rising, advocating for undocumented/nonresident students, has suggested that clear, non-threatening language be added to the Parent/Guardian Information question to better help these students understand, feel welcome and secure, and accurately self-identify
Students want a streamlined, unambiguous question that clearly explains why they are being asked for their parent information (especially when they are 18 years old)
Students want to know that their parent’s information is protected by state and federal laws and will not be used for discriminatory purposes
Students who meet eligibility requirements need clear language so they can understand they can apply for tuition exemption through AB540 / SB 68.
Colleges need to collect parent or guardian information from dependent minors (under 19 yro) in order to determine residency status for tuition purposes from the parent or guardian
Colleges want a better layout in the P/G Info question in order to collect the minor student’s parent or guardian information
Colleges also need to identify Independent minors and remove barriers for these students to apply & enroll
Colleges want minimal changes to the data structure and the download files;

Next Actions

Work with the Chancellor’s Office to confirm what language can be changed and whether the proposed layout changes are approved.

Mia Keeley offered to work with us to ensure all changes are compliant and approved for development
Review proposal for layout and language changes
Review Immigrants Rising's original concerns and feedback:

Problems with the Current Layout

The current layout has several issues:

LANGUAGE

The language in the current question is too long overall, too ambiguous, and filled with legal language that is confusing to the minors it is presented to;
The language can be unwelcoming to undocumented and nonresident minor students, and doesn’t explain that students who meet the eligibility requirements can apply for nonresident tuition exemption through AB540 / SB68.
And, finally, as cautioned by the student advocacy group, Immigrants Rising, the current language can be threatening and DOES NOT reassure these students that their parents' data will be protected and not shared;

LAYOUT

The layout is backwards - it features a confusing set of statements that appear to cater to identifying “independent” students rather than focus on the primary objective: collect the parent information required (name + relationship);
When a dependent student chooses the wrong option, the college has to do additional intake follow up with the student by phone or other time-consuming method.
While less than 8% of the minors are legitimately independent - the statements and the bulleted list make it seem that the applicant should answer that one of the bullet statements is true about them.

What Do We Need to Change?

The majority of minors are “dependents” (see Stats) and therefore the college needs to collect their parent or guardian information. However, because our current layout is ambiguous - students who are not reading closely are selecting the wrong option. The way the question is laid out, the student’s first instinct is to select the first option - the one at the top - which is: “One of the following statements is true about me” - which is the option that identifies the exceptions that classify the student as “Independent”.

Flip the Layout

We propose flipping the layout so that the collection of the parent or guardian information is collected at the top, and the “I do not have a parent or guardian…” option is clearly shown below.

The question is required and the student must either provide parent information or check the “I do not have a parent or guardian….” checkbox. When data is entered into the parent information input fields, the “I do not have a parent or guardian…” checkbox will be disabled.

Revise the Language

In addition to flipping the layout, the language needs to be revised to clarify why the student’s parent information is being collected, not just for undocumented and nonresident minors, but all minors. Acknowledging that their parents' data will be protected and not shared, will reassure the student with clear, non-threatening language.

Change: “By California law, qualification for resident tuition is based on the residency of your parent(s) or guardian(s) until you are 19 years of age, except in certain special circumstances. The following questions will be used to determine whether or not you need to provide parent or guardian information for the purposes of determining residency. Your response will not affect your admission to college.”

TO: “Determining your California residency for tuition purposes is based on the residency of your parent(s) or guardian(s) until you are 19 years of age, except in certain special circumstances. Nonresident students who meet eligibility requirements may apply for nonresident tuition exemption (AB540 / SB68). This information is protected by federal and state laws and will not be shared or used outside of the admission process.

Enter the name of your parent or guardian below, or check the box indicating you do not have a parent or guardian.”

NO CHANGE is needed to the <dependent_status> data field or the parent info fields. The proposed changes would be strictly cosmetic.

Review & Feedback

Reviewers

Mia Keeley - Chancellor’s Office
Colleen Ganley - Chancellor’s Office
Mitch Leahy - representing Admissions & Records needs from Santa Rosa College
Betty Glyer-Culver - representing research needs from Los Rios district
Nancy Jodaitis - representing undocumented and other non-U.S. residents from Immigrants Rising Organization
Debbie Raucher - representing foster youth minors - from the John Burton Foundation (who was very instrumental in changes to this question made last year to better support foster youth)

Who	Feedback	Notes
Debbie Raucher, Burton Foundation re: Foster Youth	Thank you Patty for giving me an opportunity to weigh in. I read this with the lens of the potential impact on foster youth and have the following thoughts. Regarding the sentence “Enter the name of your parent or guardian below, or check the box indicating you do not have a parent or guardian.” I would recommend adding to that sentence “…or otherwise qualify as an independent student.” It’s a little confusing for someone who is in foster care (or potentially someone qualifying as independent in some other way but who has a parent), because that first sentence implies that the box should be checked only if you don’t have a parent or guardian. You say that if someone enters a parent or guardian name, the box below with options for independent status disappears. This is concerning to me. I could easily see a foster youth entering a name in that space not realizing that if they go further down, they can check the box for being independent, despite the instructions. Once they’ve completed those fields, if the checkbox disappears before they get to the place where they’re reading the qualifications for the check box, they may not realize they should have checked the box. As we’ve discussed before, many enter “guardian” as a default when they don’t live with their bio parent, which then triggers additional verification. Could there instead be an initial question that offers two check boxes – one for I have a parent or guardian and one for I qualify as independent? That way they have to make a choice between two options and might be less likely to inadvertently check the independent box?
Mitch Leahy, Admissions & Records, Santa Rosa College	I am concerned with item #2 when you say “Could there instead be an initial question that offers two check boxes – one for I have a parent or guardian and one for I qualify as independent?”. Through the lens of non-foster youth 18 years olds, they feel that they do qualify as an independent which is incorrect for the purposes of residency determination. This results in barriers for the majority of our non-foster youth students who have to followup with more paperwork.
Mia Keeley, CCCCO	I have the same concern as Mitchell. Do want to schedule a call? Will that be easier than discussing by email?
Debbie Raucher	In lieu of a call, I have another suggestion to offer. What if there was a sentence after “Enter the name of…” in bold that says something like “Do not enter a name below if any of the special circumstances described below apply to you.”

Breakdown of Dependent Foster Care vs. Independent in Foster Care

Only 84 total minors indicated they are or were ever in foster care - out of 1.915M applications. That’s how many kids would be impacted by this change.

Foster Care Status	Dependency Status	Totals	% of Apps
0 = No Foster Care	1 = Applicant is dependent. Selected “None of the statements above is true about me.”	67
	2 = Applicant is under 19 and independent.	12
(96% of all applicants were NOT in foster care, regardless of age)	3 = Applicant is 19 or older & independent.	1,839,789	96%
1 = Currently in Foster Care	1 = Applicant is dependent.	1
	3 = Applicant is 19 or older, independent.	11,787	.006%
2 = I aged out/emancipated on or after my 16th bday.	3 = Applicant is 19 or older.	15,413
5 = I exited before my 16th .	1 = Applicant is dependent.	2
	3 = Applicant is 19 or older independent.	15,334
6 = I am not sure	3 = Applicant is 19 or older independent.	9,260
BLANK	1	1
	2	1
	3	23,822

Reference: Legal Information

Everything below is for reference only.

From the SAAM:

Self-Supporting Student
Two-Year Care & Control:
Residency for Minor

Click here to expand...

Parent

The father or mother with whom the minor resides; or, if both parents are deceased, the minor’s legal guardian. Reference: EC 68014

"Parent" means the parent with whom the minor resides; or, if both parents are deceased, his or her legal guardian. Language from Ed Code: 68014.

Determining Residency

f. The residence of the parent with whom an unmarried minor child maintains his or her place of abode is the residence of the unmarried minor child. When the minor lives with neither parent, his or her residence is that of the parent with whom he or she maintained his or her last place of abode. The minor may establish his or her residence when both parents are deceased if a legal guardian has not been appointed.
g. The residence of an unmarried minor who has a living parent cannot be changed by his or her own act, by the appointment of a legal guardian, or by relinquishment of a parent’s right of control, unless the student qualifies under the Self-Support exception (EC 68071) or the Two-Year Care and Control exception (EC 68073 and T5 54047).
h. An noncitizen, including an unmarried minor noncitizen, may establish his or her residence unless precluded by the Immigration and Nationality Act from establishing residence in the United States. See Note in (f) above.

Reference: EC 68060, 68061, 68062, 68071, 68073; T5 54022, 54045, 54047

Note: The conditions in (f) apply unless the Immigration and Nationality Act precludes the minor from establishing domicile (residence) in the United States. Language from Ed Code: 68062:

Foster Youth Status

Set the value for this field as follows:

0 = The response to “Have you ever been in Court Ordered Foster Care?” is No.

Set the field based on the option selected when Foster Care question is Yes and the additional question text displays with radio buttons:

1 = I am currently in foster care (including extended foster care after age 18).

2 = I aged out/emancipated from foster care or exited voluntarily on or after my 16th birthday.

3 = No longer used

4 = No longer used

5 = I exited the foster care system before my 16th birthday.

6 = I am not sure at what age I exited foster care.

From CCCApply Standard Application Data Dictionary v.2019.3)

Dependent of Parent/Guardian

Data Element:	dependent_status
Description:	Whether applicant is a minor subject to care and control of guardian per residency law—and if not, whether applicant is a non-minor or an independent minor.
Format, Length:	bpchar, 1
Values:	1 = Applicant is dependent. Selected “None of the statements above is true about me.” 2 = Applicant is under 19 and independent. Selected “At least one of these statements is true about me”. 3 = Applicant is 19 or older and therefore independent. The applicant will not have been presented with the parent/guardian questions.
Allows Null:	No
Default:	3
Usage:	If this field = 1, parent/guardian questions are asked and many residency-related questions are reworded to refer to parent/guardian rather than “you”.
Notes:	General law identifies a ‘Minor’ as under age 18; however, the “Evidence of Intent” rules in the Student Attendance Accounting Manual (Chapter 2), based on Title 5 section 54024, specify ‘under 19 years’ as the differentiating criterion, superseding general law.
Hover help	Whether applicant is a minor subject to care and control of guardian per residency law—and if not, whether applicant is a non-minor or an independent minor.
Question Text:	Select the statement that applies to you: At least one of the following statements is true about me: At least one of the following statements is true about me I am or have been married I am legally emancipated I do not have a living parent or guardian I was in foster care at any time after my 13th birthday As of <rdd>, I will be on active duty in the armed services As of <rdd>, I will have been self-supporting for at least one year None of the statements above is true about me None of the statements above is true about me.
Conditions:	Appears only if the applicant will be under 19 at RDD.
Additional Text: By California law, qualification for resident tuition is based on the residency of your parent(s) or guardian(s) until you are 19 years of age, except in certain special circumstances. The following questions will be used to determine whether or not you need to provide parent or guardian information for the purposes of determining residency. Your response will not affect your admission to college.
Response Options:	Must select one of the two radio buttons.
Pop-Up Help:	If any of the hyperlinks in the Question Text is clicked, a pop-up is displayed with the following text: Parent: For the purposes of this college application, your parent is a natural or adoptive mother or father with whom you live and/or who provides your support, care, and control. If you have two parents, you can enter the name of either one. Guardian: For the purposes of this college application, your guardian is a person other than a parent who has been legally appointed to provide your support, care, and control. If you have two guardians, you can enter the name of either one. Emancipated: Being emancipated means that you have been legally released from the care and control of parent(s) and/or guardian(s), and are now responsible for your own care and control. To be considered legally emancipated for the purposes of this college application, you must have received a declaration of emancipation from a California court, or have been legally emancipated in another U.S. state. Self-Supporting: You are considered to be self-supporting if you do not receive any financial support from a parent or legal guardian in the year leading up to the start of the term for which you are applying. Financial support you may receive from colleges, institutions, or individuals who are not your parent or legal guardian does not affect whether you are considered self-supporting. Court-Ordered Foster Care: You have been in foster care if you were removed from your biological family through an order by a court, which can include placement with foster parents, in a group home, or with relatives/extended family members. If you were living with relatives you must have been placed through the foster care system by an order of the court. Foster Care includes, but is not limited to, placement in out-of-home care under the supervision of the Juvenile Probation Department. As long as you were placed within the foster care system by order of a court, you were in foster care. Having a legal guardian does not necessarily mean that you have been in foster care. If you need assistance with determining whether you were in foster care, you can contact the California Foster Care Ombudsman's office at (877) 846-1602 or fosteryouthhelp@dss.ca.gov
Field Error Check:	None
Page Error Check:	Required selection; else error message, “You must select one of the options related to your parent or guardian status.”
Notes:	This question determines whether someone who will be under 19 on RDD is subject to care and control of guardian for purposes of determining residency. For residency purposes (unlike in general law), a minor is defined as someone under 19 years of age.
Data Element:	dependent_status

Additional fields:

Parent/Guardian First Name
Parent/Guardian Last Name
Parent/Guardian Relationship

These fields, along with the Dependency question above, only appear if:

Only displayed if previous response indicates the person is under 19 and not independent.