U.S. Department of Education Discriminates against Zombies

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Mark Kantrowitz

By Mark Kantrowitz

April 1, 2019

A review of guidance published by the U.S. Department of Education demonstrates that the U.S. Department of Education discriminates against zombies in the awarding of federal student aid funds. The guidance also uses insensitive language that offends the undead, such as repeated references to “living expenses.” This is despite the fact that some senior members of the administration may, in fact, be zombies themselves.

Your intrepid reporter, the first to cover the contagion effect from the subprime mortgage credit crisis, discovered that the stress and nutritional deficits from adopting an austere lifestyle contributed to the transformation of student loan borrowers with excessive debt into zombies. This triggered a malignant mutation of the cooties virus. The contagion spread when unemployed and underemployed zombies moved back home, gnawing on their siblings and parents.

Amid concerns about the student loan crisis causing the zombie apocalypse, reports began to surface of discrimination by U.S. government officials against zombies.

Unh Unh, spokesperson for Gen Z – the Zombie Generation – responded to the allegations against the U.S. Department of Education by saying, “We need more brains.”

U.S. Department of Education Guidance Concerning Zombies

Evidence that the federal government contemplates the existence of zombies can be found in the Application and Verification Guide (AVG), a source of sub-regulatory guidance published annually by the U.S. Department of Education.

The AVG provides inconsistent guidance concerning the undead. All of the following quotes are excerpts of actual guidance published by the U.S. Department of Education.

Only Some Zombies are Counted in Household Size

On page AVG-29, the U.S. Department of Education indicates that the student is always counted in household size, even if undead, but excludes undead parents.

“The following persons count in the household size of a dependent student’s parents: The student and parents, even if the student is not living … Exclude a parent who has died or is not living …”

Similarly, guidance on page AVG-33 excludes the spouse of an independent student if the spouse is undead.

“The following persons are included in the household size of an independent student: The student and his or her spouse, unless the spouse has died or is not living …” 

Colleges Cannot Disburse Aid to Zombies

Even so, the guidance disallows payments of student aid funds if the student dies. This is consistent with the regulations at 34 CFR 668.60(e), which prohibit colleges from making “any further disbursements on behalf of the applicant.” How can a zombie pay for college, if their student loans and other aid cannot be disbursed?

Zombies are Required to Complete Verification

Guidance on page AVG-82 exempts the undead from the need to complete verification.

“Death of the student. You don’t have to continue verification if you made an interim disbursement and the student died before verification was completed.”

“Unless you have reason to believe it is inaccurate, you don’t have to verify the reported FAFSA information of the parents of a dependent student if any of the following apply (including in cases where there is only one parent): … Both parents or the custodial parent has died.”

Although this is consistent with the regulations concerning exclusions from verification at 34 CFR 668.54(b), subsequent guidance on page AVG-115 concerning conflicting information suggests that this guidance was limited to scenarios in which the undead student did not re-enroll.

“The school must resolve all such conflicting information, except when the student dies during the award year …; if the student later enrolls, you are again obligated to resolve the conflicting information.”

The regulations at 34 CFR 668.57 require that joint tax returns from the prior-prior year must still be verified even if one parent is now a zombie.

Thus, zombies must complete verification even though the U.S. Department of Education does not allow the disbursement of federal student aid funds to a zombie.

Language that is Offensive to Zombies

In addition, insensitive language permeates the Application and Verification Guide, including references to the following:

  • “living allowances” (AVG-19, AVG-21, AVG-29)
  • “living with a friend” (AVG-22)
  • “living expenses” (AVG-23, AVG-41, AVG-42, AVG-45, AVG-47, AVG-48, AVG-112)
  • “parents who are unmarried and living together” (AVG-28)
  • “biological parent remains” (AVG-28)
  • “moderate level of living” (AVG-43)

The U.S. Department of Education could avoid the use of the word “living” by substituting other language, such as the word “residing.”

Guidance on page AVG-31 concerning parents who are separated makes unnecessary assertions about whether the parents “are still living.”

Particularly offensive are definitions of homelessness that require the student to be “living on the street,” “living in substandard housing” or “living in emergency or transitional shelters.” This language excludes the undead, even though most zombies do not have a permanent residence and roam the streets and abandoned buildings when not sitting in a classroom.

[Editor’s Note: Any resemblance to actual persons, living or dead, is purely coincidental.]

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