My Department does not have any remit for TUSLA.
However, officials from my Department have contacted the administrators of the HEAR scheme for clarification on the criteria and I am advised that the only way to qualify as a person in care, is if you have a letter from TUSLA.
I would, however, suggest that the student in question should contact the Access office of the college they wish to attend to discuss all the options that may be available to apply for the HEAR scheme. Details are available on the accesscollege.ie website, Participating Colleges - Access College. For example if this student were to apply under the income from their Guardian there may be allowances to disregard certain payments and this may be something that the student can also explore.