Colleges and universities are facing rising requests for emotional support animal (ESA) accommodations. To negotiate this challenge, institutions must establish policies that clearly outline both the institution’s and the student’s rights and responsibilities. EAB reviewed ESA practices at more than 100 institutions and found that most schools lack independent or comprehensive ESA policies, or have not updated their policies to reflect recent case law. As the number of ESA accommodation requests continues to increase, institutions must articulate comprehensive policies to reduce their legal exposure and ensure staff time and resources are optimized towards helping students with substantiated needs.
To help institutions fast-track their policy development or review process, EAB developed this ESA policy template. In it, we’ve incorporated essential lessons learned from 100+ reviewed practices and the U.S. Department of Justice-vetted policies established in settlements from the cases of University of Nebraska at Kearney (UNK, 2015), Kent State University (KSU, 2016), and Notre Dame de Namur University (NDNU, 2018).
Two ways to use EAB’s ESA Policy Template
Create an ESA policy
Use our policy template as input into your policy development process. Combine with EAB’s ESA Issue Brief to educate and inform discussion with recommended campus partners as you craft your institution’s policies and practices.
Audit and update an existing ESA policy
If your existing policy pre-dates the 2015 UNK settlement or did not consider available case law during initial development, EAB recommends revisiting your policy to ensure it is consistent with available legal precedent. Use EAB’s template to inform your assessment and update your policy.
Who to Involve
We recommend you engage these campus partners in developing or revising your ESA policy:
- Chief Student Affairs Officer
- General Counsel
- Director of Disability/Accessibility Services
- Director of Residence Life and Housing
- ADA, Section 504, and/or Equal Educational Opportunity Coordinator/Office
- Counseling and Psychological Services
- Housing Facilities Director/Manager
For each individual or office you involve, define their role in the policy development process to ensure clarity around who provides the recommendations, who provides input or comments on the recommendations, who needs to agree on the policy, and who has final sign-off authority. For more information, individuals and offices can also review EAB’s issue brief on accommodating the rise of emotional support animals on campus.
Download the full PDF to view EAB’s example emotional support animal policy and agreement.
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