The Catholic University of America (“University”) is committed to providing reasonable accommodations and an accessible environment to qualified students with disabilities (See the University’s Support Animals Policy and Service Animals Policy. Under the Fair Housing Act, Americans with Disabilities Act as amended, and Section 504 of the Rehabilitation Act of 1973, individuals with a qualified disability may request to have a Support Animal as a reasonable accommodation in campus housing facilities that otherwise impose restrictions or have prohibitions on non-service animals in residence. In order for a student with a disability to qualify for such an accommodation, an individual must abide by the following guidelines:
Support Animal means an animal that provides emotional support, well-being, or companionship that alleviates or mitigates symptoms of a disability. The presence of the Support Animal must be necessary in order to provide the resident with a disability the use and enjoyment of the dwelling. There must be an identifiable relationship between the disability and the support the Support Animal provides to the resident.
Support Animals are not considered service animals under the Americans with Disabilities Act (ADA). Support Animals are also not pets. In addition, please see the University’s Support Animals Policy, Service Animals Policy, and Pet Policy.
Criteria for Determining If Presence of a Support Animal is a Reasonable Accommodation:
Requests for a Support Animal as a reasonable accommodation are reviewed and approved by DSS on an individual, case-by-case basis through an interactive process between DSS and the resident. Eligibility for this accommodation is based on appropriate documentation of a disability, and an evident link between the functional limitations of the disability and the need for a Support Animal as an accommodation in order to allow the resident equal access to the residence hall or the residential education experience.
In accordance with the American Counseling Association’s March 2019 position, “professional counselors [should] not engage in the practice of writing letters for their clients, unless the counselor has specialized training and experience in working with human-animal bond in counseling such as would be outlines in the ACA AAT-C Competencies for Emotional Support Animals (ESAs) due to the potential risks involved for clients, the public, the counselor, and the animal. The ACA Code of Ethics C.2.a Boundaries of Competence states that counselors only work within their boundaries of competence based on education, training, supervision, experience and credentials. As Licensed Professional Counselors, the assessment of DSM 5 diagnoses for human clients is within the scope of practice; however, the added practices of animal behavior, behavior assessment or Human Animal Interventions are (most often) not. Emotional Support Animals may, in some specific circumstances, provide benefits to humans to minimize identified symptoms often associated with a DSM 5 diagnoses; however, because of the potential risks and unanticipated outcomes, the HAIC strongly suggests that counselors abstain from writing letters for persons seeking counseling or assessment for the sole purpose of obtaining an ESA recommendation letter."
The University may consider the following factors, among others, in determining whether the presence of the animal is reasonable and/or in the making of housing assignments for individuals with Support Animals:
- The size of the animal is too large for available assigned housing space;
- The animal's presence would force another individual from individual housing (e.g. serious allergies);
- The animal's presence otherwise violates individuals' right to enjoy peace and quiet;
- The animal is not permitted in the District of Columbia by applicable law or regulation;
- The animal is not housebroken or is unable to live with others in a reasonable manner;
- The animal's vaccinations are not up-to-date;
- The animal poses or has posed in the past a direct threat to the individual or others such as aggressive behavior towards or injuring the individual or others; or
- The animal causes or has caused excessive damage to property beyond reasonable wear and tear.
A request for a Support Animal may be denied as unreasonable if the presence of the animal: (1) imposes an undue financial and/or administrative burden on the University; (2) fundamentally alters University housing policies; and/or (3) poses a direct threat to the health and safety of others or would cause substantial property damage to the property of others, including University property.
To ensure that the presence of Support Animals is not an undue administrative burden or fundamental alteration of University housing, the University reserves the right to assign an individual with a Support Animal to a single room without a roommate.
To request a Support Animal, residents must:
- Request a Housing Accommodation, indicating the request for a Support Animal,
through the Office of Disability Support Services (DSS). The Housing Accommodation Request form can be found on the DSS website (dss.catholic.edu).
- Submit supporting documentation from a licensed, treating clinician.
The documentation should include diagnosis, provide explanations from the treating professional regarding the resident’s disability or condition, the impact of the disability or condition on a major life activity, the necessity of the Support Animal for the resident to use or enjoy campus housing, and the relationship between the resident’s disability and the relief the assistance animal provides. This documentation must come from the resident’s current treating clinician and include date, signature, and licensing information.
It is strongly recommended that the resident submit all required materials to DSS prior to the deadline to submit a housing application for the following semester. The Office of Housing Services sets these dates each year. Requests made after these dates will be processed on a case-by-case basis.
- DSS will review all materials and follow up with the resident.
DSS requires at least 10 business days to review requests for a Support Animal and supporting documentation.
If DSS determines that a Support Animal is a reasonable accommodation, the resident should submit a printed and signed copy of these guidelines to DSS as proof that the resident has read and agreed to the guidelines.
At this time, DSS will notify the Office of Housing Services and Residence Life of the type of Support Animal and resident name. The Office of Housing Services will in turn notify the other residents of the floor or community where the individual with the Support Animal resides of the type of Support Animal only.
If DSS does not determine that a Support Animal is a reasonable accommodation, the resident may appeal the decision. The Grievance Procedure explained at the end of these guidelines.
- If DSS determines that a Support Animal is a reasonable accommodation, the resident must then submit the signed emotional support animal agreement and current vaccination and licensing documentation (if applicable).
- Proof of up-to-date rabies and distemper vaccinations,
- Proof of sterilization (spaying or neutering), and
- Each dog over four months old must have a DC license and wear it on a collar at all times.
- Proof of up-to-date rabies and distemper vaccinations (kittens need distemper shots at eight weeks of age, and a booster every three weeks until they are 12–16 weeks old. Their first rabies shot is given at 14–16 weeks, and it is good for one year only. After receiving the second rabies shot, a cat must be re-vaccinated at least every three years), and
- Proof of sterilization (spaying or neutering)
- Other Animals
- Other animals must be in good health, have completed all vaccinations ordinarily required for a healthy animal of that type or species and have documentation from a licensed veterinarian dated within the past year stating that the animal is in good health. Local licensing requirements must be followed. The University reserves the right to request removal of the animal if proper documentation is not up to date.
- After all licencing documentation has been received and reviewed, DSS will provide the resident a Letter of Accommodation that should be kept on their person at all times as proof of accommodation. The resident cannot bring the Support Animal to campus before receiving a letter of accommodation for the current semester from DSS.
- A resident is required to request an accommodation for a Support Animal every semester. DSS must approve a Support Animal as an accommodation every semester.
- The Support Animal is allowed in University housing as long as it is necessary because of the resident’s disability. The resident must notify DSS in writing if the Support Animal is no longer needed or is no longer in residence. If the resident wishes to replace one Support Animal for another, a new application and review of the request and animal must be submitted.
- No Support Animal may be in a residence hall without it having been approved as an accommodation for the resident by DSS.
- If the accommodation of a Support Animal is approved, Housing Services will be notified and they may in turn notify the other residents of the floor or suite where the resident resides. Such information will be limited and will not include specific disability related information. Other residents with medical condition(s) that are affected by animals (respiratory diseases, asthma, severe allergies) or who are unable to reside with the Support Animal and need an accommodation will be asked to provide medical documentation identifying their condition. The University will resolve any conflict in a timely manner. Any conflicts could result in a change of room assignment.
- Support Animals are only permitted in an individual’s University residence and other campus areas approved by the Office of Housing Services. Requests for an animal in areas other than the residence hall room will be considered on a case-by-case basis and require a formal accommodation.
Resident Responsibilities for Approved Support Animals:
- All Support Animals must be under the control of the resident who has had the animal approved as an accommodation by DSS at all times.
- When a Support Animal is outside the private individual living accommodations, it must be in an animal carrier or controlled by a leash or harness. The resident is liable for all actions of the Support Animal.
- The resident is responsible for ensuring the Support Animal is contained, as appropriate, when the resident is not present during the day while attending classes or other activities.
- The Support Animal must be properly cared for and nourished. University personnel shall not be required to provide care or food for any Support Animal including, but not limited to, removing the animal during emergency evacuation for events such as a fire alarm. Emergency personnel will determine whether to remove the animal and may not be held responsible for the care, damage to, or loss of the animal.
- Support Animals must be housebroken. Cleaning up the waste of a Support Animal is the sole responsibility of the resident. The animal’s waste must be removed by placing the waste in a closed container and depositing it in an appropriate outdoor waste receptacle. It is the responsibility of the resident to immediately clean up any mess created by the Support Animal.
- Any cost incurred by the University to clean up the mess or repair property damage caused by a Support Animal is the responsibility of the resident.
- All liability for the actions of the Support Animal (bites, scratches, running away, etc.) are the responsibility of the resident. The University assumes no responsibility or liability for is not liable if the Support Animal. The University encourages residents to consider appropriate liability insurance.
- The resident agrees to continue to abide by all other residential policies.
- Support Animals may not be left overnight in University housing to be cared for by any individual other than the resident. If the resident is to be absent from his or her residence hall overnight or longer, the animal must accompany the resident.
- If the Support Animal escapes from the resident’s room, the resident agrees to immediately notify the Resident Assistant and Community Director.
- The resident with a Support Animal will provide to the Resident Assistant and Community Director the emergency contact information of an individual who will be on call to care for the Support Animal in the event of an emergency whereby the owner is unable to care for the Support Animal.
- The residence may be inspected by the University for fleas, ticks or other pests once a semester or as needed. The applicable housing office for the residence hall will schedule the inspection. If fleas, ticks, or other pests are detected during inspection, the residence will be treated using approved fumigation methods by a University-approved pest control service. The resident will be billed for this service and the approved Support Animal will not be allowed back in the residence hall until the owner provides proof that the Support Animal has been treated for the condition by a veterinarian.
Removal of the Support Animal:
The University may remove a Support Animal when:
- The animal poses a direct threat to the health or safety of others;
- The animal’s presence results in a fundamental alteration of a University’s program;
- The animal or its presence creates a continued disturbance or interference with the University community;
- The resident does not comply with these Guidelines for Support Animals or applicable University policies; or
- The animal repeatedly acts inappropriately or is not under control. In this circumstance, the animal may be excluded from being on campus until it can be demonstrated that the animal’s inappropriate behavior has been addressed and the animal is under control.
Should the Support Animal be removed from the premises for any reason, the resident is expected to fulfill his or her housing obligations for the remainder of the housing contract.
Appeals and Grievance Procedure:
Residents who wish to express a grievance or appeal a decision regarding a Support Animal should follow DSS’s Grievance Procedure, found on the office’s website.
Questions or concerns should be addressed to:
Office of Disability Support Services
The Catholic University of America
Pryzbyla Center 127
620 Michigan Avenue, NE Washington, DC 20064 202-319-5211 / email@example.com