Emotional Support and Service Animals Policy

This policy describes the process by which enrolled and prospective Earlham students with disabilities request and receive a reasonable accommodation for an emotional support or service animal.

Earlham College is committed to providing equal access to its programs, activities, residences, and services in accordance with the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act of 1973 (Section 504), the Fair Housing Act of 1988, and Indiana code 16-32-3. Earlham provides reasonable accommodations to qualified students with disabilities to ensure their full participation in and enjoyment of the institution’s academic, social, and residential life.

1. Emotional Support Animal (ESA): An ESA is an animal that provides emotional support, comfort, or assistance to an individual with a documented disability. ESAs do not require specific training but must be well-behaved and under the control of their owner at all ESAs are protected under the FHA and are to be kept within college housing.
2. Service Animal (SA): A dog that is individually trained to perform tasks or work for the benefit of an individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability. Other species of animals, whether wild or domestic, trained or untrained, are not service animals for the purpose of this definition. The work or tasks performed by a service animal must be directly related to the individual’s disability. Service animals are protected under the ADA and are granted access to all areas of the campus where the general public is allowed, with some exceptions.

For the Undergraduate College and the Graduate Programs in Education:

Jennifer James
Director of Disability and Accessibility Services
ADA & Section 504 Coordinator
Lilly Library, Room 230
Phone: 765.983.1390
Email: [email protected]

For the Earlham School of Religion:

April Vanlonden
Joint Seminaries Registrar
Disability Services Coordinator
Earlham School of Religion
228 College Ave, Richmond, IN 47374
Phone: 765.983.1816
Email: [email protected]

1. Students requesting an ESA or SA must submit a formal request to Disability & Accessibility Services (DAS) at Earlham The request should include documentation from a qualified healthcare or mental healthcare professional with an established relationship with the student. The documentation must verify the need for an ESA as part of the treatment plan or outline the individual’s disability and the tasks or functions the SA is trained to perform.
2. Students are typically notified of a decision with regard to an ESA or SA on the premises within 10 business days.

Information about disability may include

1. A determination of disability from a federal, state, or local government agency.
2. Receipt of disability benefits or services (SSDI), Medicare, or Supplemental Security Income (SSI), veterans’ disability benefits, services from a vocational rehabilitation agency, or services from another federal, state, or local agency.
3. Eligibility for housing assistance because of a disability.
4. Information confirming disability from a healthcare professional – e.g., physician, optometrist, psychiatrist, psychologist, physician’s assistant, nurse practitioner, or nurse.
5. Alternatively, students may use the DAS’ ESA/SA Certification Form if they choose to do so.
6. Some websites sell certificates, registrations, and licensing documents for assistance animals to anyone who answers certain questions or participates in a short interview and pays a fee. Under the FHA, a housing provider may request reliable documentation when an individual requesting reasonable accommodation has a disability and disability-related need for an accommodation that is not obvious or otherwise known. Documentation from the internet is not, by itself, sufficient to reliably establish that an individual has a non-observable disability or disability-related need for an assistance animal.
7. Earlham understands many legitimate, licensed health care professionals deliver services remotely, including over the internet. One reliable form of documentation is a note from a person’s health care professional that confirms a person’s disability and need for an animal when the provider has personal knowledge of the individual.

1. Animals commonly kept in households (Considered for Reasonable Accommodation): Dog, cat, small bird, rabbit, hamster, gerbil, other rodent, fish, turtle, or other small, domesticated animal that is traditionally kept in the home for pleasure rather than for commercial purposes. For purposes of this assessment, reptiles (other than turtles), barnyard animals, monkeys, kangaroos, and other non-domesticated animals are not considered common household animals.
2. Unique Animals (Not considered for reasonable accommodation except in very rare circumstances): If the student is requesting to keep a unique type of animal that is not commonly kept in households, then the student has the substantial burden of demonstrating a disability-related therapeutic need for the specific animal or specific type of animal. The student would need to submit documentation from a healthcare professional confirming the need for this animal.

1. The FHA does not require a dwelling to be made available to an individual whose tenancy would constitute a direct threat to the health or safety of other individuals or whose tenancy would result in substantial physical damage to the property of others. A reasonable accommodation for an assistance animal may be denied if the specific animal poses a threat that cannot be eliminated or reduced to an acceptable level through actions the individual takes to maintain control of the animal (e.g., keeping the animal in a secure enclosure).
2. Earlham may not limit the breed or size of a dog used as a service or emotional support animal just because of the breed or size but can limit based on specific issues with the animal’s conduct if it poses a direct threat or a fundamental alteration.
3. Earlham may charge for damage an assistance animal causes.
4. If a student violates Earlham’s policy, the accommodation may be revoked or reconsidered and the animal must be removed from the premises.

1. Animal Behavior: ESAs and SAs must be under the control of their owner at all They should be well-behaved, properly trained, and not pose a threat or nuisance to others.
2. Animal Care and Hygiene: Animal owners are responsible for the daily care, feeding, grooming, and sanitation of their Animals should be clean, free of fleas or ticks, and have up-to-date vaccinations as required by local and state regulations.
3. Animal Supervision: ESAs must be kept in the owner’s assigned residential space. SAs are allowed to accompany their owners in all areas of the campus where the general public is allowed, except where their presence may fundamentally alter the nature of a program or activity or pose a direct threat to the health or safety of others.
4. Leashing and Identification: ESAs and SAs must be leashed or safely contained at all times when outside the owner’s assigned residential space. SAs should wear identifiable harnesses or vests that distinguish them as working animals.
5. Cleanup and Waste Disposal: Animal owners must promptly clean up after their animals and properly dispose of waste in designated areas.

Committed to equal access for all members of the campus community, Earlham College has adopted informal and formal resolution procedures providing for prompt, equitable, and impartial resolution of complaints alleging any action prohibited by the ADA or Section 504.

Students with disabilities who have a concern related to equal access are encouraged to reach out to the appropriate office for support (see Section. IV. Responsible Offices). Concerns may be submitted in person, in writing, or electronically. The administrative faculty in the responsible office will evaluate the next steps for resolution.

A.   Confidential Campus Resources

For confidential communication, please contact one of the following on-campus or community confidential resources:

• Health Services:765-983-1328
• Counseling Services:765-983-1432
• Religious Life/Ombudsperson:765-983-1413

B.  Formal Complaints

Students wishing to file a formal complaint regarding disability accommodations should contact:

For the Undergraduate College and the Graduate Programs in Education:

Disability and Accessibility Services
Lilly Library, Room 230
Phone: 765.983.1390
Email: [email protected]

For the Earlham School of Religion:

Office of the Joint Seminaries Registrar
Disability Services Coordinator
Earlham School of Religion
228 College Ave, Richmond, IN 47374
Phone: 765.983.1816
Email: [email protected]

C.  To appeal accommodations decisions or to file a complaint or concern regarding accommodation procedures that remain unresolved after discussing with DAS:

For the Undergraduate College and the Graduate Programs in Education:

Vice President for Student Life & Dean of Students
Earlham Hall #103
Call 765-983-1311
Email [email protected]

For the Earlham School of Religion:

Dean of the Earlham School of Religion
Call 765-983-1689
Email [email protected]

D.  U.S. Department of Education’s Office of Civil Rights

The U.S. Department of Education’s Office for Civil Rights enforces several statutes that protect the rights of beneficiaries in programs or activities that receive financial assistance from the Department. These laws prohibit discrimination on the basis of race, color, and national origin (Title VI of the Civil Rights Act of 1964), sex (Title IX of the Education Amendments of 1972), disability (Section 504 of the Rehabilitation Act of 1973), and age (Age Discrimination Act of 1975).

For further information, visit https://ocrcas.ed.gov/contact-ocr for the address and phone number of the office that serves your area, email [email protected],

or call 1-800-421-3481 / TDD: 800-877-8339.

Disability and Accessibility Services reviews this policy annually. Amendments to this policy are adopted with approval by the Vice President for Student Life and Dean of Students.