Skip to main content
Students clean up the Heller Homestead Park and buildings during Heritage Day. Students are posed for a photo along the creek bed.
Academic & Accessibility Support Center

Service and Emotional Support Animal Policy

What about service or emotional support animals?

It is the policy of Moravian College to comply with all applicable federal, state and local laws regarding the use of service animals on campus.  Under Pennsylvania law, individuals with disabilities who use guide or support animals, or trainers of such animals, are entitled to equal opportunity in all aspects of employment and education, as well as equal access to and treatment in all public accommodations, and any housing accommodation or commercial property without discrimination.  

What is a service animal?

Under the ADA, a service animal is defined as a dog that has been individually trained to do work or perform tasks for an individual with a disability.  The work or task(s) performed by the dog must be directly related to the person's disability. The dog must be trained to take a specific action when needed to assist the person with a disability. For example, a person with diabetes may have a dog that is trained to alert him when his blood sugar reaches high or low levels. A person with depression may have a dog that is trained to remind her to take her medication. Or, a person who has epilepsy may have a dog that is trained to detect the onset of a seizure and then help the person remain safe during the seizure. Service animals are working animals, not pets. Dogs whose sole function is to provide comfort or emotional support do not qualify as service animals under the ADA (www.ada.gov).  Under the ADA, the dog must already be trained before it can be taken into public places. 

Service animals must be allowed to accompany their handlers to and through self-service food lines. Similarly, service animals may not be prohibited from communal food preparation areas, such as are commonly found in residence halls and campus dining facilities.

In situations where it is not obvious that the dog is acting as a service animal, staff may ask only two specific questions: (1) is the dog a service animal required because of a disability? and (2) what work or task has the dog been trained to perform? Staff are not allowed to request any documentation for the dog, require that the dog demonstrate its task, or inquire about the nature of the person's disability.

There is no requirement to document a disability or the need for a service animal.  However, any student registered on campus to take classes who uses a service animal is encouraged to register the presence of the animal with the Director of Accessibility Support.

If a student is a campus resident with a Service Animal, we request that the student register the presence of the animal with the Director of Accessibility Support so that the student can be assigned the most appropriate housing location considering the student’s needs and preferences. Registration also helps to ensure that emergency staff knows to look for service animals during an emergency evacuation process.  A request for housing with a Service Animal does not require documentation.

What are the requirements of service animals and their handlers?

Control

The handler must be in full control of the Service Animal at all times. The animal must never be let out of a residence hall (unless otherwise noted/approved) without being attended and under the control of the handler. As such, when removed from residence halls, the animal must be on a leash, unless impracticable or infeasible due to the handler’s disability. The care and supervision of a Service Animal is solely the responsibility of its handler. The handler is responsible for all actions of the animal and should be in total control and restraint of the animal at all times.

Identification

The ADA does not require service animals to wear a vest, ID tag, or specific harness.

Cleanliness

Cleaning up waste from a Service Animal is the responsibility of its handler. Feces must be removed by placing the waste in a closed container and depositing it in an outdoor waste receptacle (indoor waste receptacles are not appropriate to dispose of animal waste). Any cost incurred by the College to clean up a mess or repair damage to property caused by a Service Animal will be the responsibility of the handler. Handlers must ensure that preventative measures are taken at all times for pest and odor control. Consideration of others must be taken into account when providing maintenance and hygiene to a Service Animal.  Handlers will be liable for damage caused by a Service Animal in the same manner that they are responsible for personal damages to College property.  This includes any and all related costs associated with cleaning and pest abatement relating to the Service Animal.   

Care

  • The animal must be properly cared for and nourished. The handler is responsible for the care and nourishment of the animal.
  • License and Tags: All Service Animals must have an owner identification tag. The dog must have current license and tags from local authorities. 
  • Health: The Service Animal must be in good health. The service animal must have current vaccinations as required by Pennsylvania State Regulations. All service animals must wear a current rabies vaccination tag (if applicable to that animal). 

Residency

  • The animal may reside in all areas of the student’s designated residence.
  • If the handler of the animal takes a vacation, leaves for breaks, or has any other extended leave (more than 24 hours), the animal must be removed from the residence hall.
  • Necessary precautions should be made for Facilities and Residence Life staff to enter the residence hall room when the owner is not present.  Campus staff is not liable if the animal escapes during one of these visits.)
  • The handler of the animal will provide emergency contact to the Director of Housing and Event Management for cases where the handler is not able to care for the animal.

Conduct 

  • All liability for the actions of the animal (bites, scratches, running away, etc.) is the responsibility of the handler.  
  • The handler of the animal is responsible for taking all reasonable precautions to protect the property of the College and its residents.
  • The handler of the animal is solely responsible for any damage to college property caused by the animal. This includes any cleaning beyond that which is routinely done for any room, including, but not limited to, steam cleaning of any carpets, drapes, abatement for fleas or other pests and odor. If furniture requires replacing, this is also the responsibility of the handler. Any respective fees will be posted to the student’s individual student account.
  • The handler is responsible for the behavior of the animal. The animal must not be disruptive or pose a threat to others. The Director of Student Development and/or Director of  Residence Life and/or designee is responsible for making determinations about an animal’s conduct and care within the residence halls. The Chief of Police on campus is responsible for making determinations about an animal’s conduct on all other campus property. If it is determined that an animal is disruptive and/or poses a threat to the campus community, the animal must be removed immediately. Furthermore, the student is accountable for the conduct of the service animal and may be required to go through the student conduct process for the violation committed by the animal. 

Residence life staff will be notified as appropriate of the presence of a service animal.  The student’s roommate(s) will be notified (if applicable) of the presence of a service animal.  Allergies and fear of dogs are not valid reasons for denying access or refusing service to people using service animals. Persons with documented disabilities such as asthma, allergies, or other medical conditions affected by the presence of animals are asked to contact the Director of Accessibility Services.  The person impacted by the presence of an animal must provide verifiable medical documentation and meet with the Director of Accessibility Support to review their request.

Any further questions regarding service animals or their handlers should be directed to the Director of Accessibility Services.

What are emotional support animals or therapy animals?

Emotional support animals or therapy animals are often used as part of a comprehensive treatment plan for mental health. Emotional support animals (ESAs) provide individuals with therapeutic contact in order to improve their physical, social, emotional and/or cognitive functioning and are not considered Service Animals. The rights of people with disabilities to keep emotional support animals are stated in Section 504 of the Rehabilitation Act of 1973, the Fair Housing Amendments Act of 1988, and Title II of the American with Disabilities Act. Emotional support animals are not “pets” but rather considered an accommodation.  Federal policy requires that reasonable accommodation be considered to persons with disabilities an equal opportunity to use or enjoy a dwelling.  An emotional support animal is directly related to the functional limitation of a person’s disability. If approved by the Accessibility Committee, emotional support animals are permitted in the individual’s room within the residence hall. 

The deliberative process required to approve accommodations can take time. Students, especially those residing on campus, are encouraged to put in the request for an emotional support animal as soon as they are aware of the need for this accommodation, preferably at least four (4) weeks prior to the requested date to bring the animal to campus. 

When an emotional support animal is approved, the student will receive a notification via email, with housing cc’d.  The Director of Housing will then follow up with the student to discuss the policies and procedures on having an emotional support animal on campus. Your housing configuration must ensure a safe and appropriate environment respective of the animal’s size and habitat requirements.  Documentation from a veterinarian is required to confirm that the typical dormitory room size is appropriate for the requested animal size and needs.  A student who is approved for an emotional support animal will have housing assignment choices that support the documented needs of both the student and their animal.  Moravian College supports the needs of students covered under ADA, but also supports the laws related to animal welfare and safety under the Animal Welfare Act.  Therefore, Moravian College reserves the right to limit the size of the animal to be compatible with the size of the student’s residence based on the recommendations from the veterinarian.

What are the licensing requirements for a dog or cat that has been approved as an emotional support animal?  

  • Dogs:
    • Proof of up-to-date rabies and distemper vaccinations
    • Proof of sterilization (spaying or neutering)
    • Each dog over four months old must have a valid license and wear it on a collar at all times
  • Cats:
    • Proof of up-to-date rabies and distemper vaccinations
    • Proof of sterilization (spaying or neutering) 

What are the limitations on animals allowed as emotional/therapy animals?

No animal will be approved as an emotional support/therapy animal that does not qualify as an allowable animal under the law.  The following are typically allowable under the law:

  • Domestic dogs (excluding hybrids with wolves, coyotes or jackals)
  • Domestic cats (excluding hybrids with ocelots or margays)
  • Domestic rodents and rabbits
  • Captive-bred species of common cage birds
  • Nonpoisonous snakes, fish, turtles (traditionally kept in the home for pleasure rather than commercial purpose)

Similar to the requirements of service animals, requirements of emotional support animals and their handlers are as follows:

Identification

Identification is not required for emotional support animals, but officials may ask if the animal is a service animal or emotional support animal.

Control

The handler must be in full control of the emotional support animal at all times. The animal must never be let out of a residence hall (unless otherwise noted/approved) without being attended and under the control of the handler. This means that when removed from the residence halls, the animal must be on a leash, unless impracticable or infeasible due to the handler’s disability. The care and supervision of an emotional support animal is solely the responsibility of its handler. The handler is responsible for all actions of the animal and should be in total control and restraint of the animal at all times.

Cleanliness

Cleaning up waste from an emotional support animal is the responsibility of its handler. Feces must be removed by placing the waste in a closed container and depositing it in an outdoor waste receptacle (indoor waste receptacles are not appropriate to dispose of animal waste). Any cost incurred by the College to clean up the mess or repair damage to property caused by the animal will be the responsibility of the handler. Handlers must ensure that preventative measures are taken at all times for pest and odor control. Consideration of others must be taken into account when providing maintenance and hygiene to the animal.  Handlers will be liable for damage caused by an emotional support animal in the same manner that they are responsible for personal damages to College property.  This includes any and all related costs associated with cleaning and pest abatement relating to the animal.   

Care

  • The animal must be properly cared for and nourished. The handler is responsible for the care and nourishment of the animal.
  • License and Tags: All emotional support animals must have an owner identification tag. 
  • Health: The emotional support animal must be in good health. The emotional support animal must have current vaccinations as required by Pennsylvania State Regulations. All emotional support animals must wear a current rabies vaccination tag (if applicable to that animal). 
  • A local veterinarian must be established and maintained.

Residency

  • The animal may reside in all areas of the student’s residence.
  • If the handler of the animal takes a vacation, leaves for breaks, or has any other extended leave (more than 12 hours), the animal must be removed from the residence hall.
  • If the student is traveling on College business for more than 12 hours, the student must meet with Housing to approve a substitute caregiver during their absence.
  • Necessary precautions should be made for Facilities and/or Residence Life staff to enter the residence hall room when the owner is not present.  (The animal must be caged or crated or removed from the room, during the time that campus staff is in the room.  Campus staff is not liable if the animal escapes during one of these visits.)
  • The handler of the animal will provide an emergency contact to the Director of Residence Life for cases where the handler is not able to care for the animal.
  • The animal should be included in your planning for an emergency and/or disaster.  In addition, the handler should have the required transportation that can be used during evacuation drills, recommended by the Animal Welfare Act for the type of animal approved. 
  • Crate Size requirements:  Crate size needs to comply with the animal welfare act regulations which require specifications for crating adult dogs. (https://www.aphis.usda.gov/animal_welfare/downloads/Animal%20Care%20Policy%20Manual.pdf)

Conduct

  • All liability for the actions of the animal (bites, scratches, running away, etc.) is the responsibility of the handler.  
  • The handler of the animal is responsible for taking all reasonable precautions to protect the property of the College and its residents.
  • The handler of the animal is solely responsible for any damage to college property caused by the animal. This includes any cleaning outside that is routinely done for any room, including, but not limited to, steam cleaning of any carpets, drapes, abatement for fleas or other pests and odor. If furniture requires replacing, this is also the responsibility of the handler. Any fees associated with these things will be posted to the student’s individual student account.
  • The handler is responsible for the behavior of the animal. The animal must not be disruptive or pose a threat to others. The Director of Student Development and/or Director of Residence Life and/or designee is responsible for making determinations about an animal’s conduct within the residence halls. The Chief of Police on campus is responsible for making determinations about an animal’s conduct on all other campus property. If it is determined that an animal is disruptive and/or poses a threat to the campus community, the animal must be removed immediately. Furthermore, the student is accountable for the conduct of the emotional support animal and may be required to go through the student conduct process for the violation committed by the animal. 
  • Residence life staff will be notified as appropriate of the presence of an emotional support animal. The student’s roommate(s) will be notified (if applicable) of the presence of an emotional support animal. Allergies and fear of dogs are not valid reasons for denying access or refusing service to people using service animals. When a person who is allergic to dog dander and a person who uses an emotional support animal must spend time in the same room or facility, for example, in a school classroom or a residence hall, they both will be accommodated by assigning them, if possible, to different locations within the classroom or different rooms in the residence hall.  Persons with documented disabilities such as asthma, allergies, or other medical conditions affected by the presence of animals are asked to contact the Director of Accessibility Support.  The person impacted by the presence of an animal must provide verifiable medical documentation and meet with the Director of Accessibility Support to review their request.
  • Any further questions regarding emotional support animal or their handlers should be directed to the Director of Accessibility Services.

What is undue hardship?

Undue hardship is an accommodation which would be unduly costly, extensive, disruptive, or would substantially alter operations of the College. Such accommodations need not be provided. Nevertheless, please note that the College does have the obligation to explore and locate other suitable accommodations which would not constitute an undue hardship if possible. 
 

How does the Fair Housing Act relate to emotional support animals?

The Fair Housing Act, as amended in 1988, prohibits housing discrimination on the basis of race, color, religion, sex, disability, familial status, and national origin. Its coverage includes private housing, housing that receives Federal financial assistance, and State and local government housing. It is unlawful to discriminate in any aspect of selling or renting housing or to deny a dwelling to a buyer or renter because of the disability of that individual, an individual associated with the buyer or renter, or an individual who intends to live in the residence. Other covered activities include, for example, financing, zoning practices, new construction design, and advertising.

The Fair Housing Act requires owners of housing facilities to make reasonable exceptions in their policies and operations to afford people with disabilities equal housing opportunities. For example, a landlord with a "no pets" policy may be required to grant an exception to this rule and allow an individual who is blind to keep a guide dog in the residence. The Fair Housing Act also requires landlords to allow tenants with disabilities to make reasonable access-related modifications to their private living space, as well as to common use spaces. (The landlord is not required to pay for the changes.) The Act further requires that new multifamily housing with four or more units be designed and built to allow access for persons with disabilities. This includes accessible common use areas, doors that are wide enough for wheelchairs, kitchens, and bathrooms that allow a person using a wheelchair to maneuver, and other adaptable features within the units.