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At UH, too many complications when getting emotional support animals

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Jane Doe is a student at the University of Houston suffering from bipolar disorder.

She is seeking treatment at UH’s Counseling and Psychological Services and got referred to UH Psychiatry, where she was diagnosed and medicated. Jane Doe was struggling with her diagnoses and lack of communication within CAPS prior to the holiday break.

She used her break as a time to think, strategize and reflect on how she could be successful.
One of the things she noticed was how much animals, particularly dogs, grounded her.

She always loved dogs but this seemed like more. However, like many students, Jane Doe lived in an apartment complex that has a strict no pets policy. She mustered up the courage to speak with her therapist about the possibility of being recommended for an emotional support animal.
Her therapist was in full support; she had read studies and believed that Jane could benefit from this type of treatment.

Unfortunately, the therapist did not know the process and told Jane to speak with her psychiatrist.
Jane’s psychiatrist gave her the runaround and referred her back to her therapist.

This time, the therapist was on board but had to tell her director because she had never done this before. Jane, like many college students, acted prematurely and adopted a puppy.

A few days after Jane adopted the puppy, her therapist emailed her to inform her it was against CAPS policy to write letters for emotional support animals.

Jane recommends that you “save your time and your tears and find a good counselor in the community if you need more serious treatment options.”

Jane’s story leads us to question why this policy was not clear and why this accommodation is not supported by our campus administrators.

The rise of mental illness

Approximately 61.5 million Americans, or one in four adults, experience a mental health impairment in any year and one in 17, representing 13.6 million people, live with a serious mental illness, such as depression or bipolar disorder.

The rise of reported mental illnesses has also created an increase in students asking for accommodations.

One of those accommodations is for an emotional support animal or ESA. By their nature, and without training, these animals may relieve depression and anxiety and help reduce stress-induced pain.

Some may be asking, “What exactly is an emotional support animal and how is different than a pet?”

Well, an emotional support animal is not a pet; it is “a companion animal that provides therapeutic benefit to an individual with a mental or psychiatric disability. The person seeking the emotional support animal must have a verifiable disability” at the Michigan State University animal and legal & historical center.

The animal is viewed as a reasonable accommodation under the Fair Housing Amendments Act of 1988 to those housing communities that have a “no pets” rule.

The Fair Housing Act was created to make sure that those with physical or mental disabilities are not discriminated against unjustly. The Fair Housing Act protects against discrimination in university housing and apartments with “no pet” policies.

There has been substantial research across the health sciences that provides evidence of the human health benefits, including physiological, psychological and emotional, that can be derived from human-animal interactions.

However, universities, including UH, do not make this process a walk in the park. The process is full of hoops to jump through that can easily discourage a college student who is seeking help.

To be eligible for an emotional support animal on the UH campus, you must first request accommodations through the Center for Students with DisABILITIES.

If granted approval, you then must meet all of the requirements set by Student Housing and Residential Life. The problem with housing’s policy is that the guidelines are incredibly subjective and lacks quantitative attributes.

For example, students may not have a dog unless it has up-to-date immunizations and is spayed or neutered. This is an issue because students cannot have a dog with records prior to being approved by housing.

But before these parts of the process are even relevant, anyone needing an emotional support animal must obtain a letter from a licensed mental health professional that demonstrates there is a relationship between the practitioner and the patient along with how the animal would help the patient.

Restricting on-campus treatment

Some students may think that they would be able to receive the treatment options they need from their campus counseling center, but this isn’t always the case. Even though in Fall 2018 UH students will be pay approximately $47.36 to CAPS through their student fees, CAPS will have several new policies that restrict extremely beneficial treatment options to students.

One of those policies is that they will “NOT provide letters for emotional support animals.” However, this policy is obviously not one that is communicated amongst all staff members at CAPS. It also does not act in accordance with the U.S Department of Education guidelines as listed in Section 504 regulatory provision at 34 C.F.R. 104.3(j)(2)(i).

The Section 504 regulatory provision defines a physical or mental impairment as “any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems: neurological; musculoskeletal; special sense organs; respiratory, including speech organs; cardiovascular; reproductive; digestive; genito-urinary; hemic and lymphatic; skin; and endocrine; or any mental or psychological disorder, such as mental retardation, organic brain syndrome, emotional or mental illness, and specific learning disabilities.”

This act also mandates that colleges must accommodate individuals accordingly.

The Housing and Urban Development policy on emotional support animals has been on the books since 2013, and studies on emotional support animals have been a topic of public debate since at least 2010.

For our University to have unclear policies and protocols within a professional, fee-funded institution for at least four years is unacceptable. Students should utilize the services they pay for and should also be holding them accountable for their actions.

When comparing UH’s policy and guidelines regarding emotional support animals, the University of Texas is miles ahead of UH. UT has clearly stated definitions and policies that are laid out on their policies webpage.

UT does not let questions about mental health go unanswered on their webpage and lays out all relevant information and policies to allow for transparency for the students they serve.

Delaney Catlettstout is a political science senior and can be reached at [email protected]

2 Comments

  • Powerful, well-written piece. Can CAPS just decide to opt out of federal protections for students? I think not!

  • SHRL allows for the use of emotional support animals, 2.2.2 “Student Housing and Residential Life will allow service and emotional support animals in University Housing facilities where animals would typically not be permitted.” A google search of UH service animal will populate several links and the information is found readily here: http://www.uh.edu/housing/information-guide/housing-resource-guide/index.php under “Service and Emotional Support Animals”

    SHRL makes the requirements very clear cut for dogs and cats, as well as list out what the process is to have that animal in a SHRL facility walking the reader through the process step by step. If we evaluate the requests by SHRL they don’t seem subjective and in fact asking for shot records seems to be very quantifiable as that provides exact dates and numbers relating to the medical history of the animal. The basis for the request of the relationship and why the animal is needed follows state and federal statutes they’re allowed to inquire about.

    As for CAPS they don’t have the ability to prescribe, as noted Jane Doe went to UH Psychiatry to receive the diagnosis and prescribed medication. CAPS can really only advise and council, the request to have a third-party certification doesn’t appear to violate any of the provided documented laws or statutes. Section 104.3(j)2(i) is a definition within a statute and I’m not sure I see how they don’t act in accordance with a definition. UT’s site appears to provide the same information as the aforementioned link I provided. So I’m not sure how they’re miles ahead.They appear to simply publicize the text on a webpage as opposed to publicize it in a downloadable PDF.

    The University of Houston goes far above what is legally required by the state
    statutes found here: http://gov.texas.gov/disabilities/resources/assistance_animals

    The University appears to be entirely accommodating in the way that they handle it. Albeit it seems to me that maybe the experience and process is not as efficient or customer service oriented as it possibly could be. It seems to me that maybe a dialogue should be opened about making the process a bit more customer service
    friendly with staff being a bit more trained and information being a bit more readily available. All relatively low cost “fixes” if addressed properly with the appropriate administrative personnel here at the University.

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