Service and Assistance Animal

Applies to: Faculty (including part-time and visiting faculty), postdoctoral scholars, staff and students (including graduate/undergraduate student workers and graduate assistants) employed by University of Southern California and its subsidiaries including Keck Medicine of USC (“USC employees”) and guests on University owned or leased properties. 

1. POLICY

Issued: March 17, 2023
Last Revised: November 3, 2022
Last Reviewed: March 1, 2023

2. Policy Purpose

The purpose of this policy to articulate the conditions under which Service and Assistance Animals are permitted access to University grounds and facilities. This document explains the University of Southern California’s policy applicable to animals owned or used by individuals as Service or Assistance Animals as defined in Section 4. Definitions.

3. Scope and Application

 In accordance with Section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act of 1990 (“ADA”), the Fair Housing Act (“FHA”), and state and local law, USC will accommodate persons with disabilities who require the assistance of a qualified Service Animal or Assistance Animal. This policy does not apply to pets, research animals, or those animals otherwise owned or controlled by the university.

4. Definitions

Term	Definition
Service Animal	Service Animal means any dog or, in limited circumstances, miniature horse, that is individually trained to do work or perform tasks for the benefit of and to accommodate the functional needs of an individual with a disability. Other species of animals are not Service Animals. The work or task performed by a Service Animal must be directly related to the individual’s disability and functional limitations.
Assistance Animal	Assistance Animal means any animal, designated by a qualified medical treatment provider, that typically provides passive assistance to alleviate one or more identified symptoms of an individual’s disability. Assistance Animals are separate and distinct from Service Animals and are generally considered a housing accommodation, allowing equal opportunity to the use and enjoyment of a dwelling.  A nexus must exist between the individual’s disability and the assistance the animal provides.  As described in the Procedure Details. Assistance Animals must stay in the individual’s residence or outdoor areas—they generally cannot accompany the individual on daily tasks like attending class dining, or studying in the library. While Assistance Animals are not limited to dogs, animals that are prohibited by state or local laws including but not limited to animals considered a zoonotic risk are typically not considered a reasonable Assistance Animal accommodation. Typically, the presence of only one assistance animal is approved per student.  Additional health and behavior requirements may be required.
Pet	The University will consider an animal a pet when it does not otherwise meet the definition of a Service or Assistance animal. Pets are not covered by this policy.
Individual with a Disability	An individual with a disability is a person who has a physical or mental impairment that limits one or more of the person’s major life activities.

5. Policy Details

a. Service Animals
The University of Southern California permits the presence of trained Service Animals assisting individuals with disabilities on its campus in areas open to the public, consistent with the provisions of this policy and applicable law.  A Service Animal is generally permitted to be on University property in any place where the animal’s handler is permitted to be, although there are specific locations and activities on University property where all animals are prohibited for health and safety reasons.  Such prohibited areas may include, but are not limited to, the following: 

• Research and teaching laboratories
• Other research facilities where the animal may compromise the integrity of research
• Certain clinical/sterile environments
• Certain food preparation areas
• Mechanical rooms/custodial closets
• Areas where protective clothing is necessary
• Areas where there is a danger to the animal

Exceptions to restricted areas may be granted on a case-by-case basis by the ADA/504 Coordinator, or the Office of Student Accessibility Services, upon consultation with the department/program chair responsible for the restricted area, as appropriate.

A Service Animal must have a harness, leash, or tether unless the handler’s disability precludes use of tethers, or the tether would interfere with the Service Animal’s ability to safely perform its work or tasks. In these cases, the Service Animal must be under the control of the handler (i.e., voice commands, hand signals, or other effective means).  Members of the University community and visitors are prohibited from interfering in any way with a Service Animal or the duties it performs.

Obtaining Documentation for a Service Animal

Faculty, staff, and employed students

Faculty, staff, and USC employed students seeking to bring a Service Animal to work should contact their HR Business Partner or the institution’s Office of Institutional Accessibility’s Interactive Process Center of Expertise (IPCOE) and request use of a Service Animal as a reasonable accommodation because of their disability. To better understand the need for a Service Animal, USC may ask for documentation from a qualified treating provider that explains the need for the Service Animal, the tasks it performs, and to describes the need for the Service Animal as it relates to the employee.

Faculty and staff living in USC housing requesting the use of a Service Animal as a housing accommodation should contact the Office of Institutional Accessibility’s IPCOE to request the use of a Service Animal as a reasonable housing accommodation. If approved and necessary, University Housing may notify other residents within the residential building and/or floor (as well as maintenance and security staff, as needed) that the Service Animal will be residing in an assigned living space. USC Housing and The Office of Residential Education retain the right to relocate the Owner/Handler and approved Service Animal as necessary on a case-by-case basis.

Students
It is strongly recommended that individuals with disabilities who intend to bring a Service Animal into campus buildings notify the University of the need for a Service Animal’s presence in advance of bringing the Service Animal to campus allowing the University to provide the individual relevant information about the campus and any potential challenges. The individual with the disability may be asked whether the Service Animal is needed because of a disability and what work or task the Service Animal has been trained to perform. The appropriate campus unit(s) may work with the individual with the disability to ensure that the individual has the proper information to provide care for the Service Animal, such as identification of relief areas, storage, and emergency care plans.

When a student voluntarily registers their Service Animal with OSAS, the owner will be provided a courtesy document that confirms their right to be accompanied by the Service Animal on campus and, if applicable, USC Housing and the Office of Residential Education will be notified. The student may choose, but is not required, to share the document with members of the campus community. If necessary, University Housing will notify other residents within the housing assignment (as well as maintenance and security staff, as needed) that the Service Animal will be residing in a shared assigned living space. USC Housing and The Office of Residential Education retain the right to relocate the owner and approved Service Animal as necessary on a case-by-case basis.

University Guests and Visitors
It is strongly recommended that guests and visitors of the University with disabilities who intend to bring a Service Animal into campus buildings notify the University of the need for a Service Animal’s presence in advance of bringing the Service Animal to campus allowing the University to provide the individual relevant information about the campus and any potential challenges. The individual with the disability may be asked whether the Service Animal is needed because of a disability and what work or task the Service Animal has been trained to perform. The appropriate campus unit(s) may work with the individual with the disability to ensure that the individual has the proper information to provide care for the Service Animal, such as identification of relief areas.

b. Assistance Animals
An Assistance Animal, owned by an individual with a disability who lives in a residence hall on University property, is permitted in the Owner’s/Handler’s residence hall.  Assistance Animals are generally not allowed in residential rooms not assigned to the Owner/Handler, in any other buildings on University property, nor are they allowed in other controlled spaces on campus.

c. The University reserves the right to deny access to campus, or remove from campus, any Service Animal or Assistance Animal if:

1. The animal is disruptive or out of control and its owner does not take action that is effective to control it
2. The animal is not housebroken (i.e., cannot control waste elimination);
3. The animal poses a direct threat to the health or safety of others that cannot be eliminated or reduced to an acceptable level by a reasonable modification to other policies or procedures; or
4. The owner fails to comply with their responsibilities under this policy.

Generally, federal review standards will be utilized for all Assistance Animal accommodation requests for individuals who participate in Residential Education Programs. USC Housing and The Office of Residential Education retain the right to relocate the Owner/Handler and approved animal as necessary on a case-by-case basis. Should the animal be removed from the premises for any reason, the Owner/Handler is expected to pay for any associated costs to remove and care for the animal and to fulfill their housing obligation for the remainder of the housing contract.

d. Other accommodations

If a faculty member, staff member, or student needs any other accommodations, documentation of the disability and a request for accommodations must be made pursuant to the procedures set forth by the Office of Institutional Accessibility’s Interactive Process Center of Expertise (IPCOE) or the Office of Student Accessibility Services (OSAS), as applicable.

e. Violations of Policy

Any incidence of violations of any University policy may result in immediate removal of the animal from the University and, if appropriate, referral to the Office of Human Resources or the Office of Community Expectations for disciplinary action. While not a typical scenario, if a Service Animal or Assistance Animal is banned from campus, the individual with a disability will have the right to engage in an interactive process to determine if effective participation can occur with other appropriate accommodations.

6. Procedures

Students making requests for voluntary registration of a Service Animal or for an accommodation of an Assistance Animal must direct their requests to the Office of Student Accessibility Services (OSAS) at OSASFrontDesk@usc.edu.

Faculty and staff requests for Service or Assistance Animals must direct their requests to the Office of Institutional Accessibility’s IPCOE by contacting employeeada@usc.edu. For additional information see Service/Assistance Animal Procedures.

Grievance Procedure:
A student who feels that they have been unfairly denied the ability to bring an Assistance Animal to campus may follow the Reconsideration Policy available through Office of Student Accessibility Services. Any individual who feels that they have been unfairly denied the ability to bring a Service or Assistance Animal onto University property, or who feels that they have been unfairly denied the ability to have an Assistance Animal in university housing, may file a grievance through The Office of Equity, Equal Opportunity, and Title IX at 213-821-8298 or email at eeotix@usc.edu

Discrimination, Harassment, and Retaliation
The University prohibits retaliation against any individual for the purpose of interfering with any right or privilege secured by University policy or law, or because the individual makes a good faith report or formal complaint, testifies, assists, participates, or refuses to participate in any manner in an investigation, proceeding, or hearing under the University Policy on Prohibited Discrimination, Harassment, and Retaliation. USC will not take any adverse action, retaliate, or discriminate against an eligible employee or student for requesting or utilizing a Service or Assistance Animal as permitted under this Policy. If an eligible employee or student believes an adverse action has been or is being taken against them for the use or need for a Service or Assistance Animal, the employee or student should contact the Office for Equity, Equal Opportunity, and Title IX by phone at (213) 821-8298 or email at eeotix@usc.edu.

7. Forms

Applicable forms are housed in OSAS and/or OIA. For additional information, please visit:

If you are a student:

Office of Student Accessibility Services

If you are a faculty or staff member:

The Office of Institutional Accessibility and ADA Compliance

8. Responsibilities

Office of Institutional Accessibility and ADA Compliance (OIA), Interactive Process Center of Expertise (IPCOE)

1. Receives and evaluates employee accommodation requests for Service Animals and Assistance Animals as part of the interactive process. 2. Communicates decisions related to Service Animals and Assistance Animals as a workplace accommodation. 3. Securely stores employee documentation, accommodation decisions, and related documents for employee accommodation requests related to Service Animals and Assistance Animals. 4. Manages the interactive process with employee and supervisor(s).

Owner/Handler

1. Ensures that the Service or Assistance Animal does not unduly interfere with or disrupt the routine activities of the work environment, classroom, or residence. The owner must always be in control of the animal. Service or Assistance Animals who are perceived to not be under control of the Owner/Handler are assessed on a case-by-case basis. 2. Is financially responsible for the actions of the animal, including bodily injury or property damage. The Owner’s/Handler’s responsibility covers, but is not limited to, replacement of furniture, carpet, window, wall covering, and the like. The owner is expected to cover these costs at the time of repair. 3. Is responsible for any expenses incurred in cleaning (above and beyond a standard cleaning) or for repairs to University premises, including but not limited to residence halls, that are assessed after the student and animal vacate the residence. The University will bill the student Owner’s/Handler’s student account for unmet obligations. 4. Ensure the cleanup of the animal’s waste, and, when appropriate, must toilet the animal in areas designated by the University consistent with the reasonable capacity of the Owner/Handler. Indoor animal waste, such as cat litter, must be placed in a sturdy plastic bag and securely tied up before being disposed of in outside trash dumpsters. Litter boxes must be placed on mats so that waste is not tracked onto carpeted surfaces. The animal’s waste must be managed to prevent odors from disrupting others in the environment. 5. Is responsible for the overall health and well-being of the animal, including compliance with all state and local laws concerning animals (e.g., registration, vaccinations, and tags). Owners may be asked to provide annual documentation of the health of the animal from a licensed veterinarian. 6. May not leave a Service or Assistance Animal unattended in or on any University property, other than Assistance Animals left in an individual’s University housing for a reasonable period of time.  Animals must be taken with the Owner/Handler if the Owner/Handler leaves campus for a prolonged period of time. A student or employee may not designate another individual to care for their animal. 7. Are responsible for any fees associated with the impounding or boarding of an animal and/or any fees required to secure the release of their animal. 8. Agrees to abide by all other residential policies. An exception to the no-animals policy does not constitute exception to any other policy.

9. Related Information

• USC Student Handbook
• Pets on USC Property Policy
• OSAS: Animals on Campus
• Institutional Accessibility and ADA Compliance: Service and Support Animals
• USC Housing: Can I have a pet?
• Prohibited Discrimination, Harassment, and Retaliation Policy

10. Contacts

Please direct any questions regarding this policy to: