A Big Ten Leadership Approach to Service Animal Policy Development in Higher Education

Abstract

There is a deficiency in scholarly research on higher education service animal policy that has created definitive gaps in how disability services office (DSO) directors approach policy development and how higher education institutions (HEIs) ensure access for service animal handlers. This qualitative research study aims to narrow these gaps by investigating the Big Ten Academic Alliance (Big Ten) DSO directors’ approaches to service animal policy development and exploring how federal and state legislation influence service animal policies. Participants in this study were five DSO directors from Big Ten institutions in the United States who participated in semistructured interviews. Findings reveal four themes associated with the approach Big Ten DSO directors take when developing and implementing service animal policies: (a) the influence of federal and state legislation, (b) transformational leadership, (c) social justice, access, and equity, and (d) involvement of institutional stakeholders in policy development.

Keywords

service animal policy disability service office directors transformational leadership social justice federal and state disability legislation

In the United States, higher education system, 19.4% of undergraduate students identify with disabilities (U.S. Department of Education [DOE], 2019). Through the implementation of mandates from federal and state legislation, higher education institutions (HEIs) have charged disability service offices (DSOs) to serve this expanding community of students. DSOs assist students with disabilities by implementing reasonable accommodations and services that ensure equal access to curricular and co-curricular environments. The use of service animals within the campus environment is one reasonable accommodation that has proliferated at HEIs in recent years (Huss, 2010). Service animals have been granted full access to nearly every facet of the HEI environment through federal civil rights legislation like the Americans with Disabilities Act of 1990 (ADA), the Americans with Disabilities Act Amendments Act of 2008 (ADAAA), Section 504 of the Rehabilitation Act of 1973 (Section 504), and the Fair Housing Act of 1968 (FHA; McCombs & Kiracofe, 2022). In addition to these federal policies, some state governments provide additional protection for service animals and service animals in training through state laws (McCombs & Kiracofe, 2022, 2023; Wisch, 2021).

The U.S. Department of Justice (DOJ) has defined service animals under Title III (Title III) of the ADA, clarifying that a service animal is a dog or a miniature horse “that is individually trained to do work or perform tasks for the benefit of an individual with a disability” (Americans with Disabilities Act [ADA], 1990, 28 C.F.R. § 35.104). Service animals have been trained to assist with a wide variety of disability-related conditions (i.e., sensory, mobility, neurological, chronic health, and psychological impairments), allowing for tasks and work to be very broad if they directly relate to individuals’ conditions (McCombs & Kiracofe, 2022; Sidhu, 2009; Von Bergen, 2015). The ADA has provided guidance for HEIs and other public entities (i.e., grocery stores, museums, restaurants, etc.) when responding to handlers with service animals seeking services within their spaces (McCombs & Kiracofe, 2022). Following guidance from the ADA on the legitimacy of service animals, only two inquiries can be asked of a service animal handler when it is not apparent what tasks or work the service animal has been trained to perform: (1) Is the animal required because of a disability? and (2) What work or task is the animal trained to perform? (ADA, 1990, 28 C.F.R. § 35.136[f]). If an animal meets service animal criteria per the ADA, then the animal is also exempt from any HEI policies prohibiting animal access at the institution, such as a no-pet policy. Hence, a service animal is allowed to accompany its handler in all HEI environments, except for spaces that can cause harm to an animal (i.e., boiler rooms, metal, and wood shops, etc.; Von Bergen, 2015).

In response to federal and state legislation that protects service animals, handlers, and HEIs, several HEIs pursued self-studies leading to the formulation of campus policies and procedures. One such collective of HEIs that swiftly responded to federal and state legal activity was the Big Ten Academic Alliance (Big Ten). As the nation’s preeminent, 50-year-old model for effective academic and leadership collaboration among the research universities in the corollary Big Ten Athletic Conference, the Big Ten currently has 14 member institutions. All member HEIs are flagship, research-one universities located from New Jersey in the East to Nebraska in the Midwest; the Big Ten will expand to 16 members in 2024 with the addition of two universities in California. Big Ten universities have developed policies and procedures that provide institution-wide guidance to service animal handlers and to other institutional stakeholders who may interact with service animals. Institutional service animal policies can provide guidance in the form of procedures related to restricted areas, removal of service animals, interactions with service animals, evaluation of service animal requests, and grievances related to service animals (Purdue University, 2021; University of Nebraska-Kearney, 2015). However, some believe federal and state legislation on service animals to be ambiguous regarding policy implementation. Huss (2010) commented that there is a deficiency in the clarity of federal and state laws and institutional policies that pertain to service animals. These ambiguities and weaknesses in legislation and institutional policies have plagued handlers by creating additional barriers that prevent them from accessing many facets of life with their service animals. Furthermore, such flaws in federal and state legislation cause HEIs in the Big Ten and elsewhere to question the parameters of the policies developed at the institutional level.

DSOs’ guidance on service animal policy development is typically voiced through the DSO directors. As institutional leaders, DSO directors provide knowledge, best practices, advocacy, and guidance on federal and state legislation to ensure all aspects of the institution are accessible and inclusive for all institutional stakeholders (Evans et al., 2017). A critical responsibility of the directors includes interpreting federal and state disability legislation related to service animals. DSO directors are integral to institution-wide compliance with federal and state disability legislation. In addition to policy clarifications and enforcement, as leaders at their institutions, they share their visions of equitable and inclusive environments through their daily work with students and campus partners and the implementation of disability policies and practices (Evans et al., 2017).

Purpose Statement

Prior research on this topic has mainly focused on litigation related to service animals, leaving a gap in the literature regarding how DSO directors provide leadership in developing and implementing institutional policy. Additionally, there is little knowledge of how Big Ten DSO directors navigate federal and state legislation and institutional policies regarding service animals. This qualitative study explores the leadership roles Big Ten DSO directors fulfill in developing institutional policies and procedures for service animals within HEI environments, the Big Ten having been selected because of its forerunning efforts in service animal policy development. This study also examines how DSO leaders interpret and implement federal and state legislation during the development of service animal policies at Big Ten institutions.

Research Questions

Two general assumptions guided the research. The first was that HEI service animal policy is strongly influenced by the interpretation of federal and state policy, and the second was that DSO directors perceive themselves as institutional leaders on service animal policy. This study was guided by two research questions:

Research Question 1: How does federal and state legislation influence service animal policies at Big Ten HEIs?

Research Question 2: How do Big Ten DSO directors perceive their leadership roles in the development of higher education service animal policies?

Literature Review

The undergraduate disabled (see Note 1) population is continually increasing across the higher education landscape, with national statistics reaching 19.2% (DOE, 2019), an increase from 11.1% in 2011-2012 (National Center for Educational Statistics, 2015). This surge in the disabled student population has yielded an influx of service animals on HEI campuses throughout the nation (Huss, 2010). Huss (2010) estimated that in 2010, there were between 10,000 and 30,000 service animals in the United States. Reddin (2020) went on to share that service animals assist individuals with tasks related to physical or sensory impairments, autism spectrum disorder, neurological disorders, chronic health conditions, and mental health conditions.

As students with disabilities enroll in higher education, they can self-identify with DSOs to determine the best access solutions to remove barriers encountered in HEI spaces. It is important to note that according to federal policy, students with service animals are not required to self-identify with DSOs. However, handlers are highly encouraged to do so by DSOs to aid with navigating campus and the various barriers they may experience in higher education (McCombs & Kiracofe, 2022). This encouragement has led to an inflation of students with disabilities seeking services that have prompted institutional leaders to consider disability-related access in all facets of HEIs, including policies, procedures, architecture, learning, and programming (Hammill et al., 2019).

Federal Legislation and Service Animals

In HEI environments, individuals with disabilities are protected under four federal civil rights laws: ADA, ADAAA, Section 504, and the FHA. These laws provide equal access through accommodations, services, and protection from disability-related discrimination. In 1974, the United States established Section 504 as the first civil rights law prohibiting individuals with disabilities from being discriminated against by any educational institution receiving federal assistance (Zirkel, 2010). Zirkel (2010) noted that service animals are not expressly discussed in Section 504; however, the U.S. Department of Education’s (DOE) Office for Civil Rights (OCR), which enforces Section 504, opined the following interpretation:

If not allowing a student to bring a service dog into the classroom would effectively deny the student the opportunity, or an equal opportunity, to participate in or benefit from the education program, then the recipient school would be in violation of Section 504 and its implementing regulation. (U.S. Department of Education Office for Civil Rights, 1991, p. 1)

The ADA is a comprehensive federal civil rights law prohibiting discrimination against individuals with disabilities (ADA, 1990, § 12101). Under Title II of the ADA (Title II), individuals with disabilities are granted equal access to any public entity, including any state HEI (Huss, 2010; McCombs & Kiracofe, 2022). McCombs and Kiracofe (2022) shared that Title III of the ADA entitles individuals with disabilities to any place of public accommodation, including private HEIs. Both public and private HEIs are required to modify policies, practices, and procedures to permit the use of a service animal as a reasonable accommodation under Title III regulations unless allowing a service animal as an accommodation would constitute a fundamental alteration or undue burden to the institution (Huss, 2012; McCombs & Kiracofe, 2022; Zirkel, 2010).

The ADAAA has broadened the scope of the ADA by expanding the definition of disability and making it easier for individuals with disabilities to seek federal protection (Von Bergen, 2015). Von Bergen (2015) stated that the emphasis of the ADAAA is not to determine if an individual is disabled but rather to determine if discrimination has occurred. The ADAAA impacted service animals by setting a precedent in defining what animals can be considered service animals and opened the definition to include miniature horses and dogs (Von Bergen, 2015).

The FHA is federal legislation enforced by the U.S. Department of Housing and Urban Development (HUD). The FHA provided clear guidance to housing providers on arranging reasonable accommodations, which included service animals, so all individuals have an equal opportunity to use and enjoy the dwelling (McCombs & Kiracofe, 2022; Powers, 2014). The FHA also provided a mandate that permitted service animals in dwellings, regardless of no-pet policies, which could potentially deny animals within housing spaces (McCombs & Kiracofe, 2022).

Service Animals and No-Pet Policies

In some cases, HEIs have developed and enforced other institutional policies that can cause issues and barriers for disabled handlers, such as no-pet policies. No-pet policies can restrict animals from campus by establishing unwelcoming environments for handlers and their service animals (Von Bergen, 2015). According to Salminen and Gregory (2018), disabled handlers’ educational experiences cannot be restricted due to no-pet policies. Waivers to no-pet policies are often provided to students with service animals, allowing them to access institutional housing and campus buildings. Even with federal and state legislation, and institutional policies allowing disabled handlers access to HEIs, individuals may still face frequent occasions where they are denied access and discriminated against while on campus by stakeholders unaware of the HEIs service animal policies and federal and state legislation (Huss, 2010; Mills, 2017).

Moving the Needle: Disability Services and Leadership

Traditionally, DSOs are influenced by the various philosophical foundations and institutional roles of the administrative units in which they are set. Nevertheless, DSOs have dualistic relationships between student affairs and academic affairs (Harbour, 2009). DSOs must work closely with both units to ensure institutions provide equitable experiences for students with disabilities (Harbour, 2009). Harbour (2009) has shared that disability access is an institution-wide issue, and DSOs must lead in cultivating collaborative partnerships between academic affairs, student affairs, and administration, as the primary responsibility of DSOs is to ensure access to academics, university housing, and extracurriculars. The Association of Higher Education and Disability (AHEAD) and the Council for the Advancement of Standards in Higher Education (CAS) have provided guidance and professional standards for DSO practitioners that further define the critical knowledge and skills needed to serve students with disabilities and to cultivate socially-just HEIs (Evans et al., 2017). AHEAD’s guidance has provided direction for DSO and HEI leaders in redesigning institutions to be as accessible as possible (Strauss & Sales, 2010). DSO directors are consistently being influenced by general disability research informed by models of disability and by external (e.g., legislation, societal attitudes, etc.) and internal (e.g., disability studies, budget constraints, etc.) pressures (Evans et al., 2017; Harbour, 2009). DSO directors continuously need to consider many concerning barriers (i.e., access to the HEI and collaboration between academic affairs and student affairs) as they lead HEIs closer to equitable and accessible policies and practices. Harbour (2009) argued that DSO directors must be involved in institutional strategic planning and policy development, as they are the most familiar with disability-related legislation and the need to provide access for all stakeholders at HEIs.

Theoretical Underpinnings

This study used a multidimensional lens to investigate how Big Ten DSO leaders approach service animal policy development by layering dimensions of transformational leadership theory (TLT) over elements of the social justice model of disability (SJMD). The SJMD not only complemented TLT but also extended transformational leadership theory into the field of disability services. Transformational leaders influence “by raising our level of awareness, our kind of consciousness about the importance and value of designated outcomes, and ways of reaching them” (Burns, 1978, p. 20). Adapted from Bass’s (1985) TLT model, Bess and Dee (2012) discussed four main dimensions of transformational leadership: (a) charisma, where leaders illuminate respect, trust, and confidence, thus inspiring followers; (b) inspiration, where leaders foster the ability to communicate a vision; (c) intelligence, where leaders provide intellectual stimulation and resist the status quo; and (d) interpersonal skills, where leaders focus on the holistic self and individual needs. At the core of the SJMD is a desire to dismantle the physical, attitudinal, and societal barriers obstructing access for the disabled community (Evans et al., 2017) while also conceptualizing the social oppression of the disabled community through civil rights legislation and mandates (Shakespeare, 2010). Evans et al. (2017) provided three primary components of the SJMD framework: (a) a concentration on privilege and oppression; (b) an “emphasis on diversity and intersectionality of the disabled individual’s experiences, roles, and identities” (p. 72); and (c) an objective of a purposeful educational mission (Bell, 2013; MacKinnon et al., 2004). Together TLT and SJMD provided a foundational structure that critically reflected the strategic components of transformational and sustainable policy development in higher education.

Method

Design

This study was guided by a qualitative exploratory design to further understand service animal policies at HEIs. The research questions were focused on two key areas: (a) the influence of federal and state legislation on HEIs’ service animal policies and (b) DSO directors’ influence on institutional service animal policies. Data were collected from participants through a virtual semi-structured interview. After the interviews concluded, the researcher’s collected data were analyzed using a six-phase process of theoretical thematic analysis (Attride-Stirling, 2001; Braun & Clarke, 2006) that incorporated TLT and SJMD as theoretical and conceptual frameworks.

Participants

This study recruited participants from Big Ten HEIs to better understand how DSO directors provide leadership on service animal policy development. HEIs in the Big Ten Academic Alliance were the sole focus of this study, as the Big Ten is the largest collective of premier research universities in the nation. The DSO director is the HEIs leader in disability services and the most knowledgeable on disability-related policy, legislation, case law, and best practices. Potential participants were identified through searches of Big Ten institutions’ DSO websites, which identified the directors’ contact information. An initial personalized email was sent to each DSO director requesting participation in the study. While 8 out of the 14 Big Ten DSO directors originally responded to the recruitment email, only five directors engaged in the study, a 35.7% recruitment rate. Each participant was provided a pseudonym to ensure their anonymity.

Data Collection

The data collection followed a thorough interview protocol, where prior to the semistructured interviews, participants completed written consent forms, stating their participation was voluntary and knowing that their responses would be recorded and anonymous. Each participant individually participated in a 45-min virtual interview with the first author. All interviews were recorded and stored in the Box platform, where access was only shared with the authors. Each interview consisted of 10 semistructured questions, which allowed participants to share their experiences and perceptions pertaining to developing and implementing their institutions’ service animal policies.

Data Analysis

Two authors utilized a six-phase process of theoretical thematic analysis (Braun & Clarke, 2006; MaGuire & Delahunt, 2017). The first author began the data analysis process by transcribing each of the five participant interviews verbatim with verbal and nonverbal utterances. To check for accuracy, become familiar with the data, and identify themes using open coding, each orthographic transcript was read and reread. The first author developed and implemented an analytical rubric after reviewing the interview transcripts. Within the analytical rubric, four characteristics of Bass’ (1985) model of TLT (i.e., charisma, inspiration, intelligence, and interpersonal skills) and three characteristics of SJMD (i.e., privilege and oppression, diversity and intersectionality, and educational mission) were identified, and criteria for meeting each characteristic were developed. The analytical rubric used 21 theory-driven codes from the seven theoretical characteristics within low, medium, and high levels to determine the relevance of participant responses based on the criteria of each characteristic to the research questions.

The second author reviewed the transcripts and the analytical rubric to become acquainted with the data and ensure the analysis process was thorough, inclusive, and comprehensive. This process provided a 94.15% interrater reliability. To ensure the credibility of the data sets, the first author used member checking by providing participants with the transcription of the interviews to check for inconsistencies in statements and allow for feedback and additional information they would have liked to share. Using a latent approach to theoretical thematic analysis, two authors took a constructionist perspective to theorize the sociocultural contexts of data (Braun & Clarke, 2006). They applied the analytical rubric by separately coding each segment of data relevant to the two research questions. After each author completed the coding of the entire data set, they compared codes to ensure the accuracy and validity of the coding process. The first author gathered all relevant data associated with the themes and then checked the themes against the coded data set, ensuring the themes were logical and valid.

Results

Given that an exhaustive literature search unveiled that there are no extant studies examining service animal policy development and leadership approaches to such policy development, the results of the current investigation are forerunning. The influence of federal and state legislation emerged as the single theme associated with the first research question. Three themes emerged in response to the second research question: (a) transformational leadership, (b) social justice, access, and equity, and (c) involvement of institutional stakeholders in policy development.

Influence of Federal and State Legislation on Leadership and Service Animal Policy

The influence of federal and state legislation was a guiding theme for participants as they approached service animal policies at their institutions. Participants from each institution shared that federal and state legislation guided and influenced their implementation of policy and supporting disabled students and those using service animals on campus. Participant A shared: “Our institutional policy is very dependent on what . . . the ADA states, what the FHA states, what [the] HUD states in terms of . . . how we create procedures around service animals.”

Participant D added that federal and state legislation “. . . has been the main driver in terms of how we serve students that are utilizing service animals on campus.”

Participants C, D, and E mentioned that state laws also guide the institutions’ service animal policies and response to service animals in training in the campus environment, where Participant C communicated, “You clearly have to understand what the state laws say about service animals in training ‘cause it’s a really unique aspect; every state is very different that way, if they’re recognized or not.” When reflecting on the role of the DSO and how legislation guides the department’s daily approach to service animals on campus, Participant D shared:

I wish that we were more of a proactive office than a reactive compliance-based office, but there is that component to our work, and so, we follow . . . federal law very closely when it comes to how are they defining service animals? What is it that a service animal is designed for?

Transformational Leadership

Transformational leadership was a theme throughout participants’ statements and provided a comprehensive understanding of how DSO directors approached and responded in their leadership roles to service animal policies. Bass’s (1985) four dimensions of transformational leadership theory were coded 281 times in statements (n = 205) from all five participants in this study.

Charisma

All five participants provided statements that illuminated charisma in their leadership approach to service animal policies. The language in 32.2% of participants’ remarks illustrated the constructs of respect, trust, and confidence. When asked about their role in developing service animal policies at their institution, Participant A shared:

Our office [DSO] is very much involved in any policy that’s put in place that might affect or have impact on somebody with a disability, and that that would continue forward if we’re going to edit or modify the service animal policy.

Participant D also discussed their role as the driver of the service animal policy and stated:

I would like to see it [service animal policy] live outside of our office, but it really is something that I know no one else on campus cares about nearly as much as I do, so I think it really is my role as leader of the disability services office to continue to push this work forward and make sure that other campus partners are aware of the need for a policy.

Inspiration

Each participant provided comments that showed inspiration through their ability to communicate a vision for inclusive practices for service animals on campus. Inspiration was apparent in 43.9% of participants’ statements which indicated a commitment to a shared vision for the institution and the use of language that challenged stakeholders to be innovative problem solvers. The inspiration code was seen in four of the five participants’ responses related to how they have provided leadership when collaborating with campus partners to develop service animal policies at their institution. Participant A shared that they invite critical stakeholders with expertise on service animals into the room when developing service animal policy, stating that they take:

. . . a project management style approach . . . when we’re reviewing these policies, breaking out into smaller working groups, reviewing all current case law . . . policies, and procedures of past, that the institution has implemented before, in order to move forward with whatever policy or procedure, it is . . . that we’re working on.”

Participant D discussed how campus stakeholders are critical in making the service animal policy work and allowing service animal handlers access to all facets of the institution:

You know. . .I think that our campus partners are key to making this work because, again, policy or no policy, if our police, if our bus drivers, if our student center staff, if our faculty have no clue how to interact with an individual that’s using a service animal, there isn’t a policy in the world that’s going to make a difference in how that individual perceives their experience at [HEI]. . . and how frustrating they feel in their everyday life about barriers that they’re facing just trying to be out and about in the world.

Intelligence

The code for intelligence was expressed in 31.7% of participants’ comments, as DSO directors provided intellectual stimulation for institutional stakeholders related to service animal policies. Participants challenged current policy structures and offered language that reshaped and provided solutions to institutional practices related to service animals on campus. The intelligence code was seen in four of the five participants’ responses related to the main procedures within their institutions’ service animal policies. Participant A shared insight into procedures related to service animals in training, which is guided by state legislation and not federal policy, where they voiced:

I think that where it gets a little bit messy is when we have service animals in training. . . and then, of course, when you have. . .a two or three-month-old puppy who’s in training. That’s when the lines get blurred a little bit, but that’s where it’s important to just have that interactive process in those conversations that we’ve had in the past. . .to mitigate that as much as possible.

Participant C commented on the grievance process for service animal handers if their service animals are removed or if the handlers experience access issues or discrimination on campus, and expressed that the institution does:

. . . have a grievance process in place for anybody that has a public right to accommodation, which is what a service animal is, and we know there’s not a requirement that a service animal be registered on our campus. We do make that available because, again, it provides some assurance to the handler that it’s recognized, and they have someone they can go to if they run into a difficulty.

Interpersonal Skills

Interpersonal skills were coded in 29.2% of participants’ statements, where the participants focused on the holistic self and individual needs. Interpersonal skills were coded in statements demonstrating verbal, listening, written, and nonverbal communication skills. When asked the question related to the participants’ perceptions of institutional policy influencing the experiences of individuals with service animals, three of the five participants provided responses coded as interpersonal skills. Participant B discussed the campus culture around service animals, where they stated, “We haven’t had any concerns or complaints from my perspective. I think that . . . in general, the culture around respective service animals is pretty positive.” Participant D responded to the same question with a focus on a deficiency in institutional stakeholders’ knowledge and training on service animals, where they discussed that:

No matter what policy we have on the books, formal or informal, if campus staff, faculty, and other students aren’t trained on what a service animal is, how you act around a service animal, or the rights of somebody who’s utilizing a service animal, a policy means absolutely diddly squat because that person is still going to have a poor experience because they’re still gonna be questioned unfairly, told they can’t come into a space, somebody’s gonna try and pet their dog.

Social Justice, Access, and Equity

Social justice, access, and equity emerged as critical theme in all five of the participants’ responses. The three components of the social justice model of disability, (a) privilege and oppression, (b) diversity and intersectionality, and (c) educational mission, were coded in 161 statements (n=205). The emergence of the social justice, access, and equity theme provided a deeper understanding of the conceptual framework and the philosophy DSO directors have when developing and implementing equitable service animal policies.

Privilege and Oppression

The code for privilege and oppression was expressed in 13.2% of participants’ comments. Privilege and oppression was apparent when participants used language that demonstrated the illumination of one of the four oppressive qualities of disabled individuals: pervasive, restrictive, hierarchical, and internalized (Bell, 2013). In response to the interview question related to the participant’s perception of institutional policies influencing the experiences of service animal handlers, Participants A, D, and E had similar responses. Participant A shared, “I would say, big time. I think that whatever policy an institution puts out, regardless if it’s service animals or something related . . . it’s always going to impact experiences that folks have on campus.” Participant D responded with:

So, for me, a formalized policy is just really a starting point . . . it’s a way to serve as some recognition of, this is important, people with disabilities are important, this segment of the population of people with disabilities is important, but it’s just, it’s a floor to start working from, and . . . to me, it’s just the legitimization of things that we’re already doing and . . . an environment that we’re already trying to foster.

Diversity and Intersectionality

The code representing diversity and intersectionality was conveyed in 15.1% of participant comments, emphasizing diversity and intersectionality within a disabled individual’s experiences, roles, and identities. When asked how the participants’ institutions have supported or not supported service animal handlers, all five responded with statements pertaining to diversity and intersectionality. Participant B responded with:

I think that if [service animal handlers] were to experience anything on our campus, or, or within our purview, obviously we would, you know, go to bat for them, and try to figure out who needs the education, to make sure that we’re doing the right thing from a compliance standpoint, but also ethically.

Participant A shared a view related to other types of animals on campus that may impact a service animal handler’s experience at the institution: “I think that there’s different policies and procedures in place for those different types of animals. so, I can’t really think of a downside for folks who are using service animals specifically, on our campus.”

Educational Mission

The educational mission code was expressed in 50.2% of participants’ responses, revealing disability as a critical objective of a purposeful educational mission. Participant statements were coded when participants included statements incorporating dimensions of social justice advocacy in education, including supporting disabled students, educating disabled and non-disabled stakeholders on disability oppression, cultivating environments that promote access and advocacy, and changing institutional policies and structures supporting the oppression of the disabled community (MacKinnon et al., 2004). When participants were asked how they provide leadership when working with campus partners when developing service animal policies at their institutions, four of the five participants’ statements reflected a strong educational mission. Participant C stated they approached working with campus stakeholders “. . . really from a . . . social justice model of policy, an attitude of inclusion.” Participant B provided feedback on how their DSO educated the campus community on service animals:

I mean, we spend most of our time . . . creating and distributing educational materials that kind of help guide those with questions when they interact with an animal in their environment, right? Like somebody walks into your classroom or office with a dog, what do you do? Right? Here are the two questions you can ask; here’s who you can call for help; here’s . . . you know, what you should . . . permit them to say and consult, versus telling them to leave before you know what the facts are, so really our office is more on the education side.

Participants were asked how other HEIs or national organizations guided their role in developing service animal policies. Four of the five participants responded with language related to where they received service animal guidance. Two participants shared that they consult with the Big Ten DSO director group. One participant shared that they received guidance from AHEAD on the nuances of service animals. One participant shared that they received guidance from other institutions on communicating the service animal policy to campus stakeholders.

As a reflection, Participant C shared, “I think it has played a major role in staying grounded and understanding what others are doing and how they approach it.” When asked how participants perceive institutional service animal policy influencing handlers’ experiences at their institution, Participant C shared, “I think it provides them with a baseline of understanding of their rights. How the institution recognizes the right to have a service animal on campus, in identified places, public places.” Participants D and E provided feedback by sharing that their DSOs provide training to departments and distribute educational materials to campus stakeholders. Participant E shared:

So, the folks that are more open to the public are the ones that were really looking for guidance and support . . . and help, especially because many of them are staff or . . . frontline staff, student workers; so constantly changing . . . and what do you do when someone just shows up with an animal, right? . . . So, I think in the training materials that we put together, certainly we’re pulling, directly from the ADA and guidance, in terms of the questions that you can ask someone coming in.

Participant D stated that:

We wanted to make sure that they felt empowered to be able to ask a couple of questions, and so again, we had just these little, they’re not much bigger than the size of a business card, they’re a little bit bigger than that, they have a picture of a dog, and here’s the questions you can ask, plain and simple, and then our information on the back of where can you call for more information.

Participant D went on to share:

So, we’ve really tried to hit some of those high visibility groups, where students or members of the public may be interacting, to try and do some very targeted training around, this is what you can and cannot do when it comes to individuals that have an animal.

Involvement of Institutional Stakeholders in Policy Development

Participants shared similar experiences related to service animal policy development. Three participants shared that their institutions’ service animal policy was developed before they arrived at their HEIs. Additionally, these participants indicated they did not have a role in developing the current service animal policies. Another participant revealed that after stepping into their position, they had the opportunity to revisit the institution’s service animal policy to make needed revisions to the language and procedures. Yet another participant shared that their institution does not have a formal service animal policy, but they were interested in developing a policy after the interview.

Participants provided further insight into other institutional stakeholders that assisted in developing their institutions’ service animal policies and made it clear that there is a high need for campus partners with a stake in the policies to have a seat at the table. Four participants pointed out that their institutions’ ADA coordinators would be key partners or drivers behind the service animal policies. Participant D communicated that key partners developing a service animal policy were “. . . residence life . . . our police department . . . somebody that’s in the ethics and compliance area, our ADA coordinator . . . some representation from the academic side . . . .” General Council was another critical partner that participants agreed had a high stake in the service animal policy process. Participant A added that the “policy organization unit” would need to be involved in vetting and signing off on the service animal policy to make it formal. Participant B shared that whether the stakeholder is “. . . a permanent member of a policy renewal team . . . or people that consult . . . you know they’re going to think about everybody from the transportation providers, facilities managers . . . the academic affairs folks, that are going to encounter animals in their spaces.”

Discussion

This exploratory study aimed to identify how federal and state legislation influenced service animal policies and how DSO directors perceive their leadership roles when developing institutional policies and procedures for service animals within their HEI environments. Four themes emerged related to the two research questions: (a) the influence of federal and state legislation, (b) transformational leadership, (c) social justice, access, and equity, and (d) involvement of institutional stakeholders in policy development.

How Do Federal and State Legislation Influence Service Animal Policies at Big Ten HEIs?

The study revealed that federal and state legislation greatly influenced service animal policies at Big Ten HEIs. As a critical theme of the overall study, participants shared that legislation was the foundation and overarching authority of institutional service animal policies. The study showed that when developing institutional policies, Big Ten DSO directors mirror what federal and state law asserts regarding definitions, the scope of coverage, and the legitimacy of service animals and service animals in training. As the study revealed, the Big Ten DSOs were compliance-based and ensured the institutions were following and implementing the regulations that federal and state laws set regarding service animals in places of public accommodation. This is in line with prior literature on DSOs in that their primary role is to ensure access to the academic environment (Harbour, 2009).

How do Big Ten DSO Leaders View Their Leadership Roles When Influencing Service Animal Policy?

The study also revealed that the five Big Ten DSO director participants were transformational leaders blazing a trail for social justice, access, and equity for disabled students and service animal handlers on their campuses. Harbour (2009) discussed DSO directors’ influential role in policy development due to their knowledge and expertise regarding legislation when developing inclusive policies that can influence the disabled experience. The findings from the study aligned with Harbour’s (2009) points on DSO directors, where participants shared their roles in shaping institutional policies and protecting the interests of legitimate service animal handlers.

The three key themes that emerged from this study that correlated with the second research question were (a) transformational leadership, (b) social justice, access, and equity, and (c) involvement of institutional stakeholders in policy development. The results indicated that the five Big Ten DSO director participants identified with Bass’ (1985) four characteristics of transformational leadership: (a) charisma, (b) inspiration, (c) intelligence, and (d) interpersonal skills. The five participants led their institutions by being trusted, knowledgeable, and confident practitioners as they communicated their visions for service animal access and forged paths for inclusive service animal policies and practices. The study also revealed that the five participants approached their leadership roles and service animal policies through a social justice, access, and equity framework. Aligning with Huss’ (2010) comments on the deficiency in stakeholder knowledge about federal and state legislation and institutional policies on service animals, the study exposed that there is a lack of education among campus stakeholders on service animals. Participants felt a need to continue to educate their campus communities on service animal policies and practices. Lastly, the study revealed the importance of Big Ten DSO directors pulling together a team of institutional stakeholders with knowledge and stake in service animal policy, including the institutions’ ADA coordinators and members from the institutions’ legal offices, policy offices, transportation departments, student housing, facilities, academic affairs, and police departments. Participants also shared that they utilized fellow Big Ten directors and outside resources, such as AHEAD, when developing and implementing disability-related policies and practices. One stakeholder group missing from participant responses was service animal handlers, as none of the participants mentioned the handler experience as a critical aspect of the institutions’ service animal policy development processes.

Recommendations and Implications for Policy Development

This study informs higher education administrators on the Big Ten leadership approach to service animal policy development. To develop inclusive and comprehensive service animal policies, this study recommends that administrators invite institutional members that the policy will impact; this includes but is not limited to academic affairs, student affairs, human resources, legal counsel, university housing, dining services, office of institutional equity, student government, special events, athletics, facility management, risk management, transportation, and service animal handlers. Additionally, it is recommended that the service animal policy provides guidance on an array of topics, such as standard definitions and institutional contact information, service animals in training, guidance on restrictive areas and educational laboratories, service animal personal protective equipment practices, handler responsibilities, removal of a service animal, grievance processes, along with guidance on interacting with a service animal, and the conduct process for discriminating, mistreating or harming service animals. Lastly, it is recommended that HEI administrators develop inclusive and informative educational practices across campus; this includes developing service animal training or educational materials that inform students, faculty, and staff of what they need to know regarding service animals on campus.

There is an extensive gap in research regarding higher education service animal policy and leadership practices in developing disability-centered policy. As what could be viewed as the first research ever completed on the leadership approaches to service animal policy development, the underpinnings of this study need to be expanded to investigate service animal practices and policies at various sizes and types of HEIs (i.e., small, midsize, and large HEIs; private and public HEIs; and 2-year and 4-year HEIs). It is recommended that future scholarly work investigate the leadership qualities of various stakeholders involved in the policy development process (i.e., ADA coordinators, DSO Directors, legal counsel, university housing, academic affairs, etc.), including research on their perceptions of service animals and institutional policies. Similar studies must also be completed on the handler experience, which will assist with aiding in the development of inclusive policies and practices that support student access, success, and retention.

For HEIs to ensure access for handlers and their service animals, academic research must explore the leadership factors and frameworks that inform how DSO directors guide institutions when developing service animal policies. This study revealed that DSO directors must utilize transformational leadership and social justice approaches when developing and implementing transformative and inclusive policies and practices aimed at the disabled and service animal handler experience in higher education. The HEIs that incorporate inclusive practices related to transformative leadership and social justice can generate institutional cultures that are knowledgeable on crucial topics related to disability access and are more accepting of the disabled experience and those utilizing service animals in the academic environment. As discussed in the research, federal and state legislation provides a compliance-based foundation for institutional policy. Paired together, transformational leadership and the social justice model of disability move beyond bare minimum compliance and into a culture of increased legal literacy and higher education access for service animal handlers.

Footnotes

Author(s) Note

The original version of this manuscript was submitted by Author 1, Ryan McCombs, as part of his dissertation in April 2023. [McCombs, R. G. (2023). Service animals in higher education: A legal and qualitative exploration on the impact of legislation and policy. Unpublished doctoral dissertation. Purdue University Graduate School. ] McCombs has put a one year embargo on his dissertation due to this submission to JDPS.

Funding

The author(s) received no financial support for the research, authorship, and/or publication of this article.

ORCID iD

Ryan G. McCombs

Notes

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