Published on: April 20, 2026
A Joint NABITA and ATIXA Tip of the Week by Linda Abbott, M.S., LMHC, and Saundra K. Schuster, J.D., M.S.
Colleges and universities across the country learned that the U.S. Department of Housing and Urban Development (HUD) withdrew guidance on reasonable accommodations in campus housing. For institutionally owned and operated residence halls, this withdrawal sent a potentially misleading message.
In September 2025, HUD rescinded longstanding sub-regulatory guidance on assistance animals, including emotional support animals (ESAs). This action impacts professionals in residence life, disability services, Title IX, and campus legal counsel, particularly where Fair Housing Act (FHA) obligations intersect with ADA service animal regulations and emotional support animals as an accommodation in residential facilities.
What does HUD’s withdrawal mean? What legal obligations apply to campus housing, and how can institutions design ESA and assistance animal policies that are defensible, humane, and workable in the absence of prescriptive federal guidance? The lack of guidance does not reduce institutional risk; if anything, it increases it.
We recently explored this topic during a joint members-only Time with IX/Talking BITs event. Below are key takeaways and practical strategies drawn directly from that conversation to help you move from insight to action.
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