© Tammie Rogers 2018

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ADI Accreditation The   following….   applies   exclusively   to   United   States   military   bases.          If   you   do   not   visit   military   bases,   the   Department   of Defence “accreditation” policy does not impact you. The   Americans   with   Disabilities   Act   (ADA)   covers   access   for   all   individuals   (military   or   civilian).      if   you   are   not   on   a   military   base.     The   ADA   does   not   require   that   a   Service   Dog   is   trained   by   any   specific   organization,   and   you   may   even   train   your      own   dog   as long as it functions at the standards set by the ADA. January 7, 2016 The    Department    of    Defense    enacted    a    law    (1300.27)    that    specifies    Service    Dogs    which    are    permitted        on    military establishments    must    come    from    an    accredited    service    dog    organization.    The    DoD    definition:    "accredited    service    dog organization   -   A   non-governmental   organization   that      raises,   trains,   certifies,   and   provides   service   dogs   to   qualified   Service members,   and   that   is   accredited   by   Assistance   Dogs   International,   the   International   Guide   Dog   Federation,   or   any   other   service dog accrediting organization recognized by the U.S. Department of Veterans Affairs." Oops…. we have a problem Committed   Canine   cannot   seek   ADI   accreditation.      ADI   will   not   accredit   a   company   that   does   not   hold   a   501   (c)-3   not-for-profit status.         We   do   not      understand   how   that   status   makes   a   company   better   at   training   dogs   or   more   reliable,   responsible   or     ethical   at   caring   for   them.         We   don’t   know   how   that   status   makes   us   better   instructors   for   disabled      individuals   who   wish   to partner   with   a   Service   Dog.         But,   that   is   their   policy   and   the   DoD   (VA)   doesn’t      have   another   organization   on   their   “recognized” list.   In   2011,   when   the   VA   was   proposing   the   new   law,   I   wrote   to   ADI   no   less   than   three   times   to   ask   the      rationale   for   their requirement,   and   whether   they   would   change   that   if   the   VA   law   was   enacted.         They   never   returned   my   correspondences.         I would think that ADI would want to accredit any company that meets its standards.  But, that is not the case.   Not   for   profit   doesn’t   mean   “free”   Service   Dogs,   and   it   doesn’t   even   mean   that   the   dogs   that   are      produced   by   NFP   companies will   be   less   expensive   to   acquire   than   those   produced   by   a   private      trainer   or   for-profit   business.      It   certainly   doesn’t   mean   it will   be   faster   to   get   the   dog,   either.         There      are   costs   associated   with   maintaining   a   not-for-profit   organization.      As   a   basic, small   business   we      prefer   to   focus   on   those   activities   at   which   we   excel,   which   is   training   dogs   and   instructing   people.               We   feel that   the   way   a   business   structures   its   finances   shouldn’t   have   an   influence   on   whether   it      meets   the   standards   for   producing high functioning Service Dogs and supporting their disabled  military veteran handlers. Historically,   Committed   Canine   did   submit   an   application   for   501-c3   status   well   before   the   DoD      established   their   law.         We   did so   not   because   we   ached   to   run   a   not-for-profit   organization   but   because   we   were   at   a   disadvantage   marketing   our   existence on   websites   (such   as   Wounded   Warrior)      that   would   not   post   a   Service   Dog   company   URL   unless   it   was   a   not-for-profit.      It   did not   matter   than      our   turn-around   time   and   prices   were   better   than   most   of   the   not-for-profit   companies   we   examined      at   the time,   and   our   dog   training   experience   was   exceptional   and   deep   rooted.         We   paid   the      IRS   the   $850   application   fee.      We   were told   that,   since   Robert   and   Tammie   are   a   married      couple,   they   pose   a   conflict   of   interest   risk.      We   were   told   that   we   would need   to   identify      additional   board   members,   and   that   Tammie   &   Robert   would   not   be   able   to   vote   on   certain      financial   matters.        We   chose   to   let   the   application   expire   and   the   IRS   kept   our   money.         It      simply   did      not   make   sense   for   our   business   to   be “bigger”   administratively   to   appear   more      honest.      More   people   on   a   board   doesn’t   buy   more   integrity,   and   it   certainly   can diminish   efficiency.         That   reduction   in   efficiency   can   end   up   causing   longer   delays   and   increased   costs   for   our   clients   who   need Service   Dogs.      We   had   trained   and   placed   a   number   of   dogs   with   disabled      US   military   veterans   as   well   as   civilians   by   the   time that   we   applied   for   the   501-c3,   so   we   knew   that      we   were   helping   people   gain   independence   and   we   felt   a   desire   to   reach   out to more individuals.    But, we had to draw the line when the detriments outweighed the benefits.  Monopoly Even   if   we   were   permitted   to   do   so,   we   are   not   certain   that   we   would   seek   ADI   accreditation.   However,   the   DoD   does   not   offer another   source   for   accreditation,   besides   ADI.         We   also   question   a   couple   of   other   policies   of   the   organization.   ADI   requires   the applicant   to   provide   a   letter   of   reference   from   a   currently   accredited   ADI   member   company   as   part   of   their   application   packet.        This   concerns   us.      Is   ADI   providing   professional      inspection   of   a   company’s   capacity   to   produce   high   quality   Service   Dogs   or,   is   it a   social   organization?         What   is   the   point   of   the   certification   process   if   the   accrediting   organization      feels   a   need   to   get     feedback   from   another   company   who   has   not   ever   audited   the   candidate   firm’s   processes?      This      requirement   makes   us question   the   integrity   of   the   entire   ADI   system.      Also,   to   submit   an   application   for   ADI   membership,   the   applicant   need   only have   trained   three   Service      Dogs   which   were   still   functioning   at   the   end   of   one   year.         Yet   they   seem   to   have   a   lot   of   focus   on     things   like   how   a   company’s   Board   of   Directors   is   structured.            It   makes   us   wonder   whether   ADI   is      significantly   focused   on auditing a company’s capacity to produce high standard Service Dogs and to  adequately serve potential Service Dog handlers?    Discrimination and breach of Fair Trade Laws We   understand   that   the   Department   of   Defense   felt   a   need   to   provide   some   sort   of   validation   of   Service   Dog   companies   that serve   disabled   veterans.      However,   we   are   not   certain   that   creating   a      monopoly   that   excludes   many   reputable   companies   from assisting   veterans   was   the   best   option.   We   believe   this   is   a   case   of   discrimination.         The   Department   of   Defense   has   a requirement   that      military   veterans   must   acquire   their   Service   Dogs   from   ADI   accredited   companies   but   many      companies   that produce   high   quality   Service   Dogs   cannot   gain   accreditation   unless   they   completely      change   their   financial   structure   and   delve into   the   realm   of   operating   a   not-for-profit   organization.   The   new   law   has   significantly   limited   our   ability   to   serve   US   military disabled veterans.    Additionally,      the   law   is   quite   possibly   a   breach   of   Fair   Trade   regulations.         Because   of   the   law,   a   veteran   has   to      decide   whether he   wants   to   work   with   us   and   be   excluded   at   military   bases   when   traveling   with   his      Service   Dog   or   seek   an   alternative   which may   not   be   the   best   option   for   him.            Additionally,   while   the   ADA   (Americans   with   Disabilities   Act)   has   no   regulation   about   how a   Service      Dog   is   trained   (only   how   it   performs)   the   new   military-exclusive   law   has   prompted   more   people   to   get      wind   of   a   “new law”.         They   may   believe   it   is   a   federal   regulation,   not   just   a   military   one.         More      potential   clients   are   asking   us   about certification    and    we    find    that    we    have    to    explain    the    whole    crazy        story.        Sadly,        for    most,    especially    those    who    don’t      understand   the   entire   situation,   it   seems   far   more      safe   to   simply   seek   a   Service   Dog   from   an   ADI   accredited   company   than   to try   to   understand   the      sorted   details   of   the   military   specific   situation.         To   say   that   we   are   not   accredited   makes   it   seem   that      we are not meeting minimum standards, which is not the case.   New law removes options for disabled veterans The   most   basic   issue   that   veterans   now   face   is   that   there   may   not   be   sufficient   ADI   accredited   organizations   to   serve   them.           Here is what I was able to pull from the ADI website at the time of this writing: 91 total organizations are listed in the ADI database in the USA 15 specify Guide for blind as primary function (low / no priority for veterans who are not blind) 15 specify Hearing for deaf as primary function (ditto – “deaf”) 4 specify Diabetic Alert as the primary service (ditto – “diabetic”) 3 specify disabled children as exclusive, or primary service (low priority for veterans) 50   of   the   organizations   list   a   limited   service   radius   (meaning   that   the   recipient   must   live   within   a      prescribed   distance   of the organization) 16 are in CA o 3 of those are exclusive Guide for blind o 2 specialize in Diabetic Alert o 6 of those have  limited service ranges o 4 as small as a one county radius 7 are in FL o 1 is exclusively Guide for the blind o 3 list Hearing as primary o 1 is exclusive to children o 4  are limited to FL state or specific counties in the state 7 are in NY o 3 are exclusively Guide for the blind o 1 lists its service area exclusive to east coast 5 are in PA o 4 are limited to PA state or counties o 1 has a 150 mi radius o 1 is limited to eastern states 4 are in OH o 2 are limited to a three-state radius o one has a 90 mile radius 4 are in WA o 3 are limited to WA state (or just part of the state) You get the idea. Many   states   have   just   one   or   no   ADI   accredited   organizations   serving   them.   If   you   are   a   veteran   in   need   of   a   Service   Dog   who resides   in   the   middle   of   the   country,   you   will   be      hard   pressed   to   find   an      ADI   accredited   organization   that   will   serve   you.      That is terribly unfortunate.    With   fewer   options   available,   the   wait   time   is   likely   to   increase.         Not   to   be   overly   dramatic,   but   when      your   brain   is   trying   to convince you to kill yourself, waiting two years to partner with your Service Dog  may as well be an eternity.  We believe that the new law is bad for business and worse for veterans.