“Accreditation”  
© 2017 Committed Canine, LLC

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 new 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: 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, 3 of those are exclusive Guide for blind, 2 specialize in Diabetic Alert, 6 of those have limited service ranges, 4 as small as a one county radius 7 are in FL, 1 is exclusively Guide for the blind, 3 list Hearing as primary, 1 is exclusive to children, 4 are limited to FL state or specific counties in the state 7 are in NY, 3 are exclusively Guide for the blind, 1 lists its service area exclusive to east coast 5 are in PA, 4 are limited to PA state or counties, 1 has a 150 mi radius, 1 is limited to eastern states 4 are in OH, 2 are limited to a three-state radius, one has a 90 mile radius 4 are in WA, 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.

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.
“Accreditation”  
© Committed Canine 2016

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 new 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: 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, 3 of those are exclusive Guide for blind, 2 specialize in Diabetic Alert, 6 of those have limited service ranges, 4 as small as a one county radius 7 are in FL, 1 is exclusively Guide for the blind, 3 list Hearing as primary, 1 is exclusive to children, 4 are limited to FL state or specific counties in the state 7 are in NY, 3 are exclusively Guide for the blind, 1 lists its service area exclusive to east coast 5 are in PA, 4 are limited to PA state or counties, 1 has a 150 mi radius, 1 is limited to eastern states 4 are in OH, 2 are limited to a three-state radius, one has a 90 mile radius 4 are in WA, 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.