Risk Management: Animals and Therapy

I have a very sweet dog that I want to use as a therapy animal. What do I need to consider or do before I bring her to work with me?

Animals can be a great addition to a mental health practice, but there are many things to consider before adding your beloved pet to your practice. First, understand that animal-assisted therapy is not appropriate for all clients. Contraindications include: allergies, fear or dislike of animals, and cultural considerations related to dogs or other animals. Be sure your decision to include your pet in therapy is focused on the needs and interests of your client. One aspect of assuring that your clients’ needs are addressed is to include the issue in your informed consent form. Give clients the option to say no, and use the form to open an initial conversation about their preferences and potential positive and negative responses.

Further, it is important to consider safety issues, because even well-trained animals may act in unpredictable ways if they perceive a threat or become frightened. Strong bite inhibition and socialization with humans and other animals is a prerequisite to considering an animal for a role in a clinical setting. It is also important to consider the impact on your animal. Not all animals are suited to be therapy animals, and it is important to ensure that your pet has the appropriate temperament and training before using it as a therapy animal. Organizations and programs such as Therapy Dogs International, Delta Society Pet Partners, and the American Kennel Club Canine Good Citizen program are good places to start to get information and training for your pet.

In addition, if your pet is suitable for use as a therapy animal, remember to consider your pet welfare and comfort during its “workday.” Your pet should have a place to go to get away from “work” as needed, adequate time for sleep and play breaks, and lots of praise and attention throughout the day. There are also practical considerations such as possible restrictions on pets in your office lease and the need for adequate liability insurance to deal with potential damage or injury caused by your pet.

What is the difference between a service animal, therapy animal, and emotional support animal?

A service animal is a term defined in the Americans with Disabilities Act (ADA), and it refers to an animal (specifically, a dog or a miniature horse) that is specially trained to do work or perform tasks for the benefit of a person with a disability – including physical, sensory, psychological, intellectual, or other mental disability. Such tasks must be more than emotional support. The animal must be trained to engage in activities that the handler is unable to do, such as perform physical tasks; or to ameliorate a condition that prevents handlers from acting on their own behalf, such as calming down a person experiencing a severe panic attack. The tasks performed by a service animal should meet three criteria: 1) the task must be trained and not a natural behavior; 2) the task must mitigate the person's disability; and 3) the task must be needed by that specific handler. Service animals are the only category of animals covered by the ADA, and the ADA and other laws give handlers a legal right to have their service animals accompany them in public places.

In contrast, therapy animals may also be highly trained, but are often used to provide support and comfort to people other than their handlers. This may be accomplished through visits to hospitals, nursing homes, schools, or other places where emotional support from a therapy animal may be useful and appreciated. Therapy animals are generally what psychologists are thinking of when they consider having an animal be part of their mental health practice. These animals are trained to socialize and interact with people around them, unlike service animals which focus solely on the needs of their handlers. In addition, therapy animals do not necessarily work with people who have a disability, while service animals are defined as only working with people with disabilities. Although therapy animals are trained and may meet certification standards for the organizations within which they are working, these animals are NOT considered service animals and are NOT offered protections under the ADA. The handlers or owners of therapy animals do not have rights under the ADA to permit their animals to accompany them in public places, although some states have passed related legislation.

Emotional assistance animals differ from both service and therapy animals in that they are not specifically trained to provide a specific service to their owners. Instead, they provide support, comfort, and companionship through their presence to people who are disabled, elderly, or otherwise struggling with emotional or physical issues. Emotional support animals do not have the full protections of service animals under the ADA, but must be permitted to fly in airplane cabins with owners and must be allowed in housing, even if it is a “no pet” housing unit. Generally, a letter from a physician or mental health provider is required to establish that the animal’s owner is disabled and the emotional support animal somehow alleviates the impact of the disability for the owner. Psychologists may be called upon by clients to draft such letters and should understand the ramifications of writing such a letter before agreeing to do so.

My client is asking for a letter certifying that her pet is an emotional assistance pet. What should I do?

Proceed with caution. If the client is a therapy client, you should carefully consider your role with that person and whether it is appropriate to step into what is essentially a forensic psychology role. Further, think about the impact such a shift might have on the treatment. What if the situation otherwise does not go as the client had hoped? Of course, refusing such a letter might also affect the clinical relationship, though that can be the case whenever clinicians set limits on taking on multiple roles. In addition, consider whether you have sufficient data on which to base your opinion. Have you seen the client with his/her pet? Without? Do you have any information on which to base this legal document in addition to client self-report?

If you do determine that it is appropriate for you to draft a letter, the content of the letter will vary somewhat depending on whether it is written for the purposes of requesting an accommodation in a client’s housing situation or for the purposes of airline travel. Note that state laws may also affect the content of an emotional support animal letter for housing or other purposes. Generally, letters under the Fair Housing Amendments Act would include (a) a statement that the professional is a licensed provider; (b) that the client has a specific (DSM) mental health diagnosis that limits at least one major life activity; (c) the nature of these functional limitations; (d) an explanation of how the animal assists in alleviating that limitation (i.e., how it will benefit clients and enable them to enhance their ability to live in the community and more fully use and enjoy their home/apartment/dwelling); and (e) that the provider is prescribing or recommending as a reasonable accommodation that the client be permitted to have an emotional support animal. For airline travel under the Air Carrier’s Access Act, the primary focus of the letter — in addition to attesting to the client having a recognized psychiatric disorder — is that he or she requires an emotional support animal to travel or to engage in activities upon arrival at his or her destination.

References:

Younggren, J.N.; Boisvert, J.A.; Boness, C.L. (August 2016) Examining emotional support animals and role conflicts in professional psychology. Professional Psychology: Research and Practice, Vol 47(4), 255-260. http://dx.doi.org/10.1037/pro0000083