Emotional Support Animal Evaluations: Comprehensive Assessments for a Controversial Issue

In recent years, the use of animals to provide comfort, assistance, and therapy for individuals with various medical and psychological needs has gained attention, particularly with the rise of individuals relying on “Emotional Support Animals” (ESAs). However, there are several different types of animal-assisted interventions, and ESAs differ in important ways from service animals and therapy animals, for example. The use of ESAs became controversial as an increasing number of people began to claim their pets as ESAs and as industries appeared claiming to be able to “certify” ESAs. Further, individuals may seek a psychological evaluation to demonstrate that their animal qualifies as an ESA, and current recommendations are for these evaluations to be quite comprehensive.

Emotional Support Animals (ESAs)

ESAs are defined as “assistance animals” that offer emotional support or comfort to individuals with disabilities, including diagnosed psychological disorders (U.S. Department of Housing and Urban Development, 2020, p. 1). ESAs live and interact with their owners and are required to provide a benefit to the individual related to their disability, such as alleviating or reducing symptoms of the individual’s disorder (like symptoms of anxiety, depression, and stress). There is limited research on the benefits of ESAs to humans, as most literature has focused on service animals or on animal-assisted interventions with therapy animals (Ferrell & Crowley, 2023). Unfortunately, the research that does exist has highlighted concerns about fraudulent claims and portrayals of ESAs as service animals, ESAs injuring or killing other animals, and owners not meeting the animals’ basic needs for shelter or care (Ferrell & Crowley, 2023).

Service Animals

Service animals are highly trained to perform specific tasks that assist individuals with disabilities (see https://www.ada.gov/topics/service-animals/ for details). These tasks are directly related to the person’s disability and can include guiding visually impaired individuals, alerting those with hearing impairments to sounds, and detecting imminent medical crises like seizures or low blood sugar. The Americans with Disabilities Act (ADA) grants individuals with disabilities the right to have service animals accompany them in public places where other animals might be restricted. Currently, service animals may only be any breed or size of dog. Research on service animals is often geared towards the efficacy of their training and the impact they have on enhancing the independence and quality of life for people with disabilities. For psychological disorders, for example, numerous benefits have been found from the use of service animals (e.g., Brooks, Rushton, Lovell, Bee, Walker, Grant, & Rogers, 2018).

Reasons for an ESA

Although ESAs are considered a reasonable accommodation for housing under the Fair Housing Act, airlines are no longer required to treat ESAs as service animals as of a change to federal law in 2020 (U.S. Department of Transportation, 2020). This change occurred after a publicized rash of incidents related to individuals bringing ESAs such as snakes and peacocks on airplanes as well as ESAs destroying property or injuring other animals and people (e.g., Stockman, 2019). ESAs do not require specialized training; are not allowed legal access to non-pet-friendly spaces; and are not required to have any certification. ESA status for housing purposes is based on an individual obtaining documentation from a health professional stating that the individual has a disability that is alleviated by the ESA. This documentation can be used to assist the individual in obtaining housing accommodations (such as being allowed to have an ESA in housing that otherwise prohibits pets and/or not being charged a fee, for example).

ESA Evaluations

An ESA evaluation is intended to establish the need for an ESA, although there has been a lack of consistent standards for performing appropriate assessments in this area (Younggren, Boness, Bryant, & Koocher, 2020). The goal of an ESA evaluation is to ensure that the person’s disability-related needs align with the therapeutic benefits of their ESA. Younggren and colleagues (2020), in a detailed review, provided a suggested model for a comprehensive ESA assessment, stating that it should include:

  • A thorough evaluation of the individual establishing that the person has a disability, meaning that the person must have a “mental impairment that substantially limits one or more major life activities” (p. 5);
  • An assessment of the animal to determine that its presence or interactions with the person does alleviate symptoms of the person’s disability, as well as whether the animal’s temperament is appropriate for the locations in which it will be needed;
  • A review of records and collateral information about the individual and the animal as well as an assessment of the interaction between the person and the animal; and
  • Other necessary components of a multi-source, multi-method forensic evaluation, such as psychological testing to assess for malingering, problems/symptoms, and reduced symptoms after interaction with the animal.

In addition, the American Counseling Association (2019) stated that a mental health professional conducting an ESA evaluation and providing documentation for an ESA must consider the risks to the animal and the individual (as well as liability issues and risks to the public). For the animal, risks include neglect and abuse, as an individual’s psychological disorder may prevent them from providing adequate care for their animal. For the individual, risks can include inadequate treatment of their psychological disorder, particularly as the person may believe that their ESA is a replacement or substitute for professional care.

Issues to Consider

If you are interested in an ESA evaluation, there are several important issues to consider. This is not an exhaustive list, but some considerations include:

  • Cost:
    ESA evaluations can be expensive, given all the requirements listed above. Expect to spend at least $3000, but the total cost may be higher.
  • Need:
    Know that ESA evaluations are typically only used for housing accommodations since the law related to airline travel changed in 2020.
  • Consequences:
    These are essentially disability evaluations and being assessed as having a disability can have unintended outcomes. You must report having a disability in certain circumstances (such as for health/life/disability insurance, licenses, security clearance, and some types of employment). Having a disability can also become a factor in child custody disputes.
  • Location:
    ESA evaluations must be done primarily in person, rather than virtually.
  • Limitations:
    ESA status is not intended to be permanent but instead is designed to be a temporary part of treating a psychological condition; individuals should also be receiving therapy or other treatment for their problems.

Conclusion

While animals may offer comfort and companionship to individuals with emotional needs, the research is unclear regarding whether animals can alleviate symptoms of a person’s psychological disorder. It is important to know that ESA evaluations are comprehensive, disability-related assessments requiring several components; there are also many issues that should be considered carefully by anyone considering an ESA evaluation.

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