My Views on Writing Letters for Emotional Support Animals

This article is written for mental health therapists who are asked to write letters for people to have their pets with them in their residences, on air carriers and in public as their emotional support animals. Hopefully this information will help therapists to consider and navigate this issue ethically. It may not make some people happy but I have considered it for a long time before writing it and I believe that it is the right information to consider.

                                               What is This About Emotional Support Animals and Letters?
 
As therapists, many of you may have been asked to write a letter for your client’s pet to be recognized as their “emotional support animal (ESA).” Or perhaps the person who has asked you is not your client but rather a person calling you because you are a credentialed, licensed therapist and the person is requesting you to write this letter for them due to their belief that having their pet with them at all times will support them with their emotions and ability to function in society.
 
If you have not been asked to do this yet, you likely will be at some point.
 
So what is all this about emotional support animals and letters? First of all, it is important to discuss what an emotional support animal is. An emotional support animal is a person’s pet that can support them emotionally wherever they go. The person must be deemed by a credentialed therapist or physician as having a DSM 5 diagnosis and then the professional must declare that due to the diagnosis, the person is in need of having their pet with them at all times as an Emotional Support Animal. This must be stated in a formal letter and then the animal can live in no-pet housing and fly on some air carriers in Canada in the cabin and not contained in a pet carrier. There are no laws or regulations around whether these animals are screened for their safety in the public and no formal training to do so is required. The person writing the letter most often has never met the pet and would not be qualified to screen it appropriately for its temperament or behavior unless they are an animal behavior expert in the species, which most therapists and doctors are not. This is not an issue as there is no law stating that it must be done this way.
 
There is copious research to support the fact that animals are good for people who are suffering from mental health issues. There is no dispute about this fact and I firmly believe that animals DO help people who are in need of support. The issue is not whether the animal is a good support for the person but rather: 1). The lack of regulation around declaring a person as suffering from a mental health disorder, 2). The lack of policies and protocols for declaring the animal as safe in public places and 3). The lack of attention to how the animal may feel if they are in busy places all day, on buses or wherever the person may go.
 
Other issues with Emotional Support Animals in public include the confusion the public experiences in understanding the difference between an animal who is for emotional support an animal who is trained as a service animal. Service animals are trained extensively to be safe in public as they are trained to support one person who depends on them to live and function. Service animals are trained to be quiet, well-behaved, unreactive to other animals and chaotic events in the public as well as to have the skills and knowledge to assist people with a diagnosed disability in many ways (for example, Seeing-Eye Dogs and the Blind). They allow people to live in community and to carry out daily tasks more independently and they are recognized in Canadian Provincial Law as having rights as they are under the human rights act https://open.alberta.ca/publications/s07p5 in many provinces. They are allowed into no-pet housing, on air carriers, in restaurants and hotels and many other places because of their high level of training and capacity to not cause disruption while supporting their person. They typically wear a vest and their process is formally extensive.
 
Emotional support animals are typically someone’s pet and unless the person goes through extensive screening, training and certification for their pet with a trained professional who can assure that the pet is safe in all public circumstances, the pet is possibly not safe in public. And if the pet is not safe, the public may not be either, nor the person the pet is there to support. These animals often also wear vests and hence the confusion of the public for the type of animal that is present.
 
Just a thought, but if the pet is emotionally supporting someone and it bites another person while out in the community or gets afraid of a loud noise and is cowering under the table, how will the person in need of support of the pet help the pet or navigate the situation?
 
ESAs do not have all the same rights as service dogs in Canada but they are allowed into some no-pet housing and on some air carriers. They get into public places like restaurants and other places because business owners are not informed about the differences in the types of animals in public these days. This is causing problems for people who are in dire of a service animal for their functioning. ESAs who do not manage their behavior in public places, bark incessantly or jump on people can lead to business owners banning animals from their premises, which affects the service animal folks.
 
So what are the ethical considerations for you as a therapist in writing letters for ESA’s?
 
Scenario 1: The person requesting the letter is your client. You know this client has a diagnosed mental health disorder. This part is easy. Your client asks you to write the letter so their animal can be identified as an ESA.
 
Considerations:

1. If you write the letter, you have to state that your client has a DSM 5 diagnosis. This is a breach of confidentiality as you are now declaring your client’s clinical state to third parties for non-clinical purposes.
2. In writing the letter, you are stating that your client’s animal is addressing your client’s issue therapeutically. There is little research declaring that ESAs alleviate long-term treatment issues (Herzog, 2016).
3. Your role as a therapist/clinician is to assist your client to become more independent and to learn the skills they need to function successfully. If they are relying on the support of their pet to attend to daily activities, you may be enabling a dependency rather than providing your client with the tools they require.
4. It is unlikely that you are knowledgeable enough to screen, certify and recommend training for the animal to ensure its safety in public environments.
5. If your client’s pet harms someone in the community or has further difficulty due to an incident, you could be held liable as you have declared this animal as necessary to be in public to support your client.
6. If you refuse to write the letter for your client for an ESA due to your ethical responsibilities, your client may not be understanding and it may harm the therapeutic alliance, thereby possibly harming your client.

 
How can you avoid this from happening? One way is to include a clear statement in your informed consent that you are providing clinical services only and that you do not provide letters for ESAs.
 
Scenario 2: A person from outside your practice contacts you and asks you to write a letter for them to have an ESA.
 
Considerations:

1. This person is not your client, you do not have therapeutic rapport, you do not have knowledge of their diagnoses, which you need to declare for the letter to be legitimate.
2. As therapists, we are obligated to have a therapeutic alliance with a client to formulate our own opinions about diagnoses, even if they have been pre-diagnosed by another health care professional.

 
Possible solution? This person enters into a clinical relationship with you so you can properly diagnose or confirm diagnosis. This still leaves the problem of ensuring their animal is safe for public access unless you are an animal behavior expert in the species of your client’s pet and also opens that door of possible harm to the client if, in the end, you determine that the pet is not safe as an ESA.
 
Writing letters for ESAs could possibly be considered outside the scope of many therapists practice or competence, could have ethical ramifications and could interfere with our service to our clients and to the general public.
 
All of this does not even consider the animal involved. What if the animal is sensitive to large crowds of people, has transportation issues or does not get along with other animals it may meet in its journeys? If it is suddenly accompanying its owner on all excursions, it may take a toll on the animal’s health and welfare.
 
As therapists, we have an obligation to our clients and to the general public to do no harm. If we are writing letters for people to bring their pets into the community with or without screening, training and certification to support them emotionally for their DSM 5 diagnosis, we may not be honoring our obligations.
 
The laws in our country pertaining to ESAs require development and strengthening. In the meantime, it is best for us as therapists to stick to what we know and be cautious about treading into the deep waters this issue lurks in regarding questionable scope of practice and attesting to things we cannot be sure will actually assist our clients and protect them or the public from harm.
 
If you still want to write letters for ESAs, according to Clay (2016), the letter should be composed of several parts:

1. Confirms that the individual has a mental health diagnosis.
2. Explains how the animal helps alleviate that condition.
3. Describes your observations of how the animal and client interact and how long you observed the interaction.
4. Explains the possible negative effects of the person's not having the animal with him or her.
5. Mentions any training the animal has received from a qualified trainer, if applicable.

 
I am a huge supporter of the positive impact animals have on people’s mental health. I am an animal assisted therapist and have been practicing with animals to support people’s mental health and clinical treatment for 18 years. I fully support people having their ESAs in their homes but I do not write letters or encourage people to take their animals from their homes into the public to support them. There are just too many ethical issues at stake for the client, the animal and the public.
 
If my professional opinion is that my clients would absolutely benefit from having their pet with them at all times, I recommend them to get a service animal as these animals can be properly trained to support them while keeping them and everyone around them safe wherever they may go. The research also supports the fact that service animals provide long-term therapeutic support to people with disabilities and mental health diagnoses (Rodriguez, et. al., 2019)
 
In the United States, the Human-Animal Interactions in Counselling through the American Psychological Association has a position statement on this issue which reads as follows:
“Counselors only work within their boundaries of competence based on education, training, supervision, experience and credentials. As Licensed Professional Counselors, the assessment of DSM 5 diagnoses for human clients is within the scope of practice; however, the added practices of animal behavior, animal behavior assessment, or Human-Animal Interventions and Interactions are (most often) not. Emotional Support Animals may, in some specific circumstances, provide benefits to humans to ameliorate identified symptoms often associated with a DSM 5 diagnoses; however, because of the potential risks and unanticipated outcomes, the HAIC strongly suggests that counselors abstain from writing letters for persons seeking counseling or assessment for the sole purpose of obtaining an ESA recommendation letter.”
I couldn’t have said it any better myself and since we adopted the whole concept of Emotional Support Animals from the US, I recommend we adopt this solution to the problem that ESAs are now causing in the US which is extending to us. Rather than us as therapists taking all the responsibility for the ESAs, let’s lean on our government to put regulations in place to protect everyone involved.

​Eileen Bona
June 7, 2021