How To Certify A Dog As A Service Animal

According to her owner, Nick, 40, Rosie – a 50lb, eight-year-old yellow labrador retriever – is a very good girl. (Both man and dog are using a pseudonym for reasons which will be soon made clear.)

Much of Rosie's goodness is inherent, by virtue of her being a dog. But Rosie is not just a lovable creature, she is a helpful one, too. Rosie can open Nick's fridge for him. She can press handicap door activation buttons, heel off-leash on busy New York sidewalks, and she's even dabbled in a little search and rescue. She exhibits extreme self-control, especially when wearing her assistance animal vest, which she knows means she's on duty.

Nick doesn't fly with Rosie anymore, but when he did, she'd take up to 20 flights a year.

"When I went through the airport, people would come up to me and put their hand on my shoulder and say, 'It's so nice for you to travel with your dog,' or thank me for my service, thinking I was in the military," says Nick. "They clearly looked at Rosie, a lab, and just assumed I was in the military. I never lied, but that was the assumption people always made."

The assumption – that Nick is a veteran with an invisible disability like PTSD – is wrong. Nick has no disabilities, and Rosie is not his assistance animal. Instead, she's one of a growing number of pets whose owners have conscripted them into a life of duplicity.

To promote your pet to the status of an "emotional support animal", or ESA, all you need is a therapist's letter asserting the animal contributes to your psychological wellbeing. If you don't have a therapist, there are for-profit websites, known among some psychologists as "ESA mills", that will facilitate a quick, dubious disability appraisal by a clinician over the phone or via a web survey, then sell you miscellaneous swag like vests and tags (none of which are legally required for assistance animal owners to have) to make you pet look more official.

While ESAs are technically not legally allowed to venture everywhere in public with their owners (only service animals have that right), they do come with perks. Equipped with a therapist's letter, you may move your pet into an animal-free apartment or dormitory, and fly with your pet in a plane's cabin for free. And nothing stops ESA owners from asking for further accommodations.

Support animal or service dog?

A service dog strolls through the isle inside a United Airlines plane at Newark Liberty International Airport. — A service dog strolls through the aisle inside a United Airlines plane. Photograph: Julio Cortez/AP

In 2014, the New Yorker's Patricia Marx gallivanted freely around the city with five successive fake ESA creatures, including a snake, an alpaca, and a pig named Daphne, demonstrating how easy it is to trick bewildered staff into letting random animals into their shops, museums, and restaurants.

While no governing body keeps track of the figure, a study from the University of California at Davis determined the number of ESAs registered by animal control facilities in the state increased 1,000% between 2002 and 2012. By 2015, the National Service Animal Registry, one of several sites that sell ESA certificates, had registered more than 65,000 assistance animals. In the four years since, that number increased 200%.

While not all spurious ESAs wreak havoc, some do – with serious consequences. In 2018, Delta Air reported an 84% surge in animal incidents since 2016, including urination, defecation and biting. Recent media reports of emotional support peacocks causing pandemonium in airports, comfort hamsters getting flushed in a frenzy, and dogs storming the stage during Cats have further contributed to the sense that ESAs are an epidemic, part of a zoo where entitlement, biting, pooping, and pretty much anything else goes.

For people who do have genuine disabilities, the situation is becoming untenable.

Ryan Honick, 33, whose service labrador, Pico, helps him with myriad daily tasks, says people on social media who broadcast their fraudulent pets infuriate him. Not only can fake ESAs distract or attack working service dogs, but service providers who have been inconvenienced by bad behavior from an unruly pet often sour on accommodating all animals thereafter. (Delta Air, for example, recently banned all ESAs from flights over eight hours.)

Despite having a federally protected service animal, Honick is often denied rides from rideshare drivers; he films these exchanges and keeps a running thread of them on his Twitter feed.

"I've had drivers ask me point blank, 'What happens when your dog defecates in my car?' I've said, 'That's not how trained service dogs function,'" says Honick. "People's perceptions get skewed because somebody brought in their misrepresented animal. And that makes it harder for people like me who have a legitimately trained dog like Pico, who's never caused any problems, because there's this wariness."

Honick advocates on behalf of Canine Companions for Independence, a not-for-profit group that assists people who require service animals to mitigate the effects of physical disabilities. He tries to educate others about the difference between service animals and ESAs, having found that the layperson often doesn't understand that a service dog is a $20,000 super-animal that can smell oncoming seizures or lead the blind, and currently an ESA is more like a pet who doesn't actively sabotage its owner's mental health.

Both have their merits, but only one is the difference between someone's life and death.

Under the Americans with Disabilities Act, only service animals like Pico have legal protections and the right to be with their owners in any space (airplanes and residential buildings have their own federal legislations recognizing both service animals and ESAs). Service animals can only be highly trained dogs or miniature horses capable of performing specific tasks. Emotional support animals can be any species or breed. They need no formal training, making them much more likely to spontaneously go a bit Jumanji.

It can be hard to know whether you're looking at a service dog or an ESA without asking the animal's owner, and even that can be tricky: you are legally only allowed to ask someone with a service animal two questions: "Is that a service animal?" and "What task is it trained to perform?"

Nothing can stop people from lying, or exploiting others' confusion by using the terms "service animal" an "ESA" interchangeably. "The majority of folks who slap a vest on their pet have already crossed that line," says Honick. "The easiest giveaway is behavior. A trained service animal is going to behave unobtrusively and professionally. If those things aren't happening, odds are high the animal is fraudulent."

For business owners wary of incurring a discrimination suit for kicking a llama out of their hotel bar, it often seems safer to just accommodate all assistance animals. Unchecked, fake and unfit ESAs continue to proliferate.

The anxious generation

A golden retriever dog wears a service dog harness — Some see ESAs as a way to self-medicate without spending the time and money on an official psychological assessment. Photograph: FatCamera/Getty Images/iStockphoto

At a glance, fake emotional support animals may look like a product of rampant entitlement, but they may reflect something more complex.

The National Institutes of Health reports that "studies have found that animals can reduce loneliness, increase feelings of social support, and boost your mood", and any pet owner can confirm that having an animal companion is one of the most effective non-pharmaceutical antidotes to anxiety you can get.

Meanwhile, generalized anxiety was identified relatively recently as a mental health condition and is only tentatively understood, but its reported levels are soaring across generations. The causes are frequently beyond our control, or feel like it (climate change, gun violence, financial stress) yet the responsibility to keep our mental health in check falls squarely on individuals. To feel passably well, we are told to exercise, get more sleep, eat wisely, and maybe snuggle a couple of corgis.

Perhaps that's why millennials, "the anxious generation", are also America's largest and most enthusiastic demographic of pet owners, with a 2018 survey reporting that of the 72% of millennials who own pets, 67% consider them their "fur babies" – or part of their families.

Surely, many people who get ESA certifications for their pets are selfishly motivated by convenience – they just want to bring their pets on to airplanes or into Starbucks. But others see it as a way to self-medicate without spending the time and money on an official psychological assessment to confirm what they already know: that anxiety is affecting their wellbeing.

Eliza (not her real name), 28, had no moral dilemma surrounding her decision to "register" her three-year-old pomsky, Buzz (also a pseudonym), through a website that also sold her an ESA tag, dog vest, and certificate.

"I haven't been diagnosed with any psychological illness, but I feel as if I naturally have a great deal of anxiety and I find that having my dog around me most of the time greatly reduces it," she says. "I see my pet as my family member; instead of a child I have a dog and I want to make sure he has the best quality of life."

Yet deriving comfort from pets doesn't entitle anyone to special treatment, especially when it comes at the expense of disabled persons. And while anxiety is a difficult condition, its intensity falls on a spectrum; official ESAs are intended to aid those who suffer only from its most debilitating manifestations.

Despite Rosie's good behavior, Nick's conscience eventually caught up with him, and he ceased flying with her masquerading as his assistance animal in 2017.

"When I started flying with Rosie, it wasn't quite the thing that it is now," he says, noting he came to feel that too many people were trying to "get behind the system" with untrained dogs. "Sometimes you could tell the dogs were uncomfortable traveling, that they were scared, they were distracting real service animals, and at that point I didn't want to be part of it any more."

'Not just any pet'

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Creature comforts: has the US's emotional support animal epidemic gone too far? – video

The question is, short of relying on everyone's moral compass kicking in, how do we cut down on fraudulent ESAs?

One solution could be a collective movement towards an increasingly pet-integrated society. A small number of colleges permit pets in dormitories, a policy more could consider. Normalizing the presence of animals in more spaces may reduce the impetus for people to game the mental health system just to spend more time with their dogs.

But the more likely and impactful fix might be a change in medical policy.

According to Cassie Boness, University of Missouri PhD candidate and co-author of an article on tightening ESA regulations published by the American Psychological Association this month, the professionals who sign off on ESA letters need to adhere to a strict and standardized evaluation model.

Her research proposes a four-point evaluation system developed to empirically ensure not only that the individual in question suffers from a psychological disability that impairs their functioning, but that the specific animal they want to certify both behaves appropriately to access the spaces where they are permitted and objectively improves their handler's symptoms.

Boness and her colleagues hope their new regulations will be adopted and formalized by the American Psychological Association, but they expect backlash from scammers of all stripes.

In fact, guidelines would help anyone who requires an assistance animal: "As we have more clear guidelines, ESAs will hopefully start to be more well respected, because not just any pet can be certified," says Boness.

With stronger regulations in place, the dog days of dubious ESA certifications will be over. Until then, we're left with a failing honor system rife with confusion, selfishness, and profiteers.

This article was amended on 13 & 16 August 2019: to further clarify the difference between service animals and emotional support animals and to more accurately cite the proposals of the research of Boness.