Over the past year, guidance from the American Counseling Association and scholars in the psychology profession regarding Emotional Support Animals (ESAs) has evolved. Current recommendations state that professional counselors should not engage in the practice of writing letters of support and referral for their clients seeking to make use of an ESA “unless the counselor has specialized training and experience in working with human-animal bond in counseling…due to the potential risks of for clients, the public, the counselor, and the animal.” College health services, including CSU Health Network, do not typically have this specialized training and experience within their scope of practice to ethically conduct disability evaluations for ESAs.
With the rise in requests for ESA letters of support across the nation, there have also been increased incidences of inappropriate referrals. This has resulted in greater pushback from local housing authorities and state regulatory agencies who are requesting higher levels of accountability from practitioners. Alongside this, there have been instances of practitioners’ expertise in making such evaluations being called into question by state regulatory agencies. Moreover, putting the therapist in the role of an evaluator runs the risk of interfering with the therapeutic process.
In light of this developing professional and regulatory guidance, CSU Health Network no longer provides letters of support and referral for students seeking to make use of ESAs and Psychiatric Service Dogs.
We recommend that students seeking a letter of support and referral for an ESA or Psychiatric Service Dog seek a disability evaluation from a provider (home provider, forensic psychologist, or forensic psychiatrist) with the recommended training and experience.
Important Note: This scope of practice change at CSU Health Network does not affect the CSU policy on Service Dogs and Emotional Support Animals. There will not be changes to the university policy at this time.
For more information:
- CSU Policy: Service Dogs and Emotional Support Animals
- Service Dogs and Emotional Support Animals Policy – Frequently Asked Questions (FAQs)
- Student Disability Center – Emotional Support Animals
- Student Disability Center – Service Dogs
- American Counseling Association. Emotional Support Animals: Human Animal Interventions in Counseling Interest Network Position Statement. 20 March 2019. https://health.colostate.edu/wp-content/uploads/2019/08/ESA-ACA-statement-2019.pdf
- Clay, Rebecca A. “Is that a pet or therapeutic aid?” Monitor on Psychology, vol. 46, no. 8, September 2016, https://www.apa.org/monitor/2016/09/pet-aid
- “Dogs and PTSD.” U.S. Department of Veterans Affairs, https://www.ptsd.va.gov/gethelp/dogs_ptsd.asp