Social work practitioners are increasingly being asked by their clients to write “Emotional Support Animal (ESA) letters” to verify eligibility for ESAs as accommodation in rental housing.
Uncertainty on how to respond to such requests creates barriers to housing access for people facing housing instability who are eligible for ESA support as a housing accommodation under the U.S. Fair Housing Act or FHA.
Janet Hoy-Gerlach, PhD, LCSW, LISW-S, director of Veterinary Social Work Open Door Veterinary Collective, hosted an NASW Specialty Practice Sections webinar discussing the topic in a presentation called “Responding Ethically and Competently to ‘Emotional Support Animal’ (ESA) Letter Requests.”
About 66 percent of U.S. households report having at least one animal. “A majority of those further report that their animal is family,” Hoy-Gerlach said.
Determining an ESA request is not about being an “animal person,” it’s about being a competent professional, she noted.
“(It’s) about being able to meet the client where they are at,” Hoy-Gerlach said. “And if (having an ESA) is really significant for them, then it’s part of our skill set to be inclusive of that—even if it not necessarily something that we would ever be interested in engaging with.”
Under the disabilities provision of the FHA, it states people must be granted accommodations to their disabilities. An emotional support animal is considered a housing accommodation under the FHA, Hoy-Gerlach noted.
If the person is eligible, they have the right, with a few exceptions, to be accommodated, she said. They cannot be charged additional rent or be denied the unit because of the animal if they meet the criteria.
“You never have to write an ESA letter,” Hoy-Gerlach explained. “It is your judgement ultimately.”
To obtain competence to write ESA Letters, a practitioner needs:
- To be knowledgeable of the client’s condition and related impairment, human-animal interaction benefits, and the FHA criteria.
- The ability to identify specifically how an animal is alleviating (or is expected to alleviate) the client’s specific impairment.
- To know the values aligned with disability rights, the NASW Code of Ethics, and research-based and informed support systems.
“We are not (commenting in the letters) about the animals,” Hoy-Gerlach stressed. It’s important to make clear to the client that you are commenting on the client’s specific condition and related impairment.
Practitioners need to verify the client meets the definition of disability under the FHA, she said. According to the FHA, health care professionals should use their knowledge to diagnose, advise, counsel, treat, provide health care, and other services to their client.
“This is within your basic scope of practice,” Hoy-Gerlach said. “Your basic training as a social work professional and clinician is the knowledge base that you would use. You are not using a specialized disability evaluation, credential, (or) training.”
An ESA does not have special training, she noted. What makes these animals different is how they affect the client who is eligible for their companionship.
“The animal’s presence helps reduce (the client’s) symptoms of their chronic health or mental health condition,” she said. “It’s not that the animal is doing anything especially different, but the everyday benefit that the person gets from being with the animal helps to offset impairment.”
She noted the FHA states animals who provide emotional support that alleviates one or more identified effects of a person’s disability are not pets, but rather a sub-type of assistance animals commonly referred to as ESAs.
A person with a disability may request an ESA as a reasonable housing accommodation to afford the equal opportunity to use and enjoy a dwelling.
The SPS webinar is available here.