Online companies are getting very good at meeting the letter of the law, if not the intent. They promote themselves as a way to relieve pet owners of unfair expenses (pet deposits, airline fees, no-pets-allowed housing or other services)–oh, and sometimes as an afterthought, they add in the emotional aspect, too (insert #sarcasm).
Are ESA Online Services Legit? Maybe . . .
These services typically pre-qualify applicants based on answers to online questionnaires that are easy to fake. To find out, I tested one of the services. I answered truthfully and was turned down. Then I created a fake identity, chose the obvious “right answers” on the emotional questionnaire scale, and pre-qualified with my nonexistent ASA-wannabe ferret.
In this example, the company charges $150-200 for your choice of three versions of an ASA letter. That includes a $35 phone consultation by one of their “qualified professionals.” You pay up front, and if turned down, they promise to refund all but that $35 consult fee. I sent an email with these questions:
Thanks for reaching out. I also like to educate my readers so your information interests me. Can you tell me how your mental health professionals qualify potential candidates for ESA credentials? I see there is an online questionnaire/survey. How do you get around the “fake” folks who just want to take pets everywhere with them (heck, I’d love to take my 95-pound puppy everywhere, too!) Is there a further step to the evaluation?
Also, I know the ESA letter must be generated from a mental health professional who has diagnosed and offering active treatment of the person in question. So how is that possible with an online service?
The Company Answers
It is lovely to hear from you! I would be happy to answer any and all questions that you have and feel quite qualified to do so because I not only work for REDACTED, but used REDACTED to register my dog as ESA during a time where I didn’t have access to a therapist due to overbooking (for 6 months..,yikes!).
So we have a basic short survey that people can take to see if they would be a good candidate for an ESA. This is not what the Licensed Mental Health Professionals see – it’s more just for the candidate to understand if they might qualify. Once that short survey is taken and the candidate feels like they should move forward, they can choose if they want a housing letter, travel letter or both. They are brought to a checkout where they purchase the letter(s) – but technically are sessions with a LMHP. The candidate is then prompted to complete a lengthy questionnaire that can take up to a few hours to complete depending on the individual. The questions go extremely deep and personal just as if you had many sessions with a LMHP face to face. Once you submit the questionnaire, you are assigned to a LMHP in your state. The LMHP will then read over the entire questionnaire and schedule a time slot to have a session over the phone. After the session is over the LMHP write s a plan of action (for example, I suffer from flying anxiety and GAD so my therapist sent me an email with a plan of action to use music therapy). It is only after all of these steps that the LMPH determines if an ESA would benefit the candidate. After the letter(s) are received by the patient, the LMHP continues to check in and provide care if requested by the patient. I actually talk to my LMHP I got matched with through CertaPet all of the time!
So fakers will be fakers whether they are getting in-person therapy or online therapy, unfortunately. Having an ESA does not serve the individual the same rights as having a service animal. So ESAs can’t go everywhere with the individual. The ESA letter was put in place for housing and travel ONLY.
Wow! A 95-pound PUPPY?! What kind of pup do you have? I have an 8lb Italian Greyhound. He is the perfect travel companion and sits on my lap the majority of the day!
Please let me know if you have any more questions or if something is unclear. I know I just threw a lot at you.
Name Removed Per Request
FURTHER NOTE: The original email I received said they wanted to contribute information about ESAs to my blog after finding it (and I assume doing research/reading my blog). When I received the above answers to my questions, I replied that I would add that info to this post, whereupon I was asked to remove the person’s first name (I have done so) and add a live-link and name of the company (I will not). I’m posting for informational purposes only, not advertising one service over another. If readers like what this company provides, now you know what to look for when vetting them.
Skirting the Law? Telehealth Makes It Work
I’m grateful for the company rep’s cordial reply and glad the company helped her with certifying her dog for her needs. From her description, it sounds like the company goes far beyond what a majority of these services do.
That said, I’m still not convinced that the system satisfies the requirement to “be under active treatment for your disorder by this same mental health professional.” Because once you qualify, your ASA letter is generated by that mental health pro on his/her letterhead with his/her license number and sent to you within 48 hours.
You’re considered “under active treatment for your disorder” after completing an online survey and speaking on the phone. As promised, I’m sharing this information and look forward to any further comments or feedback from folks. What do you think? As the representative notes, an ASA and service dog are quite different.
I have friends and colleagues who train and/or partner with service dogs, including ESA — Emotional Support Animals. I’ve also been aware for some time that unscrupulous folks fake service dog credentials to take advantage of what they consider to be furry perks, like taking their dog with them into businesses and restaurants, or (a biggie!) getting pets into no-pets-allowed housing or on planes for free.
BUT MY DOG IS DIFFERENT…
Sure, we all love our dogs (cats, rats, mini-pigs, horses…). But the folks who RELY on their animal partners are being damaged by the disregard of clueless (or mean-spirited) individuals who think they’re better than the law–and taking animal companions everywhere. Here’s the problem–if YOUR sweet-as-punch pet acts inappropriately, that makes the next for-real ASA or service dog and human partnership suspect. It’s the law that service dogs be allowed in businesses, and there are rules that businesses must follow. When non-service/ASA animals don’t follow the rules, it puts businesses in a bad position, too. Read on.
FAKE SERVICE DOG CREDENTIALS
Scammers offer fake service dog credentials supposedly out of the goodness of their heart–but of course, for a fee. Both the fake-paper-pushers and the service-animal-fakers argue, “Who does it hurt? It’s a victimless crime.”
It hurts the business, the reputation of legitimate handlers and dogs, and even the animal and his owner-faker. See if you qualify for a service dog here. The only entities that make out like a bandit are organizations supplying fake paper and lining their pockets.
Reality Imitates Art–Or Vice Versa?
Actually, I researched this a bit for background in one of my thrillers, since the main character September Day has a service dog Shadow, who helps mitigate issues with her post traumatic stress disorder (PTSD). For instance, Shadow alerts in advance of panic attacks, and helps anchor September to the present during flashbacks, among other things. PTSD, debilitating migraines, seizures, diabetes, IBD and other health concerns can be helped enormously by trained service dogs. But these “hidden” issues open the door to abuse in a way that service dogs partnered with visible/physical challenges may not face.
I hadn’t planned to blog about this, at least immediately. Then on January 1, 2015 I received an email interview/story “pitch” that purported to offer reputable, legal help for those seeking ESA credentials. Frankly, the message raised alarm bells, and when I got sick with the “crud” I delayed doing anything about it. I wasn’t sure how to handle it.
Real & Fake Service Dog Credentials, Conflicts & Confusion
Heck, I’d love to take Magical-Dawg with me more places, and he’d love that, too, especially if they served bacon! Karma-Kat certainly offers me lavish emotional support, as does any animal friend with whom we share a bond. Besides, who would know–According to the Americans with Disabilities Act (ADA), a business owner is only allowed to ask two questions:
- Does the dog provide a service?
- What has the dog been trained to do?
Under ADA guidelines, only DOGS qualify as service animals (sometimes miniature horses serving as guides for the blind also qualify), and PETS are not considered service animals. The dog must be trained to provide a SPECIFIC SERVICE for SPECIFIC DISABILITIES.
Sadly, this is easy to fake. Dogs are not required to wear any kind of identification like a vest. But heck, you can order a FAKE vest for your animal, too! In reality, a real service dog/human partnership isn’t required to show documentation for training. There is no single over-arching government-endorsed training agency for service dogs.
But it’s not just the ADA that offers guidelines and regulations. The Fair Housing Act, and the Air Carrier Access Act (ACAA, administered through the Department of Transportation) also provide what can be confusing or even conflicting regulations.
Fair Housing Act
The Fair Housing Act follows the ADA definition of service animal (dogs only,) and EXCLUDES those designated as emotional support animals. However, it does state that reasonable accommodations should be made for any service animal including ESAs. To qualify, the person is evaluated by the housing provider based on answers to the following questions:
- Does the person seeking to use and live with the animal have a disability —i.e., a physical or mental impairment that substantially limits one or more major life activities?
- Does the person making the request have a disability-related need for an assistance animal? In other words, does the animal work, provide assistance, perform tasks or services for the benefit of a person with a disability, or provide emotional support that alleviates one or more of the identified symptoms or effects of a person’s existing disability?
To accept your animal as an ESA and have waived standard pet limitations, housing requires a signed letter from a “licensed mental health professional” (not just your general practitioner). The letter must include:
- The professional’s address and phone number
- State that you have a disorder listed in the fourth edition of the Diagnostic and Statistical Manual of the American Psychiatric Association.
- You also must be under active treatment for your disorder by this “mental health professional.”
ACAA doesn’t restrict Emotional Support Animals to dogs–they can be cats, birds, hamsters, lizards, goldfish–anything at all. Because so many unscrupulous people tried to take advantage and claim their pets as ESA’s on flights, most airlines no longer allow ESAs on flights.
Airlines ARE required to accept service animals, which include psychiatric service dogs (PSDs). Many online letter-generating “Airlines may require a signed letter from a “licensed mental health professional” (not just your general practitioner) for a PSD to qualify for in-cabin flights. Today, many of the ESA-mill online operations have expanded selling letters to also offering similar documentations for PSDs. Airlines may require forms developed by the Department Of Transportation attesting to a service animal’s health, behavior and training,
Ditch the Pitch? or a Big Reveal?
Remember that email pitch mentioned in the opening paragraph? Yesterday I got a LinkedIn request for a connection from a person with the same name. So I decided to reply with some pointed questions, indicating I’d like to include them in a possible future blog. Most of my questions arose from the lack of detailed information posted on the website. There were no names, no credentials listed, just a lot of generalities and promises.
The website offers an online evaluation of your completed questionnaire by an (unnamed) board-certified psychiatrist. When that evaluation confirms your qualifications, the expert then generates a letter that qualifies your ESA and thus allows plane or housing privileges afforded to service animals. For a fee, of course. If your answers to the questionnaire fail to qualify you, the fee is promised to be reimbursed.
I figured a “no response” would be telling. So I was happily surprised to receive a prompt response with detailed answers, which I’ve cut-and-pasted below. I will leave it to readers to make judgments about this particular service.
Q & A with (NAME REDACTED)
Thank you very much for your interest. Please see my responses to your questions below.
Who are you? What is YOUR background in pets? Is this you? (NOTE November 2018: the profile has now been hidden)
Yes, that’s me. I’ve had a dog for the past 10 years and a cat for the past 16.
Who is your “board certified psychiatrist” ?
My husband (NAME REDACTED). He is the co-founder of [the service].
What board certifies a psychiatrist to diagnose a patient over the Internet?
Our letter does not constitute a diagnosis. It recommends an ESA to help treat the problems that you are currently experiencing.
Why does the pop-up invite someone to get a FREE “ESA Letter” but then require a credit card to submit the questionnaire for $150?
The offer is buy an ESA letter for housing for $149 and as an added bonus, we provide a letter covering air travel, worth $149, free. Other services charge to each letter separately.
If, indeed, someone qualifies for an ESA, why would they need an annual letter for another $150 each time?
The letter itself never expires. It’s dated the day that it’s mailed out. The issue is that airlines and landlords do not accept letters that are dated more than a year old. In addition, people have to retake the questionnaire because their symptoms and health problems can change. What they said a year ago may not be the case today. No doctor can write a recommendation or prescription for someone in perpetuity. They have to be re-examined at least once a year.
What percentage of your applicants do you turn down as “not qualified” for an ESA and actually refund the fee?
None. Everyone who has come to us have [sic] met the medical qualifcations [sic] to get an ESA letter.
Are you not concerned that unscrupulous individuals would manipulate the questionnaire/answers to get an ESA letter for which they do not qualify?
The medical questionnaire is the same one a psychiatrist would give during an in-office visit. Mental health treatment for the most part is provided based on self-reported symptoms — unlike other health conditions that can be physically measured with tests. If people lie on the medical questionnaire, they could also lie during an in office visit. Psychiatrists have to take people at their word. You may deem someone as “unscrupulous” or that “they do not qualify” but that’s just YOUR opinion and judgement of them. It doesn’t make it true. Mental illnesses are invisible. A person may look and act completely normal yet still suffer from a mental illness.
Okay, gang, what do you think? How would you characterize such a service? I did fail to ask one question–does a questionnaire answered by a mental health practitioner constitute “being under active treatment for your disorder,” as required by the ACAA?
What about you? Do you think “fake” service animal credentials is a victimless crime? Are you, or do you know someone partnered with an amazing service animal? How could the “rules” be changed to improve the situation you?
I love hearing from you, so please share comments and questions. Do you have an ASK AMY question you’d like answered? Do you have a new kitten and need answers? Stay up to date on all the latest just subscribe the blog, “like” me on Facebook, and sign up for Pet Peeves newsletter. Stay up to date with the latest book giveaways and appearances related to my September Day pet-centric THRILLERS WITH BITE!
Amy Shojai, CABC is a certified cat & dog behavior consultant, a consultant to the pet industry, and the award-winning author of 35+ pet-centric books and Thrillers with Bite! Oh, and she loves bling!
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