- May 9, 2025
Emotional Support Animals: What Every Mental Health Professional Needs to Know
By Rebecca Stone, LMHC-QS of Stone Counseling & Consulting Services, LLC
As mental health professionals, we’re continually asked to balance therapeutic best practices with evolving client needs—especially when those needs intersect with legal and emotional support systems. One topic that has gained increasing attention in recent years is Emotional Support Animals (ESAs).
From anxious college students to clients managing PTSD, more individuals are turning to animals not only for companionship but for vital emotional support. But as the demand for ESA letters grows, so does the confusion—about qualifications, legal standards, ethical boundaries, and clinical responsibility.
So where does that leave us?
Let’s take a look at what you really need to know to navigate this landscape confidently—and ethically.
What Are Emotional Support Animals?
An Emotional Support Animal (ESA), sometimes referred to as a Comfort Animal, is an animal which is prescribed by medical or a licensed mental health professional to an individual with a disability. The ESA’s purpose is to alleviate one or more identified symptoms or effects of an individual’s disability. The ESA does not carry out tasks associated with daily living and is not required to accompany a person with a disability at all times.
Legally, ESAs can be requested as a disability accommodation for housing under the Fair Housing Act. Once approved by housing, the ESA is considered a disability accommodation and is only permitted within the owner’s dwelling.
Any type of animal commonly found in households could be considered an ESA – a dog, cat, rat, snake, etc. They do not have any special training and there is no centralized ESA registration (no, that listing that appears in your search results is not required and is not a valid way to claim your animal is an ESA!). Because ESAs are only permitted within the handler’s residence, vests or badges are not necessary. Animal types and behaviors range based on any training its owner has established.
It is important to know that, beginning in 2021, ESAs are no longer disability accommodations for air travel; those animals are now subject to pet rules, restrictions, and fees.
Are Emotional Support Animals the same as (Psychiatric) Service Animals?
No! It is important to know the different terminology, coverage, and rights.
A service animal is an animal which has received specialized training to perform a specific task or set of tasks for a person with a disability. You have likely noticed service animals who perform overt tasks, such as guide dogs for someone with low vision or blindness. Service animals may be trained to perform all sorts of different tasks (many covert), such as sensing blood glucose levels and alerting people with diabetes or alerting to early symptoms and ensuring safety of a person with a seizure disorder. Service animals may also be trained to support psychiatric disabilities, such as checking for safety for someone with PTSD, providing deep pressure therapy for panic disorders, interrupting self-harming behaviors, or retrieving medication and water.
Federally, service animals must be dogs only; but, in Florida and some other states, service animals can be dogs or miniature horses (mini horses about the same size/weight as many dogs and a great hypoallergenic option!). The most common dog breeds are Labradors or Border Collies; however, any size or breed of dog may be trained as a Service Animal. Service animals may be trained by the individual with the disability or a training center.
Service animals are permitted to accompany people with disabilities in all areas where members of the public are allowed to go (e.g., restaurants), but may not be permitted in places that may pose a health or safety hazard, such as in a public pool although they must be permitted on the pool deck. In cases of hotels, etc., the handler and animal cannot be required to stay in a pet-friendly room; they should be permitted to stay anywhere in the facility.
Typically, you’ll see a service animal wearing a vest or a special harness. However, special gear or identifiers are not required if it impedes the animal’s ability to perform its tasks. These are working animals and, while on the job, they typically ignore other people, animals, or stimuli in the environment.
Service animals are covered under the Americans with Disabilities Act (ADA), and the ADA indicates no specific registration or documentation can be required for service animals. Some facilities may have a voluntary registry, however; for example, a school may ask a student to register their service animal to ensure the animal is accounted in an emergency. Under the Air Travel Access Act (ACAA), self-report and/or veterinary documentation is now required for service animals and air travel.
Legally, if it’s not readily obvious that the animal is a service animal by identifiers, behavior, or otherwise, there are only two questions can legally be asked to determine if an animal is a service animal: 1) Is the dog (or miniature horse) a service animal which is required because of a disability? and 2) What work or task has the animal been trained to perform?
What about Therapy Animals? Are ESAs the same as therapy animals?
No! A therapy animal is an animal which is used within a therapeutic setting by a health or mental health professional or by an individual who is trained to handle therapy animals. Therapy animals that are permitted indoors are typically dogs or cats. Generally, therapy animals are only permitted in facilities (e.g., retirement homes) or specific areas within facilities (e.g., common areas of in a hospital or a therapy office) after review and invitation by the facility owner/operator. The facility owner/operator has to consider things like facility cleaning needs, insurance coverage, and allergies/fears of other people in the facility. There should be times where therapy animals are not in the facility to ensure everyone can access the facility/services.
Therapy animals typically have behavioral training. In many cases, they are certified through an Animal Assisted Therapy program. They typically wear vests with that say “Therapy Animal” on them. Therapy Animals, due to their training and temperament, are typically calm yet people-friendly animals. They are usually less interested in other animals, obey commands by their handlers, are well-behaved, and have become accustomed to being petted anywhere, often by more than one person at once.
Are emotional support animals the same as pets?
In many ways, yes. Emotional Support Animals are essentially pets that have been prescribed to be able to live with their handler as a disability accommodation. People who live in settings that allow pets without restrictions are really not going to benefit from an ESA accommodation. In cases where there are animal restrictions in housing, however, people with disabilities may benefit from getting an assessment to possibly have their animal live with them as a disability accommodation.
The Mental Health Professional's Role in Providing Emotional Support Animal Letters
As mental health professionals, it is our responsibility to provide services that are both legal and ethical. In many cases, our licensing boards and professional organizations may (1) not provide guidance or a position statement on our role with ESAs at all or (2) may provide information that is conflicting or confusing.
When we are faced with this dilemma of clients asking for letters and we're lost, we must get training and consultation!
Before conducting ESA assessments or issuing ESA letters, it is critical to:
Recognize that we step into dual roles: therapist and evaluator (or gatekeeper) and explore if it is within our appropriate professional scope to proceed.
Gain the appropriate knowledge, training, or experience related to ESAs and assessing clients for ESA criteria.
Have a solid ESA assessment policy and procedure in place that works for your license, liability insurance, professional standards, and overall practice.
Ensure clients give informed consent for ESA assessment, including the potential risks and benefits associated with ESAs and the assessment and potential disclosure of disability information.
Conduct a thorough assessment confirming there is a diagnosable mental health condition, the symptoms or effects of that condition meet the criteria of being considered a disability, and there is an identifiable nexus as to how the animal ameliorates one or more identified symptom or effect of the disability.
Provide psychoeducation to the client to ensure we providing essential information are minimizing risk of harm.
Ensure the animal’s presence is a part of the client’s treatment plan and recommend ongoing treatments or supports.
Have an ESA letter developed which meets requirements for review.
Disclose the letter only when appropriate release of information has been obtained.
Document everything in a way that can stand up to legal or administrative scrutiny.
It's not as simple as it seems.
Your license and credibility are on the line. This isn’t just a “yes or no” favor—it’s a formal clinical endorsement.
Final Thoughts
As the line between clinical care and client advocacy becomes more nuanced, our responsibility as therapists grows. Understanding ESAs through a clear, ethical, and legal lens, and ensuring we have prepared all of the necessary practice policies, procedures, and protections first, helps ensure that we protect not only our clients—but our licenses and reputations.
Stay informed. Get trained. Stay grounded. And when in doubt—refer to best practices, not just best intentions.
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About Rebecca Stone, LMHC-QS
Rebecca Stone, LMHC-QS, is a Licensed Mental Health Counselor, Qualified Supervisor, and owner of Stone Counseling & Consulting Services, LLC, a private practice based in Florida. With over a decade of experience in clinical therapy and a strong background in business and office management, Rebecca blends compassionate care with operational expertise. She is passionate about supporting individuals on their mental health journey—and empowering fellow professionals through supervision, consultation, training and education, and practical tools to grow thriving practices.