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Sub Rosa Mental Services, LLC

Sub Rosa Mental Services, LLC

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10 Guidelines Conducting ESA Evaluations

August 22, 2025 by Shiloh Martin, LPC-S, CCMHC

1. Licensure and Legal requirements: Before conducting an evaluation, Ensure that you meet the licensure requirements for your profession in your state. Make sure you are familiar with the appropriate federal laws governing Emotional support animals. (ESA)

2. Appropriate training: It’s recommended that you have appropriate training in the area of animal-assisted therapy, Human-animal bond Interaction, or animal-assisted interventions. This can help you understand the benefits and risks of using animals as part of a treatment plan, as well as the appropriate use of animals in different settings.

3. Review of medical/mental health history: When evaluating a person’s eligibility for an ESA, it’s important to review their medical and mental health history to determine if they have a qualifying disability or condition. This may involve reviewing medical records or conducting an assessment to determine the person’s current symptoms and functioning.

4. Determining a disability: In order to qualify for an ESA under the FHA, a person must have a disability that substantially limits one or more major life activities. This determination should be made based on objective evidence and professional judgment.

Historically the GAF was used to determine this. Best practice is to utilize the WHODAS 2.0. DSM 5 and DSM 5 TR recommend WHODAS over GAF.

5. Evaluation of the need for an ESA: Once a disability has been established, it’s important to evaluate whether an ESA would provide a benefit to the person. This may involve assessing the person’s current functioning and determining if an ESA would provide emotional support that is necessary to mitigate the effects of the person’s disability. The animal is to be considered a medical device that will assist in alleviating some symptoms of the disability.

6. Ethics of licensure board: It is important to abide by the ethical standards and regulations set forth by your licensure board when conducting an evaluation for an emotional support animal. This may involve obtaining informed consent from the person being evaluated, maintaining confidentiality, and avoiding conflicts of interest.

7. Recommendations for ESA: If you determine that a person meets the criteria for an ESA, there is not a clear cut on what needs to be included in the recommendation documentation.

Some say it is important to provide a recommendation that includes the type of animal, the specific tasks the animal will perform, and the frequency of contact the person needs with the animal to benefit from its therapeutic effects.

Others state that since the provider is not evaluating the animal nor are they animal behaviorist then they cannot specify those things and to do so would be outside their scope of training.

8. Dangers of emotional support animals: While emotional support animals can provide benefits to some people, they can also pose risks if not properly trained, socialized, or managed. It’s important to educate people about the responsibilities that come with owning an ESA and to provide recommendations for how to ensure the animal’s safety and well-being, as well as that of the person being evaluated.

9. The health and well being of the animal must also be taken into account. Is the mental health disability so severe it could impact the well being of the animal.

10. The evaluations should be conducted periodically. Federal laws can change year to year. Diagnostic criteria may change. The patient’s / client’s well-being may improve and no longer meet the criteria for an ESA. It is best practice to have the most current up to date picture of the individual and their circumstances. A minimum there should be another full-scale evaluation every year.

SubRosa Mental Services provides a client-forward approach to helping individuals, businesses, and children, in addition to offering life coaching and emotional support animal assistance. Reach out today to find out more.

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Links & Resources

  • American with Disabilities Act FAQ for Service Animals
  • Different Types of Psychiatric Service Dogs
  • Emotional Support Animals
  • What is the forensic evaluation I am doing?
  • Who Can and Cannot Do Forensic Evaluations for Emotional Support Animals and Psychiatric Service Dogs

Books

Written by Dr. Shiloh W. Martin, the book draws on his personal faith and professional expertise to provide guidance and encouragement for individuals struggling with mental health issues and their loved ones. The book explores various mental illnesses–such as depression, anxiety, and bipolar disorder–and uses scriptures to provide comfort, hope, and practical advice.

Click for details

The Anxiety Solution: Regaining Control and Finding Peace,” extends a helping hand to guide you through the labyrinth of anxiety toward a sanctuary of tranquility.

In this empathetic and insightful guide, you’ll discover practical and proven techniques to not only alleviate anxiety but to empower yourself with lasting peace.

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