Service Animals and the ADA: A Guide for Medical Facilities

Service animals provide essential support for people with disabilities. This support is protected under the Americans with Disabilities Act (ADA), and as a healthcare provider, balancing compliance and your office environment isn’t always straightforward. For example, when a patient walks through your doors with a service animal, staff members might be unsure about what they are allowed to ask, or how to handle other patients who might be afraid of dogs.

Understanding the Distinction: Service Animals vs. Emotional Support Animal

One of the most common sources of confusion in medical settings is the difference between a legitimate service animal and an emotional support animal. It is crucial to understand that service animals and emotional support animals are treated very differently under the law.

What is a Service Animal?

Under the Americans with Disabilities Act (ADA), a service animal is defined specifically as a dog that has been trained to do work or perform tasks for a person with a disability. The task must be directly related to the individual’s disability.

What about Emotional Support Animals?

Emotional support animals (ESAs), therapy dogs and comfort animals provide companionship, relieve loneliness and sometimes help with depression, anxiety and certain phobias, but they do not have special training to perform tasks that assist people with disabilities.   

Under ADA service dog laws, emotional support animals are not considered service animals. Consequently, they do not have the same access rights to public spaces. Even if a doctor has prescribed an emotional support animal as part of a treatment plan, they are not afforded the same protections under the ADA as service animals.

Determining if an Animal is a Service Animal

Your front desk staff and clinical team cannot ask for medical documentation or proof of certification for a dog. This is often a point of anxiety for staff who want to follow the rules but don’t want to violate privacy rights.

When it is not obvious what service an animal provides, staff may ask only two specific questions:

1. Is the dog a service animal required because of a disability?
2. What work or task has the dog been trained to perform?

That’s it.

If the handler cannot identify a specific job or task the dog has been trained to perform (e.g., they say “he just makes me feel safe” or “he’s for emotional support”), the animal likely does not meet the criteria for a service animal under the ADA.

Access Rights: Where Can They Go?

A frequent question from facility managers is: Are service dogs allowed in hospitals and exam rooms?

The general rule is yes. Service animals in medical facilities must be allowed to accompany people with disabilities in all areas where the public is allowed to go. This includes:

• Patient waiting rooms
• Clinics
• Cafeterias
• Examination rooms

Exceptions for Sterile Environments

While access is broad, it isn’t absolute. Service animals can be restricted from areas where their presence would fundamentally alter the nature of the service or pose a direct threat to safety. The most common example in healthcare is a sterile environment.

Service animals may be restricted from: 

• Operating rooms
• Burn units
• Sterile cores
• MRI rooms (due to metal on collars/harnesses)

However, they should generally be permitted in standard patient rooms and other non-sterile treatment areas.

What about ESAs?

So, are emotional support dogs allowed in hospitals? Under the ADA, they do not have the guaranteed right to enter. However, facilities can choose to allow them if they wish or they may have specific policies restricting them. It is important to have a clear policy in place so staff can handle these situations consistently.

Handling Allergies and Fear

It is not uncommon for staff or other patients to have allergies to dogs or a fear of them. However, under the ADA, these issues are not valid reasons for denying access or refusing service to people using service animals.

If a patient or staff member is allergic, the facility should try to accommodate both parties. For example, you might place the patients in different areas of the waiting room or schedule them for different times if possible. You cannot, however, isolate the person with the service animal or treat them less favorably.

When Can You Ask a Service Animal to Leave?

ADA service dog laws do provide protections for your facility if an animal is behaving poorly. A person with a disability can be asked to remove their service animal from the premises if: 

1. The dog is out of control and the handler does not take effective action to control it.
2. The dog is not housebroken.

It is important to note that the facility is not responsible for the care or supervision of a service animal. If a patient is unable to care for the animal during a procedure (for example, if they are going under general anesthesia), they must make arrangements for someone else to care for the dog.

By understanding these distinctions and rights, your facility can ensure it remains welcoming, compliant and safe for everyone.