Online Certifications for Assistance Animals: What You Should Know
HUD has recently focused its attention on websites that sell assistance animal certifications. HUD Secretary Ben Carson has asked the chairman of the U.S. Federal Trade Commission and the director of the Bureau of Consumer Protection to investigate these websites for compliance with federal laws that protect consumers from unfair and deceptive acts or practices. “These certificates are not an acceptable substitute for authentic documentation provided by medical professionals when appropriate,” said Secretary Carson. HUD has identified at least one website that contains the seal of HUD without authorization.
Knowing the rules on disability verification is essential to avoiding the common mistakes that lead to complaints involving requests for assistance animals. It’s particularly important to understand the verification rules now that so many applicants and residents can go online and find a quick “certification” process to say their dog is a certified assistance animal. Often, you’ll be presented with an official-looking certificate embellished with a gold seal and ready for framing. If an applicant or resident submits one of these certifications, don’t reject the request out of hand simply because it makes you suspicious. You still have an obligation to consider, respond, and act upon the request for an assistance animal.
First, you should determine whether the certification meets the requirements that it’s reliable and from someone familiar with the applicant’s disability. If it doesn’t, it’s better to say thank you, make a copy for the file, and explain to the applicant that the site requires verification from a knowledgeable third-party healthcare provider.
Explain that you need the name and contact information of the person’s healthcare provider so that you can send out a verification form. Politely decline an offer by the applicant to get the form signed himself. Explain that the site’s policy is to send out the form directly to the healthcare provider and to have it sent back directly to you.
Your form should allow you to get confirmation from the applicant’s treating healthcare provider to verify that the applicant is under the provider’s care and treatment and has a diagnosed medical or mental condition that renders the patient disabled. Also, you may request confirmation from the provider that the animal is prescribed to assist with the disability.
For Model Forms you can adapt and use to verify a resident’s need for an assistance animal, see “How to Handle Online Assistance Animal Certifications for Reasonable Accommodations,” available to subscribers here.