Handling Emotional Support Animal Requests With Care
Reasonable accommodation requests for assistance animals—including emotional support animals—create challenges for many apartment owners. They affect an owner’s ability to assess pet deposits and fees and to apply rules and policies to the requesting resident’s animal. Additionally, they expose owners to possible fair housing complaints.
To help with this issue, NAA hosted a webinar, "What the What? How to Approach Emotional Support Animal Requests," on Oct. 13. The event was well received by NAA members and 334 attendees participated in the event. The webinar featured Katie Wrenn, Regional Training and Marketing Director at Milestone Management and President of the First Coast Apartment Association, and Kirk Cullimore, Esq., Board Member and Past President of the Utah Apartment Association.
During the call, the speakers explained the basics of the law as well as lessons learned from practical experience in the field. Ms. Wrenn and Mr. Cullimore also provided information about the resources available in the NAA Toolkit, Emotional Support Animals: A Practical Guide to Reasonable Accommodation Requests, including sample forms approved by HUD through the conciliation process.
NAA compiled the answers from the webinar speakers to the top 25 questions asked by participants. This document serves as a supplement to the Frequently Asked Questions featured in the NAA Toolkit. Below are a sampling of the questions that were most commonly asked by attendees.
- How do we determine if someone has a disability? Do they have to have something in writing from a medical doctor?
- I have been presented with a so-called prescription which is simply purchased online. Do I need to accept that in lieu of the Verification for Assistance Animal Form?
- Can one person have multiple service animals? If you have a two-animal limit per apartment, do you have to allow a resident a third if one is an emotional support animal (assistance animal)?
- If a resident moves in with a pet and then later claims the animal is an assistance animal, do we have to return pet deposits, fees or rent? What about seeking payment for back pet rent?
- What steps can be taken if the assistance animal exhibits aggressive behavior or has a habit of lunging towards staff or other residents?
- What about service animals in training? Can they be treated as pets?
- How does this apply to a rent by the room situation? With respect to student housing, how would you handle a situation where one roommate requests an assistance animal while a fellow housemate objects? What if one roommate is allergic?
Answers to the questions above and many more can be found here (member login required) on the NAA website. This page houses all of NAA’s resources on reasonable accommodation requests for assistance animals, including the Q&A Addendum, the NAA toolkit on emotional support animals, any updates to the toolkit and the webinar recording. For more information on this issue, contact Nicole Upano, Manager, Government Affairs for NAA.