The Advocate Magazine 2022 Issue 3 | Page 10

The board clarified that counselors ( and other mental health professionals ) should not write ESA letters unless they have appropriate training , education , and experience in assessing the need for ESAs ; have considered potential risks and liabilities for use of an ESA ; and have provided in-person assessment and diagnosis .
Ethical Codes , Practice Standards , and ESA Letters
AMHCA ’ s Code of Ethics www . amhca . org / ethics requires that counselors “ advocate at the individual , institutional , professional , and societal level to foster sociopolitical change that advances client and community welfare ” ( I . F . 2 ). On one hand , if a client has a legitimate psychiatric disability and the use of an ESA would alleviate the effects of that disability , then writing an ESA letter might be considered a form of advocacy . On the other hand , our code requires that we remain objective ( I . A . 1 ); maintain high standards of competence ( I . C . 1 ); uphold our responsibilities for the welfare of both the client and the general public ( I . C . 1 ); limit our actions to those areas in which we are competent to practice ( I . C . 1 . a , I . C . 1 . b ); base our diagnoses and recommendations on multiple sources of data ( I . D . 2 . a ); remain familiar with state and federal laws and how they impact our work ( preamble ); and limit our treatment plans to interventions that “ offer reasonable promise of success and are consistent with the abilities ; ethnic , social , cultural , and values backgrounds ; and circumstances of the clients ” ( I . B . 1 . a ).
How might we balance these ethical prerogatives ? In my opinion , it would be wise to avoid writing an ESA letter if any of the five following conditions apply :
1 . You are not trained in and competent with disability determination . When writing an ESA letter , you are attesting that a person has one or more disabilities and that without an ESA , the client will not be able to function . If you cannot articulate what your client ’ s

Counseling Clinical Update Tips continued from page 910

Additional Resource
The National Board of Forensic Evaluators ’ ( NBFE ) on-demand webinar , “ 2021 Update : The Mental Health Professional ’ s Role in Evaluating the Need for Emotional Support Animals ,” has been approved for three CEs by NBCC . nbfe . net / event-4698668
1 . disability is , the specific functional limitations posed by those disabilities , and how the presence of a specific animal would somehow compensate for those functional limitations , then you should not write a letter .
2 . Your only source of data is the client ’ s self-report . Counselors should use additional data sources ( e . g ., tests with validity scales , records reviews , collateral interviews , etc .) to rule out whether a client is exaggerating or even feigning symptoms in order to obtain a letter .
3 . You are not intimately familiar with federal law as it pertains to ESAs and housing . I would recommend that you obtain , read , and become intimately familiar with the U . S . Department of Housing and Urban Development ’ s published guidance on assessing the need for ESA letters , bit . ly / 3rOjWJC .
4 . You have not thoroughly examined with your client the potential benefits and drawbacks of an ESA letter , or in your best clinical judgment , it would not be in the client ’ s best interest for you to write a letter . The Human Animal Interventions in Counseling Interest Network of the American Counseling Association issued a position statement on ESA letters in 2019 , bit . ly / 3Co3413 , that includes several potential benefits and drawbacks of ESA letters and can serve as a helpful reference . Also , in my 2018 article ( see box on page 8 ), I discussed the importance of formulating a goal of no longer needing an ESA to function ( i . e ., maximizing client autonomy ).
5 . You do not have evidence that an ESA will be an effective intervention . Though multiple studies document psychological benefits associated with pet ownership and interactions with animals , to date I have not found a single well-designed study demonstrating that ESA letters improve client outcomes ( hint : Sounds like the kind of gap in the professional research that would make for a good dissertation ). Given the absence of empirical support for this intervention , I think it is important that CMHCs be able to articulate the evidence that an ESA letter will improve outcomes for a client before writing a letter .
10 The Advocate Magazine 2022 , Issue # 3 American Mental Health Counselors Association ( AMHCA ) www . amhca . org