Annotated exhibit

What the paperwork actually has to say

Almost every argument over documentation comes down to two things: whether the writer knows the person, and whether the page answers the narrow question that was put. Below is a specimen, marked up element by element.

A specimen, marked up

Four numbered elements do the whole job. Everything else is decoration.

Practice letterhead Street address · telephone · licence number · dated

1 I am a licensed clinician and I have an ongoing professional relationship with the person named above.

2 They have an impairment that substantially limits one or more major life activities.

3 The animal alleviates one or more effects of that impairment.

4 Signed, printed name, credential and the date of writing.

1
A real relationship, stated plainly The writer must actually know the person. A signature bought after a two-minute online questionnaire is the single most common reason a page gets rejected.
2
The impairment, not the diagnosis The functional statement is what is asked for. Naming the condition adds nothing legally and hands over private health information for free.
3
The connection to the animal This is the sentence people leave out. Without it the page proves an impairment exists and stops there.
4
Attributable and current A signature that can be traced to a real practice, and a date recent enough to describe the present situation.

Who is in a position to write it

Broader than most people assume, and not limited to prescribers.

Treating cliniciansPhysicians, psychiatrists, nurse practitioners and physician assistants who see the person.
Mental-health professionalsPsychologists, licensed counsellors, clinical social workers and marriage and family therapists.
Peer and support workersCase managers, peer-support specialists and staff at agencies that serve people with disabilities.
Someone who simply knowsWhere the impairment is observable day to day, a person with first-hand knowledge can attest to it.

No speciality is required, no particular licence, and no state boundary applies to the writer. What matters is that the signer has knowledge to draw on.

The fence around the enquiry

Requests fall cleanly on one side of it or the other.

Inside the fence

  • Confirmation that an impairment exists
  • How the animal eases its effects
  • Who wrote the page and how to reach them
  • Whether the writer knows the person
  • The date the statement was made

Outside the fence

  • The name of the condition
  • Treatment notes or medication lists
  • Access to the medical file itself
  • A proprietary form as the only accepted route
  • Notarisation, or a fee paid to the provider
  • Annual renewal of a permanent impairment

Signals that the paper is worthless

Sites selling instant approval are the fastest way to lose a request you would otherwise win.

An identification card, vest or numbered listing. No public body maintains a roster of these animals, so nothing sold as an entry in one carries authority.
Approval promised within minutes. A judgement about someone's functioning cannot be reached before anyone has spoken to them.
A signer licensed nowhere near the customer. Several states now require the writer to hold a licence valid where the person lives, and vendors routinely ignore that.
A money-back guarantee on the outcome. Nobody can guarantee how a housing provider will decide, and offering to is a confession about the product.
Wording that mentions public entry. A page about shops and aircraft signals a template that was never written for a housing request at all.

After you hand it over

What the recipient may do with it, and what they may not.

The recipient may read it, may telephone the signer to confirm the page is genuine, and may keep a copy in a file connected with the request. They should keep it apart from the general tenancy record, and share it only with people who need it to reach the decision.

What they may not do is treat it as an invitation to go further — ringing round other clinicians, asking the signer for the diagnosis, or demanding a second opinion from a professional of their choosing. Overstepping here is itself a basis for a complaint, separate from whatever happens to the underlying request.

Retain your copy and record when it left your hands. Should the decision be challenged afterwards, arguments about what was handed over, and on which day, are usually won by whichever party filed more carefully.

Frequent snags

Is anything needed at all when the impairment is visible?
No. Where both the impairment and its link to the animal are already apparent, the enquiry is finished before it starts and nothing more may be demanded.
Can a recipient insist on their own template?
They may offer one. They may not treat it as the only acceptable route, nor ignore information supplied in another format that answers the same narrow points.
How recent does the page have to be?
Recent enough to describe the present. Where the impairment is lifelong, insisting on a fresh page every twelve months is difficult to justify.
Does a telephone call from the signer count?
It can satisfy the recipient, but neither side ends up with a record of it. Follow the call with something written, even a short email confirming what was said.

24 CFR § 100.202

Sets out the general prohibitions on disability discrimination in housing and limits inquiries into whether a person has a disability.

Federal law

HUD Notice FHEO-2020-01

HUD's central guidance on assistance animals in housing: the difference between a service animal and a support animal, what information a housing provider may request, and how requests should be assessed.

Federal law

U.S. DOJ, ADA Requirements: Service Animals

The Justice Department's plain-language explanation of the ADA service animal rules for businesses and the public.

Federal law