​Healthcare providers' "most biting questions" about service and comfort animals are answered by the law firm Baker Donelson in an August 2018 article. Animals now commonly accompany people to a variety of places, the authors say, and a healthcare facility should be prepared to encounter a patient with a service or comfort animal "sooner rather than later." Providers have a legal obligation to accommodate patients and members of the public who have disabilities, the authors note. Several federal laws require such accomodations, including the Rehabilitation Act (Section 504) and the Americans with Disabilities Act (ADA), as do certain Centers for Medicare and Medicaid Services requirements. However, service animals in a healthcare facility bring a host of risks, including allergies, spread of diseases, and biting. (For more information, see HRC Alerts, June 28, 2017: How Much Is That Doggie in the Healthcare Facility Contributing to Patient Risk?) The authors answer several frequently asked questions about service animals, including the difference between a service animal and a comfort or therapy animal. ADA defines a service animal as a dog or miniature horse that is individually trained to perform a task (such as pulling a wheelchair or alerting or protecting an individual having a seizure) for a person with a disability, the author said. Individuals who require service animals must be accommodated under ADA, the authors say. Comfort or therapy animals do not perform a specific job or task and do not need to be accommodated under ADA. A facility can, however, choose to accommodate such animals. When a patient arrives at an appointment with an animal, the authors explain, staff may ask only two questions about the animal: "Is this service animal required because of a disability?" and "What task or work has the animal been trained to perform?" Staff may not ask to see documentation or request that the animal demonstrate its training, they note. A service animal can be removed from a facility, the authors said, only if the visitor does not take effective action to control an "out of control" animal; the animal is not housebroken; the animal's behavior poses a threat to the health or safety of others; the facility cannot accommodate the animal's type, size, or weight (for instance, if the premises are too small to accommodate a miniature horse); or the animal would "fundamentally" alter the nature of the service being offered. In such cases, the authors say, the individual should be asked to return at a later time without the service animal.

HRC Recommends: Risk managers should ensure that their organizations have policies and procedures in place for the management of animals in their facilities. Additionally, risk managers should ensure that all appropriate settings are covered by the policy and that staff in those settings are aware of and enforce the organization's policies for the management of animals. The guidance from Baker Donelson can be used to distinguish in the policy between service animals and comfort or therapy animals.