By Larry Dandridge
Someone much wiser than me once said, “I do not know where dogs go when they die, but that is where I want to go when I die.”
That is my sentiment exactly.
As a 100% service-connected disabled veteran, the emotional support and love provided by my miniature Italian Greyhounds (IGs) have always been a great comfort to me. My IGs are pets, not service dogs, but they are especially helpful when I suffer from PTSD symptoms of anxiety, grief, depression, and stress.
Animal Assisted Therapy
Most veterans know that the Veterans Health Administration (VHA) uses Animal Assisted Therapy (AAT) and Animal Assisted Activities (ATT) based on the clinical needs of patients. However, many veterans may not know the rules governing animals on VHA property.
Service animals (Dogs) are permitted on VHA Property. VHA Directive 1188 establishes the policy regarding any person who wishes to access VHA property accompanied by an animal. It is VHA policy to permit service animals to accompany individuals with a disability to all areas of a VHA property on the same terms and conditions, and subject to the same regulations, as generally govern the admission of the public, while maintaining a safe environment for patients, employees, visitors, and the service animal.
Non-service animals are not permitted on VHA Property without a waiver. Non-service animals are not permitted to access VHA property unless an exception applies under VHA Directive 1188.
VA and ADA regulations are similar
Although the Americans with Disabilities Act (ADA) and its implementing regulations concerning service animals do not apply to the VA,38 CFR 1.218(a)(11), and the VA adopt many similar standards as the ADA.
VA Service-Animal and Access to VHA property
A service animal is a dog that is trained to do work or perform tasks for the benefit of an individual with a disability, and must be granted access to VHA property when accompanying the disabled person. If an animal is not a dog, it is not a service animal and must be denied access to VHA property unless an exception applies under paragraph 5.b.(4) of VHA Directive 1188.
Only trained dogs are considered service animals at the VA. Only dogs that are trained to do work or perform tasks to assist an individual with a disability are service animals. If a dog is not trained (or is in training) to assist an individual with a disability, it is not a service animal and must be denied access to VHA property unless an exception is granted.
Determining if a dog is a service animal
When determining whether a dog is a service animal, VHA staff cannot: ask about an individual’s disability; require medical documentation; require a special identification card or training documentation for the dog; and cannot ask that the dog demonstrate its ability to perform the work or task.
When it is not obvious that a dog is a service animal, VHA staff may only ask the individual with a dog the following two questions to determine if the dog is a service animal:
1. Is your dog a service animal required because of a disability?
2. What work or tasks has your dog been trained to perform?
Granting or denying access to non-service animals
Only service animals that accompany individuals with a disability and that are specifically trained to assist that individual have a right to access VHA property. Any other animal may not access VHA property, except the non-service animals described in paragraph 5.b.(4) of VHA Directive 1188.
VA Medical Facility Director’s discretion
Non-service animals that may be granted access to VHA property may only access VHA property subject to the VA medical facility Director’s discretion and the criteria in VHA Directive 1188.
Approval of non-service animals
If the VA medical facility Director approves the presence of a non-service animal, the presence of that non-service animal should be cleared ahead of time with necessary VHA staff (such as VA police department).
Types of non-service animals allowed on VHA property
The following types of non-service animals are allowed on VHA property.
1. Animals for law enforcement purposes.
2. Animals under the control of VHA Research and Development.
3. Animals for *Animal Assisted Therapy (AAT). AAT is goal-directed interaction with animals and should be documented in the veteran’s medical record as part of their treatment regimen. AAT Animals must be up to date with vaccinations, and documentation of the vaccinations must be maintained in the activity area.
4. Animals for Animal Assisted Activity (AAA). AAA is casual interaction with animals for pleasure, education, and recreation, and is not goal-directed. Animals used in AAA must be up to date with vaccinations, and documentation must be maintained in the activity area.
5. Residential Animals. Animals may reside in a VHA Community Living Center or VHA Residential Rehabilitation Treatment Program to create a more home-like environment and provide a sense of familiarity and belonging. These animals must be up to date with all vaccinations, and documentation must be maintained in the residential area.
6. VA Medical Center Subject Matter Expert (SME) on Animals on VHA Property. The Ralph H. Johnson VA Medical Center and Healthcare System SME on this subject is the Public Affairs Officer Howard W. Capps. His phone number and email are 843-789-7699 and Howard.Capps@va.gov.
Service animals are not permitted to access certain VHA areas
To ensure that patient care, patient safety, and infection prevention and control standards are met, the following areas are prohibited for service animals.
1. Operating room and surgical suites.
2. Areas where invasive procedures are being performed.
3. Acute inpatient hospital setting when the presence of the animal is not needed as part of the treatment plan.
4. Decontamination, sterile processing, and sterile storage areas.
5. Areas where chemicals are stored or mixed.
6. Food preparation areas (not to include public food service areas).
7. Areas where personal protective clothing must be worn or barrier protective measures must be taken to avoid exposure to chemicals, blood, or infectious agents.
The bottom line
Service dogs are often identified by wearing a service dog vest or tag or both, letting the public know that it is a service dog. Dogs should also be on a leash, potty-trained, and well-behaved at all times.
Veterans and their families should read the following references to learn more about service animals and the VA.
References
- 38 CFR 1.218(a)(11)
- Animals on VHA Property, Directive 1188, 26 Aug 2016.
- VHA Animal-Assisted Therapies, https://www.va.gov/WHOLEHEALTHLIBRARY/tools/animal-assisted-therapies.asp.
- VHA AAT and AAA Directive 1178, 6 Nov 2018.
- VA PTSD CENTER, Dogs – PTSD, https://www.ptsd.va.gov/gethelp/dogs_ptsd.asp
- VHA Rehabilitation/Prosthetic Services (Dog Veterinary Health Benefit), https://www.prosthetics.va.gov/ServiceAndGuideDogs.asp.
- VHA Service Dog Veterinary Health Insurance Rules, https://www.prosthetics.va.gov/factsheet/PSAS-FactSheet-ServiceDogs.pdf.
Larry Dandridge is a Vietnam War wounded warrior, disabled veteran, ex-Enlisted Infantryman, ex-Warrant Officer Pilot, and retired Lt. Colonel. He is a past Veterans Service Officer, a Patient Adviser at the RHJ VA Hospital, the Fisher House Charleston Good Will Ambassador, and the VP for Veteran Affairs for the local Army Association Chapter. Larry is the author of the award-winning book Blades of Thunder and a contributing free-lance writer with the Island News. Contact him at LDandridge@earthlink.net or 843-276-7164.
