Policy: Service Animal Policy Originator:  

All Original Issue Date: 7/1/2024  

 

Regulatory References:  

28 CFR 35.164; 28 CFR 36.104; 28 CFR 36.302(c)(2), 36.303; 29 CFR 38.9(f)(2), 34 CFR Part 361.5(9); 42USC 12182, Americans with Disabilities Act Effective Communication Guidelines; Americans with Disabilities Act of 1990 (as amended) Section 12102(1 ), Americans with Disabilities Act of 1990 (as amended) Section 12102(2), Americans with Disabilities Act of 1990 (as amended) Section 12103(1 ), Americans with Disabilities Act Amendments Act of 2008 Section 4(a)(2), Americans with Disabilities Act Amendments Act of 2008 Section 4(a)(2)(B), Rehabilitation Act of 1973 Section 7(5), TCA 62-7-112 Admission of Service Dogs in Places of Public Accommodation, Office of the Attorney General, State of Tennessee July 26, 2013 Opinion Number 13-59 What Constitutes a “Service Animal” and Accommodation Thereof, Under ADA, 75 ALR Fed. 2d 49 

 

Subject:  

Service Animals in Integrated Skin Institute (ISI) Facilities  

 

Policy:  

It is ISI’s policy to comply with all State and Federal laws, regulations, and policies regarding the accommodation of Service Animals in all ISI locations and buildings.  

 

Service animals are used by individuals with disabilities to assist with activities referred to and 

defined as “work tasks. For the purpose of this guidance, the appropriate work or task of a service animal may include, but is not limited to: • 

  • Assisting individuals who are blind or low vision with navigation and other tasks  
  • Alerting individuals who are deaf or hard of hearing to the presence of people or sound 
  • Providing nonviolent protection or rescue work  
  • Pulling a wheelchair  
  • Assisting an individual during a seizure  
  • Alerting an individual to the presence of allergens  
  • Retrieving items such as medication or the telephone  
  • Providing physical support, assistance with balance, and stability to individuals with mobile disabilities  
  • Helping people with psychiatric and neurological disabilities by preventing or interrupting impulsive or destructive behaviors  

 

 

A Work Tasks May Not Include:  

  • The crime deterrent effect of the animal’s presence 
  • The provision of emotional support, well-being, comfort, or companionship 

 

For this reason it is important to understand:

The legal definition of a service animal. 

          Responsibility of accommodation in            policies, practices, and procedures. 

Access to areas of public accommodation.

Inquires that can be made in regard to a service animal. 

The animal is out of control and effective remedial action is not taken, or fundamentally alter ISI’s operations, policies, practices or procedures. 
 

The animal is not required to be in a vest or otherwise be labeled for ISI to accommodate the Service Animal.  

The Service Animal may be excluded from operating rooms or areas where the animal may compromise a sterile environment.  

Allergies and fear of dogs are not valid reasons for denying access or refusing service to people using service animals.  

Individual with a Disability Defined:  

Has a physical or mental impairment that limits one or more major life 
activities; 


Has a record of such an impairment; or 


Any dog that is individually trained to do work or perform tasks for the benefit of an individual with a disability. In some circumstances, this can also extend to miniature horses.

 

Service Animals explicitly does not apply to emotional support animals. 28 C.F.R. §§ 35.104, 36.104, 35.136(i) (2010).  

 

When a person presents to a ISI location, an employee, contractor, vendor, volunteer, et al may:  Ask what tasks the animal is trained to perform. 


  1.  

Staff Must Not:  

-Require documentation to support service animal status (e.g., ID card, proof 
of certification and training);  

-Refuse access based upon allergies and fear of dogs; 
 

-Pet the service animal (May distract from assigned tasks); 
 

 

Requirements for Service Animals 

Service animals must be under the handler’s control at all times via at least one of the following:  

-Harness
 

-Leash
 

-Tether
 

-Voice control
 

-Motion / signal control
 

-Other effective controls


Exception —  

The devices listed above need not be used if they: 

  1. Interfere with the service animal’s work;  
  2. Person’s disability prevents using these devices 

 

Excluding or Removing Service Animals  

Any decision to exclude service animals from ISI shall be made only after an individualized assessment that the animal poses a direct threat to the health or safety of others that cannot be mitigated by modifications of policies or procedures or the provision of auxiliary aids or services. 

The Regional or Office Manager shall conduct the individualized assessment of direct threat in consultation with Compliance. 
 

The individualized assessment of direct threat must be based on reasonable judgment that relies on current medical knowledge or on the best available objective evidence to ascertain: 
 

  • the nature, duration, and severity of the risk
  • the probability that the potential injury will actually occur 

 

 

Medical Appointments