Accommodating service animals in employment

Service animals may play a vital role in allowing employees with disabilities to perform essential job functions and participate fully in the workplace. Requests for such animals are becoming more common, and for dental employers, understanding the legal obligations is key to navigating this situation effectively.

Legal obligations

The Americans with Disabilities Act (ADA) as well as state or local disability laws require employers to provide reasonable accommodation to qualified employees with disabilities-unless doing so would cause undue hardship. A service animal may qualify as such an accommodation.

Generally, service animals are working animals, not pets. They perform tasks to help the disabled individual. Emotional support animals, while not specifically trained to "work," may also qualify.

Accommodation and the "interactive process"

When employees request to bring a service animal to work, they are essentially asking the employer to modify their no-animals-in-the-workplace policy. When this occurs, the employer must consider making reasonable accommodation on a case-by-case basis, which is an interactive process.

The first step is gathering the necessary information to make an informed decision. This can be done as a conversation with the employee, or, in a case where the disability is not obvious, requesting supporting documentation. Documentation may be as follows:

Certification indicating that the employee has a disability and related limitations. This will commonly come from a health-care professional; and
Documentation about the service animal to determine if it is appropriately trained to be in the work environment. This could be obtained from the person/company who trained the service animal. Alternatively, the employer could ask for a demonstration in the workplace of the service animal's capabilities.

The second step in the process is exploring accommodation options. Employers can offer other potential solutions that may be effective alternatives to bringing an animal to work, but given the kinds of tasks service animals do, they are likely the only fully effective option. When possible, service animals should be given preference. If an employer isn't sure whether having a service animal in the workplace will pose an undue hardship, the employer may allow the employee to bring the service animal to work on a trial basis. This helps base decisions on facts, not speculation.

Step three is denying/approving the request. If the request is denied, the employer must be able to prove it causes undue hardship, which is defined as an "action requiring significant difficulty or expense." It should be noted that coworkers/patients being fearful or allergic are not grounds for an immediate determination of undue hardship. The interactive process must always be done first, but certainly significant amounts of employees quitting or patients canceling could represent an obstacle that cannot be overcome.

For approved requests, discuss:

Expectations around the employee being responsible for the behavior and care of the service animal.

Off-limit areas and, if applicable, where the animal will stay if the employee must go to those places.

The frequency of the animal needing to relieve itself, where this will occur, and how cleanup will happen.
Utilizing approved break time for the care of the animal's needs, or other scheduling concerns.

Confidentiality prohibits informing coworkers about an employee's disability or accommodation unless the individual consents. If consent does not occur, let coworkers know there will be a service animal in the workplace, and they are not to interact with it.

The final step in this interactive process, assuming the request is approved, is to monitor the accommodation and make sure it is effective. Employers should check in with the employee occasionally and leave room for adjustments to be made if there are problems arising that were unknown initially.

Documentation

Throughout this interactive process and beyond, document everything. If the accommodation needs to be denied, or later rescinded, this will become critical if a lawsuit for discrimination develops. Employers will need to show they went through this interactive process properly and that an undue hardship existed.

Final thoughts

Accommodating a service animal in a dental office may not work for every (or any) situation, but it also shouldn't be dismissed without thoughtful consideration. By making such accommodations, employers create an environment where all employees can contribute their skills and talents fully and may foster a more inclusive, supportive, and diverse workplace.

Editor's note: This article appeared in the July/August 2025 print edition of Dental Economics magazine. Dentists in North America are eligible for a complimentary print subscription. Sign up here.