HRRMC Letter to the Editor of the Ark Valley Voice,
I am writing on behalf of Heart of the Rockies Regional Medical Center (HRRMC) in response to the story posted by Jan Wondra on February 17, 2020, entitled, “Service Dog Dispute Appears to Pit Americans with Disabilities Act against HRRMC Policy.”
Due to state and federal health care privacy laws (including HIPAA), HRRMC is not able to discuss any specific patients’ situations with the media, even when a patient may choose to publicize a dispute he or she may have with the hospital in the media.
What HRRMC can say—and would like the Ark Valley Voice and its readers to know—is that HRRMC is committed to fully complying with the requirements of the Americans with Disabilities Act (ADA), including its provisions related to service animal access. HRRMC welcomes and urges any patient, guest or visitor with a disability who accesses our facilities and believes his or her ADA rights may have been violated, to bring such concerns to our attention. We are more than willing to meet with such persons to promptly address such issues because we are fully committed to complying with the law.
Unfortunately, we must point out a significant inaccuracy in Ms. Wondra’s story that could be misleading to your readers and the public. The article accurately reports that service animals are permitted “into any area that is accessible to public accommodations—in other words, anywhere the public is allowed to go,” but then it mischaracterizes this ADA access requirement as having “no exceptions.” That is not accurate. In fact, in the very next sentence Ms. Wondra accurately reports one such exception: “Service animals can’t be in the restricted environment of sterile operating rooms.” Moreover, later on in the article she accurately reports two other exceptions: a service animal can be excluded from a place of public accommodation when a service animal is out of control or when it is not housebroken. In addition to those exceptions, the ADA also permits service animals to be excluded from public areas when an individual or a service animal poses a direct threat to the health or safety of others, and when accommodating a service animal would fundamentally alter the nature of the service, program, or activity offered by HRRMC. So it is not accurate to report that the ADA service animal access rule has “no exceptions.”
Consistent with the ADA, the ADA regulations, and Department of Justice and Centers for Disease Control and Prevention Guidelines, HRRMC permits service animals in all public areas of its healthcare facilities, including public pre-operative areas, but restricts service animals from operating rooms, procedure rooms and other sterile, limited-access areas where either general or specific infection control measures are in place to protect patients and the health and safety of the public.
Because some hospital staff may encounter patients with service animals only on an infrequent basis, it is entirely appropriate for such staff to consult with their supervisors, hospital policies, hospital administrators and applicable regulatory guidance in cases where it is unclear to a staff member whether a service animal is permitted in specific areas of the hospital, particularly in and near surgical areas where infection control measures may be in place.
HRRMC is very pro-animal in the hospital, as the HRRMC Therapy Dog Program has been in existence for over ten years. Pet therapy is a term that includes animal-assisted therapy and other animal-assisted activities. Animal-assisted therapy is a growing field that uses dogs or other animals to help people recover from or better cope with health problems, such as heart disease, cancer and mental health disorders.
Currently 12 certified teams (comprised of a handler and dog) serve our hospital seven days a week. The teams are certified therapy animals through the Alliance of Therapy Dogs, International. Therapy animals go through extensive training, and handlers are vetted with a background check, Tuberculosis Test, Influenza vaccination, and complete a screening interview, in addition to receiving training on HIPAA rules and regulations to protect patient privacy. These teams provide joy, ease and comfort to our patients, visitors, and staff.
HRRMC thanks the Ark Valley Voice for the opportunity to respond to the important issues raised by this story.
Bob Morasko, CEO at Heart of the Rockies Regional Medical Center
Editor’s note: Ark Valley Voice will always post letters to the editor that contain relevant and fact-based information and works closely with sources to insure accuracy in our articles. In this case the portion of the letter above referring to the point in the article which reads “ADA, verified service animals are recognized under Title II and Title III, and are allowed to accompany their human handlers into any area that is accessible to public accommodations – in other words, anywhere the public is allowed to go, with no exceptions,” is indeed mischaracterized. The statement referenced public ares, not sterile operating rooms where the public isn’t allowed, and it is still not clearly stated whether HRRMC will allow working service dogs into the area where the conflict occurred last week. That said, we truly appreciate Mr. Morasko and HRRMC pointing this out and will continue to work very carefully to assure that the right information on this important topic reaches the public.