This piece is a work of investigative commentary. All opinions expressed are those of the author and are based on publicly available materials, consumer testing, and submitted regulatory complaints. No specific company or individual is implied unless otherwise noted.

California’s ESA Law Is a Joke—And I’m the Punchline

Ever wonder how 20 minutes of chit-chat became a mental health care diagnosis? Welcome to California’s Emotional Support Animal letter mill economy.

I’ve been mystery shopping the ESA industry, and spoiler alert: it’s a steaming pile of “mental health care theater.”

The Law: AB-468 Was Supposed to Fix This

Back in 2022, California passed AB-468, a law aimed at stopping ESA fraud in its tracks. It requires:

• A 30-day therapeutic relationship before writing an ESA letter.
• A legit clinical evaluation from a licensed California therapist.
• Disclosure of license number and jurisdiction.
• No more instant, drive-thru ESA letters.

Sounds great on paper, right?

The Reality: 15 Minutes and a Dream

Let’s talk about ****, a so-called “industry leader.” Here’s their pitch to California clients:

• Session 1: 15 minutes
• Session 2: 5 minutes
• Cost: Around $150

Twenty minutes. That’s it.

Let’s be honest—this isn’t mental healthcare. It’s a transactional speed-run to generate a document that just so happens to waive your pet rent. You don’t even get a lollipop afterward.

And **** isn’t alone. At ****, I was told that one 15-minute session might do the trick—and if I paid extra, I’d have my letter today.

A 15-Minute Diagnosis? That’s Not a Relationship. That’s a Joke.

Do you really think a therapeutic relationship is built over a 15-minute Zoom call?

Let’s be clear: AB-468 doesn’t just require 30 days to pass—it demands a legitimate, ongoing relationship grounded in clinical judgment, not customer service scripts.

In real mental healthcare:

• Therapists develop personal knowledge over time.
• Assessment tools like the GAD-7 and PHQ-9 can take 45–90 minutes to properly administer and review.
• Diagnosis isn’t based on automated checklists with self-reported answers—it’s based on history, presentation, and documented impact.
• And where are the SOAP notes? Spoiler: they don’t exist in this scam economy.

Now let’s look again at ****’s idea of “care”: session two: 5 minutes.

Five minutes. I’ve waited longer for fries at Wendy’s. And yet I’m expected to believe meaningful mental healthcare happened?

Actual providers bill using CPT codes in 12-minute increments.
Sessions under 30 minutes? That’s not therapy. That’s a PDF delivery service. And not recognized by insurance companies.

So, why are ESA (ahem) “doctors” any different?

These ESA factories appear to delegate legal risk onto therapists while retaining revenue. No disclosed HIPAA-compliant protocols, no proper intake, no records retention, no continuity of care.

HIPAA? What’s that—an optional upgrade?

Under HIPAA, if the platform stores ESA letters or clinical files for therapists, they’re a Business Associate. That means a Business Associate Agreement (BAA) is required—no exceptions.

Spoiler alert: Most of these mills likely don’t have them. That’s a possible federal violation. And the therapist? They’re on the hook.

Likely no BAA, no privacy policy, no safeguards. Just PHI floating around in Dropbox and Gmail, praying the feds aren’t watching.

Another spoiler alert: We’re jumping up and down, waving our arms.

So What’s the Medical Standard?

From Bridges v. Reinhard:

“In determining whether a plaintiff is substantially limited, several factors must be considered, including the nature and severity of the impairment, the duration, and the permanent or long-term impact.”
— 29 C.F.R. § 1630.2(j)(2)

Now tell me—what therapist is evaluating all that in 15 minutes?
This isn’t medicine. It’s mail merge masquerading as mental health.

What Real Mental Health Evaluation Looks Like

Before anyone issues an ESA letter, California law (AB‑468) and basic clinical ethics demand two things:

A Legitimate Provider–Patient Relationship

This isn’t a checkbox. It’s not a 5-minute phone call with a licensed stranger. It’s a real relationship built over time.

• The provider should know the person, their background, and their mental health history.
• Continuity matters—not just a chat and a charge.

You don’t “establish care” in ten minutes any more than you perform surgery at a Jiffy Lube.

A Real Clinical Evaluation

Let’s be blunt—ESA mills aren’t doing this.

• Real evaluations include interviews, standardized assessments, and follow-up.
• Tools like the GAD-7 (anxiety screener) and PHQ-9 (depression inventory) take time, not five minutes.

These tools aren’t checklists to justify a receipt. They’re diagnostic components used by actual professionals—not subscription-based PDF factories.

What About the DSM-5 Cross-Cutting Symptom Measure?

Oh, you mean the BuzzFeed quiz of the mental health world? Let’s go.

Yes, it’s published in the DSM-5. But it’s not a diagnostic tool—it’s a broad, self-reported screener meant to start a conversation, not justify federal disability protections.

Why it’s a joke when misused:

• It’s self-report only—no provider input required.
• It has no scoring scale—nothing to determine clinical severity.
• It screens for everything from mild sleep trouble to psychosis but doesn’t explain what any of it means.
• And most importantly: it requires interpretation by a provider who’s paying attention.

If your ESA letter is based on a DSM-5 Cross-Cut with no notes, no follow-up, and no clinical assessment, you didn’t get evaluated—you got conned.

Using the Cross-Cut alone is like waving a rectal thermometer in the air and calling it a physical.

The Coupon Industry

Let’s be real: ESA letters are being sold like discount codes, not medical documentation.

• Pet rent: $30/month
• Annual cost: $360
• ESA letter: $149

Do the math. The letter pays for itself in 5 months—and these mills know it.
They’re not providing legitimate therapeutic services—they’re selling financial loopholes wrapped in medical drag.

No treatment plan. No follow-up. No provider-patient relationship.
Just a glorified coupon code for avoiding fees.

****,: The 30‑Day Two‑Ring Circus

Here’s what **** claims on paper:

“A quick call to go over some basic information… 30 days later, another call… then the letter.”

Sounds legal-ish, right?

Then I asked how long these calls were and what’s discussed. Their answer?

“Your provider will only call you if they have any question. In most cases, intake form is self explanatory.”

Translation?
There’s no real contact. No therapy. No evaluation.
Just a self-filled form and a 30-day delay to look compliant.

This isn’t mental health—it’s document laundering.

****: When Customer Support Confirms the Scheme

Still think I’m exaggerating?

Here’s what ****’s own rep, ****, told me on June 17, 2025:

“It would be one 15-minute call the first time, then just a 5-minute call the second time. The price would be $169 in that case.”

That’s 20 minutes of total contact…
For a provider-issued disability accommodation assessment protected under federal housing law.

This isn’t a clinical process.
It’s a two-click sales funnel.

**** Letter: California Law, Compressed to 10 Minutes

This one really leans into the “time-delay theater” tactic:

“Each session typically lasts between 5–10 minutes… The ESA letter is issued only after both sessions are completed and the 30-day period has passed.”

So 10 minutes of chit-chat.
30 days of nothing.
Then a letter.

If you think that qualifies as a “therapeutic relationship,” I’ve got an ESA ferret to sell you.

****: Emoji Compliance and Empty Confirmations

I asked a simple question:

“So, two meetings, 10–15 minutes each, over 30 days and letter after?”

Their response?

“Yes. :)” — Customer Service, ****

That’s it. A smiley face.
No clinical standards. No details. No concern.

That’s not health care. That’s emoji-based compliance with a PDF attached.

**** Weighs In (and Weighs Light)

When asked about California’s legal requirements, **** reportedly stated:

“One session of 15 minutes” is all it takes.

In my opinion, that’s absurd and dangerous.
It doesn’t meet the spirit—or the letter—of AB-468.

This isn’t provider judgment. It’s a rubber stamp issued in record time, wrapped in medical credentials and marketed like it’s totally fine.

If you’re slinging federal disability documentation in 15 minutes, you’re not helping patients—you’re helping your Stripe account.

The Problem: No Oversight. No Accountability.

Here’s the truth:

• States like California pass strong laws—but rarely enforce them.
• Federal regulators won’t move unless a toddler gets bit on a plane.
• Many therapists use these platforms to cut corners and cash checks.
• Most clients don’t even know they’re being scammed.

And the result?

Thousands of unqualified ESA letters flooding housing providers, airlines, and college dorms—backed by shaky clinical work and smiley-face support emails.

This is not a therapeutic system.
It’s a compliance cosplay business, and nobody’s shutting it down.

REVOLT’s Testing Operation

That’s why we launched To Catch An ESA™—a sting-style campaign targeting these mills.

We mystery-shopped them. We posed as clients. We ran the clock. We took notes.

Here’s what we found:

• No clinical evaluation
• No disclosed HIPAA-compliant protocols… Likely no BAA
• No meaningful contact with a licensed provider
• Letters issued within 24 hours after payment—sometimes instantly

In our view, this resembles PDF drop-shipping more than clinical care.

And that might be illegal in California. That’s the part they’re all pretending doesn’t exist.

Real Letter, Real Problem: The Melissa Montrose Example

Still think we’re making this up?

In April 2025, the Louisiana State Board of Social Work Examiners publicly disciplined Melissa Montrose, LCSW.

“Ms. Montrose was selling emotional support animal letters online for a fee… to individuals whom she does not know, has not met with, and is not treating beyond a phone call of ten minutes or less.”

This isn’t just California. This is coast-to-coast.

• Licensed clinicians selling credibility
• Online platforms processing orders like pizza
• State boards waking up—but only after damage is done

If Louisiana’s willing to act, where the hell is California?

Melissa Montrose

Ready to Burn the ESA Scam Down?

We’ve seen enough.

These ESA mills aren’t providing healthcare. They’re running a legally gray, medically hollow, monetization machine that:

• Undermines fair housing law
• Puts real patients at risk
• And dilutes the credibility of legitimate therapeutic services

That’s why REVOLT Training is taking the fight beyond words:

We have submitted complaints alleging potential violations to:

• California Department of Consumer Affairs (DCA)
• California Board of Behavioral Sciences (BBS)
• U.S. Department of Health and Human Services – HIPAA Division
• Federal Trade Commission (FTC)
• Florida Attorney General’s Office
• California Attorney General’s Office
• Texas Attorney General’s Office

We’re working with civil rights groups, disability housing advocates, and investigative journalists to blow the lid off this industry.

And we’re just getting started.

Want to Tear This System Down?

Join REVOLT.training. We’ve got:

• Blueprints
• Media reach
• Legal expertise
• And zero fear of calling this industry what it is: a for-profit fraud wrapped in medical lingo.

The ESA letter scam is a house of cards.
Let’s be the wind.

About the Author

I’m Dr. T. Chaz Stevens, founder of REVOLT Training, investigative reformer, media manipulator, and longtime thorn in the side of bureaucratic nonsense.

Over the last three decades, I’ve:

• Exposed corrupt Florida politicians (some now behind bars)
• Forced the State of Florida to roll back its book ban law
• Weaponized public records, free speech laws, and malicious compliance for social change
• Served as a very competent pro se federal litigant, currently active in Stevens v. LaMarca, Case No. 0:23-cv-61523-AHS (S.D. Fla.)

This ESA exposé is part of a larger campaign to hold bad actors accountable—from licensed professionals abusing public trust to companies profiting off regulatory gray zones.

We expect pushback.

We welcome it.
We look forward to discovery.
Bring your lunch, ‘cause I’m gonna eat it.

Ready to Burn the ESA Scam Down?

We’ve seen enough.