We agree with Stark's position that the use of dogs as therapy models would not require IACUC review and approval. The dog's presence would be as a 'working' guide dog rather than a 'research subject'.

The use of guide dogs as art therapy models could generate conflicting views from the Great Eastern University's IACUC. On the one hand, the use of a species regulated by the USDA through the AWA is occurring in conjunction with research conducted using federal funds. The AWA clearly defines terms such as animal, research facility, and handling. On the other hand, the dog is privately owned and does not come under the umbrella of the PHS Policy, which includes all activities involving use of animals in research, testing, and teaching.

Adequate assessment of the need for an IACUC protocol requires the consideration of two key elements. First, we do not know if Great Eastern's PHS Assurance excludes non-PHS-funded activities. Second, one should examine state laws pertaining to allowing animals in a hospital setting. Gershowitz should check the regulations of the county or state and the hospital's policy about the presence of animals in that facility.