So far as I know, only Kindles can do this, because Kindle checkouts are entirely cloud-based, and Sony devices, because they include an ACSM verification "thingy".
Speculation has it that Kobo may soon be able to do the same, since OverDrive was bought out. But that certainly isn't the case at the moment.
darryl -- perhaps the patron doesn't like reading on a tablet. I certainly don't.
However, that looks like it may be the only way...