Section 8 Medical Expenses for Assistance Animals

At AHTCSOnline, we wanted to start off the New Year by talking about the medical expenses of assistance animals. The HUD regulations can be a bit hazy at times particularly regarding the cost of medical expenses for assistance animals.

When we search the HUD handbook 4350.3 for written guidance, policy or notices for what expenses can be deducted for assistance animals…we find food and vet care being addressed in 4350.3, but what about treats, toys, groomer, clothes, carpet cleaner, pet beds…when the handbook uses the term ‘animal and it’s upkeep’ some may view it as vague…

Although there may be scant guidance in the HUD regulations we define upkeep to mean those things that are “necessary”. Things like food, grooming, vet visits and even treats we generally see as upkeep items. Clothing, specialty items etc. we tend to view as not necessary but we tend to rely on statements from a Dr. or Veterinarian for those items when necessary.

Another way to look at things may be to say “anything for the cost or care of the animal”. This includes the cost of the animal, costs for special training, vet bills, mileage to and from the vet, food, medicine, grooming fees (are as long as they are reasonable) etc.

So we would then exclude; toys, treats, cleaning supplies or clothes, because we feel that they are not necessary for the health of the animal or for the animal to perform the function of the assistance animal.

HUD gives some guidance in the HUD Handbook 4350.3 R1, C4, Exhibit 5-3.

What about pet insurance premiums? Could we assume that the out of pocket premiums for pet health insurance (solely for the assistance animal) would be included in the medical expense calculation?

Check with your Contract Administrator on this one but, it is likely they will not allow it with the reasoning that assistance animals are similar to “auxiliary apparatus” for persons needing a reasonable accommodation. Like a wheelchair. Insurance like pet insurance should not be allowed just like “insurance” you may take out to cover repairs for your wheelchair. We do not see assistance animals as household members so the same medical insurance premium expense should not be allowed for the animal as they are for tenants.