Seeing-eye Dog: FSA Eligibility

Revenue Ruling 55-261 Treas. Reg. '1.213-1(e)(1)(iii)

What are seeing-eye dogs?

Seeing-eye dogs are a type of assistance or service dog that specifically helps with navigation for the blind and visually impaired. Seeing-eye dogs and expenses include those related to the animal's maintenance and care are eligible for reimbursement with a consumer-directed flexible spending account.

Seeing-eye dogs are covered under Americans with Disabilities Act (ADA) regulations which prohibit businesses and institutions from barring entry onto establishments by people with guide dogs or service animals. Seeing-eye dogs are specifically trained for individuals who are blind or visually impaired and require the dog's help to move in public. This is typically documented medically, though such documentation isn't required in the United States for public access by a guide dog and owner.

Seeing-eye dogs are normally trained across a variety of settings, including foster homes and professional training establishments. The investment to train a seeing-eye dog is significant and requires months and sometimes years of training by professional dog trainers. Certain dog breeds are more suited to perform as a seeing-eye dog. Certain training organizations may be more willing to work with different breeds.

Seeing-eye dogs are useful for giving a blind or visually impaired owner the confidence to take advantage of outdoor mobility. They perform this task by assisting their owners in navigating in straight lines from point to point, accounting for changes in elevation along the way. The owner must know the overall directions to their destination, but the dog will help them safely reach point along the directions, and to note changes in elevation such as curbs, streets, stairs, etc. Seeing-eye dogs can also help owners avoid overhead obstacles such as tree branches and signposts. Seeing-eye dogs cannot distinguish certain colors, and so are unable to help owners with reading traffic signals (The Seeing Eye).

Why do I need a Letter of Medical Necessity (LMN)?

Because a dog is a personal expense, a LMN is necessary from a medical professional to establish that the patient has a medical issue that can be alleviated by a seeing-eye dog.