Cooking for Dogs · Working Paper № 1

Costing the Service Dog’s Diet

A methodology for measuring service-animal food expenses under SNAP’s excess medical expense deduction

Marjorie J. Walsh, author of Cooking for Dogs (New Holland, London; Random House, New York, 2007)

with Craig W. Walsh

Honolulu, Hawai‘i · September 2026

1The deduction that has no ruler

SNAP’s excess medical expense deduction is one of the quieter instruments of American food policy. For households containing an elderly or disabled member, out-of-pocket medical costs above $35 a month are subtracted from income before benefits are computed.^[1] The policy logic, documented at length by the Center on Budget and Policy Priorities, is straightforward: every unreimbursed dollar a disabled household must spend on health is a dollar unavailable for food, and the deduction restores food purchasing power that illness or disability would otherwise consume.^[8]

Within the regulation’s list of allowable expenses — care from licensed practitioners, hospitalization, prescriptions, premiums, dentures, hearing aids, prosthetics, prescribed eyeglasses, transportation to treatment — sits one category unlike the others:

“Securing and maintaining any animal specially trained to serve the needs of an elderly or disabled member…”
— 7 C.F.R. § 273.9(d)(3)

The U.S. Department of Agriculture’s Food and Nutrition Service, in its 2019 guide to the treatment of medical expenses, confirms that keeping a service animal includes its food and veterinary care.^[7]

Now consider how each expense on that list gets documented. An insurance premium arrives with a billing notice that states the monthly amount. A prescription leaves a pharmacy record priced to the penny. A dental implant is invoiced. In every case the paperwork appears automatically, as part of paying — and, crucially, the paper is the measure. The dog is different. A household that feeds a packaged commercial food could accumulate a drawer of grocery receipts, but even the full drawer records purchases — events — rather than a monthly cost, which still has to be computed from the dog’s feeding rate. And a household that cooks for its dog generates no paper at all. Either way, his food is the one expense on the list whose measure must be constructed rather than photocopied — and no published guidance, federal or state, says how to construct it. This paper supplies the missing method: a measurement that is fair to the household, auditable by the agency, and consistent with the regulation’s own architecture. The worked example throughout is the authors’ own service dog, KaHoku, a 55-pound diabetes-alert dog living and working in Honolulu.

2The legal architecture: category, not price

The first principle any method must respect is that the regulation screens expenses by category, never by price. An expense either falls within an allowable class and belongs to an elderly or disabled member — in which case it is deductible in the amount incurred — or it falls outside the classes and is not deductible at all. Nothing in § 273.9(d)(3), and nothing in FNS’s guidance, empowers an agency to substitute a cheaper alternative for the medical choice the household actually made.^[1],[7]

The point is intuitive as soon as it is stated in terms of the other categories. A participant who elects comprehensive Medigap coverage is not told that a leaner plan would have sufficed; the premium is the premium. A participant who receives a dental implant is not told to deduct the price of dentures instead — the regulation names both without ranking them. A participant with prescribed eyeglasses chooses the frames; the prescription is what qualifies the expense, and no caseworker audits designer against discount. Purely cosmetic procedures fail the category test because they treat nothing, not because they cost too much; the same surgery performed as reconstruction is medical care and passes. The judgment about where generosity ends, in other words, was made by the drafters when they wrote the category list, and they resolved it in the household’s favor.

The service-animal category inherits this structure whole. The question an agency may properly ask is whether the animal is specially trained to serve the needs of an elderly or disabled member. Once he is, the cost of keeping him is deductible at its real amount. And a word about the regulation’s own verb: the drafters wrote “maintaining” without qualifiers — but a working dog is not maintained the way a machine is maintained, at the minimum that keeps it running. He is a medical partner whose usefulness depends on his condition. The standard the household applies — the standard any competent handler applies — is not subsistence but health: a dog fed to thrive, because a dog that merely survives does not work. The regulation sets the category; the standard of care belongs, as it does for every other expense on the list, to the household and its professional advisers.

Federal tax law, it is worth noting, states the same structure in so many words. IRS Publication 502 makes deductible “the costs of buying, training, and maintaining a guide dog or other service animal,” including “any costs, such as food, grooming, and veterinary care, incurred in maintaining the health and vitality of the service animal so that it may perform its duties.”^[24] The federal government’s own formulation ties the food not to keeping the animal alive but to keeping it fit for duty — health and vitality as the standard, the working role as the reason, and no price test anywhere in sight.

The choice is also, finally, a personal one, as medical choices are. A service dog is not equipment retrieved for tasks; he is present for every moment of the life he safeguards — the grocery store, the cinema, the car, the night. The handler who declines dentures in favor of an implant, and the nutritionist who would never feed her working partner the minimum the law allows, are exercising the same prerogative — and the regulation, read honestly, protects both.

What the agency may properly verify is the amount: the deduction covers real expenses, and a household must be able to show how its figure was reached. The regulation polices honesty, not thrift. The method in Section 7 is designed for exactly that division of labor.

3Verification: once, then only on change

The verification rules turn out to be well built for an expense like this one. At initial certification a claimed medical expense is verified.^[2] At each later recertification, the regulation confines re-verification to expenses that are newly claimed or whose amount has changed by more than $25 a month^[2] — so a documented, stable figure carries forward from year to year as a matter of course. When an agency does need something more, the rules set out the courteous mechanics: the request comes in writing, with at least ten days to respond, and with assistance for households that have difficulty obtaining documents.^[3],[4]

For a service dog’s food this design is exactly right. The expense is continuous and stable — dogs eat every day, and food prices move slowly. Verified once, with the figure’s basis on file, the deduction needs no annual re-litigation; it needs a fresh look only when the basis genuinely moves, and the $25 threshold defines “genuinely” for everyone in advance. The method in Section 7 is built to slot into precisely this cycle: one documented submission, then quiet carry-forward, then a single-step update when the shelf price finally justifies one.

4What the states publish — and the anomaly they expose

State agencies restate the federal category with varying completeness. Massachusetts publishes the fullest guidance in the country. Its Department of Transitional Assistance instructs workers that clients “can claim costs incurred for getting and caring for seeing, hearing and specially trained service animals,” that allowable costs “include, but are not limited to, food and veterinary bills,” that the agency “cannot require a specific type of training, credentials, or certification,” and that “only the amount of the unreimbursed cost must be verified.”^[9] Tennessee lists service-animal costs on its published medical-deduction information sheet.^[10] California’s legal-services annotation of CalFresh policy treats service-animal food and veterinary costs as routine deductions,^[11] as do the practitioner guides circulated in New Jersey and New York.^[12],[13]

Massachusetts, however, also states a limit that exposes the field’s central puzzle: “food and drinks that can be consumed by humans (i.e., bottled water, carrots, chicken, etc.) are not allowable medical expenses for animals.”^[9] The rationale is anti-double-counting — human-consumable food could have been bought with the SNAP benefit itself — and on its own terms it is sound. But consider what a literal reading does to the household that feeds its service dog best: the household that cooks. Fresh home preparation from whole ingredients is the gold standard of canine feeding; it is also composed entirely of human-consumable inputs. Read literally, the exclusion awards a full deduction to the household that buys packaged dog food and nothing to the household whose working dog is fed from a better kitchen — a result no drafter can have intended.

The puzzle dissolves the moment the expense is measured rather than itemized. The dog’s diet has a market price: what the equivalent premium commercial dog food — a product SNAP categorically cannot buy^[23] — costs at the household’s own store. Measuring the diet at that price claims no carrot and no chicken breast; it claims the cost of feeding the dog, expressed in the one unit every party can check at the shelf. Nor is this an exotic idea: it is how the program already handles its other recurring, invoice-less costs, as Section 6 shows.

5What a working dog must eat

Before pricing the diet, one must establish its size. Here the veterinary literature is quantitative and settled.

5.1  Energy requirements

The Merck Veterinary Manual gives the canonical formulas. A dog’s resting energy requirement is RER = 70 × (body weight in kg)^0.75; maintenance requirement is a multiple of RER — 1.6× for a neutered adult, 1.8× intact, more with activity.^[14],[15] For a 55-pound (25 kg) dog, RER is approximately 783 kcal and daily maintenance runs on the order of 1,250–1,400 kcal before any allowance for work. Cornell’s Riney Canine Health Center adds the performance dimension: sustained work is fuelled aerobically by dietary fat, and working dogs want energy-dense rations — up to 35 percent fat on a dry-matter basis for endurance work — built on “plenty of high-quality protein.”^[16]

The “active” multiplier is usually an assumption; in KaHoku’s case it is a measurement. The GPS activity collar he wears has logged, as of this writing, 5,194,979 steps — an average of 28,465 a day. A dog walking twenty-eight thousand steps daily is not a couch companion; he is an athlete on a working schedule, and his energy budget sits at the active end of the veterinary range.

5.2  The AAFCO floor, and what sits above it

The regulatory benchmark for commercial pet food in the United States is the Association of American Feed Control Officials (AAFCO), whose Dog Food Nutrient Profiles define what a product must contain to be labeled “complete and balanced.”^[17] It is essential to understand what that label is: a floor. It marks the minimum below which a food may not lawfully claim to sustain a dog. It does not grade quality above the minimum, and the peer-reviewed literature shows the range above the floor is wide. Controlled feeding trials at the University of Illinois, published in Translational Animal Science, compared fresh cooked diets against extruded kibble — all AAFCO-compliant — and found the digestibility of dry matter, protein, fat, and calories “all significantly lower” for kibble (p < 0.001), with fresh diets exceeding 90 percent dry-matter digestibility and producing roughly half the fecal output (24 g/day against 47 g/day).^[18] A 2024 follow-up study extended the finding across fresh and minimally processed formats.^[19]

Two honesty notes bound this argument, and the reader should hold both. First, mainstream veterinary nutrition maintains that good-quality kibble is complete and healthy; nothing here claims that kibble harms dogs. Second, the claim actually needed is narrower and stronger: that feeding a working medical animal above the regulatory floor — higher digestibility, higher-quality protein, greater energy density, reliable palatability — is a reasonable medical choice, made on professional advice, of exactly the kind the deduction exists to respect. For a service dog the operational stakes are real: a dog with public access works in kitchens, clinics, vehicles, and restaurants, where consistent appetite and consistent digestion are not cosmetic virtues. A medical-alert dog off his feed is a medical device out of service. This is not feeding steak to a pet; it is meeting the specification of a job.

5.3  What the profession prescribes and budgets

The working-dog organizations themselves — the institutions that breed, train, and place these animals — publish both a dietary standard and its cost, and the two lines of evidence agree. On the standard, Guide Dogs for the Blind instructs its graduates: “From puppyhood to formal training, your guide has been fed a high-quality diet. It is recommended that you continue the practice of sourcing and feeding a high-quality diet during your guide’s entire working life” — and it names acceptable premium commercial lines by brand.^[25] A high-quality diet is not, in the profession’s view, an indulgence a handler may add; it is the continuation of the feeding regime the dog’s working ability was built on.

On cost, the published program figures:

Two things should be said about that $60. First, it does not buy generic food even on the mainland: the brands the profession names — Pro Plan, Royal Canin, Science Diet, Eukanuba — are all premium lines, so $60 a month is the price of the profession’s minimum acceptable diet, premium kibble, at mainland retail. Second, these are mainland budgets, and how they translate to a given market depends on the retail channel: the authors’ own spot comparison found a national pet-specialty chain in Honolulu holding prices comparable to mainland levels, while grocery-channel food prices in Hawai‘i run high enough that USDA publishes separate cost-of-food tables for the islands.^[29] The method in Section 8 is indifferent to that question by design — it reads the household’s own shelf, whatever that shelf charges. Either way, the $60 figure is the floor of the benchmark ladder in Section 8, not its middle. The Seeing Eye’s $2,000 combined figure, asked of every applicant as a condition of readiness, makes the same point from above: these organizations treat the cost of properly feeding a working dog as a serious, budgeted obligation of the partnership, stated in writing before a dog is ever placed.

Government itself, when it is the payer, behaves the same way. Police K-9s are fed at agency expense, and at least one municipal budget publishes a food-only line item: the Exeter Township, Pennsylvania police budget carries “K-9 Dog Food” at $3,700 for 2025, for three dogs — $103 per dog per month — and explains the increase over the prior year’s $2,400 in the budget’s own words: “Reflects increased costs of care for three K-9 officers and veterinary recommendations for nutrition.”^[30]

The federal government has gone further and made it law. The Government Accountability Office, surveying the roughly 5,600 working dogs in federal and federal-contractor service, identified eighteen issues essential to working-dog health and welfare — and issue five is “Food and water,” defined as “how working dogs are provided food and water, including timing of feeding, type and amount of food, and specific regimens.”^[32] Congress then enacted the Working Dog Health and Welfare Act of 2023, Pub. L. 118-195, directing federal agencies with working-dog programs to implement GAO’s recommendations.^[31] Federal law now requires, in substance, that every federal working-dog program address the type and amount of its dogs’ food as a matter of written policy. When the working dog serves the government, the government budgets his food as an operating necessity, takes its veterinarians’ nutrition advice, and writes his welfare into statute. A working dog serving a disabled citizen runs on the same physiology.

6Measuring a cost that has no invoice

How should a continuous cost with no paperwork be documented? The program answered that question for itself long ago, in another context. Utilities are also continuous, also hard to paper month by month — and SNAP’s solution is the standard utility allowance: state agencies publish standard figures for electricity, telephone, water, and trash, and households claim the standard rather than producing twelve months of bills.^[6] The standard is not a shortcut grudgingly tolerated; it is the designed instrument, because a documented rate times continuity is better evidence of a recurring cost than any shoebox of paper.

The alternative — receipts — fails on its own terms for an expense like this. A grocery receipt records an event: one item, one day, one price. The deduction requires a rate: a monthly cost. To convert the event into the rate one needs the feeding schedule — the dog’s weight, the manufacturer’s feeding table, the daily quantity — and the schedule plus the shelf price yields the rate with or without the receipt. Nor do receipts survive to be collected: no household archives grocery slips, and even major retailers’ own online systems typically expose less than a year of history. And for the household that cooks, itemization collapses entirely: what would the records even be — a ledger allocating the drumsticks between the family table and the dog’s bowl? No kitchen keeps such accounts and no auditor could check them.

The service dog’s diet is a recurring cost with a documentable rate. It belongs to the same architecture as the utilities: a standard, established once, carried forward, refreshed on change.

7The kitchen and the register

Before stating the method, one candid question deserves a direct answer, because a careful reader will ask it. A cooking household buys its ingredients — meat, vegetables, organ meats — as ordinary groceries, and some of those groceries are eligible for purchase with SNAP benefits. Is there a circle here: benefits buying food that feeds the dog, whose cost then increases the benefits?

There are two distinct rules in play, and both are satisfied — one of them automatically.

The purchase rule is enforced by the cash register. SNAP benefits may buy food for the household — meat, poultry, fish, dairy, produce — and may not buy pet-designated products: kibble, commercial rolls, dog treats.^[23] Enforcement is built into the retailer’s point-of-sale system, which splits every basket into an EBT-eligible total and a non-eligible total; the EBT card can only ever touch the first, and every pet-designated item lands in the second, paid from the household’s own funds. Compliance is not a virtue the household performs; it is a constraint the machine imposes, and every itemized register receipt documents it for free.

The deduction rule is satisfied by the measure. The Massachusetts limit discussed in Section 4 — human-consumable food is not itself claimable as an animal’s medical expense — is a rule about what may be itemized. The method here itemizes nothing from the kitchen: it claims the price of the equivalent commercial dog food, a product outside SNAP’s reach entirely. The chicken is never claimed; the cost of feeding the dog is, in the one unit that involves no double-counting by construction.

And the arithmetic closes the question. The medical deduction does not reimburse dollar-for-dollar; it reduces the income against which the benefit is computed, and the benefit rises by roughly thirty cents per deducted dollar — up to about forty-five cents for elderly and disabled households once the deduction’s interaction with the uncapped shelter deduction is counted. A household whose dog consumes $236.72 of food value each month therefore recovers, at most, around $107 of it through the deduction, and usually less. The household funds the majority of its service dog’s diet from its own resources even when the deduction is fully allowed. There is no configuration of these rules under which the program ends up paying for the dog; the deduction merely softens, by design and only partly, a medical cost the household bears.

The cooking household’s economics, finally, run toward thrift rather than away from it. One example from the authors’ kitchen: rather than buying commercial jerky treats, Marjorie dehydrates plain chicken — a single ingredient, of known provenance, at a fraction of the shelf price of the packaged equivalent. Home preparation, done knowledgeably, produces better food for less money. A measure pegged to commercial retail prices, if anything, understates what such a kitchen delivers per dollar.

8The equivalent-commercial-price method

The method has five steps. A household can complete them in an afternoon; an agency can audit them from its desk.

1. Establish the dog’s weight — a veterinary record or a home scale; the figure is stable and uncontroversial.
2. Read the manufacturer’s feeding table for the equivalent premium commercial dog food, at the dog’s weight band. The table is printed on the package; photograph it. (For fresh-format foods these tables align with the standard fresh-feeding norm of 2–2.5 percent of body weight per day.)
3. Document the local shelf price — a dated photograph of the shelf tag at the household’s own store, identifying product, size, and unit price. Local, not national: the local shelf is what the household actually pays and what an auditor can check. Where a market diverges from mainland averages — USDA publishes separate cost-of-food tables for Hawai‘i and Alaska^[29] — the local shelf captures it automatically; where a national chain carries mainland pricing into the islands, it captures that too. The method never has to argue about regional markups either way.
4. Compute the monthly figure: daily pounds × price per pound × 30.44 (the average month). State the arithmetic on one page.
5. Submit once; update only on change. The figure then carries forward at each recertification until it moves more than $25 per month^[2] — at which point a fresh shelf photograph re-verifies it in a single step.

8.1  The worked example: KaHoku

KaHoku weighs 55 pounds. The manufacturer’s table for the leading fresh-format food prescribes 1 to 1⅜ pounds per day for dogs of 41–60 pounds; the household computes at approximately 1.3 pounds per day, inside the band and below its ceiling. The shelf price, photographed at the household’s Safeway, is $29.99 for a five-pound roll — $6.00 per pound, essentially unchanged for three years ($28.99 until mid-2025). The arithmetic:

Is $7.78 a day a luxury figure? The reader can price it against the neighborhood. In September 2026, within a mile of the same Safeway shelf: a Mexican Coca-Cola, $3.29; a Big Mac — the sandwich The Economist has used for forty years as the world’s most audited unit of purchasing power^[21] — $6.49. One of KaHoku’s two daily meals costs a Mexican Coke and sixty cents. His entire working day — all 28,465 steps of it — costs a Big Mac and $1.29, no fries.

8.2  The figure against the market

The stronger test is against the market for premium canine feeding itself. Commercial fresh-food subscription services — the closest industrial analogue to home cooking — price a dog of this class at roughly $6 to $11 per day ($171–$342 per month).^[22] And the veterinary arithmetic of Section 5 yields a striking upper benchmark: a 55-pound dog fed exclusively on fresh-format food at typical fresh caloric density (roughly 500–630 kcal per pound) requires 2 to 2½ pounds per day — $12 to $15 per day at the same shelf price, or $360–$450 per month. The worked figure of $236.72 sits in the middle of the subscription band and at roughly half the exclusive-fresh computation, which is exactly where an honest partial measure should sit.

Note what the ladder demonstrates about the “luxury” question. Nobody choosing indulgence lands below the market rate for the category. This is not feeding steak to a dog; it is feeding a working medical animal the diet a canine nutritionist would design for him, measured at less than what commercial services charge to do the same job.

9What each party should do

For the household

• Assemble the five-step file once: weight record, photographed feeding table, dated shelf-tag photograph, one page of arithmetic, and a short cover statement identifying the animal and the disabled member he serves.
• Submit it at certification and keep a copy; it carries forward until the figure moves more than $25 a month.^[2]
• Keep an itemized register receipt or two showing the EBT / non-EBT split — the point-of-sale system produces proof of the purchase rule automatically, at no effort.
• When the shelf price finally moves the figure past the threshold, update with a single fresh photograph and one line of arithmetic.

For the agency

• Accept the five-step file as verification of amount; for a recurring cost with no invoice, a documented rate is more probative than any single receipt.
• Apply the category test and stop: whether the animal is a trained service animal for an elderly or disabled member is the agency’s question; the household’s choice of diet above the AAFCO floor is not.^[1],[7]
• Treat the figure as the standard utility allowances are treated: verified once, carried forward, re-examined on documented change.^[6]
• When a question does arise, put the request in writing with time to respond, as the regulations provide^[3],[4] — a household that can be asked promptly can almost always answer promptly.

10Conclusion

Congress and USDA long ago decided that keeping a disabled person’s service animal fed is health care, and that health-care spending should not come out of a poor household’s food. What they did not supply was a ruler. The dog’s food is the one expense on the medical list that generates no invoice — the one that must be measured rather than photocopied — and no published guidance says how to measure it.

The ruler was available all along, inside the program’s own toolbox: a documented standard rate. The equivalent-commercial-price method asks the household for an afternoon’s documentation and the agency for arithmetic. It cannot drift upward, because the manufacturer’s feeding table and the shelf tag cap it; it cannot be dismissed as generous, because every benchmark in the field sits around or above it. It resolves the cooking-household puzzle, respects the category-not-price structure of the deduction, involves no double-counting by construction — and it reduces the whole question to three things anyone can check: here is the dog, here is the table, here is the shelf.

KaHoku walks twenty-eight thousand steps a day beside a man whose blood sugar he is trained to read, and he does it on $7.78 — less than a Big Mac and a dollar twenty-nine. The least the system that relies on such work can do is count it.

References