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May 24, 2017

Pet therapy program is a Section 501(c)(3) charitable activity, IRS rules

In PLR 201719018, the IRS has ruled that a charity's planned pet therapy program, which would bring trained therapy dogs to visit hospital patients and elderly nursing home residents, furthers charitable purposes under Section 501(c)(3).


Institute is a Section 501(c)(3) charitable organization that is organized (1) to conduct oncology research and education emphasizing the development, diagnosis, treatment and prevention of malignant tumors in humans and animals and (2) to advance medical research and education emphasizing recognition, prevention and treatment of diseases. In addition to these activities, Institute proposes to start a pet therapy program (the Program). The Program will bring therapy dogs to hospital patients, particularly children, and elderly nursing home residents. The Program aims to provide a positive therapeutic benefit to such individuals, lifting their spirits through playful interaction with the therapy dogs. These dog therapy sessions will be provided at no fee to the individuals treated or to the hospitals or nursing homes in which they stay. For participating hospitals and nursing homes, the pet therapy sessions will be provided on a regular weekly schedule.

The Program will use health-certified, registered therapy dogs that are trained to interact with children and the elderly. While the therapy dogs will initially be accompanied by experienced handlers, the Program will solicit volunteers to participate in the Program with their own dogs. Both the volunteers and their dogs will be required to be trained and certified for pet therapy treatment. Volunteers will be required to show a passion for the Program's mission, be responsible for their own costs with the associated training and certification, and be adequately insured.


The IRS ruled that Institute's provision of the pet therapy services will be in furtherance of its exempt purposes under Section 501(c)(3). In support of its ruling, the IRS cited revenue rulings concluding that providing services to hospital patients and other individuals suffering distress in an effort to ease that distress and provide them comfort furthers charitable purposes (Revenue Rulings 68-73 and 79-17). It further cited another revenue ruling finding that activities designed to meet the special needs of the elderly may further charitable purposes (Revenue Ruling 72-124).

The IRS noted that hospital patients, particularly children, and elderly nursing home residents may suffer physical and mental distress due to their illness or incapacity, as well as the stress of an unfamiliar environment, loneliness and other forms of emotional and mental distress. Because the Program aims to lessen this distress and improve these individuals' mental well-being, it furthers charitable purposes.


This PLR is an indication of the IRS's willingness to view innovative activities that attend to the non-medical needs of patients as furthering charitable purposes. It is well-settled that meeting the special needs of the elderly and lessening distress and improving mental well-being for patients in mental and physical distress further a charitable purpose. This can be accomplished by providing personal services such as reading and writing letters to hospital patients. (Revenue Ruling 68-73). In this case, the IRS applied these established principles to acknowledge that trained service animals from a pet therapy program utilized in a hospital setting can also further these purposes. Organizations should, however, consider certain facts pertaining to this specific program; namely, the Institute did not charge a fee for the service, the volunteers were responsible for adequate insurance as well as acquiring, training, maintaining and caring for the therapy animal, and the service was not provided by the hospital or nursing home that the Program intended to serve.

A private letter ruling is a written statement issued to a particular taxpayer that interprets and applies tax laws to the taxpayer's specific, represented set of facts, and may not be used or cited as precedent by other taxpayers or by IRS personnel. Thus, although the ruling is instructive on how the IRS might rule regarding a particular matter, organizations are cautioned not to rely on the ruling as authority, and to consult with their tax advisors to determine the tax consequences of their own facts and circumstances.

Please contact your Ernst & Young LLP tax professional with any questions.


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Contact Information
For additional information concerning this Alert, please contact:
Tax-Exempt Organizations Group
Mike Vecchioni(313) 628-7455;
Melanie McPeak(813) 225-4950;
Scott Tidwell(858) 535-4461;


Other Contacts
Exempt Organizations Tax Services Markets and Region Leadership
Scott Donaldson, Americas Director – Phoenix(602) 322-3062;
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Lucille White, Central Region – Chicago(312) 879-2670;
Bob Vuillemot, Northeast Region – Pittsburgh(412) 644-5313;
Debra Heiskala, West Region – San Diego(858) 535-7355;
Joyce Hellums, Southwest Region – Austin(512) 473-3413;
Kathy Pitts, Southeast Region – Birmingham(205) 254-1608;

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