Comment on AN51-Proposed Rule-Baker, D

RIN 2900-AN51 -- Service Dogs I wish to comment on the following statement: "a clinical determination by a VA clinician, which would be based upon the clinician's medical judgment that 'it is optimal for the veteran to manage such impairment and live independently through the assistance of a trained service dog.' I am deeply concerned that the decision on whether or not a person would optimally benefit from a service dog (SD) will be left to a medical practitioner who may not have any knowledge of or experience with SDs and their capabilities. They may also not be fully aware of the limitations of other medical aids as they apply to the individual and how a SD can mitigate these limitations. I propose that VA employ the services of an SD organisation as they are recognised specialists in the field of SDs and are experts in determining if a SD would be of optimal benefit. The SD organisations already have procedures in place to make expert determinations. The recipient completes an extensive application form and participates in a detailed interview which should also include a home observation. The SD organisation will then make a determination based on the perceived optimal benefit and the person's ability to care for the SD. As SDs are valued in the tens of thousands of dollars, this decision is not made lightly. The SD organisation's decision should be accepted by VA. For persons with owner trained (OT) SDs: If the SD organisation determines that an SD would be of optimum benefit, VA can employ them to verify that the OT SD is trained to alleviate the effect of the disability. They can also verify that the person's OT SD is trained to an appropriate standard of public behaviour by conducting a Public Access Test and providing certification. Don't allow the medical practitioner to make the determination on whether or not a person will optimally benefit from a SD - leave it to the qualified and experienced SD organisations.