Does a Sequential Compression Device (SCD) qualify for exemption from Texas sales or use tax?

Plain-English summary

A taxpayer wrote to the Comptroller asking how sales tax applies to a Sequential Compression Device (SCD) — a device that creates pressure to help force blood circulation through the veins of the limbs. The Comptroller's answer was short and favorable to the taxpayer: Sequential Compression Devices qualify for exemption from sales or use tax, and that exemption specifically extends to both the SCD sleeves and the machines that operate them.

The letter is only a few sentences long. It does not cite a specific statute or rule, and it does not explain the reasoning behind the exemption (for example, whether the device is treated as exempt durable medical equipment or under some other category). It simply states the conclusion that SCD sleeves and machines are exempt from sales or use tax.

Because the letter is this bare, it should be read as a narrow, direct answer to the specific question asked, based on the facts as the taxpayer described them, rather than as a comprehensive explanation of Texas's medical equipment exemption rules generally.

What this means for you

Patients and individuals with medical needs

If you are purchasing a Sequential Compression Device — the sleeves, the machine, or both — this letter indicates that the Comptroller has treated these items as exempt from Texas sales or use tax. You should not expect to be charged sales tax on this equipment based on this ruling.

Businesses selling or renting medical equipment

If you sell, rent, or supply Sequential Compression Devices (SCD sleeves and machines) in Texas, this letter indicates the Comptroller's position that these items qualify for exemption from sales or use tax. Because the letter does not cite the statute or rule it relies on, you should confirm the current exemption category and any documentation requirements (such as exemption certificates) before treating sales as tax-free.

Accountants and tax professionals

This is a very short, conclusory letter with no statutory citation, so it is most useful as a data point — the Comptroller has held SCD sleeves and machines exempt — rather than as a source of detailed reasoning. If a client asks whether a specific piece of compression therapy equipment qualifies, this letter shows the Comptroller's answer for materially similar facts, but you should verify current law and any applicable exemption rule before advising a client to rely on it.

Common questions

Q: Are Sequential Compression Devices (SCD) exempt from Texas sales or use tax?
A: Yes. The Comptroller ruled that SCD sleeves and machines qualify for exemption from sales or use tax.

Q: Does the exemption cover just the sleeves, or the machine too?
A: Both. The letter states that the exemption "includes SCD sleeves and machines."

Q: Does the letter cite a specific statute or rule for this exemption?
A: No. The letter states the conclusion without citing a statute or rule number or explaining its reasoning.

Q: Is this ruling still useful today even though it's from 1994?
A: It shows the Comptroller's position on this specific device at the time, but because the letter gives no statutory citation and STAR letters can only be relied upon by the original requester, taxpayers and sellers should confirm current law rather than relying on this letter alone.

Citations and references

The original letter does not cite any specific statute or rule by number.

Source

• STAR search: https://star.comptroller.texas.gov/search?doc_type_code=L&tax_type_code=SST
• Opinion: https://star.comptroller.texas.gov/view/9404L1299E07

Original ruling text

April 12, 1994

Dear **:

This is in response to your letter dated March 30, 1994,
regarding sales tax as it applies to a Sequential
Compression Device.

Sequential Compression Devices (SCD) qualify for exemption
from sales or use tax. This includes SCD sleeves and
machines.

This opinion is based on the facts presented. Different
facts, though similar, might lead to different answers. If
you have any questions or need more information, please
write or call me toll free at 1-800-531-5441, extension
50330, or 512-475-0330.

Sincerely,

Bettie Peterson
Tax Administration Division

NOTE: Previous Accession Number 9404318L