SMC-S: The Housebound Rate

SMC-S is a level of Special Monthly Compensation paid at the rate set by 38 U.S.C. 1114(s). Under 38 CFR 3.350(i), it is payable where the veteran has a single service-connected disability rated as 100 percent and either has additional service-connected disability or disabilities independently ratable at 60 percent, separate and distinct from the 100 percent service-connected disability and involving different anatomical segments or bodily systems, or is permanently housebound by reason of service-connected disability or disabilities. The housebound requirement is met when the veteran is substantially confined as a direct result of service-connected disabilities to his or her dwelling and the immediate premises or, if institutionalized, to the ward or clinical areas, and it is reasonably certain that the disabilities and resulting confinement will continue throughout his or her lifetime.

These are two separate routes, and meeting either one is enough. A veteran who meets the first does not need to be confined to the home. The 100 percent rating must be for a single disability, not a combined rating of 100 percent from multiple conditions, and the disability counted toward the additional 60 percent must be separate and distinct from it and involve different anatomical segments or bodily systems. The statute, 38 U.S.C. 1114(s), requires a disability "rated as total," and the Court of Appeals for Veterans Claims has held that a total rating based on individual unemployability (TDIU) meets that requirement when it is based on a single disability (Bradley v. Peake, 22 Vet. App. 280 (2008)), but not when it is based on multiple disabilities (Buie v. Shinseki, 24 Vet. App. 242 (2010)). A veteran who does not meet the first route may still meet the second if the housebound requirement is met. If you believe you meet either route and are not receiving SMC-S, you can ask VA to address it.

Note: This article references sections of the VA's M21-1 Adjudication Procedures Manual. The VA periodically reorganizes the M21-1 and section numbers may have changed since this article was written. For the most current section references, visit the VA's public M21-1 Web Automated Reference Material System (WARMS).