Can TDIU Qualify You for Housebound SMC?
CCK Law: Our Vital Role in Veterans Law
Yes, Total Disability Based on Individual Unemployability (TDIU) can also be a pathway to Housebound SMC, or SMC-S, a form of Special Monthly Compensation (SMC) intended for veterans who are generally confined to their homes due to their disabilities.
In this article, you will learn about the circumstances that can qualify a TDIU recipient to earn SMC-S and, therefore, gain more appropriate monthly compensation from VA.
Key points of this article include:
- TDIU and SMC-S are distinct. TDIU is reserved for veterans who are unable to work due to their disabilities, while SMC-S is awarded to veterans whose disabilities permanently confine them to their home.
- There are two pathways to earning SMC-S: the first (“factual housebound”) requires a veteran prove that they are substantially confined to their home. The second (“statutory housebound”) requires that they qualify for the “100 Plus 60 Rule” by having one disability rated 100 percent, as well as a separate disability or combination of disabilities rated 60 percent or higher.
- If a veteran is receiving TDIU based on a single disability, then recent case law has confirmed that the TDIU rating can count toward a 100 percent rating needed under the “100 Plus 60 Rule.”
What Are TDIU and SMC-S?
TDIU
TDIU allows veterans to receive disability compensation at the 100 percent level even if their actual schedular disability rating is lower. Generally, TDIU is awarded to veterans whose conditions are severe enough to prevent them from maintaining gainful employment.
As of 2026, a single veteran with no dependents will receive $3,938.58 per month through TDIU.
Housebound (SMC-S)
Housebound SMC (SMC-S) is a form of Special Monthly Compensation for veterans who are confined to their homes due to multiple service-connected conditions or a physical inability to leave. This form of SMC is established by 38 U.S.C. § 1114(s) and described on VA’s Aid and Attendance and Housebound allowance website.
Since housebound veterans typically have greater needs than other disabled veterans, SMC-S provides them with a higher amount of monthly compensation. As of the 2026 COLA adjustments, a single veteran with no dependents will receive $4,408.53 per month from SMC-S, a significant improvement over veterans who are receiving TDIU alone.
One thing that is important to note is that SMC compensation rates replace standard compensation rates for veterans. In other words, a veteran receiving $4,408.53/month from SMC-S will be paid at that rate instead of the $3,938.58/month given to veterans with just TDIU.
Looking to learn how to qualify for SMC-S through TDIU? Watch the video below featuring Bradley Hennings and Robert Chisholm, Partner and Founding Partner at CCK Law:
Can I Earn SMC-S Through TDIU?
Yes, the major pathway by which veterans can earn SMC-S through TDIU is often called the “100 Plus 60 Rule.” The rule is drawn from 38 C.F.R. § 3.350(i)(1):
- Total plus 60 percent, or housebound; 38 U.S.C. 1114(s). The special monthly compensation provided by 38 U.S.C. 1114(s) is payable where the veteran has a single service-connected disability rated as 100 percent, and
- 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.
Requirement One: TDIU Based on a Single Disability
“Bradly v. Peake held that TDIU can qualify as the single disability rated total under 1114(s) if it is based on a single disability,” says Bradley Hennings, Partner at CCK Law. “But if your TDIU is based on multiple combined disabilities (for example, orthopedic conditions plus PTSD), then it does not count as a single disability for housebound purposes.”
In other words, so long as a veteran’s TDIU rating is based on a single disability rather than a combination of disabilities, then that TDIU rating will serve as the 100 percent rating necessary to qualify for SMC-S.
For example:
- If a veteran received a TDIU rating for ankylosis of the spine alone, then that would count as a single disability and could serve as the 100 percent rating necessary to qualify for Requirement One.
- On the other hand, if a veteran’s TDIU is based on a combination of sleep apnea, pes planus, and tinnitus, then that would not count as a single disability, and they would therefore not meet the standard to qualify for Requirement One.
Requirement Two: Separate, Independently Rated Disabilities of 60 Percent or Higher
“There’s also the second requirement: the 60 percent rule,” says Robert Chisholm, Founding Partner at CCK Law. “This rule states that the veteran must also have other, separate disabilities rated at 60 percent or more, independent from the disability that forms the basis of TDIU.”
For these separate disabilities to meet this requirement, they must be service-connected and not part of the same body system or conditions that the veteran’s TDIU is based on.
Here is an example of a situation where the 100 and 60 percent disabilities are likely not independent enough:
- A veteran argues that their 100 percent rating for PTSD and 60 percent combined rating for depression, anxiety disorder, insomnia, or alcohol use disorder should qualify under the 100 Plus 60 Rule.
- But VA argues (likely successfully) that this does not qualify, because:
- The 100- and 60-percent-rated conditions fall within the same mental health body system
- They are typically rated under a single diagnostic code
- Therefore, they cannot be used to reach the sixty percent requirement
Want to learn about the eligibility requirements for SMC-S? Watch the video below featuring CCK Law’s Madeleine Eustis and Nicholas Briggs, VA-accredited advocates:
VA Denied Your TDIU and SMC-S Claim? Contact CCK Law
While it is certainly possible to earn SMC-S through TDIU, the laws regulating this process can be so complex and evolving that even VA employees may neglect to consider the possibility of SMC-S for TDIU recipients.
If your TDIU and SMC-S claim was denied by VA, then the dedicated team at Chisholm Chisholm & Kilpatrick may be able to assist. Our VA-accredited attorneys and advocates have secured favorable outcomes for 99 percent of our past clients before and helped recover over $1 billion in wrongfully denied compensation.
Call CCK Law at 800-544-9144 or contact us online for a free case evaluation.
Frequently Asked Questions
What is SMC Level S in the VA disability system?
SMC Level S, also called SMC-S or “Housebound” SMC, is a form of Special Monthly Compensation (SMC) from VA awarded to veterans who are confined to their homes by service-connected disabilities.
To qualify for SMC-S, a veteran must either have multiple, severe service-connected disabilities (called “statutory housebound”) or be otherwise substantially confined to their home or care facility (called “factual housebound”).
As of 2026, SMC-S provides veterans with monthly payments of $4,408.53, which is paid in place of the standard compensation rate for a veteran’s conditions.
How is SMC-S different from Aid and Attendance (A&A)?
Compensation for Aid and Attendance (A&A) is provided by SMC R-1 and SMC R-2, which are higher levels of SMC than SMC-S.
While SMC-S is intended for veterans who are permanently confined to their homes, SMC-R-1 and R-2 take it a step further. These levels of SMC are reserved for veterans who require regular aid from others to perform the tasks of daily living (e.g., bathing or eating).
As of 2026, SMC-S pays $4,408.53 per month to single veterans with no dependents. On the other hand, SMC R-1 would pay $9,826.88 per month to a veteran in the same circumstances, while SMC R-2 would pay $11,271.67 per month.
Can you get TDIU and SMC?
While it is possible for veterans to qualify for both TDIU and SMC simultaneously, most forms of SMC will replace the standard compensation rate offered by TDIU.
In other words, a veteran will not receive SMC payments on top of their TDIU payments, but in place of those TDIU payments. Since SMC almost universally offers higher payment rates than TDIU, however, this replacement is rarely a bad thing for veterans, financially.
An exception to this rule is SMC(k), which is a monetary benefit awarded to veterans who have lost limbs or limb function. SMC(k) is the only form of SMC paid on top of a veteran’s standard compensation rate. However, it generally offers much less compensation than other forms of SMC.
I do not qualify for the “100 Plus 60 Rule.” Can I still get SMC-S?
Yes, it is possible for a veteran to qualify for SMC-S even if they do not meet the requirements for the “100 Plus 60 Rule.” To do this, a veteran would have to prove to VA that they are permanently substantially confined to their home or care facility due to a service-connected disability or disabilities. This can be proven with the help of lay evidence or medical opinions from the veteran’s doctor or care team.
This is considered a more difficult or unpredictable standard than the “100 Plus 60 Rule,” which is the primary pathway by which veterans earn SMC-S.
