SMC Step-Up and Housebound Check
Two checks VA decisions get wrong most often: whether the statutory housebound rule is actually met, and how many intermediate-rate SMC steps — informally called "Barry bumps" — 38 CFR § 3.350(f) supports.
1. Statutory housebound (SMC-S) check
38 U.S.C. § 1114(s) requires a single disability rated 100 percent — not a 100 percent combined rating — plus separate disability independently ratable at 60 percent.
2. Intermediate-rate SMC steps
38 CFR § 3.350(f)(3) provides an intermediate (half) step for additional service-connected disability independently ratable at 50 percent; § 3.350(f)(4) provides a full step for additional disability ratable at 100 percent. After Barry v. McDonough, 101 F.4th 1348 (Fed. Cir. 2024), these are not capped at one. Count only conditions separate from the ones that established your base rate.
Educational estimator only — it does not decide entitlement and makes no prediction about any claim. If a decision applied the one-increase reading rejected in Barry, or never addressed SMC-S, that is an appealable issue. Read the Barry v. McDonough guide and the SMC-S housebound guide, then have your code sheet reviewed.
Frequently asked
Does a 100% combined rating plus a 60% condition qualify for SMC-S?
No. Statutory housebound under 38 U.S.C. § 1114(s) and 38 CFR § 3.350(i) requires a single service-connected disability rated 100 percent, plus additional separate disability independently ratable at 60 percent or more. A 100 percent combined rating built from several conditions does not satisfy that rule. A separate route exists where the veteran is permanently and substantially confined to the home by service-connected disability.
Can TDIU count as the 100 percent for SMC-S?
Under Bradley v. Peake, 22 Vet. App. 280 (2008), a TDIU award can satisfy the total-rating element of § 1114(s) when the TDIU is based on a single disability rather than the combined effect of several conditions.
What did Barry v. McDonough change about SMC?
In Barry v. McDonough, 101 F.4th 1348 (Fed. Cir. 2024), the Federal Circuit held that the intermediate-rate increases in 38 CFR § 3.350(f)(3) and (f)(4) are not limited to one. Each additional service-connected disability or combination independently ratable at 50 percent (or 100 percent for a full step) supports its own increase.
Are these SMC amounts exact?
They are the published 2026 rates for a veteran alone and are shown for orientation only. Dependent allowances, SMC-K, and aid-and-attendance findings change the figure. VA's official rate tables control.