Mar 26, 2024

Final Regs To Omit Food From In-Kind Support And Maintenance To Become Effective On September 30 But SSA Seems To Be Worried About Litigation

     Social Security will publish final regulations to omit food from in-kind support and maintenance calculations for purposes of Supplemental Security Income tomorrow. The change will not become effective under September 30, 2024. That's an awful long lead time.

    By the way, the notice contains the following language:

Severability
In the event of an invalidation of any part of this rule, our intent is to preserve the remaining portions of the rule to the fullest possible extent. In particular, we intend the clarification of consideration of others in the household in 20 CFR 416.1131 [on the 1/3 reduction rule] to be severable, as it better explains our current policy and functions independently of the other changes reflected in this final rule. We also intend the clarification of constructive receipt of income in 20 CFR 416.1102 [defining what is income] to be severable, as it better explains our current policy and functions independently of the other changes reflected in this final rule.

3 comments:

Anonymous said...

Really not sure who would have standing to litigate the issue, but that is oddly defensive. I was expecting a boilerplate severability clause, not specifically identifying particular regulations. Also, why wouldn't SSA just retract or amend 20 CFR §§ 416.1131 and 416.1102 if they thought there was a concern as to conflicts?

Anonymous said...

If it would lead to a higher state supplement, would a state have that standing?

Anonymous said...

@4:49

Interesting idea, but I do not believe state supplements are based directly on the SSI amount (ie I don't think it's a percentage added or anything like that). Actually, they are often means-tested, and I suspect if receipt of SSI is a consideration in that calculation, an increase in SSI benefits would actually potentially reduce the state's supplement.