1) Quick Overview: SMC vs CRSC
2) VA Special Monthly Compensation (SMC): Definition
SMC is a higher level of VA disability compensation paid when a service-connected condition causes certain special circumstances—for example, needing regular assistance from another person, being substantially confined to the home, or having specific anatomical loss/loss of use. VA publishes current SMC rate tables and explains the SMC structure. (VA SMC rates & tiers)
| Common SMC concept | What it generally means in practice |
|---|---|
| SMC-K (add-on) | Usually an additional amount for specific losses (often “loss of use” categories). It can be added to certain base SMC levels. |
| Housebound | Generally tied to being substantially confined to the home due to service-connected disability and/or meeting certain rating patterns (VA applies specific rules). |
| Aid & Attendance (A&A) | Needing regular help with activities of daily living (ADLs) or protection from hazards due to disability. VA uses medical evidence (often via VA Form 21-2680). |
| Higher tiers (L, M, N, O, R, etc.) | Reserved for more severe combinations—often multiple losses, very high care needs, or special circumstances. |
3) Combat-Related Special Compensation (CRSC): Definition
CRSC is a DoD program for eligible military retirees that can restore some or all of retired pay that is offset due to receipt of VA disability compensation, when the disabilities are verified as combat-related. DFAS explains the general VA offset/waiver rule and how CRSC can restore amounts in qualifying cases. (DFAS: VA waiver/offset + CRDP/CRSC)
| Combat-related category | Typical meaning (high level) |
|---|---|
| Armed conflict | Injuries incurred as a direct result of combat/engagements. |
| Hazardous duty | Examples can include parachuting, demolition, flight deck duty—depends on proof and service criteria. |
| Instrumentality of war | Military equipment/vehicles/weapons causing injury under warlike conditions (not ordinary accidents). |
| Simulated war | Training exercises that simulate war (live-fire, field training, etc.) with required proof. |
Read more: DFAS: CRSC
U.S. Supreme Court Rulings You Should Know
Soto v. United States (U.S. Supreme Court, June 12, 2025) — CRSC Retroactive Pay
In Soto v. United States, the U.S. Supreme Court addressed whether the government could limit Combat-Related Special Compensation (CRSC) retroactive payments using the “Barring Act” six-year rule. The Court ruled that the CRSC statute provides its own settlement/claims process and therefore the Barring Act’s six-year settlement mechanism (and its time limit) does not cap CRSC the way the government applied it.
Official opinion PDF: Soto v. United States (No. 24-320)
Henderson v. Shinseki (U.S. Supreme Court, March 1, 2011) — VA Appeal Deadline (CAVC)
In Henderson v. Shinseki, the U.S. Supreme Court held that the 120-day deadline for filing a Notice of Appeal to the U.S. Court of Appeals for Veterans Claims (CAVC) is a claims-processing rule and does not automatically strip the court of power (i.e., it is not “jurisdictional” in the strict sense).
Opinion PDF: Henderson v. Shinseki, 562 U.S. 428 (2011)
4) How to Get SMC (Step-by-Step)
Most SMC wins are built around one of these:
- Aid & Attendance (A&A): you need regular help with ADLs or safety.
- Housebound: you’re substantially confined to home due to service-connected disability.
- Loss of use / anatomical loss: specific body parts or functions (often SMC-K add-on; sometimes higher).
- Combinations: multiple severe conditions can move you to higher tiers (VA applies rules for stacking/combining).
VA Form 21-2680 is commonly used to document housebound status or need for regular A&A. (VA Form 21-2680)
VA Form 21-4138 can be used to provide supporting statements. (VA Form 21-4138)
- List your service-connected diagnoses that cause the limitations.
- List your ADL limitations (bathing, dressing, toileting, feeding, transfers, meds, safety supervision).
- Give 2–3 real examples of incidents (falls, leaving stove on, missed meds, inability to get to bathroom, etc.).
- Describe who helps you, how often, and what happens if they don’t.
Practically, SMC is usually requested as:
- A specific request for SMC (A&A/housebound), or
- Evidence submitted during a pending claim/appeal where the facts raise SMC entitlement.
If VA schedules an exam, show up with your caregiver notes, fall logs, medication lists, assistive device use, and your completed 21-2680.
SMC Evidence Checklist (What Wins Cases)
- Completed VA Form 21-2680 with specific functional findings (not vague).
- Caregiver statements: exactly what they do and how often (hands-on vs standby).
- Primary care / specialist notes documenting falls, ADL dependence, cognitive impairment, incontinence, medication issues.
- PT/OT evaluations describing functional limits (transfers, gait, balance, endurance).
- Assistive devices: walker, cane, wheelchair use; home safety modifications.
5) How to Get CRSC (Step-by-Step)
In general, CRSC eligibility includes being entitled to/receiving retired pay, having a VA rating of at least 10%, and having retired pay reduced by VA compensation (the VA offset). See VA and DFAS for eligibility details. (VA: CRSC overview)
DFAS instructs first-time applicants to complete DD Form 2860. (DFAS: DD 2860 instructions)
Your burden is typically: (1) VA rated it, and (2) it meets combat-related criteria with evidence.
CRSC is a branch decision process (DFAS pays after approval).
Many branches allow reconsideration when you add missing evidence or when new combat-related disabilities are rated.
CRSC Pay Basics (VA Offset, CRDP vs CRSC)
In general, federal law restricts receiving full VA compensation and full military retired pay at the same time, which creates the VA waiver/offset. DFAS explains the offset and how CRSC or CRDP may restore some or all of the waived amount depending on eligibility. (DFAS: VA waiver/offset)
- CRDP is a different program (concurrent receipt) for certain retirees; rules differ from CRSC.
- CRSC is specifically tied to combat-related disabilities and is approved by your branch.
6) SMC Rates
VA publishes the current SMC rates (effective dates included on their page). Use VA’s official table for the most accurate numbers: VA SMC rates.
7) Common Pitfalls (SMC & CRSC)
| Pitfall | Fix |
|---|---|
| SMC claim proves diagnosis, not function | Use functional evidence: ADLs, safety, frequency, hands-on needs; clinician specificity on 21-2680. |
| SMC A&A evidence ignores “hazards” supervision | Document safety supervision: falls, confusion, wandering, cooking hazards, medication mismanagement. |
| CRSC packet is a dump of records | Organize by condition with a one-page narrative + exact “combat-related” category + key exhibits. |
| CRSC filed with the wrong agency | File with your branch CRSC office using DD Form 2860 (initial claim). |
| CRSC evidence doesn’t prove combat-related nexus | Include incident/LOD-style proof, orders, awards, evaluations, VA rating decisions/code sheets, and medical records showing how it meets criteria. |