Entitlement to Special Monthly Compensation (SMC) under 38 U.S.C.

Board reasoning

The Board found that the veteran's remaining service-connected disabilities are independently ratable at 60 percent or more, meeting the criteria for SMC on the basis of a single disability achieving 100 percent (via TDIU) plus independently ratable disabilities and housebound considerations. It also held substantial compliance with previous remands and cited a case to support that the VA must consider whether a TDIU based on multiple disabilities can lead to SMC if a single disability later attains 100 percent independently.