Buck52 I think based on my award letter, the VA looked at SMC since I was being rated at 100% but only on a statutory level cause they mentioned it but not the HB "in fact" based on severity and/or condition since they didn't mention it I would guess. Since I have been researching cases and VA laws on SMC HB I've seen all different variations of how it is entitled of than the statutory way. The VA says "substantially confined" whereas Congress says "unable to earn a income". I've look over the M21-1 and it seems they've been updated it and I noticed this today.
A housebound in fact determination requires a Veteran’s inability to leave his /her place of residence and immediate premises in order to earn any income. However, it does not require a total inability to leave the place of residence and immediate premises for all circumstances. Leaving home for medical purposes cannot, by itself, serve as the basis for finding that a Veteran is not substantially confined for purposes of SMC housebound benefits. The limitations must be the result of the Veteran’s SC disabilities.
Non-medical indicators of housebound status may include but are not limited to
inability to walk substantial distances
leaving the home with assistance only occasionally for
appointments
grocery shopping, or
church, or
inability to mow one’s lawn.