LeadingAge and the National Alliance to End Homelessness submitted comments on October 17 to a Social Security Administration (SSA) proposed rule about how Supplemental Security Insurance (SSI) benefit amounts are calculated.

The National Alliance to End Homelessness, a nonpartisan, nonprofit organization, is a leading national voice on the issue of homelessness and their sole purpose is to end homelessness in the United States.

Our joint comments strongly support the proposed rule, under which the SSA would change its standard for what is considered a “rental subsidy” when SSI recipients are getting help with housing from friends/family or other informal supports. Once finalized, the proposed rule would help SSI beneficiaries, among the lowest income people in the United States, retain more of their federal SSI benefit and help prevent and end homelessness in the United States. About two million older adults receive SSI benefits in the United States.

In 2023, the full maximum benefit for a single SSI recipient is $914 and $1,319 for a couple where both people are SSI eligible. After someone is determined eligible for SSI, the SSA figures out how much in SSI benefits they are eligible for, up to these maximum benefit amounts.

If implemented, the proposed rule will mean more money in more pockets—which LeadingAge and the Alliance think will help prevent and end homelessness among older adults. For example:

• An older adult who receives SSI and lives in her adult child’s home and pays $305 a month, or 1/3 of her SSI federal benefit, for a room.
• Currently, SSA investigates the current market value of the room and determines it is $800 a month. Because the SSI recipient is only paying $305, less than market rate, SSA considers the SSI recipient to be benefitting from a “rental subsidy,” treats the support as unearned income, and applies a reduction in benefits because of its calculation of this in-kind support.
• Under the proposed rule, SSA would not determine what the market value of the rent is. As long as the SSI recipient is paying at least 1/3 of their SSI federal benefit towards rent, SSA will decide they are not getting a “rental subsidy” and will not reduce the SSI benefit.
• Under the proposed rule, because the SSI recipient is paying a third of their income for rent, SSA will find there is no “rental subsidy” and will not apply a reduction in benefits.

The proposed rule does not impact eligibility determination for SSI and does consider receipt of federal rental assistance as “rental subsidy” for purposes of determining any SSI benefit reductions.