Policy Review of the New SSI Rule: “Omitting Food from In-Kind Support and Maintenance (ISM) Calculations”

Overview of the Policy Change
The Social Security Administration (SSA) has implemented a rule that will eliminate food from the In-Kind Support and Maintenance (ISM) calculations when determining Supplemental Security Income (SSI) eligibility and payment amounts. Effective September 30, 2024, this change is designed to make the SSI process less burdensome for beneficiaries and the SSA itself. The new rule removes food support* from the definition of “unearned income” that could reduce SSI payments or disqualify individuals from receiving benefits. This adjustment is part of a broader effort by the SSA to simplify its regulations and remove barriers to accessing payments.

*Food support is defined as help from your social network and food pantries. Before this change, a person had to calculate the food they got as unearned income which would then be factored into how much SSI recipients could receive.

Strengths and Limitations of the Policy
The SSA’s new rule reflects a positive shift toward making SSI more accessible and equitable for recipients, particularly those with disabilities. Several benefits emerge from this change:

1. Administrative Efficiency: By excluding food from ISM calculations, the SSA will spend less time tracking beneficiaries’ access to informal food support. This streamlines the application process and reduces administrative costs, allowing the SSA to focus on more pressing service needs.
2. Greater Equity: The rule removes an inequitable barrier that penalized people for accepting informal help from family, friends, or community organizations. This disproportionately impacted disabled individuals and low-income families who rely on support networks. With food assistance no longer reducing their benefits, recipients will see improved financial security.
3. Payment Accuracy: The exclusion of food from ISM calculations is likely to reduce variability in monthly SSI payments, which fluctuated based on changes in informal food assistance. This consistency can improve financial planning for beneficiaries and prevent under- or overpayment scenarios, both of which have historically been common problems within the program.
4. Food Insecurity: As highlighted by experts in the articles, people on SSI are some of the most food-insecure populations in the U.S. By allowing beneficiaries to receive food aid without penalty, this policy indirectly addresses a major public health issue—access to sufficient and nutritious food.

While this rule marks a significant step forward, there are several areas where further reforms are needed.

Remaining Issues and Future Adjustments Needed
Although this change removes one specific barrier, it does not address the structural limitations of SSI that continue to impact people with disabilities and low-income individuals:

1. Asset Limits: Current SSI asset limits ($2,000 for individuals and $3,000 for couples) are archaic and fail to reflect the real financial needs of beneficiaries. These limits discourage savings and economic stability, keeping beneficiaries in a cycle of poverty. As suggested in the articles, raising these limits—potentially to $10,000 for individuals and $20,000 for couples—would be a crucial reform to enable SSI recipients to build a more secure financial future.
2. Income Limits and Work Penalties: SSI eligibility is also contingent on strict income limits, which disincentivize work and career advancement for people with disabilities. The current rule, where recipients can earn less than $1,971 per month, penalizes those who attempt to gain employment or increase their income. This is especially problematic when considering that inflation and rising living costs are outpacing income thresholds. Adjusting these income limits to align with economic realities is essential to give recipients greater financial autonomy.
3. Cost of Living Adjustments (COLA): While food assistance will no longer affect SSI payments, beneficiaries still struggle with inadequate monthly payment amounts. For 2024, the federal SSI payment maximum is $943 per month for individuals, which remains insufficient given rising costs for housing, medical care, and other basic needs. Tying SSI payments to a more accurate measure of inflation, rather than the current COLA index, would better support beneficiaries’ standard of living.
4. Shelter ISM Calculation: Though food is now excluded from ISM, shelter assistance from family and friends is still considered in SSI eligibility and payment calculations. This rule, like the food calculation, creates inequities by penalizing informal assistance, thus discouraging essential support from the community. Reforming or eliminating shelter ISM calculations should be a priority in future SSI revisions.

The Road Ahead
The SSA’s decision to omit food from ISM calculations is a significant policy advancement that simplifies access to SSI benefits and reduces financial penalties for informal food assistance. However, this rule change alone is not enough to address the broader systemic issues facing SSI recipients, particularly individuals with disabilities. To truly improve the economic well-being of SSI beneficiaries, further adjustments—such as increasing asset and income limits, revising shelter ISM calculations, and recalibrating cost-of-living adjustments—are needed. By tackling these remaining challenges, policymakers can ensure that SSI becomes a more effective and humane safety net for the millions of Americans who rely on it.