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Doe, In re
(HHS, SSA Office of Hearings & App. June 9, 1995) ; Clearinghouse Number: 50734
Description
SSI Recipient Who Lived in Her Own House Rent-Free Following Foreclosure Did Not Receive In-Kind Support and Maintenance
Abstract
The administrative law judge (ALJ) has held that SSI claimant who
continued to reside in her home after it was sold did not receive
in-kind support and maintenance. Claimant had been found disabled
as of October 1992. She could not meet her mortgage payments, and,
in December 1992, her residence was purchased by HUD at a
sheriff’s auction. However, claimant was not served with an
eviction notice until August 1993 and continued to live in her home
until that time. When the Social Security Administration (SSA)
determined claimant’s financial eligibility for SSI, it found
that she had received $164 per month in in-kind support and
maintenance from January through August 1993 because she had lived
rent-free in another’s household. On appeal, claimant argued
that, until she was served with a writ of possession and evicted,
she was residing in her own household. The ALJ agreed. The ALJ
found that until she received notice of eviction, claimant was
residing in a home in which she had an ownership interest.
Accordingly, the ALJ held that claimant should not have been
charged with $164 per month in in-kind support and maintenance and
directed SSA to pay claimant retroactive benefits.
