this is the effect of back -bias (between body and source ) , the threshold ( VT0 ) gets shifted and affects the inversion layer , so better be ground .
For low voltage circuits the foward bulk bias is used to reduce the VT by the CMOS body effect.
In genenal it is used only for ultra-low voltage operation. For example, if vdd is 0.5V a bulk to source voltage from 0 to 0.5V is safe for latchup because it occurs only from 0.7V. The maximum bulk to source voltage can be defined also by the current leakage of the forward biased bulk-source junction.