Effective Dates: 06/26/2025 - Present Previous | Next

TN 179 (06-25)

GN 04440.204 Group II Deficiencies

A. Definitions of group II deficiencies

There are two types of group II deficiencies, decisional and documentation. A group II decisional deficiency is a substantive deficiency in which the evidence supports a different onset, ending, or cessation date for a disability determination that is material i.e., the different date has the potential to affect the month of entitlement (MOE), the primary insurance amount (PIA), or the earnings freeze. A group II documentation deficiency is a substantive deficiency in which the evidence is insufficient and obtaining additional evidence has the potential to change the onset, ending, or cessation date for a disability determination.

1. Group II decisional deficiencies

The review component will cite a group II decisional deficiency based on the following issues:

a. Onset date (category 71 )

The adjudicating component allows a disability claim, but evidence supports a different onset date. In potential reopening situations, cite this deficiency when the adjudicating component:

  • •

    should have reopened, but did not (even when the established onset date (EOD) is correct),

  • •

    should not have reopened, but did (even when EOD is correct), or

  • •

    correctly reopened, but established an incorrect onset date that is material.

b. Ending date (category 72)

The adjudicating component allows a disability claim:

  • •

    for a closed period, but evidence supports a different ending date,

  • •

    for a closed period, but evidence is sufficient to show disability did not end, or

  • •

    for an open period, but evidence is sufficient to show disability ended.

c. Cessation date (category 73)

The adjudicating component ceases an individual’s disability benefits, but evidence supports a different cessation date.

2. Group II documentation deficiencies

The review component will cite a group II documentation deficiency based on the following issues:

a. Onset date (category 81)

The adjudicating component allows a disability claim, but evidence is insufficient to support the onset date. This includes situations where the adjudicating component’s EOD falls within a previously adjudicated period, and there is insufficient evidence to determine whether the prior denial determination can be reopened.

The review component should not cite a Group II onset date documentation deficiency when the field office (FO) did not inform the adjudicating component of a prior determination, and there was no indication of a prior determination in the certified electronic folder (CEF).

b. Ending date (category 82)

The adjudicating component allows a disability claim for a closed period, but evidence is insufficient to support the ending date.

c. Cessation date (category 83)

The adjudicating component allows a disability claim, but evidence is insufficient to determine the correct cessation date.

d. Unresolved work activity that has potential to affect the period of disability (category 85)

The adjudicating component allows a disability claim, but evidence is insufficient to determine either the correct onset or ending date because of unresolved work activity.

NOTE: 

When sufficient documentation exists to support a different established onset date (EOD) or if there is insufficient evidence to support the EOD, the reviewer's deficiency is based on the potential impact of the adjudicator not following policy. As explained in DI 25501.300, the EOD impacts the PIA, MOE, and the disability freeze.

B. Correcting group II deficiencies

The review component handles group II deficiencies differently, depending on the specific deficiency involved and the circumstances of the case, which may include:

  • •

    returning the case to the adjudicating component for corrective action,

  • •

    correcting the onset or ending date and processing the case, or

  • •

    sending an electronic assistance request (AR) for work activity development to the Field Office (FO).

NOTE: All of the adjudicating component's original determination and medical assessment forms, as well as notices, must remain in the CEF as part of the audit trail.

1. Case returned to the adjudicating component for corrective action - category 73, 81, 82, and 83 deficiencies

The review component returns group II documentation deficiencies involving onset (category 81), ending date (category 82), and all cessation deficiencies (categories 73 and 83) to the adjudicating component for corrective action. In these cases, the review component will:

a. code the deficiency in the case processing system,

b. complete a Request for Corrective Action per GN 04440.008B.7,

c. route the case to the adjudicating component for correction as a controlled return, and

d. follow-up with the adjudicating component in 60 days if the corrected determination has not been returned to the review component.

NOTE: If the cessation date on the SSA-832 (Cessation or Continuance of Disability or Blindness Determination and Transmittal — Title XVI) or SSA-833 (Cessation or Continuance of Disability or Blindness Determination and Transmittal –Title II) is incorrect solely due to the passage of time (i.e., the adjudicating component prepared the determination in one month and the review component conducted its review in the following month), correction should be made to the cessation date entry on the determination form and to the notice(s) without citing a deficiency. These procedures do not apply to determinations based on failure to cooperate (FTC).

2. Case corrected in the review component - category 71 and 72 deficiencies

Group II onset (category 71) and ending date (category 72) decisional deficiencies are corrected by the review component. In these cases, the review component will:

a. annotate all original determination documents, medical assessment forms, and notices completed by the adjudicating component in the CEF with "Do Not Process" or "Do Not Release", as applicable,

b. code the deficiency in the case processing system,

c. complete the Request for Corrective Action per GN 04440.008B.7,

d. correct the onset or ending date,

e. prepare and release any necessary personalized notices, and

f. route the case to the FO for effectuation.

EXCEPTION: If the case has another deficiency or technical corrective action requiring correction by the adjudicating component, or changing the ending date results in an adverse reopening of either an initial or a reconsideration case, the review component will follow the instructions in subsection B.1, to return the case to the adjudicating component for correction.

3. Correcting group II work activity documentation deficiencies - category 85

A group II deficiency based on unresolved work activity (category 85) has potential to affect the period of disability. In these cases, the review component will:

  1. a. 

    annotate all original determination documents, medical assessment forms, and notices completed by the adjudicating component in the CEF with "Do Not Process" or "Do Not Release", as applicable,

  2. b. 

    code the deficiency in the case processing system, prepare a Request for Corrective Action per GN 04440.008B7, and notify the adjudicating component of case routing to the FO for work activity development,

  3. c. 

    prepare a Request for FO Assistance outlining the specific information needed to resolve outstanding work activity issues, and

  4. d. 

    route the case to the FO.

C. Review component action after the FO responds to work activity development AR

The review component will take action based on the results of FO work activity development and substantial gainful activity (SGA) determination.

1. FO resolved work activity issue - corrective action is not required

If the FO submits documentation of SGA development and a corresponding determination indicating that the onset date remains the same, the review component will:

  1. a. 

    remove the "Do Not Process" annotations from the determination forms in the CEF, as applicable,

  2. b. 

    prepare and release any necessary personalized notices, and

  3. c. 

    route the case to the FO for effectuation.

2. FO resolved work activity issue - corrective action is required

If the FO submits documentation of SGA development along with a determination necessitating a correction to the onset date, the review component will:

  1. a. 

    remove annotations of "Do Not Process" from determination forms, as applicable,

  2. b. 

    code the deficiency in the case processing system, as appropriate,

  3. c. 

    correct the onset or ending date on the SSA-831,

  4. d. 

    prepare and release any necessary personalized notices, and

  5. e. 

    route the case to the FO for effectuation.

3. FO documentation raises additional issues - adjudicating component action is required

If FO documentation raises additional issues requiring adjudicating component corrective action, the review component will initiate a subsequent return to the adjudicating component per GN 04440.205B.

4. FO documentation raises additional issues - FO action is required

If FO documentation does not fully resolve SGA issues or other technical factors needed to establish the onset date, the review component will:

  1. a. 

    prepare a subsequent Request for FO Assistance outlining the specific issues that require further development or resolution, and

  2. b. 

    route the case to the FO.

To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/0204440204
GN 04440.204 - Group II Deficiencies - 06/26/2025
Batch run: 06/26/2025
Rev:06/26/2025