DDSs will not make determinations of disability in claims for Totalization benefits
(unless a determination is necessary in a concurrent SSI claim). The Office of International
Operations (OIO) will make a disability determination in claims for Totalization benefits
if, after receipt of the foreign coverage record, the NH is insured for disability
benefits. However, the DDSs may have to develop medical evidence in these cases. When
referring such cases for development of medical evidence, field offices (FOs) will
include the notation “Totalization Claim—No Determination Necessary.”