TN 47 (10-15)

DI 11005.065 Curtailing Potential Onset Date Development

A. Policy for curtailing Potential Onset Date (POD) development

Adjudicators rely on the field office to determine the POD as an alert to guide case development. The POD is the earliest possible date the onset of disability can be established, based on non-medical factors. It may be the same as, earlier than, or later than the AOD. When medical evidence supports a determination of an allowance, the POD also provides the adjudicator with the earliest possible date to consider when establishing the established onset date (EOD) based on non-medical factors. Curtail POD development in the following situations:

1. No DDS determination required

Do not provide a POD for a Title II technical denial or any other claim that does not require a DDS determination.

For example, curtail POD development if:

  1. a. 

    The disability insurance benefits (DIB) claimant clearly does not meet disability insured status as of the alleged onset date (AOD) or later, and you cannot establish a POD before the DLI because of SGA-level work activity or other non-medical factors; or

  2. b. 

    The DIB claimant has never been insured for DIB benefits based on information on the earnings record and any lag earnings; or

  3. c. 

    The disabled widow(er)’s benefits (DWB) claimant's AOD is after the end of the prescribed period; or

  4. d. 

    The childhood disability benefits (CDB) claimant's AOD is after age 22 or after expiration of the reentitlement period.

2. CDB claimant alleged onset prior to age 18

If the claimant’s AOD was prior to the last day of the month before he or she attained age 18, and the claimant did not subsequently perform substantial gainful activity (SGA), do not develop a precise POD. In this situation, the POD is the last day of the month before the claimant attained age 18 and meets all the non-medical requirements.

3. Title XVI claims

For title XVI claims, do not document a POD if it is the same as the filing or protective filing date unless the claimant performed SGA after the filing or protective filing date. See DI 25501.220 C.1.a.

B. Procedure for curtailing POD development

In cases requiring a DDS determination, document the SSA-3367 or the EDCS 3367 with the reason for curtailing Title II POD development in the Remarks section. No explanation is required for curtailing POD development for Title XVI claims.

C. References

  • DI 11010.075 Initial Title II Technical Denials and Claims Not Requiring a Disability Determination

  • DI 11015.030 FO authorization of a Disabled Widow(er)’s Benefit Technical or Non-Medical Denial

  • DI 11020.050 FO Authorization of Childhood Disability Benefits (CDB) Involving Substantial Gainful Activity (SGA) and Technical Denials

  • DI 25501.220 Potential Onset Date (POD)

  • DI 25501.330 Establishing an Established Onset Date (EOD) for Childhood Disability Benefits (CDB) Claims

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DI 11005.065 - Curtailing Potential Onset Date Development - 01/25/2017
Batch run: 01/11/2019