The narrative fields on the Request for Corrective Action include:

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  Item 11 ("ACTION REQUESTED AND RATIONALE") on the first page and

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  A 20,000 character maximum limit.

In item 11, summarize the relevant facts of the case and clearly state:

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  the policy issue,

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  reasons why the case is deficient, and

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  necessary corrective action(s).

To explain or justify the deficiency, do not use:

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  Disability Policy’s policy memorandums,

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  PolicyNet Questions and Answers (Q & As) or

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  other similar written guidelines that are not part of National policy.

NOTE: Quality reviewers cannot cite a Q & A as the sole basis for a deficiency, but may refer to a Q & A on the Request for Corrective Action, for clarification purposes only, as long as the Q & A is not expired or archived.

Acceptable references include:

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  The Program Operations Manual System (POMS)

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  The Social Security Act

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  Regulations

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  Social Security and Acquiescence Rulings

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  Administrative and Emergency Messages

Follow the appropriate format when completing each section of the narrative discussion on the Request for Corrective Action, as explained here.

The QR case processing system propagates the header section onto the Request for Corrective Action. The heading will differ based on the type of review and deficiency code.

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  QR’s case processing system propagates a heading that includes the deficiency group, deficiency category, deficiency sub-category, and primary/other deficiency.

Provide a brief summary to describe the basis of the deficiency. Two to three sentences is generally sufficient.

Follow the Federal Plain Language Guidelines, as enacted by the Plain Language Act of 2010, when writing the narrative discussion of the Request for Corrective Action.

If applicable to the return, the section should include:

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  A brief statement of the claimant's allegations and the alleged onset date.

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  Discussion of the vocational issues, including incorporation of specific policy references to support any deficiency findings.

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  Discussion of the medical issues, with respect to sufficiency of documentation or medical severity, as it relates to listing requirements or impact on the claimant's residual functional capacity (RFC). Include incorporation of specific policy references.

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  Discussion of symptom evaluation, medical source statements, all opinion evidence, and any related policy.

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  Discussion of the earnings issue(s) or other work activity issues which requires development.

DO NOT:

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  Cut and paste POMS sections into the return without providing a discussion of the policy interpretation and how it specifically applies to the cited deficiency.

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  Provide a list of references or cite a range of POMS chapters.

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  Cite a POMS table of contents or introductory section, unless the introductory section contains specific instructions related to the deficiency (e.g., introductory text in specific Listing of Impairments).

NOTE: Be very specific. Adjudicating components,Disability Policy's Request for Program Consultation staff, and subsequent reviewers must be able to identify the incorrectly applied policy to determine the proper course of corrective action(s).

Explicitly state the action(s) necessary to correct the deficiency.

If documentation is necessary, specify the type of documentation. Do not direct the adjudicating component to purchase a consultative examination or otherwise tell them how to obtain the evidence. For additional information on routing and correcting deficient cases, see QR 04440.202, QR 04440.203, and QR 04440.204.

If the return does not require corrective action by the adjudicating component, include the statement, “No corrective action required”.