The regional MC or PC prepares an SSA-392 or SSA-392-SUP if the adjudicating component
prepared an RFC assessment and a medical/vocational determination is appropriate.
The MC and PC generally use an SSA-416 to provide medical comments if the determination
should have been on a medical onset basis (i.e., non-severe impairment or meets/equals)
or the case has a medical documentation deficiency.
The quality reviewer is responsible for reviewing the medical comments on the SSA-416
and requesting clarification or additional information, when necessary. If multiple
body systems are involved, the quality reviewer should ensure that the SSA-392(s)
reflects the medical opinions for all body systems involved.
The quality reviewer should not request that the MC or PC provide clarification on
an SSA-416 if the information has been provided elsewhere in file. For example, if
the SSA-392 is sufficiently complete, i.e., it thoroughly describes the nature of
the RFC disagreement and the reason(s) why the adjudicating component’s RFC was incorrect;
no SSA-416 is required. However, in most instances, you need a supplemental SSA-416
for a full explanation of the issues surrounding the RFC disagreement. The important
point is that the file fully explains the discrepancy or disagreement with the adjudicating
component, regardless of what form you use to do so.