TN 109 (07-20)

GN 04440.525 Completing the SSA-392-SUP, Medical Consultant's Review of Mental Residual Functional Capacity Assessment

A. Background on using the SSA-392-SUP

Federal review medical contractors (MC) and psychological contractors (PC) may use the SSA-392-SUP to record agreement or disagreement with the adjudicating component SSA-4734-F4-SUP, Mental Residual Functional Capacity Assessment (MRFC). The MC or PC may complete the SSA-392-SUP when there is an SSA-4734-F4-SUP in file.

For an exhibit of an SSA-392-SUP, see GN 04440.930.

1. When to complete an SSA-392-SUP

The MC or PC may complete an SSA-392-SUP when:

  • An SSA-4734-F4-SUP is in file, and

  • A mental impairment of less than listing level severity requiring an RFC assessment is present.

For a further explanation of when to use the SSA-392-SUP, see GN 04440.135.

NOTE: When an MRFC is not in the file, but one is required, the reviewing MC or PC will prepare the assessment on an SSA-4734-F4-SUP. The reviewing MC or PC may use the SSA-392-SUP to prepare an MRFC assessment.

2. When not to complete an SSA-392-SUP

The MC or PC may not complete an SSA-392-SUP when:

  • The adjudicating component prepared an SSA-4734-F4-SUP, but MC or PC review establishes that the adjudicating component should have made the disability determination on a medical basis only, (i.e., the impairment is a “not severe” mental impairment, or the impairment is of listing-level severity.), or

  • The disability determination is not supported by sufficient medical evidence and additional medical evidence is needed (i.e., a medical documentation deficiency), regardless of whether the adjudicating component decided the case on a medical-vocational basis.

NOTE: For situations in GN 04440.525A2, the MC or PC records case analysis and disagreement(s) with the MRFC determination on an SSA-416, Case Analysis.

B. Procedure for completing the SSA-392-SUP

1. Heading (SSN through Level of Claim)

The items in the heading are self-explanatory. In the field, “DATE OF SSA-4734-F4-SUP BEING REVIEWED”, enter the MRFC date(s) or date range, as documented by the adjudicating component.

2. Section I - Summary of Agreement/Disagreement

After you review all the evidence, complete Section I.

  • If you agree with the narrative statement regarding all four mental areas, (Understanding and Memory; Sustained Concentration and Persistence; Social Interaction; and Adaptation), and evidence is supportive, check the appropriate "agree" block, and do not complete Section II; and

  • Sign, date, and enter the MC code; or

  • If you disagree with any of the four mental areas, check the "disagree" block and complete Section II of the SSA-392-SUP; or

  • If the adjudicating component’s narrative is inadequate or insufficient to address any particular mental area (A,B,C, or D), check the block appropriate to the mental area; and

  • Indicate if documentation is sufficient to support the assessment provided by checking the block for "YES" or "NO".

3. Section II. - Narrative Discussion

Complete Section II only for substantive disagreement with the SSA-4734-F4-SUP narrative statement of the four areas of mental impairment(s) or for incomplete documentation in support of that narrative statement.

  • If Section I indicates substantive disagreement or need for documentation, provide a complete, detailed narrative discussion of the reason(s), as applicable to each mental area;

  • In your discussion, cite specific evidence that supports mental capacity conclusions that are substantively different from those presented in the adjudicating component's SSA-4734-F4-SUP narrative statement;

  • If the deficiency is for missing or incomplete evidence, explain what evidence is needed; and

  • Sign, date, and enter the MC code on page 2.

To Link to this section - Use this URL:
GN 04440.525 - Completing the SSA-392-SUP, Medical Consultant's Review of Mental Residual Functional Capacity Assessment - 07/03/2019
Batch run: 07/16/2020