TN 11 (04-16)

GN 04461.030 Protesting Deficiency Citations for Supplemental Security Income (SSI) Quality Review Cases - Rebuttals

A. Introduction to protesting deficiency citations

The Office of Quality Review (OQR) uses the SSA-93 (Quality Review Feedback Report), to notify the Field Office (FO) and the Office of the Regional Commissioner (ORC) of findings that identify payment errors and informational items that require FO action but may not affect payment.

The purpose of the rebuttal procedure is to resolve case-related disagreements between FOs and OQR components. This process resolves issues systematically and ensures affected SSI records are correct. We encourage informal communications between OQR and operating components to expedite resolution.

B. Protesting a deficiency citation

The FO may rebut a cited deficiency only if it meets the criteria for a rebuttable issue outlined in GN 004461.030C. The FO may contact OQR to informally resolve other issues. To submit a rebuttal, the FO goes to the SSA-93 website within 45 days of the date OQR transmitted the SSA-93 and:

  • Selects Rebuttal Request Sent to OQR in the Respond To SSA-93 area of the SSA-93 website;

  • Describes the reason for the rebuttal in the comments area;

  • Scans all supporting material into the electronic folder and clearly indicates the location in the comments area of the website; and

  • Updates the SSA-93 Quality Review website to notify OQR of the rebuttal request by automated email.

Delay corrective action only on the contested deficiencies pending final resolution. Correct all non-disputed deficiencies.

C. Criteria for rebuttable issues

To rebut the following types of deficiencies cited by OQR, the FO may use the formal rebuttal process in GN 04461.030E through GN 04461.030F:

  • Stewardship Review: Payment deficiencies of any dollar amount that affect the sample period's payment, and

  • SSI Transaction Accuracy Review (SSI TAR): Payment deficiencies in the review period of $5 or more or dollar deficiencies of any amount resulting in ineligibility for all months in the review period.

D. Issues not subject to rebuttal

OQR identifies non-payment and informational issues on the SSA-93. Do not forward protests of these items through the rebuttal process.

The following deficiencies cited by OQR are not subject to the rebuttal process.

  • All non-payment deficiencies;

  • All informational items;

  • SSI TAR dollar deficiencies that affect the amount of the sample period's payment by less than $5; or

  • Any deficiencies cited on Special Studies.

If the FO disagrees with OQR on any of the above, they must contact the OQR office that cited the issue and resolve informally. If necessary, OQR revises the Quality Review (QR) system to reflect the informal decision. The FO must document the SSA-93 website by selecting the “Other” option and explaining the issue in the comments area if the informal decision is that corrective action is unnecessary or will differ from the original OQR findings.

E. Rebuttal procedure

When the OQR field site receives the rebuttal request, they review it to determine the appropriate action.

1. OQR affirms decision but FO subsequently agrees

If the OQR field site disagrees with the FO rebuttal or revises the error but FO corrective action is still required, they annotate the SSA-93 website. The OQR field site also directs an email via the website to the Division of Title 16 Quality and Service Evaluation (DT16QSE) in OQR central office stating the rationale for affirming the original determination in the website comments area within 15 calendar days after the receipt of the rebuttal.

The website also notifies the FO and ORC via email that the case was referred to DT16QSE for a final review and determination.

If, through informal discussions, the FO subsequently agrees with the OQR decision, the OQR field site notifies DT16QSE by email of the FO agreement. DT16QSE updates the website to affirm the error finding and return jurisdiction to the FO for necessary action.

2. OQR reverses decision

If the OQR field site reverses its decision, they make any necessary changes to the QR system and notifies the FO and the ORC of the modified decision by email via the SSA-