If the DDS examiner, the disability hearing officer (DHO) or administrative law judge
(ALJ) did not address the need for a Title II CDR, the FO will initiate a CDR or consider
an adverse reopening of the Title II determination whenever there is an unfavorable
action on an age-18 redetermination. Normally, the DDS, DHO, or ALJ will address this
issue. The FO will not delay implementation of the Title XVI determination due to
pending action on the Title II CDR issue.
The standard for continuing disability is different from the standard applied during
an age-18 redetermination. It is not unlikely that disability will cease on the Title
XVI case while disability is continued under Title II. Once eligibility continues
based on an age-18 redetermination, treat the case, for all purposes, as an adult
disabled individual (DI) claim. An age-18 redetermination cessation will act as a
permanent bar to the cross title adoption of any favorable determination that pre-dates
the cessation action.
NOTE: The DDS must never adopt a pre-age 18 determination to a Title II claim.