DI 24503.030 Articulation Requirements for Medical Opinions and Prior Administrative Medical Findings – Claims filed on or after March 27, 2017
A. When to use this section
For claims with a filing date on or after March 27, 2017, follow the guidance in this section. For claims with a filing date before March 27, 2017, follow the guidance in DI 24503.035 Evaluation and Articulation Requirements for Medical Opinions, Opinions, and Prior Administrative Medical Findings - Claims Filed before March 27, 2017. For more information about how to determine the filing date of a claim, see DI 24503.050 Determining the Filing Date for Evaluating Evidence.
B. Articulation requirements
1. General policy
Always provide a written analysis of the persuasiveness of the medical opinions in the file. For claims at the reconsideration level, also provide a written analysis of the administrative medical findings in the initial determination.
2. Source-level analysis
When a medical source provides multiple medical opinions, discuss all of the medical source’s opinions in one written analysis. Similarly, when evaluating a reconsideration claim discuss all of a medical consultant’s (MC’s) or a psychological consultant’s (PC’s) prior initial administrative medical findings in one written analysis.
If your electronic case processing system does not allow for combined analysis, you may either:
Provide a separate written analysis for each medical opinion or prior administrative medical finding, or
Provide a combined written analysis for all medical opinions or prior administrative medical findings in one location and add text as appropriate in all other relevant locations referring a subsequent reviewer to the location of the combined analysis.
3. Factors that must be in the written analysis
Articulate how you considered the factors of supportability and consistency for all medical opinions and prior administrative medical findings because these are the most important factors. Also, articulate how you considered the other most persuasive factors if you find that two or more different medical opinions are both equally well supported and consistent.
4. Factors that may be in the written analysis
The appropriate level of articulation will depend on the unique circumstances of each claim. In most situations, you should also explain how you considered the remaining factors to provide the claimant and subsequent reviewers with a full understanding of your analysis of the evidence.