TN 11 (11-12)

DI 25501.430 Medical and Psychological Consultant’s, and Adjudicator’s Roles in Determining Onset for the Established Onset Date (EOD)

This section will explain our policy regarding the medical consultant’s, psychological consultant’s, and the adjudicator’s roles in determining the established onset date

REMINDER:

  • The onset date is the first day the claimant meets the definition of disability or statutory blindness as defined in the Act and regulations.

  • The established onset date (EOD) is the date that a claimant meets the definition of disability and all the relevant entitlement or eligibility factors.

A. Medical consultant’s (MC) and psychological consultant’s (PC), and adjudicator’s roles in determining onset for the established onset date (EOD)

The medical consultant’s (MC) or psychological consultant’s (PC) role in determining onset for the EOD is to prepare a severity assessment(s) for the relevant period(s).

The adjudicator has the final responsibility for the accuracy of the EOD determination. The adjudicator will establish an EOD based on pertinent medical, technical, and vocational factors.

We must assess the severity of the claimant’s condition(s) from the claimant’s alleged onset date (AOD) or potential onset date (POD), if different from the AOD through all relevant periods. An MC, PC, or single decision maker (SDM), if the adjudicator is an authorized SDM, prepares a Residual Functional Capacity (RFC), Mental Residual Functional Capacity (MRFC), a Childhood Disability Evaluation Form, or other severity assessment document each time the severity of the claimant’s condition changes and subsequently results in work related changes in the claimant’s functional capabilities.

NOTE: An SDM cannot sign a Childhood Disability Evaluation Form (Form SSA-538). However, Disability Examiners (DEs) may assist in preparing all assessment documents including the SSA-538.

B. Component roles concerning the MC’s or PC’s responsibility for determining onset

1. Field office (FO)

The FO does not have a role in implementing this policy.

2. Disability Determination Services (DDS)

The adjudicator is responsible for establishing the EOD and advising the MC/PC about non-medical factors affecting the EOD. The MC/PC is responsible for assessing the severity of the claimant’s condition for the relevant period(s), depending on the claim type.

C. DDS instructions concerning the MC’s or PC’s responsibility for assessing the severity of the claimant’s condition

Disability Determination Services (DDS)

Assess the severity of the claimant’s condition(s) from the claimant’s POD through all relevant periods. An MC, PC, or SDM (when authorized) prepares an RFC, MRFC, or other severity assessment, to address each time the severity of the claimant’s condition changes, resulting in work related changes in the claimant’s functional capabilities. Both the MC/PC and the adjudicator ensure the timeframe for the severity assessment is clearly annotated on the assessment document.

1. DE Instructions:

  • Notify the MC/PC of the timeframes to be assessed.

  • When the MC/PC returns the claim to you, ensure the MC/PC has assessed all pertinent periods.

  • Consider the RFC, MRFC, Childhood Disability Evaluation Form, or other severity assessment, together with other technical and vocational factors, to determine if the claimant is disabled for that period, starting from the earliest RFC, MRFC, Childhood Disability Evaluation Form, or other severity assessment form period.

  • Consider each assessment period to determine if the RFC, MRFC, Childhood Disability Evaluation Form, or other severity assessment, together with other technical and vocational factors, results in a finding that the claimant is disabled for that period.

  • Select the earliest date that is consistent with insured status, SGA, the claimant’s protective filing date, and other non-medical factors, for the claimant’s EOD.

NOTE: DEs should be alert to variances in severity assessments from POD to present, as they could result in closed period allowance(s). See DI 25510.010 through DI 25510.015, for more info