TN 1 (03-17)

DI 27021.015 Requirements for the Rationale When Revising a Prior Determination

When revising a prior determination (whether favorable or unfavorable), the Disability Determination Services (DDS) is not required to prepare a revised determination rationale (as outlined in DI 27020.001). However, a simplified rationale is still required if not documented in eCAT or elsewhere in the file:

A. Medical opinions

Cite each medical opinion by source name and date and briefly describe each medical opinion. Assess each medical opinion according to the instructions in:

  • DI 24503.025 Evaluating Medical Opinions and Prior Administrative Medical Findings – Claims Filed on or after March 27, 2017

  • DI 24503.030 Articulation Requirements about Medical Opinions and Prior Administrative Medical Findings – Claims Filed on or after March 27, 2017

  • DI 24503.035 Evaluation and Articulation Requirements about Medical Opinions, Opinions, and Prior Administrative Medical Findings- Claims Filed before March 27, 2017.

For statements on issues reserved to the Commissioner such as that the individual is “disabled” or “unable to work,” see Evaluating Statements on Issues Reserved to the Commissioner in section DI 24503.040 (for instructions about when you are required to provide analysis).

B. Inconsistencies material to the determination

Explain any inconsistencies that are material to the determination; for example, evidence that might support a different determination outcome.

C. Symptom evaluation

If the claimant is not engaging in substantial gainful activity, at each of the remaining steps in the sequential evaluation process, consider any allegation(s) or report(s) of pain or other symptoms to determine the severity and functional effects of the claimant’s impairment(s).

Explain any inconsistencies in the evidence concerning pain or other symptoms. If these inconsistencies are not addressed on the residual functional capacity or psychiatric review technique form, then a supplemental rationale stating how the adjudicator considered the claimant’s allegations of pain or other symptoms must be prepared according to the instructions in DI 27021.005. Discuss the claimant’s statements about his or her symptoms and their functional effects. Assess the claimant’s statements and explain the reasons for your assessment and conclusion. For additional information on evaluating symptoms, see DI 24501.021.

D. Closed period cases

Explain how we demonstrate medical improvement in closed periods of disability. Follow the requirements in Closed Period of Disability in section DI 25510.001.

E. Vocational rule

Explain in the rationale what rules we consider in a medical/vocational decision when the vocational rules are used as a framework for the decision, because no vocational rule is met, see Vocational Factors Do Not Match a Medical-Vocational Rule in section DI 25025.025.

F. Requirement to cite occupations or a Social Security Ruling (SSR)

If transferable skills are material to the determination, Transferability of Skills Assessment, see A Significant Number of Jobs to Support a Framework “Not Disabled” Determination in section DI 25025.030.

G. Court cases

Follow the rationale requirements in Court Cases in subchapter DI 32500.000.


To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/0427021015
DI 27021.015 - Requirements for the Rationale When Revising a Prior Determination - 03/24/2017
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