TN 2 (08-15)
DI 28090.001 Cessation or Continuance of Disability or Blindness Determination and Transmittal (SSA-832/833) Rationale
A SSA-832/833 rationale represents complete documentation of the evaluation process used in continuing disability review (CDR) claims adjudication.
Rationales for CDR determinations must clearly reflect all applicable steps in the CDR evaluation process; present an explicit explanation of the decision, including the documentation used to support the decision; and incorporate legislative requirements. It is important for the rationale to reflect the step-by-step evaluation process.
NOTE: We often use the terms “technical,” “disability decision,” and “summary” interchangeably in describing SSA-832/833 rationales. For clarity, the term “summary” will refer to rationales described in DI 28090.000, while the term “supplemental” will describe rationales described in DI 28091.000.
Adjudicators must prepare a rationale whether the determination is a continuance or a cessation. The rationale documents application of the medical improvement review standard (MIRS) required on all CDRs. When disability continues, the rationale establishes a basis for comparison in the subsequent CDR.
The CDR rationale discusses the following, as needed:
Basis for the comparison point decision and reason for current medical review;
Individual's reason(s) for continued entitlement (impairment allegation(s));
Meets or equals determinations;
Medical improvement (MI);
Whether medical improvement is related to ability to work;
Ability to do substantial gainful activity;
Residual functional capacity (RFC);
Ability to perform past relevant work;
Ability to perform other work;
Basis for the disability determination; and
We discuss the rationale content for these 16 topics in DI 28090.015 through DI 28090.200.
A summary rationale is not required if the relevant issues are thoroughly discussed elsewhere in the file. Federal or State agency management decides whether to require a summary CDR rationale, e.g., for training purposes, rather than a supplemental rationale. For supplemental rationale procedures, see DI 28091.000.
NOTE: Some sites use the Electronic Claims Analysis Tool (eCAT) for documenting electronic CDR (eCDR) case analysis. In eCAT, users document each step of the CDR evaluation process. eCAT provides a complete claim explanation in one document, the Disability Determination Explanation (DDE), which is imaged to the electronic folder case documents (A. Payment Documents/Decisions (Yellow Front)). Adjudicators will follow the eCAT User Guide and their site’s business process to document information not contained elsewhere in the file or DDE. For additional guidance on eCDR rationales, see DI 81020.230.