When the adjudicating component disagrees with any cited group I or group II deficiency
in a fully electronic case, they are encouraged to resolve the disagreement on an
informal basis by submitting an IRR via the Office of Disability’s (ODP) IRR web-based
NOTE: RPC will not accept submissions when the disagreement involves a change in deficiency type, otherwise
known as a wrong deficiency situation, unless the case has first been through the IRR process. A wrong deficiency situation occurs
when one type of deficiency is cited but program instructions support a different
type, e.g., documentation vs decisional or group I vs group II. In these situations,
there is no rescission of the deficiency, but the reviewing component codes the correct
deficiency in the OQR legacy system. This still only results in one chargeable deficiency against the adjudicating component.
EXAMPLE: The reviewing component cites a decisional deficiency, changing an allowance determination
to a denial determination, but fails to recognize in doing so, that the adjudicating
component must first develop all allegations or medical sources prior to denying the
claim. The adjudicating component requests the reviewing component change, or replace,
the decisional deficiency to a documentation deficiency, agreeing that the evidence
does not currently support an allowance, but acknowledging the adjudicating component
must develop all allegations or medical sources before making a denial determination.
The reviewing component corrects the OQR legacy system to reflect a documentation
deficiency, thus there is only one chargeable deficiency for the adjudicating component.
If the adjudicating component chooses not to resolve the disagreement through the
IRR process, or if they cannot resolve the deficiency after the IRR process, the adjudicating
component may submit an:
RPC to OPCA for a fully electronic case (see DI 30007.125 – Submitting a case for Request for Program Consultation (RPC)); or
OQR rebuttal to the reviewing component for a case that is not fully electronic (see
DI 30005.510 The Office of Quality Review (OQR) Rebuttal Process).
If the adjudicating component does not resolve the deficiency through the IRR process,
or submit an RPC or OQR rebuttal, they must complete the request for corrective action
on the deficiency transmittal form.