When the adjudicating component disagrees with any cited group I deficiency, group
II deficiency, or technical corrective action (TCA), in a fully electronic case, they
are encouraged to attempt to resolve the disagreement on an informal basis by submitting
an IRR via the Office of Disability Policy’s (ODP) IRR web-based tool.
NOTE: RPC will not accept submissions when the disagreement involves a change in deficiency type only,
otherwise known as a "wrong deficiency cited", unless the case has first been through the IRR process. A wrong deficiency citation 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 review component codes the correct
deficiency in the OQR case processing system. This still only results in one chargeable deficiency against the adjudicating component.
EXAMPLE: The review 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 review 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 review component corrects the OQR case processing system to reflect a documentation
deficiency, thus there is only one chargeable deficiency for the adjudicating component.
If the adjudicating component chooses not to attempt 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, if the criteria is met, to OPCA for a fully
electronic case (see DI 30007.125 – Submitting a case for RPC). The adjudicating component may not simultaneously submit an IRR and RPC.
If the adjudicating component does not resolve the deficiency through the IRR process,
or submit an RPC, they must complete the request for corrective action(s) noted in
the SSA-1774-U5, Request for Corrective Action.