TN 4 (10-16)

DI 30007.105 Request for Program Consultation (RPC) Process Overview

A. Introduction to the RPC process

In these instructions, the following terminology applies.

  • References to the Disability Determination Services (DDS) in these instructions also apply to the federal case-processing units.

  • References to the Centers for Disability (CD) apply to the regional CDs.

  • The Office of Disability Determinations (ODD) applies to ODD headquarters.

  • References to the disability quality branch (DQB) apply to quality review field site components.

  • The Office of Quality Review (OQR) applies to OQR headquarters.

The Request for Program Consultation (RPC) process is a function of the Office of Policy Consultation and Analysis (OPCA) in the Office of Disability Policy (ODP). ODP designed the RPC process to resolve policy disagreements between DDSs and DQBs regarding DQB-cited deficiencies collaboratively. ODP maintains a database of RPC case-related information to capture policy and workload data for trends analysis.

NOTE: The RPC process only applies to certified electronic files.

The primary goal of the RPC process is policy-supported resolution of case disagreements, not case re-adjudication (“de novo” review).

While RPC is a tool available to resolve conflict between DDSs and DQBs, DDSs should consider first whether other conflict resolution procedures, such as informal phone or email contact, or informal resolution request (IRR) are appropriate for the specific case situation. If the “other” procedures do not resolve the conflict, RPC remains available.

B. The RPC panel and panel discussion

The RPC panel is composed of one member each from ODP, ODD, and OQR. An ODP/RPC staff member facilitates the panel discussion. The panel discussion is the mechanism RPC uses to resolve policy and procedure disagreements.

The panel members must work together cooperatively to ensure determinations are supported by the evidence and programmatic policy and procedure. Each panel member is required to review the entire case file and must come prepared to discuss the case facts; issues presented in the RPC submission and Request for Corrective Action (SSA-1774); other issues identified during case review; and policy/procedural application and compliance. See DI 30007.145 for more detail on the panel discussion.

C. Objectives of the RPC process

The objectives:

  • Provide a policy-supported resolution to case-specific questions concerning application of disability policy and procedure;

  • Provide an objective and transparent process to resolve policy disputes;

  • Improve the accuracy and consistency of disability determinations and quality reviews;

  • Identify trends and policy and procedural issues requiring clarification or training;

  • Protect claimants and beneficiaries from incorrect determinations;

  • Protect the Social Security Disability Insurance program and the Supplemental Security Income program from incorrect determinations:

  • Affirm correctly cited deficiencies; and

  • Rescind deficiencies when policy supports the DDS’s determination.

D. What is the RPC resolution?

The RPC resolution is SSA’s official response to disability policy disagreements between a DDS and a DQB. While the resolution provides case-specific policy guidance, the resolution itself is not disability policy.

E. Case jurisdiction

The DDS retains jurisdiction of the case during the RPC process. The DDS cannot process or transfer jurisdiction of the case until they receive the resolution and complete all required actions specified in the resolution. ODP will not assume jurisdiction of any case.

EXCEPTION: When a DDS submits an RPC on a case not in their jurisdiction, such as a Group II decisional deficiency where the DQB changed the onset, it is the DDS’s responsibility to ensure any changes in the determination resulting from the RPC resolution are made.

F. Specific Instructions