Last Update: 1/21/2020 (Transmittal I-2-232)

HA 01250.034 When to Obtain Medical Expert Opinion

Renumbered from HALLEX section I-2-5-34

A. When to Obtain a Medical Expert (ME) Opinion

Generally, an Administrative Law Judge (ALJ) must competently read and understand medical terminology and medical records, and should thoughtfully evaluate the specific circumstances of a case to determine whether ME input is necessary. In some circumstances, an ALJ is required to seek an ME's opinion, e.g., when a court orders the ALJ to do so. In other cases ordering an ME opinion is discretionary.

The ALJ may obtain an ME opinion either through testimony at a hearing or via written interrogatories. Before ordering an ME, the ALJ must provide a written rationale explaining the need for the ME to the Hearing Office Chief ALJ (HOCALJ), as outlined in Hearings, Appeals and Litigation Law (HALLEX) manual HA 01250.034B.

1. When an ALJ Must Obtain an ME Opinion (Required)

The ALJ must obtain an ME opinion, after providing rationale to their HOCALJ, when:

  • The Appeals Council or Federal court ordered the ALJ to do so;

  • Compliance with an Acquiescence Ruling requires the use of an ME; or

  • An ALJ believes a preponderance of evidence in the record may support a finding that an individual is disabled based upon medical equivalence at Step 3 of the sequential evaluation process (SEP)(Social Security Ruling (SSR) 17-2p).

2. When an ALJ May Seek to Obtain an ME Opinion (Discretionary)

An ALJ may seek an ME opinion, after providing rationale to their HOCALJ, when the ALJ:

  • Needs further explanation of an uncommon medical impairment(s) to determine equivalent listings or potential functional limitations;

  • Needs evaluation regarding the accuracy of medical test results reported or the background medical test data supporting these results. For more information, see HALLEX HA 01250.014E;

  • Is assessing a claimant's failure to follow prescribed treatment and the evidence in the claim is insufficient to make the required assessments in the failure to follow prescribed treatment determination (SSR 18-3p);

  • Believes a claimant's drug addiction or alcoholism may be material to finding a claimant disabled (SSR 13-2p);

  • Needs to infer the date the claimant with a non-traumatic or exacerbating and remitting impairment first met the statutory definition of disability (SSR 18-1p).

NOTE: 

An ALJ must never ask or permit an ME to perform an examination of a claimant. If an ALJ finds an examination is necessary because there is not enough evidence about an impairment(s) for the ALJ to make a finding, the ALJ will request a consultative examination. See HALLEX HA 01250.020.

B. Actions an ALJ Must Take to Obtain an ME Opinion

Before ordering an ME opinion, the ALJ will email their HOCALJ, as outlined in SHOP Section 3.4.1, a memorandum containing the following information:

  • The reason for the request, including the expected scope of the information sought, the specific functional or other limitation for which they require input, and specific evidence in the record that supports their request;

  • If seeking to determine whether medical equivalence exists, the ALJ must document the listing they suspect might be equaled, cite the listing criteria that are already supported by the record, and cite other potential criteria that requires an ME opinion;

  • The specialization of ME requested; and

  • Whether to receive the ME's opinion in testimony at a hearing or in response to written interrogatories.

Hearing office staff should not schedule an ME to appear at the hearing or send interrogatories to an ME until the ALJ has submitted rationale for the request to the HOCALJ and documented such communication in a Case Note, as described in SHOP Section 3.4.1. The ALJ should then advise Hearing Office (HO) staff to select an ME pursuant to HALLEX HA 01250.036. HO Staff should then follow the procedures outlined in HALLEX HA 01250.038 and HA 01250.042 for scheduling the ME to appear at a hearing or sending interrogatories.


To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/2501250034
HA 01250.034 - When to Obtain Medical Expert Opinion (I-2-5-34) - 01/21/2020
Batch run: 04/27/2026
Rev:01/21/2020