Social Security

This Emergency Message (EM) is to notify all disability claims adjudicating components that the Disability Case Processing System (DCPS) is a policy compliant place to record case information for adjudicating components using DCPS.

Background

DCPS is a critical initiative that will replace 52 independently operated legacy systems used by state agencies (Disability Determination Services or DDSs) that make disability determinations for SSA as required by statute. DCPS will replace the legacy systems with a modern, accessible, and secure application capable of providing the flexibility and high performance that the DDSs and federal sites need to process disability claims timely and efficiently.

We are issuing this EM to provide notice that adjudicators have met documentation requirements when they use DCPS to record required documentation previously recorded in a system DCPS is replacing.

Policy

We want to ensure that there is consistent and reasonable application of policy during the transition from legacy systems to DCPS. Over time, we will update all of the Program Operational Management System (POMS) that refer to an exact place to record case information to include the appropriate DCPS notations. Until that time, DCPS is also a policy compliant place to record case information for adjudicating components using DCPS.

Examples

· Procedure for telephone contact for evidence or action request, DI 23007.005E.1.a, requires the adjudicating component to “document the case development summary worksheet with the details of the development undertaken.” In addition, DI 22515.030D requires that the adjudicating component document any additional work history information in the Claim Communications section of the electronic Claims Analysis Tool (eCAT). DCPS users should document a telephone contact for evidence or action in the “Case Notes” section in DCPS.

· DI 25015.017H provides guidance on documenting the transferability of skills assessment. It instructs the adjudicating component to “document each step in the Disability Determination Explanation (DDE) section of the electronic Claims Analysis Tool (eCAT) — e.g. Vocational Explanation Claim Communications, Vocational Explanation textbox.” DCPS users should document the transferability of skills assessment in the “Case Note” section in DCPS.

· DI 25015.006G instructs adjudicators to document their consideration of borderline age in the Electronic Claims Analysis Tool (eCAT) in the text box found in the Borderline Age section of the Past Relevant or Other Work page(s) or in the E section (Disability Development and Documentation) of the electronic or paper modular disability folder. If you are using DCPS, document consideration of borderline age in the “Vocational Assessment” page.

· DI 24510.060A.4. instructs the adjudicating component to document the mental residual functional capacity decision using form SSA-4734-F4-SUP. In this Section III-Functional Capacity Assessment is for recording the actual mental residual functional capacity (RFC) assessment by explaining the conclusions indicated in Section I, in terms of the extent to which these mental capacities or functions could or could not be performed in work settings. DCPS users may document this information in the “MRFC Additional Textbox” that is noted to be optional.

Direct all program-related and technical questions to your Regional Office (RO) support staff or Program Service Center (PSC) Operations Analysis (OA) staff. RO support staff or PSC OA staff may refer questions, concerns, or problems to their Central Office contacts.

References:

DI 20503.001 Documenting the Disability Folder – Disability Determination Services (DDS)
DI 22515.030 Use of Work History Report Form SSA-3369-BK
DI 23007.005 Failure to Cooperate With Requests to the Claimant for Evidence or Action
DI 24503.025 Evaluating Medical Opinions and Prior Administrative Medical Findings – Claims filed on or after March 27, 2017
DI 24505.025 Evaluation of Mental Impairments
DI 24510.060 Mental Residual Functional Capacity Assessment
DI 25015.006 Borderline Age
DI 25015.017 Transferability of Skills Assessment (TSA)