Identification Number:
GN 04440 TN 84
Intended Audience:
Originating Office:OARO Office of Quality Review
Title:Federal Quality Review of Disability Determinations
Type:POMS Transmittals
Program:All Programs
Link To Reference:
 

PROGRAM OPERATIONS MANUAL SYSTEM
Part GN – General
Chapter 044 – Quality Appraisal
Subchapter 40 – Federal Quality Review of Disability Determinations
Transmittal No. 84, 12/02/2019

Originating Component

OQR

Effective Date

Upon Receipt

Background

This is a Quick Action Transmittal. These revisions do not change or introduce new policy or procedure

Summary of Changes

GN 04440.501 Completion of the SSA-1774-U5, Request for Corrective Action

The Office of Quality Review (OQR) is making editorial changes and completing updates throughout the quality review sections of POMS to improve consistency, add clarity, and ensure conformance with Plain Language Guidelines.

We made the following revisions to section B:

  • Made minor changes to clarify content;

  • Replaced the phrase "legacy system" with the updated phrase "case processing system"

  • Shortened sentences, where possible.

GN 04440.501 Completion of the SSA-1774-U5, Request for Corrective Action

A. Use of an SSA-1774-U5

The Office of Quality Review (OQR) completes an SSA-1774-U5 to return group I and group II deficiencies, as well as some technical corrective actions, that may affect the disability determination or the period of disability, to the adjudicating component.

For additional information regarding the types of transmittal forms and an exhibit of the SSA-1774-U5, see the references below:

B. Procedure for completing an SSA-1774-U5

The sections below explain how to complete the SSA-1774-U5 form.

1. How to complete the fields

Information from OQR's case processing system electronically propagates sections 1 through 6 and 8 through 11 of the SSA-1774-U5. NOTE: The “date” field in section 1 does not automatically propagate and must be entered manually. See GN 04440.501B.4.

Manually enter onset information in section 7 for deficient initial and recon disability determinations. Complete the alleged onset (AOD) field. Enter the adjudicating component’s established onset date (EOD) for all allowance determinations. Complete the reviewer onset date (ROD) field when a group I decisional deficiency results in a favorable disability determination or a group II decisional deficiency warrants a different onset date.

For complete and accurate data propagation, quality reviewers must complete all OQR case processing system coding prior to creating the SSA-1774-U5. Following completion of the appropriate review screens, quality reviewers must:

  • Review the propagated fields for accuracy and make any necessary changes in OQR’s case processing systems, as applicable.

  • Incorporate policy references into the case discussion. Do not list policy references in section 10 ("REFERENCES").

  • Select the “YES” or “NO” block for the "FOLDER ATTACHED" section of the SSA-1774-U5, as applicable.

  • Select the "YES" or "NO" blocks for “MEDICAL REVIEW” and “MED NOTE IN FILE", as applicable.

2. How to format and organize the narrative discussion

The following sections explain how to complete the narrative fields on the SSA-1774-U5.

a. Narrative fields

The narrative fields on the SSA-1774-U5 include:

  • Item 11 ("ACTION REQUESTED AND RATIONALE") on the first page and

  • Continuation pages (up to 10 total) provided when you select the ["More"] button.

In item 11, summarize the relevant facts of the case and clearly state:

  • the policy issue,

  • reasons why the case is deficient, and

  • necessary corrective action(s).

To explain or justify the deficiency, do not use:

  • Office of Disability Policy’s policy memorandums,

  • PolicyNet Questions and Answers (Q & As) or

  • other similar written guidelines that are not part of National policy.

NOTE: Quality reviewers cannot cite a Q & A as the sole basis for a deficiency, but may refer to a Q & A on the SSA-1774-U5, for clarification purposes only, as long as the Q & A is not expired or archived.

Acceptable references include:

  • The Program Operations Manual System (POMS)

  • The Social Security Act

  • Regulations

  • Social Security and Acquiescence Rulings

  • Administrative and Emergency Messages (See the last sentence of the NOTE in GN 04440.007B.2 for additional information.)

Follow the appropriate format when completing each section of the narrative discussion on the SSA-1774-U5, as explained below.

b. The header section of the SSA-1774-U5

The OQR case processing system propagates the header section onto the SSA-1774-U5 form. The heading will differ based on the type of review and deficiency code.

  • For cases with "TYPE OF REVIEW" noted as “OTHER” in block 4, OQR’s case processing system propagates a heading of “Informational Only”.

  • For cases with a deficiency code between 10 and 85, OQR’s case processing system propagates a heading that includes the deficiency group, deficiency type, OQR’s case processing system assigned deficiency code, and a narrative description of the deficiency code. The information will be correct if the reviewer completes OQR’s case processing system coding prior to creating the SSA-1774-U5. For example, Group I Decisional – 11 – Incorrect Impairment Severity Decision.

c. How to complete the “ISSUE” section

Provide a brief summary to describe the basis of the deficiency. Two to three sentences is generally sufficient.

d. How to complete the "CASE DISCUSSION & POLICY ANALYSIS" section, including relevant policy citations

Follow the Federal Plain Language Guidelines, as enacted by the Plain Language Act of 2010, when writing the narrative discussion of the SSA-1774-U5. Compose the body of the SSA-1774-U5 in typeface Courier New, Arial Regular, or Times New Roman with font size 10 to 14 points.

If applicable to the return, the section should include:

  • A brief statement of the claimant's allegations and the alleged onset date.

  • Discussion of the vocational issues, including incorporation of specific policy references to support any deficiency findings.

  • Discussion of the medical issues, with respect to sufficiency of documentation or medical severity, as it relates to listing requirements or impact on the claimant's residual functional capacity (RFC). Include incorporation of specific policy references.

  • Discussion of symptom evaluation, medical source statements, all opinion evidence, and any related policy.

DO NOT:

  • Cut and paste POMS sections into the return without providing a discussion of the policy interpretation and how it specifically applies to the cited deficiency.

  • Provide a list of references or cite a range of POMS chapters.

  • Cite a POMS table of contents or introductory section, unless the introductory section contains specific instructions related to the deficiency (e.g., introductory text in specific Listing of Impairments).

NOTE: Be very specific. Adjudicating components, the Office of Disability Policy's Request for Program Consultation staff, and subsequent reviewers must be able to identify the incorrectly applied policy to determine the proper course of corrective action(s).

e. How to complete the “REQUEST FOR CORRECTIVE” section

Explicitly state the action(s) necessary to correct the deficiency.

If documentation is necessary, specify the type of documentation. Do not direct the adjudicating component to purchase a consultative examination or otherwise tell them how to obtain the evidence. For additional information on routing and correcting deficient cases, see GN 04440.201E.1.

If the return does not require corrective action by the adjudicating component, include the statement, “No corrective action required”.

NOTE: Select the ["More"] button at the bottom of page one of the SSA-1774-U5 if you need additional pages to explain the reason for the return. If you need more than the allotted ten continuation pages, use an SSA-1774A-U5 Continuation sheet.

3. How to access the continuation pages of the SSA-1774-U5

Item 11 on the first page of the SSA-1774-U5, and each continuation page, is recognized as a separate narrative field. At times, you must “work around” the space limitation (displayed in the “current field” attributes in each of the narrative fields) by selecting and moving some of the text to a continuation page. The pages are separate fields and text will not "wrap" like it would in a Word document.

  • To access continuation page 2, scroll down, and select the ["More"] button located at the bottom right of page 1.

  • To access additional continuation pages, scroll down, move the cursor to the far right margin, and select the ["More"] button.

4. How to sign the SSA-1774-U5

The name of the person who creates the SSA-1774-U5 form will propagate in the "REVIEWER" field at the bottom left of the SSA-1774-U5.

If the primary basis of the deficiency involves a medical, psychological, or psychiatric issue, you must manually enter at least one name in the "MEDICAL REVIEWER" field located under the "REVIEWER" field on the SSA-1774-U5.

If the primary basis of the deficiency does not involve a medical, psychological, or psychiatric issue, the "MEDICAL REVIEWER" field may be left blank.

The approving official must manually enter information in the "OFFICE", "APPROVED", and "DATE" fields. The “DATE” fields include those located at the top and bottom right of the SSA-1774-U5 and must coincide with the date the case returns to the adjudicating component.

5. How to upload the SSA-1774-U5 to the certified electronic folder (CEF)

To upload the final version of the SSA-1774-U5 to the CEF, select the form for upload at OQR’s case processing system clearance screen. Authorized SSA personnel may view the SSA-1774-U5 in the CEF.


GN 04440 TN 84 - Federal Quality Review of Disability Determinations - 12/02/2019