SSA - POMS: DI 25501.200 - Overview of Onset Policy

A. Definitions of onset date and established onset date (EOD)

The onset date is the first day the claimant meets the definition of disability or statutory blindness as defined in the Social Security Act (Act) and regulations. Before a period of disability can begin, the claimant must meet certain entitlement or eligibility factors. We call the date that the claimant meets the definition of disability and all the relevant entitlement or eligibility factors the EOD. You need an EOD for every allowance.

NOTE: In some claims, the POMS instructions allow the adjudicator to establish an EOD before the date the claimant is first eligible or entitled to benefits. See DI 25501.300 through DI 25501.380 for specific information on when an EOD can be established before the date a claimant is first entitled or eligible for benefits.

1. Factors relevant to the determination of an EOD

Factors relevant to the determination of an EOD include, but are not limited to:

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the date the claimant alleged he or she first became disabled. (See DI 25501.210, Alleged Onset Date)
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the type of claim filed,
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the claimant’s age,
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the claimant’s work history,
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the nature of the impairment,
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the medical and other evidence, and
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whether or not the claimant filed a prior claim.

We evaluate these and other entitlement or eligibility factors to arrive at an EOD.

CAUTION: The EOD is not simply the first date the claimant met the medical criteria for disability.

2. Rules for establishing an EOD are different based on claim type

Each type of claim (e.g., Disability Insurance Benefit, Disabled Widow(er)’s Benefit, Childhood Disability Benefit, and Supplemental Security Income) has unique rules for establishing the EOD. We provide detailed instructions for establishing an EOD for each type of disability claim in the following Program Operations Manual System (POMS) sections.

NOTE: Never establish EOD during a prior period of disability that ended in cessation or termination. A period of disability that ended after 12 months due to failure to cooperate would be considered a period of disability that ended in termination.

B. Component roles and responsibilities to establish an EOD

Establishing an accurate EOD requires collaboration between the field office (FO) and the Disability Determination Services (DDS). Both components have vital roles and responsibilities in establishing an accurate EOD. Each section of this subchapter begins with an explanation of a specific policy regarding establishing an accurate EOD. The second part of each section, explains each component’s role in establishing an accurate EOD. In the third part of each POMS section, we provide detailed instructions for each policy component to implement the appropriate policy.

C. Component Instructions for Documentation of the EOD

Claims representatives should document their reasons in proposing a potential onset date (POD). Disability adjudicators should also explain how they determined the EOD in every case.

1. Field office instructions for documenting alleged and potential onset dates and work activity

a. Documenting alleged and potential onset dates (AODs) and (PODs)

The FO documents information about the claimant’s AOD and POD, if applicable, in Sections 2-7 of the SSA-3367 (Disability Report, Field Office).

For more information on completing the SSA-3367, see DI 11005.045.

For more information on completing the Form SSA-3367 in the Electronic Disability Collect System (EDCS), see DI 81010.025.

See DI 25501.210 for policy concerning the alleged onset date.

See DI 25501.220 for policy concerning the potential onset date.

b. Documenting work activity

The FO is responsible for documenting all work activity that may affect the EOD, and resolving and explaining any discrepancies in work activity affecting the POD. When inconsistencies in work activity affect the POD, the field office completes:

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Form SSA-821-BK (Work Activity Report – Employee) and Form SSA-823 (Report of SGA Determination), if the work activity is the result of an employer-employee relationship, , or
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Form SSA-820-F4 (Work Activity Report – Self-Employed Person) and Form SSA-823 (Report of SGA Determination), if the work activity is the result of self-employment.

When the claimant is in an employee/employer relationship, the FO documents work activity affecting the EOD by completing appropriate sections of the SSA-821 (Work Activity Report-Employee) and SSA-823 (Report of SGA Determination).

For more information concerning documenting employment cases using the SSA-821 and the SSA-823, see DI 10505.035.

When the claimant is self-employed, the FO documents work activity affecting the EOD by completing appropriate sections of Form SSA-820 (Work Activity Report-self-employment) and Form SSA-823 (Report of SGA Determination). For more information concerning documenting self-employment cases using the SSA-820 and the SSA-823, see DI 10505.025.

2. DDS Instructions for documenting the EOD

When you use adjudicative judgment in establishing an EOD, you should explain why you selected this date. In the Disability Case Processing System (DCPS), put this explanation in the onset text box in the determination page. Document additional information in a Case Note in the Disability Case Processing System (DCPS), or on the Case Development Worksheet (CDW).” Preparing an explanation will help ensure that a quality reviewer does not substitute his or her judgment for your judgment.

EXCEPTION: You need a rationale when you make a borderline age determination. See DI 25015.006G Borderline Age–Documenting consideration of the borderline age.

D. References

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DI 24001.005 Work Activity Development Responsibilities
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DI 24001.010 Effect of SGA on Disability Status
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DI 24005.001 Unsuccessful Work Attempt (UWA)

Program Operations Manual System (POMS)

DI 25501.200 Overview of Onset Policy