SSA - POMS: DI 11010.030 - Field Office (FO) Operating Instructions for Deferred Title II Initial Claims

A. Application process

During the initial claims interview or online claims intake, secure the primary application and necessary disability information. For related instructions on processing:

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Claims in the Electronic Disability Collect System (EDCS), see DI 81010.020.
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Certified Electronic Folder (CEF) exclusions and EDCS/eView limitations, see DI 81010.030.
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Internet Disability Reports (IDR), see DI 81007.005.
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Forms used in disability claims, see DI 11005.016.

Accept any evidence which the claimant offers and store the evidence using applicable retention systems (e.g., Evidence Portal (EP)). Prior to transfer of the claim to the Disability Determination Services (DDS), complete required earnings development to determine insured status and evaluate substantial gainful activity (SGA) issues in the period covered by the application. If any further nonmedical development is necessary, advise the claimant of the proofs needed (e.g., workers compensation documentation, lag earnings verification) and that SSA may recontact the claimant later to again request any outstanding evidence.

NOTE: Use applicable screens (e.g., EARN or WORK pages in the claims systems path) or sections of the application to document allegations of lag earnings which may affect insured status.

B. Establishing intent to file for auxiliaries and survivors

For general policy about protective filing, see GN 00204.010.

Use the following guidelines to establish protective filing in disability claim situations.

1. Deferred development

When the number holder (NH) establishes protective filing for the auxiliary on the disability benefit application, the protective filing date for the disability and auxiliary benefits will be the same and remain protected if the disability claim is allowed at any level of adjudication (e.g., initial, reconsideration, or hearing).

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When development is deferred pending a final disability determination or decision, do not issue a closeout for the protected auxiliary. For more information on deferred development cases and potential auxiliary benefits in disability claims, see DI 11010.025C.
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In the event of a disability allowance, auxiliary entitlement is possible. Resume development of potential auxiliary benefits in the claim and either secure the complete valid application or provide protective filing closeout notification as appropriate.
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For when to establish an auxiliary as a delayed claimant on the Master Beneficiary Record (MBR), see GN 01010.140.
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For when to initiate simultaneous development, see the table in DI 11010.030B.2 in this section.

NOTE: In a Quick Disability Determination (QDD) or Compassionate Allowance (CAL), an EDCS onscreen message will prompt the FO to complete simultaneous development. For when the QDD predictive model or CAL selection software determines that a case qualifies for priority processing, see DI 23022.030.

2. When development cannot be deferred

Simultaneous Development

If	Then
• The proper applicant for the auxiliary benefit insists on filing, • the proper applicant is present at the disability claim interview and recontact would be difficult (e.g., due to medical and geographical considerations), or • full nonmedical development is required following instructions in DI 11010.025D (e.g., QDD, CAL).	• Obtain the auxiliary claim, • Use applicable systems (e.g., Shared Processes) to store available proofs, and • complete development for any other necessary evidence.
Upon medical allowance:	Ensure development is complete and process the awards.
When evidence is still needed to establish only the auxiliary entitlement:	Do not hold payment of the disability benefit while requesting further evidence for the auxiliary benefit.
Upon medical denial:	Process the disallowances.
When a valid appeal is filed on the issue of disability:	Both claim types may continue through the appeals process.

3. Children

In situations when the claimant indicates an expected child (i.e., when the pregnancy is ongoing and the child is not yet born) and the disability insurance benefits (DIB) application includes enough information to identify the child, ask about intent to file and establish a protective filing for that child, as appropriate.

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Even when the child is not yet named, document the relevant information. For example, an unborn child whose birth is referred to on the NH's application with a statement such as: "My spouse is pregnant and expecting our baby in 4 months and, if my disability claim is approved, we will file for the child's benefits as soon as the child is born" receives the same filing date protection as the NH.
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Prepare a manual follow-up issue or diary to control in the applicable claims system and provide any further required closeout notification to the NH upon a medical allowance in the disability claim (or in the month of the child's expected birth when later than the date of the medical allowance). For information on the first possible month of entitlement to an auxiliary child benefit, see RS 00203.010.

When further contact with the NH is necessary for any required disability development in the pending claim and intent to file remains unresolved for an auxiliary child listed on the application, to ask about intent to file and record the response during contact with the NH, follow instructions in GN 00204.010. In the applicable claims system, document the record with a report of contact or remarks (for example, the remark “there is intent to file for the listed children when benefits are awarded for the disability claim” in the Modernized Claims System (MCS)).

NOTE: When the disability claim is medically allowed and the NH was never previously asked about intent to file for the child named on the application (e.g., an internet Claim (iClaim) application), issue a closeout notification using the same protective filing date for the auxiliary child benefits as for the NH's disability benefits. When manual Title II closeout notification is required for a child listed in a disability iClaim, see Document Processing System (DPS) letter instructions in NL 00703.740.

C. Earnings record review

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Obtain most earnings record information with an Earnings Computation (EC) request or with the Informational/Certified Earnings Record System (ICERS), see GN 01010.010.
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Review the Earnings Alert Query (EARQ) to identify potential earnings record discrepancies, see DI 11010.050.

Review the earnings record for insured status prior to transfer of the disability claim to the DDS.

Earnings Issues

If	Then
There is a delay in receiving the earnings information:	Review it upon receipt to determine whether it may affect benefit eligibility.
Material earnings discrepancy arises:	Develop to resolve the discrepancy, regardless of the status of the medical determination.
Earnings development is in progress; available evidence indicates insured status is met once such development is complete:	Initiate and continue this development while the case is pending at the DDS.
After additional development, insured status is not met and there is no potential onset date (POD) (as described in DI 25501.220) for the entitlement:	Input an FO determination to close the case. (In general, an FO determination input will close a CEF case even when already at the DDS. However, when a CEF exclusion case is pending at the DDS, the FO must recall the folder.)

NOTE: If, at any point in the claims process, the FO becomes aware that the claimant is ineligible for any nonmedical reason, input an FO determination to close the case in EDCS (and other applicable claims systems) or recall the folder from the DDS for additional FO action, as appropriate. For related instructions on:

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Development and evaluation of a potential period of SGA, see sections in DI 10501.000.
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Development and evaluation of an apparent technical denial, see DI 11010.040.
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FO determinations in EDCS/eView, see DI 81010.140.

D. Nonmedically completing the claim

When Nonmedical Completion (NMC) criteria apply, and sufficient nonmedical development of eligibility is complete prior to the medical determination, the FO inputs NMC to set an auto-initiated adjudication trigger. Upon receipt of the medical determination from the DDS, NMC completes processing the claim through EC without manual intervention.

NOTE: NMC does not automate the sequential evaluation process to determine disability (i.e., the medical determination, as described in DI 22001.001). When auto-initiated adjudication is successful, NMC automatically completes certain nonmedical processes (e.g., benefit computation, award notice, payment release) through existing systems. The automated processes are transparent and completed claims remain available for review in applicable claims systems.

In deferred development DIB claims, NMC criteria apply when the claimant meets the nonmedical requirements for eligibility and none of the following special conditions are involved:

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Appointed representative fee, see GN 03940.015B
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Statutory blindness DIB freeze, see DI 11005.071
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Prisoner or fugitive felon (FF) issues, see sections in GN 02607.000

For DIB eligibility requirements, see DI 10105.005.

1. Age and citizenship development

When proof of age development is unnecessary for eligibility (as explained in DI 11010.055), input the trigger for NMC without further proof of age development. Do not delay an award effectuation while developing to resolve an age discrepancy unless the discrepancy materially affects whether the claimant is entitled to the benefits awarded.

Use caution in effectuation of a DIB allowance without proof of citizenship:

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Although not an entitlement factor for DIB or a DIB freeze, citizenship or lawful presence is required for payment of benefits (as explained in RS 00204.010).
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To avoid potential suspended payment status, develop necessary evidence of citizenship or lawful presence, following instructions in RS 00204.015, before NMC.
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Adjudicate an award into suspended payment status for absence of citizenship or lawful presence proofs only if required attempts to obtain the proofs were unsuccessful.

Suspended Payments

If	Then
A DIB allowance is input without the applicable proof of citizenship or lawful presence:	The MBR Ledger Account File (LAF) will display suspended payment status, e.g., LAF-S9 (NOUSCP).
The FO obtains required proof to remove the LAF-S9 status on the MBR:	Complete reinstatement inputs in applicable systems (e.g., Post-Entitlement Online System (POS), Consolidated Claims Experience (CCE)) to release the payment and related notice.
If the FO’s reinstatement input excepts (i.e., is unsuccessful) due to other special conditions pending on the MBR (e.g., attorney fee due, Title XVI windfall offset):	Applicable screen alerts display and an Action Control Record (ACR) generates to notify the processing center (PC) of manual PC action necessary to complete the reinstatement.

2. Offset development

When material workers compensation or public disability benefit (WC/PDB) development is unresolved, exclude the disability claim from NMC. In general, WC/PDB development is:

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“material” when the WC/PDB payments offset (i.e., reduce) the potential Social Security payments, and
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“unresolved” when requested evidence necessary to establish the offset remains outstanding.

NOTE: In the electronic claim path, the SSA-546 (WC/PDB Questionnaire) is part of the application screens and displays a statement explaining that any entitlement to or change in WC/PDB payments must be reported to SSA immediately.

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Accept any evidence that the claimant offers with the application and, when necessary, request additional evidence to verify WC/PDB payments (following instructions in DI 52140.001A).
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Review the DIB application and related information to determine WC/PDB offset (following instructions in DI 52140.001B).
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When applicable, use the State maximum rate for the offset until we receive requested WC/PDB documentation (following instructions DI 52140.001C).

WC/PDB development need not be completed prior to NMC in the following situations:

a.
No WC/PDB offset applies.
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  For reverse jurisdiction, see DI 52105.001.
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  For other payments which will not cause WC/PDB offset, see DI 52125.005 and DI 52105.015.
b.
The claimant neither received any WC/PDB payment to date nor knows when to expect any future WC/PDB payment and whether the potential payment type could cause an offset. For example, when the claimant alleges:
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  a pending WC/PDB claim where reverse jurisdiction applies, or
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  merely an intent to file an unspecified type of WC/PDB claim at some unknown date in the future. (For how WC/PDB types and “unknown” responses appear on the signed/attested SSA-546, see DI 52140.005C.)
c.
If the actual amount of compensation is unverified at the initial interview, the FO may input the trigger for NMC when using the claimant's allegation or the State maximum amount until receipt of requested proofs, unless lag earnings affect the Average Current Earnings (ACE) (explained in DI 52150.010) or Title XVI windfall offset applies.
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  Advise caution when alleged future WC amounts are above the applicable limit (explained in DI 52150.015) and below the State maximum (explained in DI 52150.045), as this range affects the specific offset computation. To help avoid future overpayments, the claimant may use the State maximum or give the highest applicable estimate for WC payment projections (as explained in DI 52140.001F).
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  When appropriate, remind the claimant that failure to timely report WC/PDB updates may lead to overpayments and obtain a repayment statement (as explained in DI 52140.001E).

3. Lag earnings development

When the claimant alleges lag earnings, request proof of lag earnings following instructions in RS 01404.005.

Unverified Earnings

If	Then
Unverified lag earnings leave insured status in question:	Resolve required lag earnings development prior to NMC or award effectuation.
Unverified lag earnings affect only the potential Title II benefit amount (i.e., insured status is currently met and no Title XVI windfall offset applies):	Exclude the lag earnings from EC and input the trigger for NMC.
Receipt of evidence verifies lag earnings:	Update the claim to record new verified lag earnings and, as applicable, complete or recomplete NMC inputs.

E. Processing allowances

The Workload Action Center (WAC) DIB Action Items tab has a capability issues list to help identify which claims may require a capability determination or representative payee development upon allowance.

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For resolution of representative payee issues, see DI 11055.215.
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For when to establish direct payment, or an initial “no payment” award (with benefits in temporary LAF-S8 (DEVPYE) suspense status pending further payee development), see GN 00504.110.

If a claim processes via NMC and the NMC trigger cannot effectuate the allowance, the development worksheet (DW) screen alerts the FO that additional evidence or further development is needed. For example, if capability is unresolved, the DW shows DDSRV (generated with an explanation in the issue Remarks field) and additional exclusion codes (e.g., DDS-EX, DDS-PL, DDS-FL) as applicable. The NMC trigger may fail to effectuate allowances (though not certain disallowances) in claims with other processing issues or limitations, e.g.:

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Fee payment to an appointed representative, see GN 03940.015
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Favorable reopening of a prior medical determination, see DI 25501.250
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Felony related impairment, see DI 10105.100
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Offset from multiple WC/PDB claims for the same period, see DI 52150.035F
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Retroactive benefits withheld for recovery of a prior overpayment, see GN 01010.040D
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Certain EC screen edits, see DI 11010.015

Resolve any material discrepancies between the Primary Insurance Amount (PIA) on the MBR of a prior award and EC (following instructions in GN 01010.100). Review trial computations in EC; if one agrees with the MBR PIA (the guarantee as explained in RS 00605.035), EC will correctly use the prior period of disability (PPD).

NOTE: When the disability determination is on the Workload Management Information (WMI) listing, but the CEF (or other official folder) is pending in the Disability Quality Branch (DQB) (or equivalent review section), hold effectuation until the case returns from the DQB. To verify the DQB determination, review the:

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EDCS Action Page for case return, see DI 81010.100
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Case Review/Action History, see DI 81005.055 and DI 10005.020A.1
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SSA-831 Disability Determination and Transmittal

In a medical allowance, take the following action immediately upon receipt of the AL indicator code on the WMI list (or other equivalent alert from the DDS/DQB):

1.

Initiate all further required nonmedical development (including auxiliary claims).
2.

For CEF cases, open the case in eView. Look at the eView Status/History to make sure the case is back at the FO and not still pending in the DQB.
3.

Check eView messages, the EDCS Actions page, and SSA-831 remarks for any special notice, routing, or other processing instructions. (Or check for receipt of the official folder, which may occur first.)
4.

Receipt in the DDS disability determination (DDSDEC) issue on the DW. FO processing time on the WMI completed list will typically be counted from the application receipt date to the date of transfer (DDSDEC REQ date) in EDCS (FO1 time) and then from the FO receipt (DDSDEC REC date) to when the MBR updates for the disability determination (FO2 time). For successful NMC auto-initiated adjudications, batch updates automatically complete FO2 time after the DDS case clearance back to the FO (regardless of DDSDEC dates on the DW). For partial adjudication, see GN 01010.110 and GN 01010.120.
5.

If the disability determination did not trigger payment via NMC, ensure the nonmedical development for the entitlement is complete and manually process the award.
6.
Most auxiliary claims, including childhood disability benefits (CDB) and disabled widow(er)s benefits (DWB), will process as subsequent claims through EC (unless there is a processing limitation, e.g., the “"NH benefit adjustment needed" edit when EC attempts to complete a subsequent auxiliary award that affects current WC/PDB offset computations as described in DI 52140.001J).
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  The FO has authority to delay the claimant's payment for a short period (generally no more than 5 working days); if deferred or full auxiliary development can be completed within that time, the FO may process all the claims through EC.
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  If the case has not been triggered for NMC, and the claimant has a future month of entitlement at the time of the disability claim allowance (e.g., case is still in the waiting period), the FO may delay the EC trigger until the auxiliary development is complete when necessary to enable all the claims to process together through EC.
NOTE: This optional procedure reduces the number of subsequent auxiliary claims requiring Manual Adjustment Credit and Award Process (MADCAP) processing. However, use this procedure only when the EC triggers of the primary and auxiliary claims occur soon enough to assure timely payment to the claimant.

F. Processing denials

In a medical denial:

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The DDS inputs their determination and releases the notice.
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Use the SSA-831 in the folder or the WMI code showing the disallowance reason to identify and process the denial.
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When the DDS disability determination is in the CEF, the "DDS Determination Added" action item or another applicable message appears on the EDCS Action page. View the determination and take appropriate action.

NOTE: If the determination is on the WMI listing but the official folder is pending in a DQB, hold effectuation until the official folder returns from the DQB. To verify the DQB determination, review the EDCS Action Page for case return, Case Review/Action History, and SSA-831 (in eView or the folder). Do not effectuate the determination until the DDS/DQB closes the case.
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If the case had not been triggered for NMC at the time of the DDS medical denial, manually effectuate the denial.
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Resolve any material earnings discrepancies that require further action, following instructions in DI 11010.050. Process the disability claim denial and, if additional evidence is necessary to complete an earnings correction, follow the usual closeout procedures for earnings corrections, see sections RM 03800.000.
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If the official file is paper, follow applicable instructions in DI 11010.370.

Social Security

Program Operations Manual System (POMS)

DI 11010.030 Field Office (FO) Operating Instructions for Deferred Title II Initial Claims