When the adjudicating component disagrees with any cited group I deficiency, group
II deficiency, or technical corrective action (TCA), in a fully electronic case, they
are encouraged to attempt to resolve the disagreement on an informal basis by submitting
an IRR via the Office of Disability Policy’s (ODP) IRR
web-based tool.
NOTE: RPC will not accept submissions when the disagreement involves a change in deficiency type only,
otherwise known as a "wrong deficiency cited", unless the case has first been through the IRR process. A wrong deficiency citation occurs
when one type of deficiency is cited, but program instructions support a different
type, e.g., documentation vs decisional or group I vs group II. In these situations,
there is no rescission of the deficiency, but the review component updates the OQR
case processing system database with the correct deficiency. This still only results
in one chargeable deficiency against the adjudicating component.
EXAMPLE: The review component cites a decisional deficiency, changing an allowance determination
to a denial determination, but fails to recognize in doing so, that the adjudicating
component must first develop all allegations or medical sources prior to denying the
claim. The adjudicating component requests the review component change, or replace,
the decisional deficiency to a documentation deficiency, agreeing that the evidence
does not currently support an allowance, but acknowledging the adjudicating component
must develop all allegations or medical sources before making a denial determination.
The review component updates the OQR case processing system database to reflect the
correct deficiency, thus there is only one chargeable deficiency for the adjudicating
component.
NOTE: The OQR case processing system allows displaying of more than one deficiency code
if applicable as a result of the Federal quality review. However, only the deficiency
marked as "Primary" is counted against the adjudicating component. Deficiencies marked
as "Other" do not count against the adjudicating component unless they subsequently
become "Primary" as a result of the IRR or RPC.
If the adjudicating component chooses not to attempt to resolve the disagreement through
the IRR process, or if they cannot resolve the deficiency after the IRR process, the
adjudicating component may submit an RPC, if the criteria is met, to OPCA for a fully
electronic case (see DI 30007.125 – Submitting a case for RPC). The adjudicating component may not simultaneously submit an IRR and RPC.
If the adjudicating component does not resolve the deficiency through the IRR process,
they must complete the request for corrective action(s) noted in the SSA-1774-U5,
Request for Corrective Action or SSA-847-U3, SSA Request for Case Action, OR submit
an RPC, if the case meets the criteria for RPC submission (see DI 30007.125 - Submitting a Case for RPC).