Basic (08-25)

QR 04410.040 Protesting Deficiency Citations- Rebuttals Title II

 

A. Introduction to protesting deficiency citations

Quality Review (QR) uses the SSA-93 Quality Review Feedback Report to notify the field office (FO), processing center (PC), the Office of the Regional Commissioner (ORC), and the Associate Commissioner (AC) of the Office of Central Operations (OCO) (for PC 7 and 8) of findings that identify payment errors and informational items which require corrective action but do not affect the sample payment.

The purpose of the rebuttal process is to resolve case-related disagreements between QR and operating components. This process ensures that issues are resolved systematically and objectively and that affected beneficiaries receive a correct benefit payment. Informal communications between QR and the operating components are encouraged to expedite resolution.

B. Protesting a deficiency citation

The FO or PC may rebut a cited deficiency only if it meets the criteria for a rebuttable issue outlined in QR 04410.040C in this section.

Use the SSA-93 Quality Review website to submit a rebuttal to the reviewing QR field site within 45 days of the date QR transmitted the SSA-93.

  • Select “Rebuttal Request Sent to QR” in the “Respond to SSA-93 Review” area of the detail screen on the SSA-93 website,

  • use the Comments box to explain the issue, and

  • scan all supporting material into the electronic folder and clearly indicate the location in the Comments box.

The SSA-93 website notifies the ORC/AC of OCO of the rebuttal request once submitted.

Delay corrective action only on contested deficiencies pending final resolution. Correct all non-disputed deficiencies cited on the case.

C. Criteria for a rebuttable issue

Only dollar deficiencies that affect the sample period’s payment cited by QR are subject to the formal rebuttal process.

D. Issues not subject to rebuttal

QR identifies non-payment and informational items on the SSA-93. Informally resolve questions related to non-payment and informational items via email or telephone contact. The FO or PC should reconcile any item where a policy misinterpretation is involved. If necessary, QR revises the quality review database to reflect an informal resolution. The FO or PC must document the case when the decision is that corrective action is unnecessary or one that differs from the original QR findings.

Deficiencies cited by QR not rebutted by the FO or PC under the rebuttal process described in this section are:

  • Non-payment deficiencies,

  • evidentiary deficiencies, and

  • all informational items.

E. Operational component rebuttal process

If the FO or PC disagrees with a deficiency, follow the rebuttal process described in this section. Resolution of a rebuttal is possible at any level in this process. When all SSA components involved reach an agreement, the rebuttal is resolved. Encourage informal communications via telephone or email to expedite problem resolution. The FO or PC and QR record the rebuttal decision on the SSA-93 Quality Review website.

F. Level I rebuttal process

If the PC or FO disagrees with a rebuttable deficiency finding, the PC or FO contacts the reviewing QR office within 45 calendar days of the date of transmission of the SSA-93 feedback report to the SSA-93 Quality Review website.

If attempts to resolve the issue informally fail, the PC feedback coordinator or FO should use the SSA-93 website to submit a formal rebuttal as described in QR 04410.040B in this section.

To prevent the PC from initiating corrective action on FO caused errors in the rebuttal process, the FO should

  • contact the PC feedback coordinator via telephone or email;

  • inform the PC of their disagreement with QR's findings; and

  • instruct the PC not to take action on the protested deficiency pending a resolution.

The SSA-93 website will automatically notify the appropriate ORC/AC of OCO of the first level rebuttal once submitted.

You can find contact information for QR Field sites (AIPQBs) at OQR Field Sites.

1. QR field site reverses their decision

If the AIPQB director agrees with the FO rebuttal (i.e., disagrees with the original position of QR), QR removes the deficiency from the QR database. QR notifies the PC feedback coordinator and the FO (if they initiated the rebuttal) of the decision. The PC feedback coordinator notifies all operational components.

If the AIPQB director believes an interpretation of policy is involved, the AIPQB will consult with Division of Title II Quality and Special Studies (DT2QSS) in central office to determine if a policy submittal to the Office of Income Security Programs (OISP) is appropriate before responding. Notify the PC feedback coordinator and the FO of the possible delay in responding pending a reply from OISP.

2. QR field site affirms or amends their decision

When the AIPQB affirms all or part of the error findings, the AIPQB provides an explanation of the decision and information about supporting documentation in the Comments box and transfers jurisdiction back to the FO or PC. The decision will explain the additional corrective actions the FO or PC needs to take.

G. Level II rebuttal process

If the FO or PC agrees with the AIPQB rebuttal decision, the FO or PC annotates the SSA-93 Quality Review website after all corrections are complete.

If the FO or PC disagrees with the AIPQB rebuttal decision, the FO or PC must update the SSA-93 website within 15 days to request a second level rebuttal. The rationale for the second level rebuttal request is required in the Comments box. The SSA-93 website sends an automated email to the RO with the rebuttal request and comments.

1. ORC/AC of OCO agrees with the deficiency

If, after review of the material, the ORC/AC of OCO agrees with the decision of the AIPQB they will explain the decision in the Comments box. The SSA-93 website sends an automated email to the FO or PC. The decision is final and the FO or PC must complete the corrective action. The follow-up process resumes until the FO or PC updates the SSA-93 website to show all actions are complete.

2. ORC/AC of OCO disagrees with the deficiency

If the ORC/AC of OCO disagrees with the position of the AIPQB, the ORC/AC of OCO must submit a second level rebuttal on the SSA-93 website within 10 days. The ORC/AC or OCO must provide the rationale for the disagreement in the Comments box. The SSA-93 website sends an automated email to QR headquarters (HQ) with the request and rationale for review.

a. QR HQ disagrees with the QR field site decision (reversal or modification)

If QR HQ agrees with the rebuttal (i.e., disagrees with the original position of the AIPQB), QR HQ will post the decision and rationale to the SSA-93 website, and an automated email is sent to the FO or PC, and the RO. QR will take action to remove the error from the eQA Quality Review database.

b. QR HQ agrees with the QR field site decision (affirmation)

If QR HQ upholds the original decision, QR HQ posts the decision and rationale to the SSA-93 website, which sends an automated email to the FO or PC and RO within 15 calendar days of the date of the second level rebuttal request.

The QR HQ decision is final. If QR HQ affirms or amends the deficiency, the FO or PC must take the corrective action. The case will return to the follow-up process until the FO or PC completes all corrections and updates the SSA-93 website.

H. Rebuttal conclusion

After resolution of all rebuttal actions, the FO or PC takes corrective action within 90 days and updates the SSA-93 Quality Review website. The ORC/AC of OCO is responsible for ensuring that corrective actions are completed.

I. List of ORC/AC of OCO and PC contacts

Refer to the chart for ORC/AC of OCO and PC addresses:

 

ORC, PC, and AC of OCO Contacts

ORC

E-mail Address

Phone

Boston ||BOS CPS RSI SSI 617-565-2882
New York ||NY CPS 212-264-8355
Philadelphia ||PHI MOS CTR PROG SYSTS 215-597-1251
Atlanta ||ATL MOS CPS 404-562-1301
Chicago ||CHI ARC MOS CRSI SSI 312-575-4240
Dallas ||DA RO TAR Feedback Reports 214-767-4224
Kansas City |^KC CPS Quality Review 816-936-5640
Denver ^DENVER TAR 303-844-0763
San Francisco ||SF MOS cdps 510-970-8251
Seattle ||SEA CPS RPST 206-615-2175

Processing Center

E-mail Address

Phone

NEPSC ||NY ARC PCO OAS NEPC 718-557-3735
MATPSC ||PHI ARC PCO OSB OAS 215-597-3552
SEPSC ||SEPSC FEEDBACK 205-801-2287
GLPSC ||CHI ARC PCO OSB 312-575-4250
WNPSC ||SF WNPSC OAS 510-970-1427
MAMPSC ||KC OAS 816-936-5880
ODO ^OCO OQA TAR SSA93 410-966-4481
OIO ^OCO OQA TAR SSA93 410-597-4396

 


To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/1304410040
QR 04410.040 - Protesting Deficiency Citations- Rebuttals Title II - 08/11/2025
Batch run: 08/11/2025
Rev:08/11/2025