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DI 30007.155: The Request for Program Consultation (RPC) Resolution and Post-Resolution Actions

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  • Effective Dates: 10/04/2016 - Present
  • Effective Dates: 08/09/2018 - Present
  • TN 4 (10-16)
  • TN 5 (08-18)
  • DI 30007.155 The Request for Program Consultation (RPC) Resolution and Post-Resolution Actions
  • A. Timeframe for issuing the RPC resolution
  • RPC’s goal is to issue a resolution within 14 calendar days of receipt of the DDS’s RPC submission. However, a variety of factors may affect this goal, including current caseloads, available staff, the size of the RPC case file, and whether there is a need for additional medical, vocational, or policy input.
  • B. The RPC resolution is SSA’s official response
  • The RPC resolution is the result of the three-member RPC panel discussion vote. The resolution is binding on both the DDS and the DQB involved. The components are required to take the actions identified in the RPC resolution.
  • The panel members base the decision to affirm or rescind a deficiency on whether the DDS’s development, documentation, and determination are reasonable in relation to program instructions. These are the same criteria discussed in OQR’s Quality Review Standard in GN 04440.007. The ODP RPC discussion panel member drafts the final RPC resolution document, sends it to RPC’s technical expert for editing and approval, and completes all remaining RPC tool screens. Once approved, the ODP RPC panel discussion member uploads the document into the RPC tool and submits the completed case for closure. Upon closure, the RPC tool automatically emails notification to the involved DDS, DQB, and Center for Disability (CD) that the resolution is available online. The tool also automatically sends a copy of the resolution to the certified electronic folder, to become a part of the official claim file.
  • The panel members base the decision to affirm or rescind a deficiency on whether the DDS’s development, documentation, and determination are reasonable in relation to program instructions. These are the same criteria discussed in OQR’s Quality Review Standard in GN 04440.007. The ODP RPC discussion panel member drafts the final RPC resolution document, sends it to RPC’s technical expert for editing and approval, and completes all remaining RPC tool screens. Once approved, the ODP RPC panel discussion member uploads the document into the RPC tool and submits the completed case for closure. Upon closure, the RPC tool automatically emails notification to the involved DDS, DQB, and Center for Disability (CD) that the resolution is available online. The tool also automatically sends a copy of the resolution to the certified electronic folder, to become a part of the official claim file.
  • C. DDS actions after RPC resolution
  • If there are actions for the DDS, the DDS will immediately take the action(s) specified in the RPC resolution and finish processing the case. Once RPC has issued an RPC resolution, it is the DDS’s responsibility to code the Rebuttal field in their legacy system before routing the case back to the DQB. For all RPC cases, the DDS must enter “1” in the Rebuttal field.
  • This entry propagates to the pending receipt list in the Disability Case Adjudication and Review System (DICARS) for easy identification of rebuttals. This action ensures the DQB will give the case priority handling. The DDS must transfer the case to the DQB and input the rebuttal code even if the RPC resolution did not direct corrective action, in order to demonstrate compliance with RPC guidance.
  • The DDS will follow current procedures for processing and returning the case to the DQB to update their DICARS database with the RPC resolution.
  • D. DQB actions after RPC resolution
  • Upon receiving the case back from the DDS, the DQB will:
  • * Immediately take the actions specified in the resolution regarding the deficiency;
  • * Review the corrected case for accuracy, ensuring the DDS and the DQB completed the actions identified in the resolution;
  • * E-mail notification to RPC (include the RPC case number in the subject line) at “^ODP OPCA Controls” to the attention of the Director when:
  • * The DDS has not completed actions identified in the resolution and informal attempts to resolve the issue with that component are unsuccessful, or
  • * The corrected determination is inaccurate.
  • * Send email confirmation of post-RPC deficiency affirmations, modifications, or rescissions to the DDS, the CD, and OQR.
  • * When a resolution does not support either the DDS or the DQB, handle and report on this universe of claims (“Wrong Deficiency Cited”) as follows:
  • * Capture case outcomes on a report under the category, “Agency Deficiencies Cited”; and
  • * Ensure the OQR database and all reports reflect the resolution findings.
  • E. Follow-up questions
  • Although the RPC resolution is final, components may submit questions to RPC for further clarification of an RPC resolution. Components should send follow-up questions to RPC (include the RPC case number in the subject line) using the “^ODP OPCA Controls” mailbox. RPC will respond to the inquirer via email, cc’ing ODD, OQR and CD. RPC will also attach the question and response as an additional document to the case in the RPC Tool.
  • NOTE: RPC must receive follow-up question within ten business days of the date of the RPC resolution.
  • NOTE: RPC must receive follow-up question within 15 business days of the date of the RPC resolution.
  • F. A follow-up question indicates program instructions may not support the original resolution
  • F. A follow-up question indicates program instructions do not support the original resolution
  • In rare situations, a follow-up question may cite policy, procedures, or published instructions that indicate program instructions may not support the original resolution. When needed, RPC will refer the case to the appropriate ODP policy component for guidance. If the policy component determines that program instructions do not support the original resolution, RPC will correct the RPC resolution in its response to the question and, if needed, will notify the DQB to reinstate or rescind the deficiency citation.
  • In rare situations, a follow-up question may cite policy, procedures, or published instructions that indicate program instructions do not support the original resolution. When needed, RPC will refer the case to the appropriate ODP policy component for guidance. If the policy component determines that program instructions do not support the original resolution, RPC will respond to the question, correct the RPC resolution in its response to the question and, if necessary, advise the DQB to reinstate or rescind the deficiency citation.
  • G. RPC Audits
  • 1. The DDS or the DQB identifies a case where they feel the other component has not completed all of the actions required by the resolution.
  • When this occurs, the DDS or the DQB may contact the other component to discuss and resolve the issue informally. If informal consultation does not resolve the issue, the DDS or the DQB may send an email to ^ODP OPCA Controls”, (include the RPC case number in the subject line) cc’ing the CD, explaining the concern.
  • * An assigned RPC staff member reviews the resolution, the actions taken to date, and the issues presented in the audit request, to determine the need for any additional action.
  • * If, after reviewing the case, the RPC staff member determines all components completed all actions as directed, he or she will send a written explanation back to the originator of the audit request, explaining why the actions taken are sufficient.
  • * If the staff member determines that not all actions identified in the resolution were completed, or the revised determination is incorrect, the staff member emails either the CD or the DQB, cc’ing ODD and OQR on the message. The e-mail will explain the facts of the case, the requirements of the resolution, and additional actions required. RPC staff will fax a copy of the e-mail into the electronic folder using the RPC-ODP document with annotation “RPC Audit”. The CD will work with the DDS to ensure they complete the additional actions.
  • 2. RPC audits a case after resolution and finds the DQB needs to return the case to the DDS for additional corrective actions
  • The DQB will take the following actions:
  • * Prepare an informational Form SSA-1774 (Request for Corrective Action), or Form SSA-847 (Request for Case Action), instructing the DDS to refer to the “RPC Audit” document in the electronic folder for the necessary additional corrective action. If using an SSA-1774, annotate it “Informational Only—No Additional Deficiency Charged”;
  • * Return the case to the DDS; and
  • * Control the return.
  • 3. RPC audits a case after resolution, and finds a party has not completed all actions identified in the resolution
  • RPC will contact the CD or the DQB to discuss the case and the additional required action(s).
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