POMS Reference

GN 04440: Federal Quality Review of Disability Determinations

TN 8 (06-04)

A. Policy - Corrective Action

Corrective action for group II deficiencies depends on the specific deficiency involved and the circumstances of the case as follows:

  • Certain deficiencies are always returned to the adjudicating component for corrective action, e.g., cessation date decisional and documentation deficiencies;

  • Certain deficiencies are sent to the FO for resolution; and

  • Certain deficiencies may be corrected in the review component. The review component corrects cases by making a pen-and-ink correction to the onset date or ending date on the SSA-831-C3/U3 (GN 04440.217).

In addition, group II onset date documentation deficiencies may be corrected pre-adjudication or post-adjudication depending upon the circumstances of the case. Regardless, all group II deficiency cases that are returned for correction must be controlled and results data input to DICARS upon completion of the corrective action.

GN 04440.218 through GN 04440.228 provide specific instructions for correcting and routing various group II deficiencies.

NOTE: Do not charge a Group II deficiency if an exact EOD is not required per DI 25501.300A.2, or the EOD meets the onset expedient criteria in DI 25501.300A.5. Before citing an onset date documentation deficiency, make sure that the provision for inferring onset date in DI 25501.450 does not apply. If the incorrect onset is due to an obvious typographical error, the review component may correct the onset date on the determination form without citing a group II decisional deficiency.

B. Definitions

1. Alleged Onset Date (AOD)

The AOD is the date claimants report they became unable to work because of the effects of their illnesses, injuries or conditions.

The AOD is generally the date entered in:

  • Section 4, Item C. of Form SSA-3368-BK or

  • The response given to the comparable question (“when did you become unable to work because of your illness, injuries or condition”) on the Internet Disability Report - Adult SSA-3368 (i3368)

  • Section 3, Item C. of Form SSA-3820-BK (Disability Report - Child).

See DI 11005.023B.3., DI 11005.030B.3. and DI 11005.045B.1.b

2. Potential Onset Date (POD)

The POD is the earliest date that disability can be established based on non-medical factors alone.

The POD “alerts” the disability examiner that there are non-medical factors present that, if supported by the medical evidence, could establish an onset date earlier or later than the AOD.

The POD is entered in the Potential Onset screen on the Electronic Disability Collect System 3367 and in item 3 of the paper Form SSA-3367-F4 (Disability Report - Field Office) and is for DDS use for development purposes. See DI 11005.045B.1.c.

3. DDS Established Onset Date (EOD)

The DDS EOD is the date initially established by the adjudicating component prior to the receipt of the claim in the review component (DQB). It is determined by the disability examiner and is based on the medical and other evidence in the case, and with consideration of the POD. The ultimate EOD may be different from the initial DDS EOD and may be established by the review component (DQB EOD).

4. DQB EOD

The DQB EOD is the onset date established by the DQB when they determine that the onset date established by the adjudicating component is incorrect.

5. Interim Onset Date (IOD)

The IOD is the onset date set by the review component when there is a group II onset date documentation deficiency to permit payment of benefits while the adjudicating component or FO develops for an earlier onset date. An IOD may also be set by the DDS, ODO or the PSC. The IOD is established based on the evidence in the claims file at the time of the review and may be the same as the DDS EOD.