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What guidance from 2023–2024 changed how SSA weights prior administrative medical findings in CDR decisions?
Executive summary
In 2023–2024 the Social Security Administration issued policy updates and a new Social Security Ruling (SSR 24‑2p) and published a Federal Register final rule that together changed how prior administrative medical findings and prior work are considered in Continuing Disability Reviews (CDRs), notably aligning CDR final steps with initial‑claims steps and clarifying how to assess residual functional capacity (RFC) and past relevant work (PRW) (SSR 24‑2p; Federal Register) [1] [2]. The agency also circulated internal instructions (EM‑24021) and POMS revisions that shifted CDR workload priorities and reconsideration procedures, affecting how those medical findings are processed in practice [3] [4] [5] (coverage of some implementation detail is limited in the available documents).
1. What the formal guidance changed: alignment of CDR and initial‑claim steps
The Federal Register final rule and SSR 24‑2p make explicit that while the statutory sequential process for CDRs differs, the last two steps of CDR adjudication mirror the final two steps of initial disability claims—meaning adjudicators must apply comparable RFC and PRW analyses when weighing prior administrative medical findings in cessation decisions [2] [1]. That alignment signals SSA expects greater consistency between how evidence is treated at application and at review stages rather than treating prior administrative findings as a separate, lower‑weight category in CDR cessation determinations [2] [1].
2. SSR 24‑2p: detailed Q&A on RFC and prior work evaluation
SSR 24‑2p provides practical, question‑and‑answer guidance on determining whether a beneficiary “retains the RFC to perform the demands of their PRW,” including examples about short‑term work and how it counts toward PRW [1]. By publishing concrete examples (e.g., whether work of fewer than 30 days qualifies) the SSR narrows ambiguity about when prior work should affect a CDR outcome and clarifies how prior administrative findings feed into the RFC/PRW analysis [1].
3. POMS and reconsideration guidance: operational changes in 2023
SSA’s POMS updates from 2023 set out Field Office processing guidelines for requesting reconsideration of medical CDR determinations and instructions for reconsideration of medical cessations (DI 12026.025 and DI 12026.001), which alters the administrative pathways by which prior medical findings can be challenged or re‑weighed during a CDR [4] [5]. These POMS entries affect how field offices and adjudicators operationalize the higher‑level SSR and rule guidance in day‑to‑day reconsiderations [4] [5].
4. EM‑24021 and workload directives: practical effects on how findings are used
SSA’s one‑time workload instruction EM‑24021 (and its later revisions) redirected how many full medical CDRs to process in 2024, and by extension how much attention and resources are available to re‑examine prior administrative medical findings in CDRs [3] [6]. The workload cap and postponements influence whether adjudicators will have time for deeper review of prior findings or will rely more heavily on streamlined approaches; SSA documents and external summaries note targets were lowered (e.g., from 575,000 to 375,000) and CDR processing paused or rescheduled—an operational constraint that changes real‑world weighting of evidence [7] [3].
5. Competing perspectives and limits of the record
SSA’s rulemaking and SSR emphasize consistency and clearer analytic steps [2] [1], which supporters argue reduces arbitrary differences between CDRs and initial determinations. Critics, reflected in practitioner summaries, contend that the combination of stricter analytic alignment and reduced CDR workload may produce inconsistent outcomes or faster reliance on summaries of prior findings rather than full re‑examination [7] [8]. Available sources do not mention detailed case‑level outcomes or statistical evidence showing how weighting changed across adjudicators after these changes; empirical effects are not reported in the documents provided (not found in current reporting).
6. Practical advice for claimants and advocates
The SSR and POMS updates demonstrate that prior administrative medical findings now must be considered within the RFC/PRW framework used for initial claims, and examples in SSR 24‑2p show how short work spells are treated [1]. Given operational workload adjustments (EM‑24021) and reconsideration pathways (POMS), claimants should ensure contemporaneous, clear medical records and be prepared to invoke the POMS and SSR language on reconsideration if an adverse CDR rests on prior findings [1] [4] [3]. The sources stress procedural changes but do not provide step‑by‑step appellate outcomes or empirical validation of effectiveness (not found in current reporting).
Sources cited: SSR 24‑2p [1]; Federal Register final rule [2]; POMS DI 12026.025 and DI 12026.001 [4] [5]; EM‑24021 and related workload materials [3] [6]; SSA workload/press summaries and practitioner reporting [7] [8].