What guidance did SSA issue to state Disability Determination Services about evaluating residual functional capacity in 2025 CDRs?

1. What the new POMS item says—age and time on the rolls matter

On 02/18/2025 the SSA posted POMS DI 28015.310 entitled “Consider Age and Time on the Rolls When Assessing Residual Functional Capacity (RFC) in Continuing Disability Reviews (CDRs),” instructing adjudicators at State DDS offices to explicitly factor a recipient’s age and how long they have been receiving benefits into RFC assessments during CDRs ^[1]. This is an operational direction within the POMS CDR RFC framework and therefore applies to how RFC comparisons are done when determining medical improvement or its absence in CDRs ^{[1] [4]}.

2. How that fits into existing RFC rules and the CDR process

The POMS update operates inside the broader RFC and CDR architecture: SSA’s regulatory framework requires RFC determinations to consider all relevant evidence about physical, mental, sensory and other limitations and to assess capacities on a regular-and-continuing-basis ^{[2] [3]}. POMS already provides a “General Approach to RFC Comparison in CDRs” that governs how adjudicators compare prior and current RFCs; the 2025 instruction supplements that approach by highlighting age and tenure on the rolls as factors to weigh ^{[4] [1]}.

3. Why age and time on the rolls might change conclusions in CDRs

POMS’ direction signals that adjudicators should assess whether a claimant’s functional capacity is meaningfully affected by aging or by conditions associated with long-term disability benefits. Age has long been an explicit vocational consideration in disability decisions because it affects transferability of skills; incorporating “time on the rolls” into the RFC comparison emphasizes longitudinal context for medical improvement analyses during CDRs ^{[1] [5]}. The POMS change therefore reframes part of the CDR inquiry to look at trajectory, not just cross-sectional medical findings ^[1].

4. What the guidance does not (explicitly) say—limits of available text

Available sources do not mention specific numerical thresholds, new forms, or any changes to the legal standard that the SSA must prove medical improvement in CDRs; the POMS entry focuses on instructing evaluators to consider age and time on the rolls when assessing RFC rather than rewriting statutory standards ^[1]. Detailed procedural steps or examples for how adjudicators should operationalize “time on the rolls” in RFC scoring are not included in the excerpted POMS entry provided here ^{[1] [5]}.

5. Potential implications for claimants and advocates

Practically, emphasizing age and duration on benefits could make it harder for SSA to show medical improvement in older beneficiaries whose work-related capacities decline with age, and could conversely mean adjudicators probe more deeply into age-related functional changes when reviewing long-tenured claimants ^{[1] [2]}. Advocates will likely press for documentation that clarifies how DDS should weigh longitudinal evidence and vocational factors; the POMS update does not eliminate the need to assess RFC from the entire case record as required in SSA regulations ^[3].

6. Competing perspectives and where disputes may arise

Supporters of the guidance could argue it brings realism to CDRs by forcing consideration of age-related functional decline and the long-term course of disabling conditions ^[1]. Critics may contend the change risks conflating normal aging with disability determinations or could produce inconsistent outcomes unless DDS offices receive detailed operational guidance—issues not addressed in the POMS excerpt provided ^{[1] [5]}. The SSA regulations and existing POMS RFC framework remain the baseline; the new instruction is an overlay, not a statutory change ^{[2] [4]}.

7. How to follow up and confirm operational details

For readers seeking the full operative language and any linked procedure, review POMS DI 28015.310 directly on SSA’s POMS site and check the RFC Table of Contents and the general RFC CDR guidance for related instructions and forms ^{[1] [5] [4]}. If you need legal interpretation about how this will affect an individual case, the POMS entry is administrative guidance—practitioners commonly combine it with CFR rules and case-specific medical evidence in advocacy ^{[2] [3]}.