How could 2026 rule changes alter the frequency or criteria for continuing disability reviews (CDRs)?
Executive summary
The Social Security Administration’s FY2026 budget signals a major push to eliminate the backlog of continuing disability reviews (CDRs) and to process “200,000 more CDRs” in FY2026 by using automation, productivity gains, and AI investments—steps SSA says will put it “on the path to eliminate the continuing disability reviews (CDR) backlog” [1]. At the same time, reporting indicates SSA has only notified OIRA of possible “proposing improvements” to disability adjudication and has not published final rule changes; agency spokespeople cautioned against drawing conclusions before rules are published [2].
1. Budget muscle and operational changes: more reviews likely
The FY2026 President’s Budget commits program‑integrity funding and lists expectations that automation, information‑technology upgrades and AI will raise productivity so SSA can process roughly 200,000 additional CDRs in FY2026 and work toward eliminating the backlog [1]. That budget framing implies a near‑term increase in CDR volume driven by resources and technology rather than an immediate statutory change in eligibility criteria [1].
2. Rulemaking vs. administrative practice: proposals on the horizon, not finalized
Reporting from AARP and SSA statements make clear the agency has notified the Office of Information and Regulatory Affairs that it will propose “improvements to the disability adjudication process,” but SSA “has not published any planned rule changes” and warns speculation is premature [2]. Therefore any concrete shift in CDR frequency or medical/functional criteria depends on what the proposed rules actually say once published [2].
3. How rule changes could alter CDR frequency—mechanisms to watch
If SSA’s proposed rules change “adjudication” protocols, typical mechanisms that could increase or re‑prioritize CDRs include new definitions of medical improvement, expanded use of electronic data to trigger reviews, or altered schedules for periodic reviews; budget language already signals SSA expects to use data and automation to accelerate integrity work [1]. Available sources do not mention the specific statutory or regulatory levers SSA plans to modify [2].
4. How rule changes could alter CDR criteria—what would matter
Changing the evidentiary standards or how SSA evaluates “available work” or functional capacity could tighten or loosen continuing eligibility; outside commentators already flag that changes in data use and work evaluation may be on the horizon [3]. AARP reporting shows SSA is considering broader improvements but notes the specifics—and their impact on eligibility determinations—are not yet public [2].
5. The role of automation and AI: speed with tradeoffs
SSA explicitly links IT improvements and “accelerated artificial intelligence (AI) investments” to handling more CDRs and reducing backlogs [1]. That can increase review frequency by enabling faster case triage and document processing, but sources do not analyze accuracy, appeals workload, or potential for erroneous determinations; those consequences are not described in the provided reporting [1].
6. Practical impacts for beneficiaries: what to prepare for
Practitioners and advocacy pieces advise beneficiaries to expect more review notices and to be ready with up‑to‑date medical records and representation—because SSA’s FY2026 plan to ramp up CDRs implies a higher volume of notices even before any rule change is finalized [3] [1]. AARP’s coverage cautions beneficiaries against alarm but emphasizes that finalized proposals could change adjudication practices and should be monitored [2].
7. Conflicting signals and political context
The budget promises more program‑integrity work, which typically appeals to fiscal stewardship narratives, while SSA’s public messaging to OIRA emphasizes procedural review rather than substantive tightening—an implicit balancing act between preventing improper payments and not unduly disrupting beneficiaries [1] [2]. Advocacy groups and legal advisors may read the budget line and OIRA notice differently—either as a resource boost to clear administrative backlogs or as a precursor to tougher eligibility scrutiny [1] [2] [3].
8. Bottom line and what to monitor next
Expect higher CDR volume in FY2026 driven by the SSA’s budgeted personnel, automation and AI plans—an operational increase already announced [1]. Do not assume changes to statutory eligibility or specific review criteria until SSA publishes proposed rules and the public comment record; SSA has not yet published such rules and has told the public that it’s only at the notification stage with OIRA [2]. Key documents to watch: the published proposed rule text, the Federal Register notice and SSA materials explaining how automation and AI will be used [2] [1].
Limitations: reporting in these sources specifies agency intentions and budget targets but does not include the text of any proposed regulatory changes or analyses of appeals outcomes—those details are not found in current reporting [1] [2].