DI 25501: Onset
TN 11 (11-12)
A. Policy for alleged onset date (AOD)
1. Definition of AOD
In title II disability claims and title XVI adult disability claims, the AOD is always the date the claimant alleges he or she became unable to work because of his or her medical condition, whether or not that date appears to be appropriate.
2. AOD is the starting point
The claimant’s AOD is the starting point in establishing the established onset date (EOD). If the medical and other evidence, and the entitlement or eligibility factors, are consistent with the AOD, the AOD is also the EOD, the date we establish the claimant first meets the medical, vocational, and other entitlement or eligibility requirements for disability benefits. If there are non-medical factors present that prohibit the disability examiner (DE) from establishing an EOD as of AOD (e.g., work after onset), or could allow the DE to establish an EOD earlier than the AOD, if supported by the medical evidence (e.g. an unsuccessful work attempt), the FO proposes a potential onset date (POD).
For more information about the role of the POD when establishing an EOD, see DI 25501.220A.1.
3. AOD may be the last day of substantial gainful activity (SGA)
We consider the date the claimant stopped performing SGA when establishing the EOD. The fact the claimant performed SGA on the AOD is not relevant. If medical and other evidence indicates the claimant’s disability began on the AOD, an EOD can be established on that date even if the claimant worked a full day. We will not establish onset before the last day SGA was performed. For information on closed periods, see DI 25501.210A.4. in this section.
Exception: For Disability Insurance Benefit (DIB) claimants who meet our statutory definition of blindness, we establish a disability freeze on the date they meet our statutory definition of blindness, regardless of SGA. For more details on establishing onset of blindness, see DI 25501.380.
4. Closed periods
We establish a closed period of disability in situations where a claimant was unable to engage in SGA for a continuous period of 12 months, but, by the time the determination is made, the claimant is no longer disabled and is engaging in SGA or is capable of engaging in SGA, if the claimant meets all other requirements. The AOD may be prior to a current period of SGA.
5. Unsuccessful work attempts (UWA)
Some claimants attempt to work despite their impairment(s) and stop work after a short period because of the impairment(s). Under certain conditions, this effort is a UWA. In such cases, the AOD may be before the UWA because worked determined to be a UWA is not SGA.
For more information, see:
DI 11010.250 for information on the field office’s policy for using work activity reports to annotate UWAs,
DI 24005.001 for background policy regarding UWAs and
DI 25501.400 for more detailed policy regarding onset of disability and UWAs.
6. Title XVI disabled child (DC) claims
The AOD for DC claims is the date the applicant provides in answer to the question: “When did the child become disabled?” in section 3C on the SSA-3820 (Disability Report-Child) or i3820 (Internet Child Disability Report). The AOD is the applicant’s own perception of when the child’s disability began. The applicant always provides the AOD regardless of whether or not that date appears to be appropriate.
7. Documentation of the AOD
The AOD appears on:
the disability application(Form SSA-16),
the case data section of an electronic disability folder,
the Electronic Disability Collect System (EDCS) or SSA-3367 (Disability Report – Field Office), and
the SSA-3368 (Disability Report – Adult) or i3368 (Internet Adult Disability Report).
Generally, the AOD will be consistent throughout the file. If the AOD is not consistent throughout the file, the Disability Determination Services (DDS) will contact the field office (FO) and request clarification.
The claims representative will provide a POD if there are non-medical factors that prohibit establishing the EOD on the AOD or if non-medical factors permit an earlier EOD. For information on Potential Onset Dates, see DI 25501.220.
NOTE: If the AOD differs from the POD, your explanation of the POD is crucial to disability development. For more information on documenting a POD, see DI 25501.220.
B. Component roles
The Teleservice Center, filed office, and DDS staff take the following roles in developing the AOD.
1. Teleservice center (TSC)
The TSC records the claimant’s AOD on the Lead Protective Filing 2 (LPF2) screen.
2. Field office (FO)
The FO obtains the AOD from the claimant and establishes a POD, if necessary. The FO also records the claimant’s AOD in Modernized Claim System (MCS) and Modernized Supplemental Security Income Claims System (MSSICS).
The DDS develops the claimant’s complete medical history for at least the 12 months preceding the month in which the claimant filed his or her application, unless there is a reason to believe that we need to develop for an earlier period, or the claimant states his or her disability began less than 12 months before he or she filed his or her application.
C. Component instructions for recording AOD
1. Teleservice center (TSC)
Record the claimant’s AOD on the LPF2 screen.
2. Field office (FO)
Record the claimant’s AOD in the MCS or the MSSICS. MCS or MSSICS may contain propagated data from the Integrated Client Data Base (ICDB) from information received from the 800 lead system. You may over-key this data, if necessary.
3. Disability Determination Services (DDS)
Develop the claimant’s complete medical history for at least the 12 months preceding the month in which the claimant filed his or her application, unless you have a reason to believe that you need to develop for an earlier period, or, unless the claimant says his or her disability began less than 12 months before he or she filed his or her claim. For information on POD, see DI 25501.220. For more information on developing medical evidence, see DI 22505.001.
In some situations, you may need to develop additional Medical Evidence of Record (MER) prior to the AOD or POD, to document the severity of the claimant’s condition or the duration of the claimant’s condition.
In cases where the claimant alleges a traumatic impairment and a fully favorable EOD can be established based on evidence of the claimant’s traumatic impairment, you do not need medical evidence 12 months prior to AOD or POD to adjudicate the claim.