U.S. RAILROAD RETIREMENT BOARD

OFFICE OF INSPECTOR GENERAL 

The Railroad Retirement 

Board’s Disability Briefing 

Document Process Was Not 

Fully Effective

Report No. 21-07 August 16, 2021
OFFICE OF INSPECTOR GENERAL

U.S. RAILROAD RETIREMENT BOARD

The Railroad Retirement Board’s Disability Briefing Document 

Process Was Not Fully Effective

Report Summary August 16, 2021 Report No. 21-07

What We Found

The Railroad Retirement Board’s (RRB) Disability Briefing 

Document Program (D-BRIEF) process was not fully effective to 

ensure that examiner rationales for their decisions were 

completely documented. As a result, doubt exists regarding 

whether information recorded in the output of D-BRIEF 

(Disability Briefing Document) was consistent with supporting 

documentation in the electronic case file. Although we did not 

identify any exceptions directly related to consistency, 

examiners did not always adhere to agency procedure to 

acknowledge and document discussions of conflicting medical 

evidence and how they were resolved. Instead, examiners 

resolved these issues prior to entering responses in the 

Disability Briefing Document and indicated that there was no 

conflicting medical evidence. In addition, D-BRIEF was not being 

fully utilized for its intended purpose and there was a lack of 

transparency in RRB annuitant disability records that increased 

the risk for potential fraud in the disability determination 

process.

What We Recommend

To address the weaknesses identified in this audit, we made 

three recommendations related to (1) updating policies and 

procedures in the Disability Claims Manual to require that all 

medical evidence considered in the determination of conflicting 

medical evidence is entered into D-BRIEF and discussed on the 

Disability Briefing Document; (2) updating policies and 

procedures to ensure that all relevant medical evidence and 

supporting documentation pertaining to the applicant’s claim 

for disability is documented in D-BRIEF and the electronic case 

file, prior to the finalization of the initial disability decision; and 

(3) ensuring that the Disability Benefits Division works with 

Policy and Systems to implement system modifications to 

D - BRIEF to ensure that the Disability Briefing Documents do 

not contain an incorrect statement.

RRB management concurred with recommendations 1 and 2 but 

did not concur with recommendation 3. Although the RRB did 

not concur with recommendation 3, they stated that procedure 

will be revised to improve the accuracy of statements in D-BRIEF. 

What We Did

Due to the high dollar value of 

annual disability annuities, and 

previous findings by Office of 

Inspector General, Government 

Accountability Office, and our 

contracted auditors, we conducted 

this performance audit because it 

is imperative that the disability 

decision process is as complete, 

accurate, and transparent as 

possible.

The scope of the audit was all 

initial disability decisions made in 

fiscal year 2019. 

Our audit objectives were to 

determine if the D-BRIEF process 

was fully effective to ensure that 

(1) examiner rationales for their 

decisions were completely 

documented and (2) information 

recorded on the Disability Briefing 

Document was consistent with 

supporting documentation in the 

electronic case file.

In order to complete this work, we 

considered applicable laws, 

regulations, guidance and RRB 

policies and procedures related 

initial disability decision process in 

the D BRIEF, conducted sample 

testing, and reviewed agency 

documentation, records, and 

system data. We also conducted

walkthroughs and interviewed 

applicable agency staff.
OFFICE OF INSPECTOR GENERAL – U.S. RAILROAD RETIREMENT BOARD 

 

Contents

INTRODUCTION 1

OBJECTIVES, SCOPE, AND METHODOLOGY 1

BACKGROUND 3

RESULTS OF AUDIT 6

THE D BRIEF PROCESS DID NOT ALWAYS ENSURE THAT DISABILITY DECISION RATIONALES WERE 

COMPLETELY DOCUMENTED AND DOUBT EXISTS REGARDING THE CONSISTENCY AND 

TRANSPARENCY OF SOME RESPONSES 6

THE D-BRIEF PROCESS DID NOT ALWAYS ENSURE THAT DISABILITY RATIONALES WERE 

COMPLETELY AND CONSISTENTLY DOCUMENTED 6

DISABILITY DECISIONS WERE NOT ALWAYS FULLY DOCUMENTED OR SUPPORTED 8

THE D BRIEF PROCESS DID NOT ALWAYS ENSURE THAT INFORMATION RECORDED ON THE 

DISABILITY BRIEFING DOCUMENT WAS CONSISTENT WITH SUPPORTING DOCUMENTATION 9

SOME DISABILITY BRIEFING DOCUMENTS INCORRECTLY STATED THAT CASES WERE 

RATED USING ICE 9

RECOMMENDATIONS 10

MANAGEMENT’S COMMENTS AND OUR RESPONSE 10

APPENDIX I: MANAGEMENT COMMENTS 11

APPENDIX II: NONGENERALIZABLE SAMPLE METHODOLOGY AND RESULTS INITIAL DISABILITY RATIONALES 

IN THE D-BRIEF PROGRAM OCTOBER 1, 2018 THROUGH SEPTEMBER 30, 2019 13

APPENDIX III: OBSERVATION METHODOLOGY AND RESULTS - SAMPLE REVIEW OF INITIAL OCCUPATIONAL 

DISABILITY CASES THAT WERE RATED USING INDEPENDENT CASE EVALUATION (ICE) IN D-BRIEF

OCTOBER 1, 2018 THROUGH SEPTEMBER 30, 2019 16

APPENDIX IV: STATISTICAL SAMPLE METHODOLOGY AND RESULTS - REVIEW OF INITIAL OCCUPATIONAL 

DISABILITY CASES THAT WERE RATED USING INDEPENDENT CASE EVALUATION (ICE) IN D-BRIEF

OCTOBER 1, 2018 THROUGH SEPTEMBER 30, 2019 18

APPENDIX V: METHODOLOGY AND RESULTS - SUMMARY OF TABLES 4 AND 5 FOR INITIAL OCCUPATIONAL 

DISABILITY CASES THAT WERE RATED USING INDEPENDENT CASE EVALUATION (ICE) IN D-BRIEF

OCTOBER 1, 2018 THROUGH SEPTEMBER 30, 2019 20

LIST OF FIGURES

FIGURE 1. THREE POSSIBLE ANSWERS TO CONFLICTING MEDICAL EVIDENCE QUESTION 7

LIST OF TABLES

TABLE 1. INITIAL DISABILITY DECISION CATEGORIES 1
OFFICE OF INSPECTOR GENERAL – U.S. RAILROAD RETIREMENT BOARD 

 

TABLE 2. UNIVERSE AND SAMPLE FOR APPENDIX II 14

TABLE 3. SAMPLE TEST RESULTS FOR APPENDIX II 14

TABLE 4. SAMPLE RESULTS FOR APPENDIX III 17

TABLE 5. SAMPLE RESULTS FOR APPENDIX IV 19

TABLE 6. SAMPLE RESULTS FOR APPENDIX V 21
OFFICE OF INSPECTOR GENERAL - RAILROAD RETIREMENT BOARD

The RRB’s Disability Briefing Document Process Was Not Fully Effective - Report No. 21-07 1

INTRODUCTION

This report presents the results of the Office of Inspector General’s (OIG) audit of the Disability 

Briefing Document Program (D BRIEF).

Objectives, Scope, and Methodology

Our audit objectives were to determine if the D-BRIEF process was fully effective to ensure that 

(1) examiner rationales for their decisions were completely documented and (2) information 

recorded on the Disability Briefing Document was consistent with supporting documentation in 

the electronic case file.

It should be noted that the objective of our audit did not include making an assessment as to 

whether or not the initial disability decisions (to allow or deny) were correct, nor did we make 

an assessment as to the veracity of the submitted documentation. 

The scope of the audit was all initial disability decisions made in fiscal year 2019. During 

fieldwork, the universe consisted of 2,366 initial disability decisions made in fiscal year 2019 

and was made up of 4 different categories, as displayed in Table 1. 

Table 1. Initial Disability Decision Categories

Initial Disability Decision Type Totals

Occupational 1,047

Total and Permanent (T&P) 941

Widow 137

Child 241

Total Initial Disability Decision Universe 2,366

Source: RRB Fiscal Year 2019 Initial Disability Data.

To accomplish the audit objectives, we 

 identified applicable laws and regulations for the initial disability decision process;

 identified and reviewed Railroad Retirement Board (RRB) policies and procedures for 

the initial disability decision process in the D-BRIEF;

 determined and documented whether internal control is significant to the audit 

objectives;

 interviewed appropriate RRB officials and agency staff including management from the 

Office of Programs;
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The RRB’s Disability Briefing Document Process Was Not Fully Effective - Report No. 21-07 2

 conducted walkthroughs of the Disability Benefits Division (DBD)’s D-BRIEF process;

 conducted a walkthrough of Program Evaluation and Management Services’ quality 

assurance review process; 

 developed a test strategy and sampling plan; 

 tested a randomly selected nongeneralizable sample of 46 Disability Briefing Documents 

for consistency and completeness. We considered an attribute accurate if the 

information on the Disability Briefing Document was consistent with the information 

recorded in the electronic clam file in WorkDesk;

 developed an additional test strategy and sampling plan for initial occupational disability 

cases that used Independent Case Evaluations (ICE); and

 tested the Disability Briefing Documents for an additional randomly selected, 

statistically valid sample of 168 initial occupational disability cases that used ICE, for 

information related to conflicting medical evidence.

We assessed the data reliability of the fiscal year 2019 initial disability decision data provided 

by the Office of Programs by: (1) performing electronic testing of required data elements, 

(2) reviewing existing information about the data, and (3) interviewing agency management 

and staff knowledgeable about claims processing. In addition, we compared the fiscal year 2019 

initial disability decisions in the data extract we received from the Office of Programs with an 

independent extract from our own OIG, Office of Audit, Data Analytics Team. The data 

contained no data validity errors, using the Audit Command Language verify command, and the 

data was complete and sufficiently reliable to answer our audit objectives. This validation did 

not assess the entirety nor the veracity of the documentation submitted.

Our testing methodology considered the risks inherent with unreliable data and the availability 

of corroborating evidence in the form of source documents as recommended by Government 

Accountability Office (GAO). We determined that the computer processed data obtained from 

the Office of Programs was sufficiently reliable for our testing purposes and do not believe 

using the data would weaken our analysis of the audit objectives or lead to an incorrect or 

unintentional conclusion about our findings, conclusions, or recommendations.

We developed a sampling plan and test strategy to support our audit objectives. We initially 

used (stratified) discovery sampling, which recommended 45 samples out of our total universe 

of 2,366 cases. We used a stratified sample to ensure a representative selection of each type of 

initial disability decision was selected which directed a sample of 45. However, we decided to 

round our sample up to 46. At that point our sample became a nongeneralizable (judgmental) 

sample. 

We tested attributes related to data consistency and completeness in the D-BRIEF process (as it 

was documented on the Disability Briefing Document and supporting documentation in 

WorkDesk). To determine if the rationale for the decision was consistent, we compared the 

information listed on the Disability Briefing Document with the information on the disability 

application and information contained in WorkDesk. To determine if the rationale was 

completely documented, we compared the information on the application and in WorkDesk to 
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The RRB’s Disability Briefing Document Process Was Not Fully Effective - Report No. 21-07 3

see if it was completely discussed on the Disability Briefing Document. Conversely, we looked to 

see if the information documented on the Disability Briefing Document was supported by

evidence in WorkDesk. Because we selected a nongeneralizable sample, we did not project an 

error rate to the universe, but concluded only on actual errors and observations noted during 

testing. Again, we did not make an assessment as to whether or not the initial disability 

decisions (to allow or deny) were correct, nor did we make an assessment as to the veracity of 

the submitted documentation. 

We conducted this performance audit in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions 

based on our audit objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives.

We conducted our fieldwork at the RRB’s headquarters in Chicago, Illinois from November 2019 

to August 2020, and from December 2020 through June 2021. Our audit was suspended from 

August 2020 through November 2020 to devote resources to our mandated audits.

Background

The RRB was created in the 1930s by legislation establishing a retirement program for the 

nation’s railroad workers. The RRB is an independent agency in the executive branch of the 

Federal Government. The RRB’s mission is to administer retirement/survivor and 

unemployment/sickness insurance benefit programs for railroad workers and their families 

under the Railroad Retirement Act (RRA) and the Railroad Unemployment Insurance Act (RUIA). 

These programs provide income protection during old age and in the event of disability, death, 

or temporary unemployment and sickness. The RRB’s mission statement says that it will pay 

benefits to the right people, in the right amounts, in a timely manner, and will take appropriate 

action to safeguard their customers’ trust funds. 

The RRA provides for payment of disability benefits, based on age and service in the railroad 

industry, to those who are permanently disabled from work in their regular railroad occupation 

(known as occupational disability annuities), or who are totally disabled from any regular 

employment (known as total and permanent, or T&P disability annuities). 

Under the RRB’s disability program, the RRB handles the full range of disability claims 

processing in support of T&P and occupational disabilities. A T&P disability annuity is based on 

permanent disability for all employment and is payable at any age to employees with at least 

10 years of railroad service and under certain conditions to employees with 5 years of service 

after 1995. An occupational disability annuity is based on disability for the employee’s “regular 

railroad occupation,” which may or may not be the employee’s current occupation, and is 

payable at age 60 if the employee has 10 years of service, or at any age if the employee has at 

least 20 years of service. A “current connection with the railroad industry” is also required for 

an occupational disability annuity. The current connection requirement is normally met if the 

employee worked for a railroad in at least 12 of the last 30 consecutive months immediately 

preceding the annuity beginning date. 
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The RRB’s Disability Briefing Document Process Was Not Fully Effective - Report No. 21-07 4

Annuities are also payable to spouses and divorced spouses of retired workers, widow(er)s, 

surviving divorced spouses, remarried widow(er)s, children, and parents of deceased railroad 

workers.

Within the RRB’s Office of Programs, the DBD is responsible for processing all disability claims. 

For fiscal year 2019, the RRB reported that they paid disability benefits totaling $1.02 billion, 

including $638 million in occupational disability benefits. The RRB reported that they processed 

approximately 1,986 initial occupational and T&P disability decisions.1 The approval rate for 

occupational disabilities remained close to 100 percent, at 96.9 percent during fiscal year 2019.

The OIG has previously identified deficiencies in the occupational disability program and has 

made numerous recommendations for improvement in program integrity. While the RRB has 

taken some actions to address our recommendations, additional improvements are needed. 

GAO also audited the RRB’s disability program and reported that “a nearly 100 percent 

approval rate in a federal disability program is troubling, and could indicate lax internal controls 

in RRB’s decision-making process, weakness in program design, or both.”2

The RRB uses D-BRIEF to document disability examiners’ (examiners) rationales for disability 

decisions. DBD put D-BRIEF into production in September 2003. D-BRIEF is an interactive 

personal computer program and it contains all of the sequential evaluation questions that are 

required to make an initial disability annuity decision. It provides space for free form discussion 

of the medical evidence. Once an examiner completes the initial disability rationale in D-BRIEF, 

it is reviewed and approved by a post examiner. Once approved, the disability decision is 

finalized and a Form G-325B (Disability Briefing Document) is created as an output of D-BRIEF.3

For occupational disability decisions, the Disability Briefing Document records job information 

and medical evidence that the examiner considered in determining if the claimant was 

“disabled from work in their ‘regular’ railroad occupation.” After the Disability Briefing 

Document is created, it is uploaded into WorkDesk, as support for the disability decision.4

WorkDesk acts as the electronic disability folder that should include all supporting 

documentation for disability claims. As soon as the Disability Briefing Document is approved by 

the authorizer, the decision is recorded in agency systems and RRB can begin to process the 

annuity that has been granted (allowed). Policy and Systems, within the Office of Programs, is 

responsible for developing and managing systems, including D-BRIEF, to support bureau 

operations. 

 1 After our audit field work was completed, Railroad Retirement Board (RRB) revised their total for occupational 

disability decisions by 2, from 1047 to 1045. Therefore, there is a difference of 2 between Table 1 and RRB’s 

reported total for occupational and Total and Permanent cases combined. 

2 Government Accountability Office (GAO), Railroad Retirement Board: Review of Commuter Railroad Occupational 

Disability Claims Reveals Potential Program Vulnerabilities, GAO-09-821R (Washington, D.C.: September 9, 2009). 3 Form G-325B (The Disability Briefing Document) is an output of Disability Briefing Document Program (D-BRIEF) 

and it contains the initial disability decision and date of onset, if approved. 

4 WorkDesk is used to access documents in the RRB’s imaging system.
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The RRB’s Disability Briefing Document Process Was Not Fully Effective - Report No. 21-07 5

As part of the D-BRIEF adjudication process, for occupational disability cases, RRB procedures 

instruct examiners to document conflicting medical evidence that is relevant to the decision for 

applications that require an ICE. The RRB uses tables to evaluate evidence provided for 

disability cases when the medical condition and the railroad job are listed. ICE is required in the 

following circumstances: 

 if the medical condition or the railroad job title is not listed in the table; 

 when the job and medical condition are met, but there is no matching disability test; 

 when the disability rating has not been made because medical variations make it 

necessary to look at specific job information and/or specific medical information to 

make a determination; or 

 situations in which the job titles and medical conditions may be covered, but the 

information is not consistent or cannot be simply clarified.

During fiscal year 2019, the RRB reported that they utilized ICE to adjudicate approximately 

75 percent of the occupational disability cases.

In 2019, OIG contracted for a series of audits related to the RRB’s disability process. One of 

these contracted audits found that the RRB disability decision process lacks preventive controls 

to adequately address fraud risk indicators. The contractors made three recommendations to 

address this weakness, however, only one was related to our current audit objectives: 

We recommend that the Office of Programs/Disability Benefits Division establish 

additional supervisory review and documentation protocols to ensure that decisions 

for higher risk applications are sufficiently reviewed and consistently documented to 

reflect the basis for the decision.5

Although this recommendation does not directly relate to the D-BRIEF process, it does highlight 

that our contracted auditors previously identified a need to implement documentation 

protocols and review procedures in the disability decision process to ensure that decisions for 

applications at a higher risk for fraud are consistently documented and sufficiently reviewed. 

Due to the high dollar value of annual disability annuities, and previous findings by OIG, GAO, 

and our contracted auditors, it is imperative that the disability decision process is as complete, 

accurate, and transparent as possible. 

 5 RRB Office of Inspector General (OIG), The Railroad Retirement Board Disability Programs Do Not Effectively 

Consider Fraud Risk Indicators in the Disability Decision Process, Report No. 19-16, Recommendation 3 (Chicago, IL: 

September 27, 2019).
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The RRB’s Disability Briefing Document Process Was Not Fully Effective - Report No. 21-07 6

RESULTS OF AUDIT

Our audit determined that the D-BRIEF process was not fully effective to ensure that examiner 

rationales for their decisions were completely documented. In addition, doubt exists regarding 

whether information recorded on the Disability Briefing Document was consistent with 

supporting documentation in the electronic case file. Although we did not identify any 

exceptions directly related to consistency, examiners did not always adhere to agency 

procedure to acknowledge and document discussions of conflicting medical evidence and how 

they were resolved. Instead, examiners resolved these issues prior to entering responses in the 

Disability Briefing Document and indicated that there was no conflicting medical evidence. As a 

result, doubt exists regarding the completeness and consistency of responses used as a basis to 

make disability determinations. In addition, D-BRIEF was not being fully utilized for its intended 

purpose and there was a lack of transparency in RRB annuitant disability records that increased 

the risk for potential fraud in the disability determination process. 

The details of our audit findings and recommendations for corrective action are provided in this 

report. The full text of management’s response is provided in Appendix I.

The D BRIEF Process Did Not Always Ensure that Disability Decision 

Rationales Were Completely Documented and Doubt Exists Regarding 

the Consistency and Transparency of Some Responses 

The D-BRIEF Process Did Not Always Ensure That Disability Rationales Were 

Completely and Consistently Documented 

We determined that the D-BRIEF process did not always ensure the completeness of 

documented examiner rationales that should have been factored into the disability 

determination process. We learned that instead of discussing conflicting medical evidence and 

its resolution, as required by agency procedure, most of the examiners resolved any conflicts 

prior to recording the response to this question in D-BRIEF and, therefore, they did not 

document the existence of conflicts or how they were resolved on the Disability Briefing 

Documents.

We identified a new issue related to the completeness of documentation for some disability 

decisions during our initial sample testing. Therefore, we performed additional tests for 

completeness. 

During our walkthrough of the D-BRIEF process, an examiner told us that she normally makes 

her decision to grant or deny a disability prior to entering information into D-BRIEF. Based on 

our sample results that only 2 of 183 cases (1 percent) discussed conflicting medical evidence, 

combined with the information obtained during the walkthrough, we decided to poll the 

examiners who prepared all of our sample cases, to learn how they addressed the conflicting 

medical evidence question. We learned that 15 of the 19 disability examiners that responded to 

our survey resolve any conflicting medical evidence prior to entering their responses in D-BRIEF 

and, therefore, they indicate on the Disability Briefing Document, that there was no conflicting 

medical evidence. As a result, doubt exists regarding the consistency of some responses 
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The RRB’s Disability Briefing Document Process Was Not Fully Effective - Report No. 21-07 7

pertaining to conflicting medical evidence as compared to supporting documentation in the 

electronic case file.

During our sample testing of 2 separate samples totaling 183 initial occupational disability cases 

that used ICE, we found that only 2 of the Disability Briefing Documents discussed conflicting 

medical evidence. The combined sample results are shown in Appendix V. The total for 

183 cases was from the sample results separately discussed in Appendices III and IV. 

The 183 sample results discussed in this finding resulted from 2 separate samples of 

occupational disability cases. Our testing began with a nongeneralizable sample during which 

we tested 15 cases. We found 1 case where the conflicting medical evidence question remained 

“Unanswered" and 14 cases where the response was that there was no conflicting medical 

evidence. See Appendix III. Due to the results of that sample, we conducted a separate 

statistically valid random sample of 168 cases. We found 2 cases where conflicting medical 

evidence was discussed and 166 cases reflected that there was no conflicting medical evidence. 

See Appendix IV. See Appendix V for the combined sample results.

For initial occupational disability cases that used ICE, D-BRIEF inserts an automatic statement 

when the examiner indicates that there is no conflicting medical evidence and also when this 

question remains “Unanswered.” In both instances, the following statement is documented on 

the Disability Briefing Document: “There is no conflicting medical evidence in file that is 

relevant to the decision.” D-BRIEF does not require any additional entries regarding conflicts 

when the response is “No” or “Unanswered.”

The RRB’s policies and procedures for actions related to disability claims are documented in the 

online Disability Claims Manual (DCM). D-BRIEF procedures in the DCM explain that the 

conflicting medical evidence question has three possible answers: “Yes”, “No”, or 

“Unanswered.” The “Unanswered” response is the system default, until the examiner changes 

it. Figure 1 displays the question in the D-BRIEF: “Is there conflicting medical evidence in file 

that is relevant to the decision?”

Figure 1. Three Possible Answers to Conflicting Medical Evidence Question 

Source: Screenshot of response to conflicting medical evidence question in D-BRIEF.

When disability examiners documented the rationale for their decisions in D-BRIEF, the DCM 

required a description of the supporting documentation used and relied upon when a “Yes” 

response was chosen to the question: “Is there conflicting medical evidence in file that is 

relevant to the decision?” In the case of a “Yes” response, the statement: “There is conflicting 

medical evidence in file that is relevant to the decision.” appears on the Disability Briefing 

Document, along with a description of the conflicting medical evidence. 
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The RRB’s Disability Briefing Document Process Was Not Fully Effective - Report No. 21-07 8

Although we learned that examiners make the decision to grant or deny the disability claim 

prior to entering responses, relevant medical evidence, and supporting documents in D-BRIEF, 

the DCM states that the examiner can access D-BRIEF at any point in the decision process. This 

means that the examiner is not required to make the decision prior to or during the process of 

using D-BRIEF. 

Potential conflicting medical evidence relevant to the decision was not always documented on 

the Disability Briefing Documents because DCM policies and procedures did not require 

examiners to document conflicts relevant to the decision that had been resolved prior to entry 

into D-BRIEF.

Due to the “No” and “Unanswered” responses for conflicting medical evidence and D-BRIEF’s 

automatic insertion of text stating that there was no conflicting medical evidence in file 

relevant to the decision, the disability examiner’s rationale for their determination that the 

railroad employee was indeed disabled from their regular railroad occupation, was not fully 

transparent and was not always consistent with the supporting documentation in the electronic 

case file. 

This lack of transparency in RRB annuitant disability records indicated that D-BRIEF was not 

being fully utilized for its intended purpose, which increased the risk for potential fraud in the 

initial disability decision making process, as claim examiners could have prepared cases 

containing conflicting medical evidence without acknowledging the conflict or documenting 

how the conflict was resolved. Also, an authorizer may not have recognized the existence of 

conflicting medical evidence if it was not recorded, and, therefore, was not afforded an 

opportunity to review and assess those decisions that were made by the examiner. 

Disability Decisions Were Not Always Fully Documented or Supported

Our disability sample testing identified one exception related to completeness, because the 

recorded entry was not completely supported, as required by disability procedures. In 1 of 41 

cases, the disability decision documented on the Disability Briefing Document, was not 

completely supported by evidence in the case file maintained in WorkDesk. See Appendix II.

We tested 41 initial disability decisions to determine if statements made on the Disability 

Briefing Document were supported by documentation in WorkDesk. For this one exception 

case, we found that although the Disability Briefing Document stated that the Railroad Job 

Information Report (Form G-251A) was returned from the railroad employer, and a comparison 

was done between it and the vocational report, we could not find the Form G-251A in 

WorkDesk. Therefore, we concluded that the decision documented on the Disability Briefing 

Document was not completely supported. 

DCM Part 3.3 outlines the evidence requirements for initial disability annuities. One such 

requirement is related to the “Job Information” for occupational disability decisions. It states 

that job information is always required from the employee and will be requested from the 

railroad employer.
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The RRB’s Disability Briefing Document Process Was Not Fully Effective - Report No. 21-07 9

Because most examiners make their disability determinations prior to the entry of information 

into D-BRIEF, the examiner might have mentioned the Form G-251A on the Disability Briefing 

Document although it had not been loaded into WorkDesk. 

As a result, rationales for disability decisions were not always completely documented or fully 

supported by evidence in the electronic claim file in WorkDesk. 

The D BRIEF Process Did Not Always Ensure that Information Recorded 

on the Disability Briefing Document was Consistent With Supporting 

Documentation 

Some Disability Briefing Documents Incorrectly Stated That Cases Were Rated 

Using ICE 

Some T&P disability cases contained entries in the Disability Briefing Document that gave the 

appearance of being occupational disability cases. As we were in the process of identifying the 

universe of cases, we identified 16 cases that appeared to be occupational disability cases, but 

we were informed by DBD that they were T&P cases. These cases were mistaken for 

occupational disability cases because they contained an inaccurate statement on the Disability 

Briefing Document that read: “The employee was rated using the Independent Case 

Evaluation.” The statement is incorrect because it is only applicable to occupational disability 

cases and not to T&P disability cases. DBD explained that these cases were changed from 

occupational disability to T&P disability decisions.

The DCM outlines the evidence requirements for initial disability annuities. One such 

requirement is related to the medical evidence for occupational disability decisions. According 

to the DCM: 

disability (medical evidence) is always required for an employee disability annuity. 

The DCM also outlines that ICE is a three step process used by claims examiners to rate 

occupational disability decisions where:

 medical information is reviewed to establish diagnosis and to establish an 

understanding of the condition by the claims examiner;

 job information is evaluated to determine the job demands; and

 medical information regarding relevant impairment is compared to the job demands. 

According to DBD, these 16 cases where changed to T&P decisions (from occupational disability 

decisions) after the examiner changed the disability onset date to an earlier date. D-BRIEF does 

not allow the examiner to go back and edit the sequential evaluation answers previously given 

in D-BRIEF. So once the cases are changed from occupational to T&P, examiners could not go 

back to change the ICE indicator in D BRIEF. Therefore, the Disability Briefing Document 

contained an incorrect statement and the type of disability decision was not transparent to 

readers.
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The RRB’s Disability Briefing Document Process Was Not Fully Effective - Report No. 21-07 10

As a result, users of D-BRIEF and those that reviewed the Disability Briefing Document may 

have wrongly concluded that the cases were occupational disability decisions, when in fact, 

they were T&P disability decisions.

Recommendations

We recommend that the Office of Programs

1. update policies and procedures in the Disability Claims Manual to require that all 

medical evidence considered in the determination of conflicting medical evidence is 

entered into D-BRIEF, (including potential conflicting medical evidence and how the 

conflict was resolved) and as a result, discussed on the Disability Briefing Document;

2. update policies and procedures to ensure that all relevant medical evidence and 

supporting documentation pertaining to the applicant’s claim for disability is 

documented in D-BRIEF and WorkDesk, prior to the finalization of the initial disability 

decision; and

3. ensure that the Disability Benefits Division works with Policy and Systems to implement 

system modifications to D-BRIEF to ensure that the Disability Briefing Documents for 

decisions changed from occupational to total and permanent disabilities do not contain 

the incorrect statement that the (railroad) employee (applicant) was rated using 

Independent Case Evaluation.

Management’s Comments and Our Response

The Office of Programs concurred with recommendations 1 and 2. See the full text of 

management’s response in Appendix I.

For recommendation 3, the Office of Programs nonconcurred and stated,

The Office of Programs does not concur. The scenario described is based on an eligible employee 

attaining age 60, a critical age for occupational annuities. Based on the age, the final annuity 

determination is that the annuitant is occupationally disabled; however, in some cases an earlier 

onset allows for a total annuity before attaining age 60. There is a very small percentage of cases 

that meet this criteria. The recommended changes to D-Brief require significant updates and 

programming. In light of the IT Modernization, the Office of Programs is limited in making 

substantial systems changes. However, to improve the accuracy of statements within D-Brief and 

the final determination rationale, DCM 12.5.1 will be revised to instruct disability examiners to 

complete a template of the G-325B, Disability Briefing Document, explaining their decision, including 

the annuity type being rendered. The G-325B will be imaged. The template will be used until D-Brief 

is revised or replaced with a new documentation tool.

Although management did not concur with recommendation 3 because they stated that they 

are limited in making substantial systems changes due to information technology 

modernization, they stated that they plan to revise their procedures to improve the accuracy of 

statements within D-BRIEF. We continue to see the need for recommendation 3, and will 

evaluate whether procedural changes meet the intent of recommendation 3 if and when the 

procedural revisions as described are implemented.
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APPENDIX I: MANAGEMENT COMMENTS
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APPENDIX II: NONGENERALIZABLE SAMPLE METHODOLOGY AND RESULTS 

INITIAL DISABILITY RATIONALES IN THE D-BRIEF PROGRAM 

OCTOBER 1, 2018 THROUGH SEPTEMBER 30, 2019

This appendix presents the methodology and results for the sample testing conducted of the 

initial disability rationales in D-BRIEF. 

Sample Objective

Our sample objective was to test for various consistency and completeness test attributes to 

determine if the D-BRIEF process for initial disability decisions was completely and accurately 

documented. We considered an attribute accurate if the information on the D-BRIEF was 

consistent with the information recorded in the electronic clam file in WorkDesk. We did not 

make an assessment as to whether or not the initial disability decisions (to allow or deny) were 

correct, nor did we make an assessment as to the veracity of the submitted documentation. 

Scope

Our sample was selected from the initial disability decisions for the period of October 1, 2018 

through September 30, 2019.

Universe/Sampling Unit

The sampling universe consisted of 2,366 initial disability decisions for the period 

October 1, 2018 through September 30, 2019. The sampling unit was one initial disability 

(claim) decision.

Sample Selection Methodology

We used nongeneralizable sampling to test for specific controls (attributes) to determine if the 

D-BRIEF process was fully effective to ensure that (1) examiner rationales for their decisions 

were completely documented and (2) information recorded on the Disability Briefing Document 

was consistent with supporting documentation in the electronic case file. We used a stratified 

sample to ensure that a representative sample of each type of initial disability decision was 

selected which directed a sample of 45. However, due to rounding, we judgmentally selected a 

sample of 46. 

Initial disability decision types are categorized by Occupational (O), Total and Permanent (T&P), 

Widow (W), and Child (C). 
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Table 2. Universe and Sample for Appendix II

Initial Disability Decision Category Initial Disability Decisions in 

Universe

Sample 

Size

Occupational (O) 1,047 20

Total and Permanent (T&P) 941 18

Widow (W) 137 3

Child (C) 241 5

Total fiscal year 2019 Initial Disability 

Decisions

2,366 46

Source: RRB OIG generated sample size.

Sample Evaluation Methodology

For each transaction, we obtained and reviewed evidence from various agency mainframe 

systems including WorkDesk and D-BRIEF, in order to accomplish our sampling objectives.

Results of Review 

Our reviews resulted in the following errors (exceptions), as identified by attribute. 

Table 3. Sample Test Results for Appendix II

Attribute Tests

Attributes 

Applicable to 

Decision 

Categories

Number of 

Records 

Tested a

Exceptions

Prepopulated fields from APPLE were 

properly documented. (consistency)b

O, T&P, W 41 0

Other eligibility information on the Disability 

Briefing Document was properly 

documented. (consistency)c

O, T&P, W 41 0

If the railroad employer returned Form 

G-251A, the occupation and work shown 

agrees with the applicant claimed job 

information on the application. 

(Form AA - 1A) (consistency)

O 12d 0e

Statement regarding medical or job 

information referred to on the Disability 

Briefing Document was supported in 

WorkDesk. (completeness) 

O, T&P, W 41 1

Conflicting medical evidence discussed on 

Disability Briefing Document was supported 

in WorkDesk. (completeness) 

O, T&P, W 0f 0

Response entered by the examiner states 

that there is no conflicting medical evidence 

relevant to the decision in WorkDesk. 

(consistency)

O 14 0 

See appendix III for 

further observations.
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Attribute Tests

Attributes 

Applicable to 

Decision 

Categories

Number of 

Records 

Tested a

Exceptions

Eligibility requirements were met for widow 

applicants. (consistency) 

W 3 0

Disability was granted for widow, based on 

skills or age, (i.e. vocational rule) and there 

is supporting documentation. (consistency) 

W 3 0 

 Total Number of Exceptions 1 a Note: The total sample size was 46, however, the 5 child cases selected were not tested as they were not processed in 

D-BRIEF. Sample cases for occupational, T&P, and widow cases totaling 41 were tested. 

b Note: The prepopulated fields are applicant name, applicant social security number, and date of birth. c Note: For this attribute test, auditors were looking for any eligibility information that they noted on the Disability Briefing 

Document that were inaccurate based on supporting documentation in WorkDesk.

d Note: We found evidence in WorkDesk that the railroad employer returned 12 of 20 Forms G-251A for the occupational 

disability decisions. Therefore, we tested those 12 for this attribute related to consistency and we found no exceptions for 

consistency. The remaining eight cases could not be tested for consistency, because the Forms G-251A were not returned or 

were not evidenced in WorkDesk. 

e Note: Although we found no consistency errors or discrepancies related to the job information, we found one exception 

related to completeness because the examiner said a Form G-251A was returned and compared, but we found no Form G-251A 

supporting the statement in WorkDesk. This exception is shown in the evidence test above as a completeness error rather than 

a consistency error because the auditor could not locate the Form G-251A in WorkDesk, to support the statement in G-251A. f Note: Conflicting medical evidence was not discussed on any of the Disability Briefing Documents, therefore, we did not test 

for this attribute for completeness.

Source: OIG auditor generated sample results.

Auditor’s Conclusion

Our evaluation of the nongeneralizable sample of 41 initial disability decision rationales 

identified 1 actual completeness exception. As a result, disability decisions as evidenced on the 

Disability Briefing Document were not always completely documented or fully supported by 

evidence in the electronic claim file in WorkDesk. 
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APPENDIX III: OBSERVATION METHODOLOGY AND RESULTS - SAMPLE 

REVIEW OF INITIAL OCCUPATIONAL DISABILITY CASES THAT WERE RATED

USING INDEPENDENT CASE EVALUATION (ICE) IN D-BRIEF

OCTOBER 1, 2018 THROUGH SEPTEMBER 30, 2019

This appendix presents the methodology and results for the observation of initial occupational 

disability cases that were rated using Independent Case Evaluation (ICE) to determine if the 

question "Is there conflicting medical evidence in file that is relevant to the decision?" was 

answered “Yes” in the D-BRIEF program.

Observation Objective

Our testing objective was to determine the number of ICE that were marked “Yes” for 

containing conflicting medical evidence that is relevant to the decision.

Scope

This sample of 20 was a subset of our original sample 46 initial disability decisions for the period 

of October 1, 2018 through September 30, 2019. See Table 2 on Appendix II. 

Observation Methodology

During our sample testing we observed that conflicting medical evidence was never discussed 

on the Disability Briefing Document. We subsequently realized that according to Disability 

Claims Manual 2.5.6.2 for occupational disability ICE, conflicting medical evidence has to be 

resolved in D-BRIEF only if the question "Is there conflicting medical evidence in file that is 

relevant to the decision?" on the employee qualifications screen was answered “Yes.” As a 

result, we expanded our testing to identify if the question "Is there conflicting medical evidence 

in file that is relevant to the decision?" for ICE cases was ever answered “Yes” in the D-BRIEF 

program. Of the 20 occupational disability sample cases, 15 of the Disability Briefing Documents 

stated they were rated using ICE. We tested 100 percent of the 15 ICE cases to determine if the 

question "Is there conflicting medical evidence in file that is relevant to the decision?" for ICE 

cases was ever answered “Yes” in the D-BRIEF program.

Observation Evaluation Methodology

For each transaction, we obtained and reviewed evidence from various agency mainframe 

systems including WorkDesk and D-BRIEF in order to accomplish our sampling objectives. 

Results of Review

Our reviews resulted in the following responses.
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Table 4. Sample Results for Appendix III 

Attribute Test

Number 

of ICE 

Records 

Tested

Conflicting 

Medical 

Evidence 

Question 

with “Yes” 

Responses

Conflicting 

Medical 

Evidence 

Question with 

“No” 

Responses

Conflicting Medical 

Evidence Questions 

with “Unanswered” 

Responses 

Conflicting medical evidence 

button in D-BRIEF.

15g 0 14 1

g Note: For the 20 occupational cases mentioned in Appendix II, only 15 were rated using Independent Case Evaluation. 

Source: RRB OIG initial sample results.

Auditor’s Conclusion

Our evaluation of 20 initial occupational disability decisions identified 15 cases that were rated 

using ICE, of which 0 were marked “Yes” as containing conflicting medical evidence that is 

relevant to the decision, 14 were marked “No”, and 1 was “Unanswered.” Because the question 

was either marked “No” or remained “Unanswered” in all 15 cases, the statement, “There is no 

conflicting medical evidence in file that is relevant to the decision” was documented on all of 

the 15 Disability Briefing Documents reviewed. 

Therefore, we concluded that the D-BRIEF process did not always ensure that disability 

decisions were completely documented or fully transparent, and doubt exists regarding the 

consistency of some responses.
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APPENDIX IV: STATISTICAL SAMPLE METHODOLOGY AND RESULTS -

REVIEW OF INITIAL OCCUPATIONAL DISABILITY CASES THAT WERE RATED

USING INDEPENDENT CASE EVALUATION (ICE) IN D-BRIEF

OCTOBER 1, 2018 THROUGH SEPTEMBER 30, 2019

This appendix presents the methodology and results for the additional testing performed of 

initial occupational disability cases that were rated using Independent Case Evaluation (ICE) to 

determine if the question "Is there conflicting medical evidence in file that is relevant to the 

decision?" was answered “Yes,” “No,” or “Unanswered” in the D-BRIEF. 

Sample Objective

Our testing objective was to determine the number of ICE cases that were marked “Yes,” “No,” 

or “Unanswered” for containing conflicting medical evidence that is relevant to the decision. 

Scope

Our sample was selected from a total of 782 initial occupational disability cases that were rated 

using ICE during the period of October 1, 2018 through September 30, 2019.

Sample Methodology

According to Disability Claims Manual 12.5.6.2 for occupational disability ICE, conflicting 

medical evidence has to be resolved in D-BRIEF only if the question "Is there conflicting medical 

evidence in file that is relevant to the decision?" on the employee qualifications screen was 

answered “Yes.” As a result, we expanded our testing as provided in Appendix III to identify if 

the question "Is there conflicting medical evidence in file that is relevant to the decision?" for 

ICE cases was answered “Yes” in the D-BRIEF program. We tested an additional 168 ICE cases 

out of the 782 initial occupational disability ICE decisions made in fiscal year 2019 to determine 

if the question "Is there conflicting medical evidence in file that is relevant to the decision?" for 

ICE cases was answered “Yes,” “No,” or “Unanswered” in the D-BRIEF program.

Sample Evaluation Methodology

For each transaction, we obtained and reviewed evidence from various agency mainframe 

systems including WorkDesk and D-BRIEF in order to accomplish our sampling objective. 

Results of Review

Our reviews resulted in the following responses.
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Table 5. Sample Results for Appendix IV

Attribute Test

Number 

of ICE 

Records 

Tested

Conflicting 

Medical 

Evidence 

Question 

with “Yes” 

Responses

Conflicting 

Medical 

Evidence 

Question with 

“No” 

Responses

Conflicting Medical 

Evidence Questions 

with “Unanswered” 

Responses 

Conflicting medical evidence 

button in D-BRIEF.

168 2 166 0 

Source: RRB OIG additional sample results.

Auditor’s Conclusion

The result of our additional tests of 168 cases that used ICE showed that 2 were answered “Yes” 

as containing conflicting medical evidence that is relevant to the decision, 166 were answered 

“No,” and 0 were “Unanswered.” These testing results of 2 out of 168 samples containing and 

discussing conflicting medical evidence that is relevant to the decision, raises concerns that the 

examiners’ rationales for their initial disability decisions are not always fully transparent or 

consistent. Because the 166 cases with a response of “No” to the question "Is there conflicting 

medical evidence in file that is relevant to the decision?" did not explain what medical evidence 

was considered to make the determination, unlike the 2 with “Yes” responses. 

As noted in the body of this report, potential conflicting medical evidence relevant to the 

decision was not always documented on the Disability Briefing Documents because policies and 

procedures did not require examiners to document conflicts relevant to the decision that had 

been resolved prior to entry into D-BRIEF. Therefore, we concluded that the D-BRIEF process 

did not always ensure that disability decisions were completely documented or fully 

transparent, and doubt exists regarding the consistency of some responses.
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APPENDIX V: METHODOLOGY AND RESULTS - SUMMARY OF TABLES 4 AND 

5 FOR INITIAL OCCUPATIONAL DISABILITY CASES THAT WERE RATED USING 

INDEPENDENT CASE EVALUATION (ICE) IN D-BRIEF

OCTOBER 1, 2018 THROUGH SEPTEMBER 30, 2019

This appendix presents the methodology and results for all testing performed of initial 

occupational disability cases that were rated using Independent Case Evaluation (ICE) to 

determine if the question "Is there conflicting medical evidence in file that is relevant to the 

decision?" was answered “Yes, “No,” or “Unanswered” in the D-BRIEF.

Sample Objective

Our testing objective was to summarize tables 4 and 5 for the total number of ICE cases that 

were marked “Yes,” “No,” or “Unanswered” for containing conflicting medical evidence that is 

relevant to the decision.

Scope

Our sample was selected from a total of 782 initial occupational disability cases that were rated 

using ICE during the period of October 1, 2018 through September 30, 2019. 

Sample Methodology

Per the Disability Claims Manual 12.5.6.2 for occupational disability ICE cases, conflicting 

medical evidence has to be resolved in D-BRIEF only if the question "Is there conflicting medical 

evidence in file that is relevant to the decision?" on the employee qualifications screen was 

answered “Yes.” From the original sample of 20 occupational disability cases, we found that 15 

of them were rated using ICE. We tested all 15 cases to determine if the question "Is there 

conflicting medical evidence in file that is relevant to the decision?" for ICE cases was answered 

“Yes” in the D-BRIEF program (as provided in Appendix III). As a result, we expanded our testing 

to identify if the question "Is there conflicting medical evidence in file that is relevant to the 

decision?" for ICE cases was answered “Yes” in the D-BRIEF program. In addition to the 15 

cases tested in appendix III, we tested an additional 168 ICE cases out of the 782 initial 

occupational disability cases that were rated using ICE made in fiscal year 2019 to determine if 

the question "Is there conflicting medical evidence in file that is relevant to the decision?" for 

ICE cases was answered “Yes,” “No,” or “Unanswered” in the D-BRIEF program (as provided in 

Appendix IV.

Sample Evaluation Methodology

For each transaction, we obtained and reviewed evidence from various agency mainframe 

systems including WorkDesk and D-BRIEF in order to accomplish our sampling objectives. 
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Results of Review

Our reviews resulted in the following responses.

Table 6. Sample Results for Appendix V

The following table shows the results of our initial testing of ICE cases, the results of our 

additional testing, and the totals combined:

Attribute Test Number of 

ICE Records 

Tested

Conflicting 

Medical 

Evidence 

Question with 

“Yes” 

Responses

Conflicting 

Medical 

Evidence 

Question with 

“No” 

Responses

Conflicting 

Medical 

Evidence 

Questions with 

“Unanswered” 

Responses 

Initial Testing Results: 

Conflicting medical evidence 

button in D-BRIEF.

15 0 14 1 

Additional Testing Results: 

Conflicting medical evidence 

button in D-BRIEF.

168 2 166 0 

Total Testing Results: 

Conflicting medical evidence 

button in D-BRIEF

183 2 180 1

Source: RRB OIG summary of table 4 and table 5.

Auditor’s Conclusion

The results of our testing of 183 Independent Case Evaluations showed that 2 were answered 

“Yes” as containing conflicting medical evidence that is relevant to the decision, 180 were 

answered “No,” and 1 was “Unanswered.” The total results of 183 cases shown in Table 6 

combined the sample results discussed in Appendices III and IV.

Therefore, for the combined samples of 183 total initial occupational disability cases that used 

ICE, only 2 of the 183 questions related to conflicting medical evidence were answered “Yes,” 

and were then discussed on the disability briefing documents. For the remaining 181 cases 

tested, the statement “There is no conflicting medical evidence in file that is relevant to the 

decision” was documented, with no further discussion of potential conflicting medical evidence 

documented on the Disability Briefing Documents. 

As noted in the body of this report, potential conflicting medical evidence relevant to the 

decision was not always documented on the Disability Briefing Documents because policies and 

procedures did not require examiners to document conflicts relevant to the decision that had 

been resolved prior to entry into D-BRIEF.

As result, we concluded that the D-BRIEF process did not always ensure that disability decision 

rationales were completely documented or fully transparent, and doubt exists regarding the 

consistency of some responses.