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6.1 Introduction

6.1.1 General

Every disability annuitant is also rated under the Social Security (SS) Act for a period of 

disability. Non-disability annuitants may also file for a disability freeze (DF). However, 

the annuitant has the right to request that a DF not be granted. (See DCM 6.3.1) 

The freeze provision of the SS Act protects disabled workers and their families against 

the loss of, or the reduction in, benefits because of the worker's disability. When a 

freeze is established, the worker's wage record is frozen and the period during which he 

is disabled and not likely to have substantial earnings is excluded to the worker's 

advantage when determining insured status and benefit amounts. 

The Railroad Retirement Board (RRB) uses the freeze provision in retirement cases to 

increase primary insurance amounts (PIA), make the tier I portion taxable like a social 

security benefit, establish early Medicare and windfall entitlement, and to apply the 

Disability Insurance Benefit (DIB)-Overall Minimum (O/M). In survivor cases, the freeze 

may produce higher monthly rates that would otherwise not be payable.

A survivor can file an application to establish a DF for a deceased employee if the

application is filed within 3 months of the employee’s death. Although a disability 

annuity cannot be paid to the survivor, the establishment of the DF may increase the 

amount of survivor annuity. For background information and processing instructions, 

see RCM 8.1.185. 

6.1.2 History Of And Agency Authority To Make Freeze Determinations

The original period of disability (disability freeze) SS Act provisions were enacted in 

1954 to preserve the rights of individuals who are under disability. The provisions 

preserved the individual's insured status and the amount of the benefit from the time the 

person qualified for a disability freeze. Since the person's rights were preserved from 

that time, these provisions became commonly known as the disability freeze provisions. 

At this point, benefits could be increased when the person attained age 65 if a disability 

freeze was established.

The 1956 SS Act Amendments provided cash disability benefits effective 1-1-57 or later 

to wage earners who had attained age 50. Auxiliary benefits became payable 9-1-58 or 

later on the same basis as those made to auxiliaries of retired workers.

Prior to September 6, 1958, the Social Security Administration (SSA) had sole authority 

under the law to establish a disability freeze for career railroad (RR) employees who 

would be insured under the SS Act if their RR service after 1936 were credited as 

employment under that Act. Under an agreement between SSA and RRB, the RRB 

was delegated authority to obtain disability freeze applications and other necessary 
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evidence from RR employees to make disability freeze determinations. These disability 

freeze determinations were subject to the review and approval of SSA.

Since September 6, 1958, RRB has had independent statutory authority to determine a 

disability freeze for any RR employee who files an application for a disability annuity 

and has completed 10 years of RR service. For such determinations, an employee's 

RR service after 1936 is to be considered as "employment" under the SS Act.

RRB may accept an earlier disability freeze determination made by SSA. If there is no 

inconsistency between the SSA disability freeze determination and the rating of 

disability made by RRB, the SSA decision may be used without further development.

6.1.3 DF Decisions Completed By The RRB

The RRB completes DF decisions for career railroad employees only. There are three 

types of DF decisions.

A. Single Freeze (SF)

SF cases are those disability claims filed by or on behalf of career railroad 

employees (DCM 6.7.2) with the RRB where there is little or no potential for Social 

Security benefits ever being paid.

Authorized RRB personnel prepare a SF determination and complete it without SSA 

review. SF decisions can be completed at all adjudicative levels.

B. Joint Freeze (JF)

JF cases are those disability claims filed by or on behalf of career railroad workers 

(DCM 6.7.2) which are processed jointly by RRB and SSA where there is some 

likelihood of social security benefits being paid or cases included in the financial 

interchange (FI) sample (DCM 6.7.3).

Authorized RRB personnel prepare a JF determination and SSA reviews and 

countersigns the decision.

A JF case originates as a claim for a disability annuity filed with the RRB by or on 

behalf of a career railroad worker. In other words, a disability application filed with 

SSA before a disability application is filed with the RRB is not considered as a JF. 

This includes SSA Title II (Disability Insurance Benefits [DIB]) or Title XVI 

(Supplemental Security Income [SSI]) applications.

EXCEPTION: ALL disability applications in the FI sample must be processed in 

our systems using OLDDS SSA-831 regardless of whether it was initially filed at 

SSA or RRB.

See DCM 6.7.3 and the list of exceptions as to when a JF decision is or is not 

required. In general,
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• All proposed JF awards or denials adjudicated in DBD are coordinated with SSA 

(EXCEPT when the same claim for RR Act disability annuity is denied). 

• A claim denied as a JF in DBD but subsequently awarded at the reconsideration 

level is coordinated with SSA.

C. Unilateral Freeze

Unilateral freeze cases are those disability claims where the RRB makes an 

independent decision on a DF claim after the RRB and SSA are unable to reach an 

agreement through the JF reconciliation process or when a claim is awarded at the 

RRB appeal level (decisions completed by a hearings officer or the three-member 

Board).

Authorized RRB personnel attempt to reconcile differences in a JF decision with 

SSA. Unreconciled JF decisions are completed with DBD or Reconsideration 

Section supervisory or senior examiner signatory approval but without SSA 

countersigning the decision. 

NOTE: A courtesy copy of the administrative record and determination rationale are 

sent to SSA for DF claims awarded by a hearings officer or three-member Board 

only in the FI sample, as shown in DCM 6.7.3 D. 

6.2 Disability Insured Status For Freeze

6.2.1 Requirements For A Freeze

An employee qualifies for a freeze if all the following requirements are met:

A. Application, as explained in DCM 6.3.1

B. Freeze Insured Status, as explained in DCM 6.3.2

C. Disability Under the SS Act, as explained in DCM 6.3.3

D. Waiting Period, as explained in DCM 6.4.3

6.2.2 Using SS Disability Standards

For freeze decisions, the RRB follows statutory standards of the SS Act. The following 

technical standards and guides furnished by SSA are used.

Social security regulations

Program operations manual system (POMS)

Social security rulings-Disability
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6.3 Development And Evidence Requirements

6.3.1 Application

Disability freeze ratings (both grants and denials) are to be made in all disability cases, 

regardless of whether or not the rating will actually affect the annuity payment or the 

Medicare effective date. An application for a disability annuity is legally considered to 

be an application for a disability freeze also, and the claimant has the right to be notified 

of our decision in that regard. He/she also has reconsideration and appeals rights for 

the disability freeze decision which are described to him/her on the Form AB-32 

enclosed with the disability freeze notification letter.

EXCEPTION: The annuitant has the right to request that a disability freeze not be 

granted. This could occur for a number of reasons (e.g. employee and spouse would 

get better coverage under private insurance than under Medicare.) In such cases, have 

the field obtain a signed statement from the employee that all of the advantages of the 

freeze (early Medicare, O/M, possible tier 1 increase, tax advantage, possible survivor 

benefit increase) have been explained to him and that he still does not want to be rated 

for a disability freeze. Once the statement is received, do a technical denial of the 

disability freeze even if there is sufficient evidence to make a favorable decision. Make 

a notation in the remarks section of OLDDS that the DF was denied per employee’s 

request. Use RL-260c as a notification letter. This can be done even if the case would 

ordinarily be a joint freeze decision.

6.3.2 Freeze Insured Status

A disability insured status is established when an employee has at least 20 quarters of 

coverage (QC) in a period of 40 consecutive calendar quarters (10 years) ending with 

the quarter of the disability onset date.

In most cases, when the employee is also fully insured under the SS Act, the case must 

be adjudicated as a joint disability freeze (see DCM 6.7.3 for exceptions, RCM 5.6.11

for detailed explanation of disability insured status, and RCM 5.6.5 for detailed 

explanation of insured status under the SS Act). DCM 6 Appendix 5 shows how many 

QC's are required depending on the employee's age on the date of the disability, to be 

fully insured under the SS Act.

An employee who has a disability onset before the quarter in which (s)he attained age 

31, must have acquired QC's equal to one-half of the quarters that elapsed between the 

quarter after (s)he attained age 21 and the quarter before his disability began to receive 

a disability insured status.

For benefits payable 1-1973 or later, a statutorily blind worker does not need to meet a 

"20/40" or "disability before age 31" insured status test. In determining the number of 

QC's required for fully insured status, the individual must have at least one quarter of 

coverage for each year elapsing after 1950 (or, if later, the year in which (s)he attained 

age 21) up to the year in which the qualifying QC is earned. (There is a minimum 
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requirement of 6 QC's). Where the disability freeze does not begin with the quarter of 

onset, because insured status is not met at that point, it will begin in the first quarter 

thereafter in which fully insured status exists provided the wage earner is disabled in 

that quarter. (Fully insured status is determined as if the wage earner attained SS Act 

retirement age in that quarter.) This provision applies regardless of the age at which the 

individual is disabled.

A statutory blind wage earner who had a disability insured status before 1-1973 by 

reason of meeting the "20/40" or "disability before age 31" insured status requirement, 

in addition to having fully insured status, may have a disability freeze established 

beginning at an earlier date, based on fully insured status only, if (s)he files an 

application in or after 10-1972. Any increase in benefits due to the revised disability 

freeze can be effective no earlier than 1-1973.

6.3.3 Disability Definition Under SS Act

Disability means either:

A. Inability to engage in any substantial gainful activity (SGA) because of a 

medically determinable physical or mental impairment which can be expected to 

result in death or has lasted or can be expected to last for a continuous period of 

not less than 12 months. The physical or mental impairment(s) must be of such 

severity that the individual is not able to do his previous work and cannot, 

considering his age, education and work experience, engage in any other kind of 

SGA which exists in the national economy regardless of whether such work 

exists in the immediate area in which he lives, or whether a specific job vacancy 

exists for him, or whether he would be hired if he applies for work. The phrase 

"work which exists in the national economy" means work which exists in 

significant numbers either in the region where such individual lives or in several 

regions of the country; or

B. Statutory blindness, which is central visual acuity of 20/200 or worse in the better 

eye with the use of correcting lens. An eye which has a limitation in the field of 

vision such that the widest diameter of visual field subtends an angle no greater 

than twenty degrees shall be considered as having a central visual acuity of 

20/200 or less.

When the disability definition of blindness is met, the activity to engage in SGA 

will be disregarded for the purpose of the disability freeze only but not for 

Disability Insurance Benefits (DIB) purposes. This means that the wage record is 

preserved for purposes of insured status and PIA calculations from the time the 

medical criteria is met, but the person cannot receive cash benefits while SGA 

continues.

Blind applicants under age 55 must continue to meet the test of "inability to 

engage in any SGA (as shown in DM 6.3.3A) to become entitled to a DIB.
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6.3.4 Wage Record Development

Before making a disability freeze determination, the disability examiner will check the 

wage record from the Retirement Estimate Annuity Program (REAP) program for joint 

disability freeze cases and check the wage record on-line for single disability freeze 

cases. After viewing the REAP record, the examiner will send it directly to imaging. 

NOTE: Effective May 4, 2015, printing of wage records containing federal tax 

information (FTI) such as DEQY/SEQY records and report from The Work Number 

(TWN) is no longer allowed. These items should be imaged for documentation.

6.3.5 Social Security Act Application Requirements

A freeze or disability cash benefits cannot begin until an application for a disability 

determination under the SS Act is filed. An AA-1d is an application for a freeze and a 

DIB under the SS Act.

The filing date of the AA-1d is deemed to be the filing date with SSA in joint freeze 

decisions. (See Appendix B for deemed filing dates before September 7, 1958.)

If the period of disability has ended, the freeze may be established only if the application 

is filed by the earlier of:

A. 12 months following the month FRA is attained; or,

B. 14 months following the month the disability ceased.

Note: The 1967 SS Act amendments extended this period to 36 months after the end of 

the period of disability when failure to file was due to a physical or mental condition 

which prevented execution of an application.

If the employee died before filing, the application requirement for a freeze is met if a 

survivor files a disability application within 3 months after the month that the employee 

died.

6.3.6 Development Of The Disability Freeze (DF) RATING When A CDR Is Due

A disability application is not considered finalized until the disability freeze determination 

is completed. Therefore, DBD policy is that a disability freeze rating must be completed 

before a CDR determination can be made on the same case. In some instances, an 

examiner may have a case in which a disability freeze and a CDR (due to work) 

determination are both required. In these situations, the disability freeze decision should 

be done prior to the continuance decision.

This does not preclude the examiner from putting the disability annuity into suspense 

due to earnings or work activity. After the examiner puts the case into suspense for 
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earnings or work activity, the case should be developed for the disability freeze 

determination. Any information which may affect the continuance determination should 

also be used when making the disability freeze determination. For example, any work 

activity the annuitant may be involved in should be considered when making the 

disability freeze determination. If earnings above the SGA level are involved, the 

examiner should consider the possibility of a closed period of disability in the disability 

freeze determination.

A. Disability Freeze Denial Determination Made

If a disability freeze denial decision is rendered and the disability freeze denial 

letter released, the case should be routed to the dormant cabinet with a 60 day 

call-up pending a possible reconsideration request. When the case is pulled 

from the dormant cabinet, the CDR determination will be handled. If the 

annuitant requests a reconsideration of the disability freeze determination, route 

the case to the reconsideration section to handle the reconsideration decision 

before the CDR determination is made.

B. Disability Freeze Allowance Determination Made

If the examiner makes a disability freeze allowance determination, he/she should 

then develop for the CDR. However, if the reason for the CDR is due to earnings 

and/or work activity and the work/earnings are reconciled with the disability 

freeze allowance, the examiner should set an appropriate CDR call-up. 

NOTE: Code Paragraphs 2717, 2718 and 2719 are used in disability freeze 

denial letters to indicate that the employee's disability freeze is denied but there 

is no effect on the employee's annuity. These paragraphs cannot be used if the 

annuity has been put into suspense due to earnings and/or work activity. 

Therefore, a modified RL-260 letter should be used in cases where the annuity is 

in suspense.

Once the initial disability freeze determination is completed, applications for 

subsequent disability freeze determinations should be considered before the 

CDR if the application was filed prior to the CDR call-up date or earnings 

notification. If the CDR call-up date or earnings notification is prior to the filing 

date of the subsequent application for a disability freeze, the CDR should be 

conducted first.

6.3.7 Examiner’s Determining Residual Functional Capacity Assessments 

In certain single freeze cases, disability claims examiners have the latitude to render a 

decision based on a section of a treating source RFC or consultative examination RFC 

that is supported by the objective findings, even if the RFC in its entirety is not 

supported.

These single freeze cases require the following:
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• The claimant’s age to be 55 years or older at the time of the disability onset date,

• the physical RFC leads to a decision finding of a grant, and 

• the physical RFC from a treating source or consultative examination is supported by 

the objective findings based on the disability claims examiner's judgment. 

6.4 The Disability Freeze

6.4.1 Beginning Date For A Disability Freeze

The beginning date for a disability freeze (DF) is the first day within the effective period 

of the application on which an employee:

• Has a DF insured status (earnings requirement) (DCM 6.3.2); and,

• Is under a disability as defined in the SS Act (medical requirement) (DCM 6.3.3). 

Normally, the beginning date for a DF will be the actual date of onset. Where the 

employee is not fully insured until a later quarter, the DF will begin on the first day of the 

quarter in which a DF insured status is acquired. (However, Medicare coverage based 

on age begins at age 65, regardless of FRA.)

EXAMPLE: A RR employee met the SS Act disability requirement in August 2011 

but had only 19 quarters of coverage (QC) in the 40 calendar quarter period ending 

in September 2011 (i.e. the calendar quarter of onset). He was paid sufficient 

vacation allowance in the next succeeding calendar quarter (i.e. calendar quarter 

beginning October 2011) which would give him the required 20 QC’s. Therefore, the 

qualifying QC requirement for the DF is met on the first day of the calendar quarter 

in which he was paid the vacation allowance which gave him the required 20 QC’s. 

Accordingly, he met both the medical and earnings requirements on October 1, 

2011, and that date is the beginning date of the DF.

Beginning in January 1973, an employee must be disabled for a continuous period of 

not less than 5 full calendar months (i.e. the waiting period) before a DF can be 

established. (Prior to January 1973, the requirement was 6 full months. Therefore, a 

DF will always be at least 5 months.) As long as the waiting period requirements are 

met, a DF rating can be completed. If the waiting period requirements are not met, the 

DF claim must be technically denied.

 

EXCEPTION: If an employee qualifies for a DIB without a waiting period

(DCM 6.4.4), he would qualify for a DF for any month he is entitled to a DIB, even as 

short as 1 calendar month.

A DF cannot begin at full retirement age (FRA) or later. However as long as:
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• An application was filed within 12 months following the month after the RR 

employee attained FRA (DCM 6.3.5), and

• The RR employee meets the definition of disability under the SS Act (DCM 6.3.3

), and

• The RR employee fulfills the waiting period requirement (DCM 6.4.3),

the rating can be completed. If the waiting period requirement cannot be met before 

FRA was attained and a previous DF period did not end within 60 months of the earliest 

possible date that disability under the SS Act could begin as a result of the current 

application, the claim does not require a formal disability determination and should be 

technically denied.

EXAMPLE: Joe’s previous disability for DF purposes terminated December 31, 

2000 as a result of returning to work. While working, he injured himself on January 

15, 2008 and could no longer perform past relevant work. However, his employer 

allowed him to perform light duty work. He attained FRA on February 15, 2008 and 

his employer laid him off on March 31, 2008. Since he could not find another job, he 

finally filed an application for disability on November 1, 2008 claiming an onset date 

of January 15, 2008.

Presuming the medical evidence cannot establish an onset date any earlier than 

January 15, 2008, Joe’s claim would have to be technically denied. Since Joe’s 

previous DF period ended more than 60 months prior to the earliest possible date of 

current disability, he must meet the DF waiting period requirement. However, since 

he was not disabled for 5 months prior to FRA, his claim must be technically denied.

In cases in which a DF has previously been denied, and does not meet the criteria for 

re-opening, and the reconsideration period has passed, the onset date of the new 

decision cannot be prior to the date of the previous decision. For purposes of setting 

the onset date of the new decision, the date of the previous decision is either:

• The date the physician/medical specialist signed the SSA-831 in joint freeze cases. 

• The date the reviewer signed the OLDDS decision for single freeze cases or 

unilateral freeze cases. 

NOTE: The date of the previous DF denial letter is used for reconsideration and reopening purposes, but not for the purposes of setting an onset date.

6.4.2 Ending Date For A Disability Freeze

The ending date for a period of disability is the earliest of:

• The last day of the month in which the worker dies.

• The last day of the month preceding the month in which the worker attains FRA.
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• The last day of the second month after the month in which the disability ceases.

When determining a disability cessation date, the trial work period does not apply to the 

freeze unless the worker is also entitled to:

• A DIB under the SS Act; or,

• The DIB O/M under the Railroad Retirement Act (RR Act), even if it does not 

apply.

6.4.3 Waiting Period

Before payments based on a disability freeze in accordance with the SS Act can be 

awarded or before entitlement to Medicare benefits can begin prior to age 65, the 

waiting periods of 5 full months for a disability freeze and 24 months after the ABD or 29 

months after the disability onset date for Medicare entitlement must be met. 

HOWEVER, THE DISABILITY FREEZE RATING DETERMINATION CAN BE MADE 

BEFORE THE DISABILITY FREEZE WAITING PERIOD IS SERVED.

DISABILITY FREEZE ONSET - The waiting period begins with the first full calendar 

month after the date of disability onset, if onset is not on the first day of the month, 

during which the person met disability freeze-insured requirements.

Although the waiting period is counted in full calendar months, a disability freeze may 

begin on the day onset is determined to have occurred even if it is not the first day of 

the waiting period, provided insured status requirements are met on that day.

6.4.4 Waiting Period Not Required

A waiting period is not required if a previous freeze or DIB ended within 60 months 

before the month the current disability began. In this situation a freeze will exist for any 

month there is DIB entitlement. Refer to RCM 3.2.22 for additional information and 

instructions.

The 60-month period begins with the month in which the prior disability freeze ceased or 

DIB terminated and ends with the month before the first full month the worker is under a 

disability.

Therefore, when the current disability begins on the first day of a month, the 60-month 

period ends with the preceding month; if it begins on other than the first day of the 

month, the 60-month period ends with the month in which the current disability began.

If the worker does not have DIB insured status in the month his current disability begins, 

he is not eligible for a DIB until the first month in which he has an insured status. 

Consequently, more than 5 years may elapse between the end of his previous disability 

and the first month of his current period of DIB entitlement, but no waiting period is 

required if the current disability began within the 60-month period. 
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6.4.5 Felony Conviction Provisions That Affect Disability Freeze Determinations

P.L. 96-473 contains provisions which imposed restrictions on SSA title II disability 

determinations and payments to prisoners who are convicted of an offense punishable 

by imprisonment for more than one year, regardless of the actual sentence imposed. 

(For purposes of this procedure, the word “felony” is used interchangeably with an 

offense punishable by imprisonment for more than one year.) These restrictions affect 

disability freeze determinations. Sub-sections A and B discuss the two situations where 

the prisoner conviction provisions can affect a disability determination. Sub-section A 

will affect the disability freeze determination while sub-section B will not. Subsection C 

consists of definitions explaining the concepts involved in this law. Additional 

information about prisoner conviction cases can be found in RCM 6.3.7. 

A. "Permanent Disregard" of Felony-Related Determinations - An impairment(s) 

arising or aggravated (but only to the extent of the aggravation) in connection 

with the commission of an offense is to be permanently disregarded for disability 

freeze purposes. This applies only for offenses committed after October 19, 

1980, and for which the claimant has been subsequently convicted. It is not 

necessary that there be a causative connection between the commission of the 

offense and the impairment, but is must be closely related to, or associated with, 

the commission of the offense. The impairment or aggravation of a pre-existing 

impairment must occur at a time and location that is near to the offense. 

EXAMPLES:

An impairment arising from an automobile accident which occurred while fleeing 

the scene of an offense, such as a bank robbery, would be considered 

associated with the commission of the offense.

An impairment arising from an automobile accident a week after the bank 

robbery (e.g., a car runs a red light and runs into the robber's car injuring the 

robber; the police find the stolen money in the car and charge the robber with a 

felony), would be too remote to be considered to have arisen in connection with 

the robbery. This accident ordinarily would not be considered sufficiently close in 

time and place to the scene of the robbery to be considered associated with the 

offense. 

Since the permanent disregard of an impairment or aggravation of a pre-existing 

impairment incurred in the commission of a felony hinges on the individual's 

subsequent conviction, there may be claims allowed considering all the medical 

evidence in which the person has been charged with but not convicted of a 

felony. Thus, in a case where benefits were allowed on the basis of an 

impairment which may arise, or aggravation of a pre-existing impairment incurred 

in connection with the commission of a felony, the subsequent conviction of the 

individual for that offense could affect the earlier award.
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In such a case of subsequent conviction, DBD will reevaluate the original 

disability freeze decision to exclude any such impairments or aggravations. If the 

disability freeze is then denied because of this exclusion, the increased benefits, 

if any, paid under the original award will be considered overpayments. 

Conversely, a denial because of disregard of an impairment(s) connected with a 

felony may be reopened under the rules of administrative finality in the event the 

felony conviction is subsequently overturned.

B. "Temporary Disregard" of Impairments Connected with Confinement - For any 

month during which the individual is confined, any impairment which arises, or 

the aggravation of an impairment which occurs, in connection with an individual's 

confinement due to conviction of an offense committed after October 19, 1980, 

must be disregarded in determining whether the individual is under a disability for 

purposes of benefits payable.

Impairments connected with confinement cannot be considered in determining 

disability for the payment of benefits for any month during confinement. 

However, this provision does not preclude consideration of confinement-related 

impairments for purposes of establishing a disability freeze. 

Thus, DBD may use these impairments to establish a disability freeze for a 

claimant. (The disability freeze provision does not apply to Child Disabled Benefit 

(CDB) and Disabled Widow Benefit (DWB) applicants.)

C. Definitions

1. CONFINED

An individual who is under a sentence of confinement, pursuant to a 

conviction, to a jail, or other penal institution or correctional facility, 

including any facility which is under the control and jurisdiction of the 

agency in charge of the penal system, or any facility in which convicted 

criminals can be incarcerated, is considered confined.

2. COURT OF LAW

Any duly constituted judicial tribunal administering the laws of the State or 

nation is a court of law.

3. FELONY

A crime is a felony if it is an offense which constitutes a felony under 

applicable law. However, some legal jurisdictions, such as the State of 

New Jersey, the U.S. military under the Uniform Code of Military Justice, 

and some foreign countries, do not classify any crime as a felony.

In jurisdictions such as the above, an offense punishable by death or 

imprisonment for a term exceeding 1 year will be considered a felony for 
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purposes of this procedure. As a general rule, if an individual has been 

sentenced for a term of more than a year for conviction of an offense, 

correctional authorities consider that individual to be a felon.

4. PENAL INSTITUTION OR CORRECTIONAL FACILITY

In general, penal institutions or correctional facilities are those facilities 

which are under the control and jurisdiction of the governmental agency in 

charge of the penal system, or are facilities in which convicted criminals 

are incarcerated, such as a hospital for the criminally insane.

6.4.6 Disability Freeze Notices

Disability freeze (DF) notices in the RL-210 series (RL-210, RL-210b, RL-210c, and RL210d) and the RL-260 series (RL-260, RL-260a, RL-260b. RL-260c, and RL-260d) are 

found on RRAILS. These letters can also be accessed through D-BRIEF. The RL-210 

series is used when the DF decision is a grant. The RL-260 series is used when the DF

decision is a denial. A copy of the letter is filed in the annuitant’s claim folder and sent 

to imaging. Form AB-32 is sent with every letter. In joint freeze (JF) decisions, an SSA 

letter must be sent in addition to the letter from the RL-210 or RL-260 series in most 

instances.

Most letters contain inserts as do some of the commonly used code paragraphs. Some 

of the letters may contain pop-ups or drop-downs. The letters do not contain “edits” that 

ensure completion of inserts, drop-downs, etc. Therefore, you must tab through the 

letter from the beginning to see all of the places that choices or inserts are needed. 

However, when typing in an unprotected area, use the mouse to enter and exit the 

unprotected area.

It is important to proof read every letter before it is sent to imaging and released. If the 

letter is to a rep payee, you must change the pronouns in any codes paragraphs used 

from “you/your” to “he/she/his/her.”

This chapter describes the situations in which each letter is used.

6.4.6.1 The Single Freeze OR Unilateral Freeze Decision is a Grant

A. Complete a RL-210 when: 

• the DF onset date is the same or later than annuity onset date, and 

• there is either no Medicare based on Social Security (SS) entitlement or the SS 

Medicare effective date is the same as or later than the RRA Medicare effective 

date. (The information that can be used to calculate a Medicare effective date 

based on SS benefits can be found on PREH Screen 3206, which gives the SSA 

disability entitlement date and the SSA disability onset date.) 
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There are 2 date inserts on the RL-210: the DF onset date and the RRB Medicare 

effective date.

B. Complete a RL-210b when: 

• the DF onset date is earlier than the annuity onset date (initial annuity decision 

and DF decision are not simultaneous), and 

• the annuity onset date is being changed to match the DF onset date.

There are two date inserts in the RL-210b: the DF onset date and the Medicare 

effective date. 

C. Complete a RL-210d when: 

• the DF onset date is the same or later than annuity onset date, and 

• the employee is entitled to a Medicare effective date based on SS entitlement 

that is earlier than the Medicare effective date based on RR ABD and onset date. 

(The information that can be used to calculate a Medicare effective date based 

on SS benefits can be found on PREH Screen 3206, which gives the SSA 

disability entitlement date and the SSA disability onset date.)

There are two date inserts in the RL-210d: the DF onset date and the Medicare 

effective date. Use SSA’s Medicare effective date.

6.4.6.2 The Single Freeze OR Unilateral Freeze Decision is a Denial

A. Complete a RL-260 when the DF is denied for failure to meet the medical 

requirement.

B. Complete a RL-260a when: 

• the DF is denied for failure to meet the earnings requirement, and 

• there is no Medicare entitlement. 

While you are tabbing through the letter on RRAILS, 

• a pop-up will appear with the following question: “Claimed onset after DLI?” 

(DLI: Date Last Insured) If the alleged disability onset date is earlier than the 

actual disability onset date and the claimant did not have an insured status in the 

alleged onset date quarter, answer “yes”. Otherwise, answer “no”. 

• another pop-up will appear asking for either the alleged onset date or the annuity 

onset date
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• Another pop-up will appear with the following question: “Is this letter being sent 

to a third party?” If you answer “yes” to this question, you will also get a pop-up 

that says: “Is the claimant male?” 

• After you have answered the pop-ups, continue tabbing through the letter to 

move through the gray boxes that require additional entries. 

If you answer “yes” to the question about the claimed onset after the DLI, code 

paragraph 2714 (see RCM 10.5.170.2714) will be inserted in the letter. If you 

answer “no”, code paragraph 2715 (see RCM 10.5.170.2715) will be inserted in the 

letter. If the alleged disability onset date is earlier than the actual disability onset 

date and the claimant did not have an insured status in that quarter, answer “yes” to 

insert code paragraph 2714 in the letter. Otherwise, answer “no” to insert code 

paragraph 2715. 

There are 3 date inserts for code paragraph 2714: the alleged disability onset date, 

the first day of the first month of the calendar quarter in which the alleged disability

onset date occurs, and the last day of the last month of the calendar quarter in which 

the claimant is last insured. A pop-up will ask you for the alleged onset date, but the 

other dates must be entered manually into the body of the letter.

EXAMPLE : The alleged disability onset date is February 12, 2003 and the 

claimant was last insured in the second quarter of 2000. The date inserts would 

be February 12, 2003, January 1, 2003, and June 30, 2000. 

There are 3 date inserts for code paragraph 2715: the actual disability onset date, 

the first day of the first month of the calendar quarter in which the actual disability 

onset date occurs, and the last day of the last month of the calendar quarter in which 

the claimant is last insured. A pop-up will ask you for the annuity onset date, but the 

other dates must be entered manually into the body of the letter.

EXAMPLE: The actual disability onset date is May 12, 2003 and the claimant 

was last insured in the first quarter of 2000. The date inserts would be May 12, 

2003, April 1, 2003, and March 31, 2000.

After you have tabbed to and filled in all of the dates, press the tab key again. A 

pop-up will appear asking if you wish to open Form AB-32. After you have 

answered, another pop-up will appear that offers a selection of the following code 

paragraphs: 4000, 4001, 4002, and 4003. If you answered “no” to the question 

“Claimed onset after DLI?”, select one of the first three paragraphs (4000, 4001, or 

4002) and code paragraph 4003. Code paragraphs 4000, 4001, and 4002 require 

date inserts and code paragraph 4003 requires the list of medical records used in 

the decision. Bear in mind, that if the letter is to a rep payee or third party, you will 

need to manually change the pronouns “you” and “your” to “he/she” or “his/her” in 

the code paragraphs. 
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Following these paragraphs, there is an unprotected area for free form typing. Other 

code paragraphs can be accessed by pressing Ctrl/Shift/F4. 

C. Complete a RL-260b when: 

• the DF is denied for failure to meet the earnings requirement, and 

• there is Medicare entitlement. Medicare entitlement can be established when the 

1974 Act provisions apply (see DCM 6.8.1) or when government employment 

can be used as quarters of coverage (see DCM 6.8.2).

While you are tabbing through the letter on RRAILS, 

• a pop-up will appear asking: “Claimed onset after DLI?” If the alleged disability 

onset date is earlier than the actual disability onset date and the claimant did not 

have an insured status in the alleged onset date quarter, answer “yes”. 

Otherwise, answer “no”. 

• Another pop-up will appear with the following question: “Is this letter being sent 

to a third party?” If you answer “yes” to this question, you will also get a pop-up 

that says: “Is the claimant male?” 

• After you have answered the pop-ups, continue tabbing through the letter to 

move through the gray boxes that require additional entries. 

There are 4 date inserts for the RL-260b: the disability onset date or the alleged 

onset date, the Medicare effective date, the first day of the first month of the 

calendar quarter in which the disability onset date occurs, and the last day of the last 

month of the calendar quarter in which the claimant is last insured. A pop-up will ask 

you for the alleged onset date or the annuity onset date, but the other dates must be 

entered manually into the body of the letter.

EXAMPLE: The disability onset date is May 12, 2003, the ABD is November 1, 

2003, and the claimant was last insured in the first quarter of 2000. The date

inserts would be May 12, 2003, November 1, 2005, April 1, 2003, and March 31, 

2000.

After you have tabbed to and filled in all of the dates, press the tab key again. A 

pop-up will appear asking if you wish to open Form AB-32. After you have 

answered, another pop-up will appear that offers a selection of the following code 

paragraphs: 4000, 4001, 4002, and 4003. If you answered “no” to the question 

“Claimed onset after DLI?”, select one of the first three paragraphs (4000, 4001, or 

4002) and code paragraph 4003. Code paragraphs 4000, 4001, and 4002 require 

date inserts and code paragraph 4003 requires the list of medical records used in 

the decision. Bear in mind, that if the letter is to a rep payee or third party, you will 

need to manually change the pronouns “you” and “your” to “he/she” and “his/her” in 

the code paragraphs.
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Following these paragraphs, there is an unprotected area for free form typing. Other 

code paragraphs can be accessed by pressing Ctrl/Shift/F4. 

D. Complete a RL-260c when the employee has submitted a statement that he does 

not want to be considered for a DF. There is one date insert in this letter: the date 

of the statement.

E. Complete a RL-260d in cases with a filing date of January 1, 2008 or later when the 

total and permanent annuity rating is based on alcoholism or drug addiction (see 

DCM 4.8.4) and no other impairment is severe enough to be a grant for the DF. (For 

occupational annuity cases, use the RL-260.) There is one date insert in this letter: 

the annuity onset date.

NOTE: If you access letters in the RL-260 series from D-BRIEF rather than from 

RRAILS, you will not get a pop-up asking if the letter is to a third party or if the claimant 

is male. The correct pronouns will be pre-filled from D-BRIEF.

6.4.6.3 The Joint Freeze Decision is a Grant

A. Complete a RL-210 when: 

• there is agreement between RR and SS about the DF onset date, and 

• the DF onset date is the same or later than annuity onset date. 

If the person does not have a DF insured status (DCM 6.3.2), also send a SSA-L810

and enclose SSA Publication No. 05-10058, Your Right To Question The Decision 

Made On Your Claim. 

B. Complete a RL-210b when: 

• there is agreement between RR and SS about the DF onset date, and 

• the DF onset date is earlier than annuity onset date, and the annuity onset date 

is being changed to match the DF onset date. 

If the person does not have a DF insured status (DCM 6.3.2), also send a SSA-L810

and enclose SSA Publication No. 05-10058, Your Right To Question The Decision 

Made On Your Claim. 

C. Complete a RL-210c when there is disagreement between RR and SS about the DF

onset date. If the person does not have a DF insured status (DCM 6.3.2), also send 

a SSA-L810 and enclose SSA Publication No. 05-10058, Your Right To Question 

The Decision Made On Your Claim. 
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6.4.6.4 The Joint Freeze Decision is a Denial

Complete a RL-260 and SSA-L813.1 and enclose SSA Publication No. 05-10058, Your 

Right To Question The Decision Made On Your Claim. 

6.5 RRB/SSA Coordination

6.5.1 General Guidelines

In order to properly coordinate disability decisions, SSA and RRB must exchange 

medical evidence and wage records, review medical decisions, settle/reconcile

disagreements about disability decisions, and institute an authorization process for 

certain types of disability freeze (DF) cases. All attempts to coordinate RRB/SSA 

claims shall be made to help limit or prevent different decisions from being effectuated 

and to avoid duplication of development of evidence. The RRB prepares and signs 

railroad (RR) disability determinations for career RR workers or the dependents of 

deceased career RR workers and SSA prepares and signs Social Security 

determinations for the same claimants. Coordination of decisions is based on a signed 

Memorandum of Understanding (MOU) between both agencies. Each agency has 

mutually agreed to share evidence which it has obtained.

A. Disability Freeze Decisions

Independent DF decisions made by either SSA or RRB are not binding on the other 

agency. However, joint freeze (JF) decisions completed at the initial and reconsideration 

levels of adjudication are. See DCM 6.7.3 when a JF is to be completed. See 

DCM 6.7.4 for JF processing procedure. 

Where all aspects of JF decisions are coordinated between SSA and DBD, independent 

single freeze (SF) decisions are not required to be coordinated although each agency 

has agreed to furnish required information about disability decisions made for RR 

employees. See DCM 6.6.4 for DBD examiner or Reconsideration Section handling of 

a SF.

If both agencies are unable to reach an agreement on a JF decision through the 

coordination and reconciliation processes or when a claim is awarded at the RRB 

appeal level (DCM 6.1.3 C), the RRB will complete a unilateral freeze decision. 

Unilateral freeze decisions completed by a DBD-DPS examiner require supervisory or 

senior examiner signatory approval. Unilateral freeze decisions completed by a 

Reconsideration Section specialist require signatory approval by a second specialist. 

See DCM 6.7.4 for DBD or Reconsideration Section handling of a unilateral freeze. 

6.5.2 Coordination Actions

When a disability application is filed at the RRB, the TRIC request made for the 

application will earmark the SS record. SSA takes no action on the earmark unless they 

have a pending application.
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If our disability application or other evidence in file indicated that the claimant also filed 

for a DIB or SSI benefits, the field office will request, by Form RR-5, the medical 

evidence and decision from SSA's Disability Program Branch (DPB) to be sent directly 

to DBD. DBD will either telephone (only when a case must be expedited) or use Form 

RR-5 to request this information from DPB when the field office has not released a Form 

RR-5 request. The RR-5 is either sent to:

Disability Program Branch

Great Lakes Program Service Center

Social Security Administration

Post Office Box 87755

Chicago, Illinois 60680

Or, the request can be sent by email with the RR-5 as an attachment to 

CHI.ARC.PCO.DPB@ssa.gov. Type “RR-5” in the subject line. Do not include the SSA 

disability examiner’s name, claimant’s name, social security number, or other personally 

identifiable information in the subject line. If known, type the name of the SSA disability 

examiner who is assigned these terminal digits and the full claim number in the body of 

the email.

If, upon examination of the SSA evidence, the disability rating examiner cannot reach a 

disability decision under section 2(a)(1)(v) that is consistent with the disability 

determination previously made by SSA, the rating examiner should refer the case to the 

supervisor or senior examiner. (S)he will decide on what further action, if any, should 

be taken to reconcile the conflict in the disability determination.

If DBD receives an application for a disability annuity and it is determined that the 

employee has less than 120 RR service months and less than 60 RR service months 

after 1995, the application and pertinent claims material are transferred to SSA.

When a disability application is filed at SSA, DPB will query their systems to determine 

service months when their applicant indicates railroad service. If 120 months of RR 

service or 60 months after 1995 are verified, DPB will furnish DBD with the claim 

number and request medical evidence. We reply with Form RL-34b the status of claims 

activity at DBD. SSA will transmit information on their decision with Form SSA-415. 

DBD will review the SSA decision. If the file indicates a disability rating allowance under 

the RR Act can be made, use G-239 to secure an application from the career RR 

employee if one has not been filed.

6.6 Single Freeze Determinations and Simultaneous Ratings

6.6.1 Definitions and General Program Policy

A simultaneous disability annuity (D/A) rating and a disability freeze (DF) rating should 

be completed except when DBD management has advised that simultaneous D/A and 

DF ratings should not be completed due to DBD workload or other agency 

considerations. This would occur in both single freeze (SF) cases and “no conflict” 
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cases. SF cases are those disability claims filed at the RRB by or on behalf of career 

railroad employees where there is little to no potential for social security benefits ever 

being paid. The DF rating for these cases can be made by the RRB alone. “No conflict” 

cases are those in which SSA has already made a disability decision which we have 

reviewed and concur with the medical determination, vocational determination, and 

onset date. “No conflict” case decisions “adopted” by the RRB are handled as a SF 

because a claim for DF was already filed at SSA.

HOWEVER, DO NOT DELAY THE AWARD OF D/A FOR DEVELOPMENT OF 

ADDITIONAL EVIDENCE OR INFORMATION NEEDED FOR A DF DECISION. 

The annuitant has the right to request that a DF not be granted. (See DCM 6.3.1) 

When the claim for a D/A is denied, the DF is automatically and concurrently denied. If 

a previously denied D/A is reopened and revised to an allowance, the DF determination 

must also be reconsidered by completion of G-325 or an SSA-831, even if the decision 

will still be a denial.

6.6.2 When Simultaneous D/A And DF Decisions Cannot Be Made

A simultaneous rating cannot be made in the following cases:

A joint freeze determination is required. (See DCM 6.7.3) 

Additional medical evidence (M/E) is required because M/E that was obtained in support 

of the employee's D/A rating is not adequate for making a disability freeze 

determination.

SS wage data has not been received and such record is required. (E/R of employee has 

an "SS" indication.)

Additional vocational information is required about a claimant's non-railroad work for 

making a disability freeze determination when the decision is based on both medical 

and vocational factors.

6.6.3 Actions By DPS To Determine Whether Applicant Has QC

A. As of Alleged Quarter of Disability (AQD) - First determine whether the applicant 

meets the insured status test as of the AQD (i.e., the quarter in which he became 

unable to work) based on the filing or deemed filing date of the disability freeze 

application. If the applicant does not have a 20/40 insured status, as of the AQD, 

see whether he has the qualifying QC's after or before the AQD. When making 

the appropriate test, keep in mind when a disability freeze recalculation is 

applicable, and when DIB entitlement could otherwise begin.

B. After the AQD but Not in Alleged Quarter - An applicant who has insufficient 

earnings when first disabled may be eligible for a disability freeze period if he 

meets the qualifying QC requirement after the onset of his impairment. In such 
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cases, the disability freeze period begins on the first day of the quarter in which 

the qualifying QC requirement is met.

If an employee has only 19 quarters in the 40-quarter period ending in the AQD, 

and was paid sufficient vacation allowance in the next succeeding quarter which 

could give him the required 20 QC's, he would meet the qualifying QC 

requirement for disability freeze on the first day of the quarter he was paid the 

vacation allowance. However, if he was awarded a D/A which began to accrue 

on or before the date he was paid the vacation allowance, that quarter cannot be 

used to meet the qualifying QC for disability freeze, unless his annuity is recertified to begin on the date following the last day for which he was paid the 

vacation allowance. In such a case, the annuity payments previously made to 

him are erroneous.

If an employee has insufficient quarters in the 40-quarter period ending in the 

AQD, and was paid miscellaneous compensation in a period which could give 

him the required 20 QC's, the miscellaneous compensation can be used to give 

the required QC’s.

This is also true, if an employee is receiving regular compensation that does not 

provide a service month in a period which could give him the required 20 QC’s. 

The regular compensation can be used to provide the required QC’s.

C. Before AQD But Not In or After That Quarter - Even when it appears that the 

qualifying QC requirement cannot be satisfied at any time in or after the alleged 

quarter in which disability occurred, the applicant may be eligible for a disability 

freeze if he had the necessary qualifying QC at some point before the AQD. This 

is so because the actual date of disability may have been much earlier than that 

alleged. This actual date cannot ordinarily be established until medical 

development and examination have been completed.

If the applicant appears to have the qualifying QC at some point earlier than the 

alleged date of onset of his disability, and the earnings record (E/R) indicates that 

his earnings ceased before the alleged date, it is possible that the date of onset 

was incorrectly stated by the applicant. However, it is also possible that the 

applicant was merely unemployed or engaged in work not covered by the RR Act 

or the SS Act. In such cases, the disability examiner considers the merits of the 

applicant's explanation given on Form AA-1d and decides whether medical 

development should be undertaken to determine whether the applicant was 

unable to engage in any SGA in or after the quarter in which he had the 

qualifying QC.

D. Development When Applicant Does Not Appear to Have Qualifying QC in or After 

AQD - When the applicant apparently does not meet the qualifying QC 

requirement either in or after the quarter when alleged disability began, compare 

his allegations of his work history with his reported earnings. Assume that the 

E/R is correct unless development on the basis of any conflicting allegations of 
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the applicant proves it to be incorrect. If the applicant alleges employment or SE 

not reflected by the earnings data and such work would be sufficient to establish 

the necessary qualifying QC, it should be investigated. No further action should 

be taken with respect to the application for a disability freeze until the question is 

resolved.

E. Explanation of Earnings After AQD - When the applicant has the qualifying QC 

as of the AQD and the E/R shows that he has earnings after the quarter in which 

the disability allegedly began, the earnings reported for periods after the AQD, 

should be satisfactorily explained on Form AA-1d completed by the applicant as 

to whether the amounts reported after the AQD are special payments (sick pay, 

vacation pay, bonuses, etc.), or payments for services actually rendered after the 

AQD.

F. Determining QC's at RRB January 1, 1978 or Later - Effective January 1978, a 

QC is based on yearly earnings and is not assigned to a specific calendar quarter 

in the year. For calendar years 1978 or later, the amount of earnings required for 

a worker to be credited with a QC is written into the SS Act and will be adjusted 

each year with the rise in average wage levels (see RCM 5.6.18). Therefore, 

even though an employee may only have worked in one quarter in a particular 

year, the employee may be credited up to 4 QCs if his earnings are high enough.

6.6.4 Making Single Freeze Decisions

Single Freeze (SF) decisions are not coordinated with the Social Security Administration 

(SSA) and may be completed by DBD examiners or Reconsideration specialists using 

the following process:

A. DBD Handling

1. Distribution of Incoming Claims

Cases are generally distributed to and adjudicated by DBD examiners according 

to terminal digits. 

2. Adjudication and Evidence Development

Adjudicators review the evidence in file and, when necessary, take appropriate 

actions to develop for sufficient evidence needed to make a reasonable disability 

decision. Actions include but are not limited to development of: pertinent 

medical and non-medical evidence, vocational reports, earnings record 

(DCM 6.3.4), application forms, activities of daily living, and medical consultant’s 

opinion (MO).

See DCM 4.10.13 for information regarding the age of medical evidence in SF 

cases. 
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NOTE 1: Adjudicating personnel must check to see if an application for Disability 

Insurance Benefits (DIB; Title II) or Supplemental Security Income (SSI; Title 

XVI) was already filed at SSA. Indications that a disability application was filed at 

SSA can be found in/on:

• Form AA-1 (APPLE and paper);

• Form AA-1d;

• SSA Master Benefit Record (MBR);

• SSI Record;

• DATAQ;

• DEQY (if already in file or in imaging); and

• Contact Log.

Adjudicators can request a MBR, SSI record, and DEQY from RRB personnel 

who have been authorized by SSA to access their system. Instructions how to 

read a MBR can be found in POMS SM 00510. Instructions how to read a SSI 

record can be found in POMS SM 01601. Adjudicators can also request a report 

from The Work Number (TWN); see DCM 3.4.205.

NOTE 2: Medical evidence of record may conclusively show that the severity of 

a RR employee’s impairment or combination of impairments is medically 

disabling without considering his or her age, education, or work experience. 

Examples include but are not limited to: a biopsy report indicating that the 

claimant has been diagnosed with small-cell (oat cell) carcinoma of the lung; the 

claimant suffering amputations of both hands; the claimant who has received a 

lung or liver transplant and the case is being completed within 12 months of the 

transplant surgery. The severity of any medically-documented impairment(s) 

included in the Listing of Impairments (DCM 4.12; POMS DI 34001.000), as 

issued by SSA, is considered medically disabling.

In addition, a RR employee may have a medically-documented terminal illness 

(TERI) or a medical condition in SSA’s Compassionate Allowance (CAL) list. An 

illness which is generally considered terminal or a medical condition in the CAL 

list (DCM 3.4.100) indicates a high probability that the RR employee is disabled. 

Presuming that there is no other conflicting medical evidence in file which would 

lead one to question whether the severity of an impairment(s) is medically 

disabling as shown in the SSA Listing of Impairments, situations such as these 

do not require a MO and DBD-DIS or DPS examiners and Reconsideration 

specialists have the latitude to complete SF decisions without the MO. A case 
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tagged as a TERI or CAL claim (DCM 3.4.100) has no bearing on this decision, 

although it may be an indication that a MO may not be needed.

As a general rule of thumb, however, if a medical judgment by a licensed 

physician or psychologist is required to determine whether the severity of an 

impairment(s) is medically disabling, a MO must be obtained. (See DCM 4.11.1

through 4.11.4).

NOTE 3: Any case in the Financial Interchange (FI) sample (DCM 6.7.3 D) must 

always be recorded into the RRB systems as either a joint freeze or unilateral 

freeze, even if an application for DIB or SSI was already filed at SSA.

3. Administrative Actions Before Authorization

After reviewing all of the information and coming to a determination, the 

examiner:

a. Composes a rationale (D-Brief G-325B if completing a concurrent D/A and SF 

decision; RRAILS G-325.1 if completing a SF only decision). (See DCM 5.1.6

) 

The rationale must be sent to the imaging authorization folder if the decision 

requires authorization.

b. Completes the appropriate OLDDS G-325 screen entries (see DCM 12.1.4).

NOTE: If a SF allowance ALSO allows an earlier D/A onset date, a single 

OLDDS entry may be completed on the same day.

c. Composes the appropriate RRAILS RL-210 series or RL-260 series letter. 

(See DCM 6.4.6).

The letter must be sent to the imaging authorization folder if the decision 

requires authorization.

d. If necessary, sets an appropriate CDR call-up (see DCM 8.5.2 and 8.5.3). 

e. If required, submits the case for authorization. 

NOTE: Printouts of the G-325 OLDDS screens, G-325B or G-325.1 rationale, 

and, if applicable, CDR call-up sheet are to be filed on the left side of the claims 

folder by the rating examiner. 

4. Authorization Process (IF NECESSARY)

Follow the instructions in DCM 3.4.302. 

When all is complete, the claims folder is sent to:
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• Claim Files, if the SF is allowed EXCEPT when a DF has been granted for 

a deceased railroad employee (DCM 6.9.1).

• Reconsideration Section, if the SF is denied.

NOTE 1: See DCM 3.4.300 and 3.4.301 for general information about the 

authorization process in DBD and Reconsideration Section.

NOTE 2: Simultaneous disability annuity (D/A) and SF ratings should be 

completed except when DBD management has advised that simultaneous D/A 

and SF ratings should not be completed due to DBD workload or other agency 

considerations. 

If D/A and SF ratings are authorized simultaneously, the SF determination letter 

shall NOT be released at the same time as the D/A determination letter. Rather, 

the claims folder will be held in AFCS location T0SP until the D/A award has 

been paid partial or final by the RRB. The SF determination letter will be 

released after the D/A has paid partial or final by appropriate DBD personnel. 

In addition, SF-only decisions (i.e. SF decisions which are not rated 

simultaneously with a D/A decision) must not be authorized on OLDDS and the 

SF determination letter shall not be released until the D/A award has been paid 

partial or final by the RRB. 

NOTE 3: DBD examiners and authorizers are both responsible to proofread the 

disability determination letter for the correct name and address, accurate content, 

and proper grammar before it is sent to the imaging authorization folder (or 

released to the claimant and imaging system if the decision does not require 

authorization by another examiner).

B. Reconsideration Section Handling

1. Incoming Claims and Distribution

DBD sends claims folders to the Reconsideration Section at the time that an 

individual is rated not disabled for a SF in anticipation of a possible request for 

reconsideration.

Incoming requests for reconsideration of a wholly or partially unfavorable SF 

determination are screened to determine if the request was made timely. Timely 

requests are logged into USTAR (FOM1 15120) and a letter acknowledging 

receipt of the request is released. A USTAR tracking sheet is printed and 

attached to the request and claims folder. (Claims folders not already in the 

Reconsideration Section are obtained). 

Requests for reconsideration are distributed to Reconsideration specialists by

date of receipt, the oldest requests being distributed first, except when there is 

special (i.e. Congressional, Board member, etc) interest.
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2. Adjudication and Evidence Development

See DCM 6.4.4 A.2

3. Administrative Actions Before Authorization

After reviewing all of the information and coming to a determination, the 

adjudicating specialist:

a. Rationale (See DCM 5.1.6) 

• If fully affirming a previous determination

Composes a rationale explaining why the previous determination was 

reasonable. The document is then placed in the Reconsideration 

Rationale SharePoint site.

Do not place a copy in the claims folder.

• If partially or fully revising a previous determination 

Completes Form G-325.1 (DCM 11 G-325.1).

Place a copy of Form G-325.1 on the left side of the claims folder before 

submitting the case for authorization.

b. OLDDS (If necessary) (DCM 12.1.4) 

OLDDS is only completed if the SF determination in effect is changed 

(allowance/denial) or a disability onset date is revised. 

If completed, a copy of all OLDDS screens is placed on the left side of the 

claims folder before submitting the case for authorization. (See RCM 5.12.10

) 

c. Disability Determination Letter

Appropriate Reconsideration Section code letters and paragraphs are used. 

The adjudicating examiner must send the letter to the imaging authorization 

folder. 

NOTE: Reconsideration Section specialists are responsible to proofread the 

reconsideration determination letter for the correct name and address, 

accurate content, and proper grammar before it is released to the 

claimant/annuitant and sent to the imaging authorization folder. 

d. Reversal Sheet (if necessary)
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A reversal sheet is completed only if partially or fully revising a previous 

determination. It is placed in the claims folder.

4. Authorization Process (IF NECESSARY) 

SF decisions at the reconsideration level require authorization by another 

specialist ONLY if partially or fully revising a previous disability determination. 

If the case requires authorization by another specialist:

a. The adjudicating specialist will log the claims folder into the AFCS location of 

the fellow specialist reviewing the case and bring it to him/her.

b. The authorizing specialist will thoroughly review all aspects of the proposed 

disability determination for sufficiency, accuracy, and content, including but 

not limited to: medical and non-medical evidence, all medical opinions, 

determination rationale, system entries, formal determination letters of 

notification, and any other forms and documentation relevant to the decision.

The authorizing and adjudicating specialists will immediately discuss the case 

if there are any disagreements in any aspect of the decision. As a last resort, 

the Reconsideration Section supervisor should be consulted if the 

disagreements cannot be rectified informally. 

c. The authorizing specialist will approve OLDDS and verify that it processed 

correctly into the system.

d. After the case has processed into the system, the authorizing specialist will 

log the claims folder into the AFCS location of the adjudicating specialist and 

return it to him/her.

5. Administrative Actions After Authorization

a. The adjudicating specialist will print three (3) copies of the formal disability 

determination notification letter. One copy is released to the individual 

requesting reconsideration. One copy is placed on the right side of the claims 

folder. One copy is given to the Chief of the Reconsideration Section.

A fourth copy (carbon copy; cc:) is printed if an attorney is or appears to 

represent a claimant/annuitant. Send the cc: to the attorney if the 

reconsideration determination is partially or fully favorable. Send the cc: to 

the claimant/annuitant if the original determination is fully affirmed.

All letters must be sent to imaging.

b. Enter an appropriate CDR call up diary (DCM 8.5.2 and 8.5.3), if it is 

warranted, using the CDR call up program (DCM 12.3). A copy is placed on 

the left side of the claims folder. 
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 28 of 56

NOTE: Existing medical diary call ups in the CDR call up program should be 

closed and an up-to-date diary entered. 

c. The adjudicating specialist will release one copy of the Reversal Sheet to 

DBD. A second copy (attached to the USTAR tracking sheet) is placed in the 

incoming tray of the Chief of Reconsideration Section.

d. When all is complete, the claims folder is either sent to: 

• Claim Files, or

• Survivor Benefits Division - Initial Section if a DF has been granted for a 

deceased railroad employee (DCM 6.9.1). 

NOTE: If the payment of a D/A or O/M is affected such as could occur when 

an earlier DF onset date is allowed, notify the Retirement Benefits Division via 

an E-mail.

6.7 Joint Freeze, Unilateral Freeze, and Financial Interchange 

Disability Determinations

6.7.1 Introduction To Joint And Unilateral Freeze Determinations

Joint RRB/SSA disability freeze (DF) decisions are not required by law or regulation but 

are the results of interagency policy formed in September 1958 to protect certain 

railroad employees and their families against the possible adverse effect of independent 

and/or conflicting DF decisions made by two agencies based on the same provisions of 

law. Joint freeze (JF) decisions also eliminate any potential administrative problems for 

both agencies due to uncoordinated decisions.

Although the Railroad Retirement Board (RRB) has independent statutory authority to 

make DF decisions for our annuitants, there are no provisions of law that requires the 

Social Security Administration (SSA) to recognize our ratings for benefits under the 

Social Security Act (SS Act). JF decisions insure that the employee's family will have 

the advantage of higher survivor benefits after his death.

A JF determination is defined as a disability claim processed jointly by RRB and SSA 

where there is some likelihood of social security benefits being paid OR cases included 

in the financial interchange sample. RRB prepares the DF determination and SSA 

reviews and countersigns the decision.

An application for a disability annuity (D/A) filed with the RRB is also deemed to be an 

application for a DF under the SS Act. If a claim for D/A filed with the RRB meets the 

criteria (but not an exception) shown in DCM 6.7.3, the RRB is required to attempt to 

coordinate the DF decision with SSA as a possible JF decision. 
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• If, at the initial or reconsideration levels of adjudication, the RRB and SSA agree 

that the claimant is disabled beginning on a specific date, a JF has been 

established from that date and the disability determination is entered into the 

RRB system using OLDDS SSA-831 (DCM 12.1.6). 

• If, at the initial or reconsideration levels of adjudication, RRB and SSA EITHER

 disagree that the claimant is disabled

OR

 agree that the claimant is disabled but disagree on the date that disability 

begins

the RRB may decide to unilaterally conclude that the claimant is disabled for DF 

purposes. The period of time which the RRB decides to make an independent 

decision on the claim after the RRB and SSA are unable to reach an agreement 

through the JF coordination/reconciliation process is considered a unilateral 

freeze period. Unilateral freeze decisions completed in DBD require supervisory 

or senior examiner signatory approval. DF decisions denied in DBD but 

subsequently unilaterally allowed in the Reconsideration Section require 

authorization by a second Reconsideration specialist.

• The RRB and SSA have agreed that DF claims meeting the criteria in DCM 6.7.3

but completed at the appeals or Board level are considered unilateral freeze 

decisions. Appeals and Board-level decisions are entered into the RRB systems 

through OLDDS differently than initial and reconsideration-level decisions.

NOTE: A courtesy copy of the administrative record and determination rationale 

are sent to SSA for unilateral DF claims awarded by a hearings officer or threemember Board which are in the financial interchange sample, as shown in 

DCM 6.7.3 D. 

All JF and unilateral freeze decisions are important for Financial Interchange (FI) 

purposes. See DCM 6.7.8 for additional information regarding the FI.

6.7.2 SS Definition Of "Career RR Employee"

SSA considers any person to be a career RR employee if the person has: 

• 120 months of creditable service under the Railroad Retirement Act (RRA), or

• Completed 60-119 months of creditable service under the RRA with at least 60 

months after 1995, or

• Been awarded an RR disability or retirement annuity.
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A person who does not meet the conditions mentioned above is termed a "non-career" 

RR employee.

6.7.3 Determining When A Joint Freeze Is Required 

A. When a Joint Decision is required

Joint disability decisions for an initial disability freeze (DF) and continuing entitlement to 

a disability freeze will be made for career railroad employees when there is potential 

entitlement to social security benefits. A joint freeze decision will be made when one of 

the following conditions exist: 

1. The employee does not have a current connection (C/C).

2. The employee has sufficient wage quarters to be eligible for a disability insurance 

benefit (DIB) as of the alleged quarter of disability onset (AQD).

3. Social Security Administration (SSA) denial code 090 (DIB insured status not met 

based on social security earnings only) is shown on SSA’s Master Beneficiary 

Record (MBR) or Supplemental Security Income Data (SSID). 

4. The case is included in Financial Interchange (FI) sample. The FI sample consists of 

employees, widows and children cases with six digit claim numbers and the last two 

digits of the claim number of 55; or cases with nine digit claim numbers and the last 

two digits of the claim number of 30. 

5. SSA reports wages of over $5,000 but does not identify the quarters of coverage for 

that year.

Provided an applicant has been disabled for at least five months at the time a disability 

decision is made under the Railroad Retirement Act and we have sufficient medical 

evidence to make a disability freeze decision under the Social Security Act, an attempt 

should be made to make that decision. Use all earnings sources including EDMA, 

DEQY/SEQY, and The Work Number (TWN) in conjunction with information on the 

application about recent work to determine whether a single or joint decision is required. 

Note: These items or records must be imaged. Do Not print as they contain federal 

tax information and must be properly safeguarded.

B. When a Joint Decision is not required

A single freeze decision will be made when one of the following conditions exist:

1. All cases in which the annuity and disability freeze are being simultaneously 

denied.

2. All denials for lack of insured status based on combined railroad and social 

security earnings.

3. The employee has a C/C and died before adjudication.

4. All cases in which the applicant has filed for either Title II or Title XVI under the 

Social Security Act. Note: This does not apply for denial at SSA for reason code 

090. See DCM 6.7.3 A. 
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5. Denials for which the annuitant has submitted a statement that he/she does not 

want to be granted a DF. See DCM 6.3.1

6. Denials for failure to cooperate.

6.7.4 Making Joint And Unilateral Freeze Decisions

All claims for disability annuity (D/A) filed with the RRB meeting the criteria in 

DCM 6.7.3 are considered joint freeze (JF) decisions. Initial JF claims are coordinated 

with the Social Security Administration (SSA) by examiners in the Disability Benefits 

Division - Disability Post Section (DBD-DPS). In addition, JF claims initially denied by 

DBD-DPS but allowed by a claims specialist in the Reconsideration Section (Recon) are 

coordinated with SSA.

NOTE 1: Affirmations of initially denied JF’s are not coordinated with SSA by Recon 

claims specialists.

NOTE 2: If a claim for D/A was denied initially by DBD but reversed by a 

reconsideration specialist AND the claim meets the criteria for JF coordination

(DCM 6.7.3), Recon will return the claims folder back to DBD-DPS to coordinate the 

JF decision with SSA since it had not been previously attempted.

Disagreements may occur between the RRB and SSA with regards to medical and/or 

vocational issues as well as, if an allowance, the proposed onset date. Those disability 

claims where the RRB makes an independent decision after the RRB and SSA are 

unable to reach an agreement through the JF reconciliation process are considered 

unilateral freeze decisions. In addition, disability freeze (DF) decisions meeting the 

criteria in DCM 6.7.3 but completed at the appeals or Board level are considered 

unilateral freeze decisions. Appeals and Board-level decisions are entered into the 

RRB systems through OLDDS differently than initial and reconsideration-level 

decisions.

NOTE: A courtesy copy of the administrative record and determination rationale are 

sent to SSA for unilateral DF claims awarded by a hearings officer or three-member 

Board which are in the financial interchange sample, as shown in DCM 6.7.3 D. 

The process that follows is used to coordinate decisions with SSA. 

6.7.4.1 Distribution of Incoming Claims

A. DBD Handling

Cases are generally distributed to and adjudicated by DBD examiners according to 

terminal digits.

DBD sends the claims folder of initially denied JF’s to Recon at the time that an 

individual is rated not disabled in anticipation of a possible request for 

reconsideration.
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B. Reconsideration Section Handling

Incoming requests for reconsideration of a wholly or partially unfavorable JF 

determination are screened to determine if the request was made timely. Timely 

requests are logged into USTAR (FOM1 15120) and a letter acknowledging receipt 

of the request is released. A USTAR tracking sheet is printed and attached to the 

request and claims folder. (Claims folders not already in Recon are obtained.)

Request for reconsideration are distributed to Recon specialists by date of receipt, 

the oldest requests being distributed first, except when there is special (i.e. 

Congressional, Board member, etc) interest.

6.7.4.2 Adjudication and Evidence Development

The DBD-DPS examiner or Recon specialist obtains all information needed to make a 

DF decision including but not limited to: any pertinent medical and non-medical 

evidence, vocational reports, earnings record (DCM 6.3.4), application forms, activities 

of daily living and medical consultant’s opinion (MO) of the claimant’s residual functional 

capacity. 

NOTE 1: Adjudicating personnel must check to see if an application for Disability 

Insurance Benefits (DIB; Title II) or Supplemental Security Income (SSI; Title XVI) 

was already filed at SSA. Indications that a disability application was filed at SSA 

can be found in/on:

• Form AA-1 (APPLE and paper);

• Form AA-1d;

• SSA Master Benefit Record (MBR);

• SSI Record;

• DATAQ;

• DEQY (if already in file); and

• Contact Log.

Adjudicators can request a MBR, SSI record, and DEQY from RRB personnel who 

have been authorized by SSA to access their system. Instructions how to read a 

MBR can be found in POMS SM 00510. Instructions how to read a SSI record can 

be found in POMS SM 01601. Adjudicators can also request a report from The Work 

Number (TWN); see DCM 3.4.205).

If a career railroad employee has also filed a claim with SSA for a DIB or SSI, the DF 

decision must be processed into the RRB systems as a single freeze (DCM 6.6.4; 

DCM 12.1.4) EXCEPT when a claim is in the Financial Interchange (FI) sample, as 
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 33 of 56

shown in DCM 6.7.3 D. If the claim is in the FI sample, the DF decision must be 

processed into the RRB systems through OLDDS SSA-831 (DCM 12.1.6).

NOTE 2: Affirmations of initially denied JF decisions or JF disability onset dates are 

not coordinated with SSA by Recon claims specialists. If a Recon specialist affirms 

a JF which was initially denied or a JF disability onset date, do not follow the 

instructions in DCM 6.7.4.3 through 6.7.4.5. Disposition of the case shall continue 

as in DCM 6.7.4.6 A.2. 

6.7.4.3 Administrative Actions Before Coordination With SSA

After reviewing all the information and coming to a determination, the DBD examiner or 

Recon specialist:

1. completes a RRAILS Form G-325.1, Disability Decision Rationale, for the proposed 

decision (DCM 11 G-325.1), and

2. records and signs the JF decision on Form SSA-831-U3, Disability Determination 

and Transmittal.(See DCM 11 SSA-831) 

The above information is placed on the top of the left side of the claims folder. (See 

RCM 5.12.10 for information how a claims folder is organized.)

3. images a copy of the REAP earnings record and/or DEQY/SEQY/ and report from 

The Work Number (TWN) for documentation (if needed). (Do not send these items 

to SSA). 

6.7.4.4 Sending Claims Folders To SSA

The DBD examiner or Recon specialist places the claims folder in terminal digit order in 

the T0GL file cabinet located in DBD and logs the folder into AFCS sublocation T0GL 

(DBD-Cases Going to GLPSC). The claims folder will then be sent by messenger 

(generally once each week) to SSA’s Great Lakes Program Service Center-Disability 

Program Branch (GLPSC-DPB) for JF coordination efforts. 

Folders leaving the Board for GLPSC will be logged into AFCS sublocation T017 (DBDJoint D/F at SSA). 

NOTE: The claims folder with the proposed JF decision may be released to SSA before 

a D/A award has been paid partial or final by the RRB.

6.7.4.5 Coordination Actions With SSA

The GLPSC claims examiner reviews the decision for concurrence and then sends the 

claims folder to their doctor(s) to review the evidence and provide a written MO. Any 

differences between agencies are reconciled before the GLPSC claims examiner and

SSA doctor certify the decision by each signing Form SSA-831-U3.
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A. SSA agrees with the proposed RRB JF determination (i.e. medical and/or vocational 

issues as well as disability onset date)

The GLPSC disability examiner will keep a photocopy of the certified Form SSA831-U3 for their records, leave any MO’s and other related paperwork in the claims 

folder, complete and staple SSA Form GLPSC-38 to the front of the file, and return 

the claims folder to the RRB. 

Disposition of the case shall continue as in DCM 6.7.4.6 A.1 (DBD-DPS) or 

DCM 6.7.4.6 A.2 (Recon). 

B. SSA disagrees with the proposed RRB JF determination

Neither the GLPSC disability examiner nor their doctor will certify Form SSA-831-U3. 

The GLPSC disability examiner will leave the MO’s and other related paperwork in 

the claims folder, complete and staple SSA Form GLPSC-38 to the front of the 

claims folder with an explanation for the disagreement, and return the claims folder 

to the RRB. 

Upon return of the claims folder, the DBD-DPS examiner or Recon specialist will 

review all of the evidence and any supporting rationale that SSA has provided.

1. If the DBD-DPS examiner proposed a JF allowance or denial but now agrees 

with SSA’s proposed denial or allowance, (s)he will complete a new RRAILS 

Form G-325.1, Disability Determination Rationale, and Form SSA-831-U3, 

Disability Determination and Transmittal, and place them above the original G325.1 and SSA-831-U3 forms. (A large “X” shall be written on the original G325.1 and SSA-831-U3 forms and each form will be left in file for documentation 

purposes.) A “GLPSC Conflict Case” label shall be stapled to the front of the 

claims folder to alert the GLPSC representative that they have previously 

reviewed the file. The claims folder will then be resubmitted to SSA. Follow the 

instructions in DCM 6.7.4.3. 

If the Recon specialist proposed a JF allowance but now agrees with SSA’s 

proposed denial, (s)he will follow normal Reconsideration section procedures to 

affirm the denial. Disposition of the case shall continue as in DCM 6.7.4.6 A.2. 

2. If the DBD-DPS examiner or Recon specialist disagrees with SSA’s proposed 

determination, a judgment should be made as to the next course of action. If 

necessary, the examiner or specialist must make reasonable attempts to 

reconcile vocational issues and differences in medical opinions including but not 

limited to attempting to obtain any additional medical and/or vocational evidence 

and scheduling consultative examinations requested by SSA.

If the examiner or specialist continues to feel that the evidence is sufficient, (s)he 

can resubmit the claims folder with additional information and/or supporting 

rationale for its decision to SSA. In addition, DBD-DPS examiners may refer the 
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 35 of 56

claim to the DBD-DPS supervisor or senior examiner with a written request for 

advice. The request should briefly summarize the case and suggest a course of 

action. The DBD-DPS supervisor or senior examiner will review the evidence and 

provide a written opinion regarding what further action, if any, should be taken to 

reconcile the possible conflict. Both the request for advice and opinion must 

remain documented in the claims folder.

A new RRAILS Form G-325.1, Disability Determination Rationale, and/or Form 

SSA-831-U3, Disability Determination and Transmittal, may need to be 

completed and placed in the left side of the claims folder if it is resubmitted to 

SSA. A “GLPSC Conflict Case” label shall be stapled to the front of the claims 

folder each time it is returned to SSA to alert the GLPSC claims examiner that 

they have already reviewed the case. The claims folder will be resubmitted to 

SSA. Follow the instructions in DCM 6.7.4.3. 

If, after reasonable attempts to reconcile the differences, a disagreement still 

exists between the RRB and SSA, the RRB may decide to make an independent 

determination, referred to as a unilateral freeze decision. All unilateral freeze 

decisions completed by a DBD-DPS examiner require supervisory or senior 

examiner signatory approval. Unilateral freeze periods allowed in the 

Reconsideration Section require signatory approval by a second Recon

specialist.

Unilateral freeze decisions proposed by a DBD-DPS examiner or Recon 

specialist require a written explanation (separate from the determination 

rationale) of the reason(s) for the decision. The rating DBD-DPS examiner shall 

give the claims folder and explanation to his/her supervisor or senior examiner

for review. The rating Recon specialist shall give the claims folder and 

explanation to a second Recon specialist for review. The supervisor, senior 

examiner, or Recon specialist will review the proposed decision and either 

approve or deny it by signing the explanation (and including any additional 

explanation when necessary). The original approval/explanation shall be filed on

the right side of the claims folder. (Unilateral freeze decisions completed as a 

result of an appeal do not require any approval.) 

Disposition of the case shall continue as in DCM 6.7.4.6 B.1 (DBD-DPS) or 

DCM 6.7.4.6 B.2 (Recon) after signatory approval has been obtained. 

See DCM 12.1.4 for proper OLDDS coding for item 24 for unilateral freeze cases 

on the G-325 screen.

After OLDDS processes, the claims folder shall be returned to the DBD-DPS 

supervisor or senior examiner who approved the unilateral freeze decision. 

Similarly, the claims folder shall be returned to the Recon specialist who 

proposed the unilateral freeze decision
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The DBD-DPS supervisor or senior examiner who approved the decision OR 

Recon specialist who proposed the decision is responsible to formally advise the 

SSA of the unilateral freeze decision, including any additional evidence or 

supporting rationale (s)he may choose to provide. The notification should be 

made by E-mail to: CHI.ARC.PCO.DPB@ssa.gov.

C. SSA agrees with a JF allowance but not with the proposed disability onset date or 

Medical-Vocational rule

SSA may or may not certify Form SSA-831-U3. If Form SSA-831-U3 is certified, the 

GLPSC will cross out the entries to be changed and write in the revised information. 

Regardless of whether it is certified, the GLPSC claims examiner should leave the 

MO’s and other related paperwork in the claims folder, complete and staple SSA 

Form GLPSC-38 to the front of the claims folder (with a brief explanation of the 

changes), and return the claims folder to the RRB. 

NOTE 1: In these situations, be alert to the possibility of an earlier onset date for 

the D/A determination or a unilateral freeze request for the period prior to the 

onset date SSA agrees to.

NOTE 2: RRB and SSA regulations specify that a person reaches a particular 

age on the day before his or her birthday. (See RCM 4.2.3) Consideration of an 

individual’s age does not take place until step 5 of the sequential evaluation 

process for disability onset date purposes. Although the Medical-Vocational 

rules (DCM 5.6) are not to be applied mechanically, in borderline age situations 

(see DCM 5.3.6 and POMS DI 25015.005), a DF onset date based on the 

attainment of a particular age as shown in the Medical-Vocational rules is 

normally established as the day before the claimant’s birthday.

Upon return of the claims folder, the DBD-DPS examiner or Recon specialist will 

review all of the evidence and any supporting rationale that SSA has provided.

1. If the DBD-DPS examiner or Recon specialist agrees with SSA’s proposed 

changes, (s)he will complete a new RRAILS Form G-325.1, Disability 

Determination Rationale, and place it above the original Form G-325.1. (A 

large “X” shall be written on the original Form G-325.1 and it shall be left in 

file for documentation purposes.) No changes are to be made to Form SSA831-U3, Disability Determination and Transmittal. 

Disposition of the case shall continue as in DCM 6.7.4.6 A.1 (DBD-DPS) or 

DCM 6.7.4.6 A.2 (Recon). 

2. If the DBD-DPS examiner or Recon specialist disagrees with SSA’s proposed 

changes, a judgment should be made as to the next course of action. If 

necessary, the examiner or specialist must make reasonable attempts to 

reconcile vocational issues and differences in medical opinions.
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(S)he may resubmit the claims folder with additional information and/or 

supporting rationale to SSA. In addition, DBD-DPS examiners may refer the 

claim to the DBD-DPS supervisor or senior examiner with a written request 

for advice. The request should briefly summarize the case and suggest a 

course of action. The DBD-DPS supervisor or senior examiner will review the 

evidence and provide a written opinion regarding what further action, if any, 

should be taken to reconcile the possible conflict. Both the request for advice 

and opinion must remain documented in the claims folder.

If the claims folder is resubmitted to SSA, a new RRAILS Form G-325.1, 

Disability Determination Rationale, and/or SSA-831-U3, Disability 

Determination and Transmittal, shall be printed and placed on the left side of 

the claims folder. A “GLPSC Conflict Case” label shall be stapled to the front 

of the claims folder each time it is returned to SSA to alert the GLPSC claims 

examiner that they have already reviewed the case. The claims folder will 

then be resubmitted to SSA as in DCM 6.7.4.3 above.

If, after reasonable attempts to reconcile the differences (most likely due to a 

difference in the disability onset date) a disagreement still exists between the 

RRB and SSA, the RRB may decide to make an independent determination. 

The period of time that SSA does not agree with the RRB that the career 

railroad employee is disabled would be considered as a unilateral freeze. All 

unilateral freeze decisions completed by a DBD-DPS examiner require 

supervisory or senior examiner signatory approval. Unilateral freeze periods 

allowed in the Reconsideration Section require signatory approval by a 

second Recon specialist.

All periods of time considered as a unilateral freeze and proposed by a DBDDPS examiner or Recon specialist require written explanation (separate from 

the determination rationale) of the reasons(s) for the decision. The rating 

DBD-DPS examiner shall give the claims folder and explanation to his/her 

supervisor or senior examiner for review. The rating Recon specialist shall 

give the claims folder and explanation to a second Recon specialist for 

review. The supervisor, senior examiner, or Recon specialist will review the 

proposed decision and either approve or deny it by signing the explanation 

(and including any additional explanation when necessary). The original 

approval/explanation shall be filed on the right side of the claims folder. 

(Unilateral freeze decisions completed as a result of an appeal do not require 

any approval.)

After signatory approval has been obtained, the case must be properly 

completed. Disposition of the case shall continue as in DCM 6.7.4.6 B.1

(DBD-DPS) or DCM 6.7.4.6 B.2 (Recon). 

See DCM 6.7.5 for proper OLDDS coding in this situation.
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After OLDDS processes, the claims folder shall be returned to the DBD-DPS 

supervisor or senior examiner who approved the unilateral freeze period. In a 

similar manner, the claims folder shall be returned to the Recon specialist 

who proposed the unilateral freeze period.

The DBD supervisor or senior examiner who approved the decision OR 

Recon specialist who proposed the decision is responsible to formally advise 

SSA that the RRB considered a period of time as a unilateral freeze period. 

The notification may include any additional evidence or supporting rationale 

(s)he may choose to provide and should be made by E-mail to: 

CHI.ARC.PCO.DPB@ssa.gov. 

6.7.4.6 Administrative Actions After Coordination With SSA

The DBD-DPS examiner or Recon specialist will take appropriate actions after SSA 

certifies the proposed JF decision and/or approval for a unilateral freeze decision.

A. Joint Freeze Decisions

1. DBD-DPS Handling

a. OLDDS

Enter and process the certified JF decision on the OLDDS SSA-831 screen

(see DCM 12.1.6). Authorization is not required because SSA has approved 

the decision. (DCM 3.4.304) 

EXCEPTION: If a JF allowance ALSO allows an earlier D/A onset date, 

actions to enter the earlier D/A onset date MUST be completed before 

actions to enter the JF onset date so that PREH processes correctly. In 

this situation, complete the following actions as follows: 

• DAY 1: Complete OLDDS G-325 to allow the earlier D/A onset date

• DAY 2: After the earlier D/A onset date has processed, complete 

OLDDS SSA-831 to allow the JF onset date

• DAY 3: After the JF onset date has processed, send the claims folder 

to the DBD-Disability Post Section senior examiner so that they 

release an E-mail to RPS about the earlier D/A onset date. Advise the 

senior examiner if the claims folder needs to be sent to another 

location rather than to claim files.

Place a printout of all OLDDS screens above Forms SSA-831-U3 and G325.1 on the left side of the claims folder.

JF decisions must not be authorized on OLDDS until the disability 

annuity award has been paid partial or final by the RRB.
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 39 of 56

NOTE: See DCM 6.7.5 for procedure how to enter OLDDS in an onset date 

conflict.

b. Disability Determination Letter

Compose and release the appropriate RL-210 series or RL-260 series letter. 

In addition, either the SSA-810 or SSA-813 (with SSA publication No. 05-

10058, Your Right To Question The Decision Made On Your Claim) must be 

concurrently released. (See DCM 6.4.6 and DCM 6.7.6) 

EXCEPTION: If the JF is allowed and the EE has both a fully insured 

status (RCM 5.6.5; DCM 6 Appendix 5) under the Social Security Act (SS 

Act) and a disability insured status (DCM 6.3.2) based on Social Security 

earnings, (s)he is insured for a Disability Insurance Benefits (i.e. DIB; cash 

annuity) under the SS Act. In this situation, do not release Form SSA-810

(or SSA publication No. 05-10058) to the EE. SSA will release their SSAL810 letter and solicit the EE for an application for DIB.

Make a second copy of the RL-210 or RL-260 series letter and place it on the 

top of the right side of the claims folder. Do not print a copy of the SSA-810 

or SSA-813 for the claims folder.

Send all letters to imaging.

c. CDR Call-Up Diary

If necessary, establish an appropriate CDR call-up diary in the CDR Call-Up 

program. (See DCM 8.5.2 and DCM 8.5.3) 

If a CDR call-up diary is established, place a printout on the left side of the 

claims folder.

d. DF-Only Applications

DF-only applications are manually coded out of KOR. DBD-DPS examiners 

should enter the appropriate information on the coding sheet. The coding 

sheet will be E-mailed back to the DBD-DPS senior examiner at the end of 

each calendar month.

e. Other Miscellaneous Actions Involving the Claims Folder

File the SSA-certified Form SSA-831-U3 on the left side of the claims folder.

File all other documentation received from SSA, including but not limited to 

Form GLPSC-38 and SSA medical opinion form on the right side of the claims 

folder. 
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 40 of 56

Send the EE’s earning record (REAP or DEQY/SEQY and report from The 

Work Number (TWN)) electronically to imaging.

• 

f. Medicare

If the Medicare effective date is in a previous month, the current month, or 

any of the five months following the award, the DBD-DPS examiner or Recon 

specialist must notify the Medicare Section of the Medicare entitlement using 

Form G-405 attached to an Email. (See RCM 11 G405) 

It is highly recommended that the examiner or specialist place a photocopy of 

the E-mail and Form G-405 on the right side of the claims folder.

g. Disposition

Send the claims folder to claim files EXCEPT when a DF has been granted 

for a deceased railroad employee, in which case the folder should be sent to 

the Survivor Benefits Division - Initial Section. (See DCM 6.9.1).

2. Reconsideration Section Handling

a. OLDDS

OLDDS is only entered if the Recon examiner revises the JF decision

(allowance/denial or disability onset date) originally made by DBD-DPS and 

SSA certifies that decision. If this occurs, follow the instructions in DCM 

6.7.4.6 A.1.a. 

b. Disability Determination Letter

Use RRAILS letter +RECONDEC. 

If the initial JF decision is fully or partially reversed, either Recon Section 

code letter RL-210a (if decision is reversed) or code paragraph RS 807 (if 

revising a disability onset date) is used. Additional Recon Section code 

paragraphs and other text may need to be added to the letter. Also, code 

letter RL-210a.ATTACHMENT is used if a JF decision is reversed. If the 

claimant is represented by an attorney, the original is released to the claimant 

and a carbon copy is sent to the claimant’s attorney. 

If the initial JF decision is affirmed, either Recon Section code paragraph RS 

808-1 (if a denial is affirmed) or RS-811 (if affirming a disability onset date) is 

used. Additional Recon Section code paragraphs and other text may need to 

be added to the letter. If the claimant is represented by an attorney, the code 

paragraph RS 809-1 is used if a JF denial is affirmed. Regardless, if a 
DCM Part 6

DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 41 of 56

claimant is represented by an attorney, a carbon copy is sent to the claimant 

and the original is sent to the claimant’s attorney.

Send all letters to imaging.

c. CDR Call-Up Diary

Affirmations of initial JF decisions do not require a revised CDR call-up diary. 

However, if an initial JF denial is reversed or a disability onset date is revised, 

follow the instructions in DCM 6.7.4.6 A.1.c. to update the CDR call-up diary.

d. Other Miscellaneous Actions Involving the Claims Folder

Follow the instructions in DCM 6.7.4.6 A.1.e. 

e. Medicare 

Follow the instructions in DCM 6.7.4.6 A.1.f. 

f. Disposition

Follow the instructions in DCM 6.7.4.6 A.1.g. 

In addition, attach a copy of the Recon tracking sheet to a copy of the letter 

and place it in the appropriate incoming tray in the office of the Chief of 

Reconsideration.

B. Unilateral Freeze Decisions

1. DBD-DPS Handling

a. OLDDS

Enter and process the unilateral DF decision on the appropriate OLDDS G325 screens (see DCM 12.1.4, especially for correct coding instructions for 

item 24). Authorization is not required because the supervisor or senior 

examiner has approved the decision. (See DCM 3.4.304) 

NOTE: A single OLDDS entry can be completed on the same day if a 

unilateral freeze allowance ALSO allows an earlier D/A onset date. 

Place a printout of all OLDDS screens above Form G-325.1 on the left side of 

the claims folder. 

Unilateral freeze decisions must not be authorized on OLDDS until the 

disability annuity award has been paid partial or final by the RRB.

NOTE: See DCM 6.7.5 for procedure how to enter OLDDS in an onset date 

conflict.
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b. Disability Determination Letter

Compose and release the appropriate RL-210 series or RL-260 series letter. 

(See DCM 6.4.6) 

Place a printout of the RL-210 or RL-260 series letter on the top of the right 

side of the claims folder.

Send the letter to imaging.

c. CDR Call-Up Diary

Follow the instructions in DCM 6.7.4.6 A.1.c. 

d. DF-only Applications

Follow the instructions in DCM 6.7.4.6 A.1.d. 

e. Other Miscellaneous Actions Involving the Claims Folder

File the original approval/explanation from the supervisor/lead examiner on 

the right side of the claims folder.

File all other documentation received from SSA, including but not limited to 

Form GLPSC-38 and SSA medical opinion form on the right side of the claims 

folder.

Send the EE’s earning record (REAP or DEQY/SEQY and report from The 

Work Number (TWN)) electronically directly to imaging.

SSA must be notified of the unilateral freeze decision by sending an E-mail to 

CHI.ARC.PCO.DPB@ssa.gov. 

f. Medicare

Follow the instructions in DCM 6.7.4.6 A.1.f. 

g. Disposition

Follow the instructions in DCM 6.7.4.6 A.1.g. 

2. Reconsideration Section Handling

a. OLDDS
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 43 of 56

OLDDS is only entered if the Recon examiner revises the DF decision 

(allowance/denial or disability onset date) originally made by DBD-DPS and 

SSA does not agree with the decision. If this occurs, follow the instructions in 

DCM 6.7.4.6 B.1.a.

b. Disability Determination Letter

Use RRAILS letter +RECONDEC.

If the initial DF decision is fully or partially reversed, either Recon Section 

code letter RL-210a (if the decision is reversed) or code paragraph RS 807 (if 

revising a disability onset date) is used. Additional Recon Section code 

paragraphs and other text may need to be added to the letter. Also, code 

letter RL-210a.ATTACHMENT is used if a DF decision is reversed. If the 

claimant is represented by an attorney, the original is released to the claimant 

and a carbon copy is sent to the claimant’s attorney.

Send all letters to imaging.

c. CDR Call-Up Diary

Follow the instructions in DCM 6.7.4.6 A.1.c. 

d. Other Miscellaneous Actions Involving the Claims Folder

Follow the instructions in DCM 6.7.4.6 B.1.e. 

e. Medicare

Follow the instructions in DCM 6.7.4.6 A.1.f. 

f. Disposition

Follow the instructions in DCM 6.7.4.6 A.1.g. 

In addition, attach a copy of the Recon tracking sheet to a copy of the letter 

and place it in the appropriate incoming tray in the office of the Chief of 

Reconsideration.

NOTE: SSA will request by an email to the DBD group mailbox photocopies of the RRB 

file for any JF case where the employee is insured for an SSA DIB (20/40 insured case) 

and files for a disability benefit at SSA. DBD will retrieve the file from claims files and 

send the photocopies attached to a G-26f within 3 weeks of receiving the request. Keep 

a copy of the G-26f in the file as documentation that the photocopies were sent. 

Requests are handled by the DBD-DPS lead examiners.
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6.7.5 RRB/SSA Disability Onset Date Conflict In Joint Freeze Decisions

At times the RRB and SSA may agree to grant a disability freeze (DF), but a conflict 

exists as to the appropriate disability onset date. Although SSA and RRB will make 

every effort to reconcile a conflict, the RRB is not bound to accept SSA's onset date. If 

after reasonable attempts to reconcile the differences, a disagreement still exists 

between the RRB and SSA, the RRB may decide to make an independent 

determination for the period of time prior to the date of disability onset that SSA agrees 

to. That period of time would be considered as a unilateral freeze period.

All unilateral freeze decisions completed by a DBD-DPS examiner require supervisory 

or senior examiner signatory approval. Similarly, all unilateral freeze decisions 

completed by a Recon specialist require signatory approval by a second Recon 

specialist. 

The rating DBD-DPS examiner shall give the claims folder and explanation to his/her 

supervisor or senior examiner for review. The rating Recon specialist shall give the 

claims folder and explanation to a second Recon specialist for review. The supervisor, 

senior examiner, or Recon specialist will review the proposed decision and either 

approve or deny it by signing the explanation (and including any additional explanation 

when necessary). The original approval/explanation shall be filed on the right side of 

the claims folder. (Unilateral freeze decisions completed as a result of an appeal do not 

require any approval.)

In an unreconciled disability onset date conflict, the RRB date will be used for Taxation 

and Medicare. For any payment adjustment to a claim in this situation, refer to 

RCM 8.11.15 E. 

When all efforts to reconcile the date conflict have been exhausted and the SSA-831 

has been returned to DBD, signed off and with SSA's own disability onset date, and 

DBD supervisory/senior examiner or second Recon specialist signatory approval has 

been approved for a unilateral freeze period, process the case as follows:

• Enter the information from the form SSA-831 on OLDDS screen SSA-831 as 

described in DCM 12.1.6. Even though RRB will not use the onset date on this 

form, the information must be entered for financial interchange purposes. Allow 

the OLDDS SSA-831 to process on the nightly run; 

• After the SSA-831 information has been entered and processed, complete the 

screen G-325 on OLDDS for a DF only (see DCM 12.1.4). Item 24, Employee 

Dis Code, should contain a "7." The actual onset date used by the RRB, the 

RRB date and SSA date must all be completed. In the actual onset date and 

RRB date of this item enter the disability onset date recognized by the RRB. For 

the SSA date enter the disability onset date used by SSA. This information must 

be entered to correctly update PREH and TAX databases with the RRB onset 

date; 
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 45 of 56

• Prepare allowance notice RL-210C as well as SSA-L810. Enter the RRB DF

onset date and Medicare coverage beginning date on the RL-210C. Enter the 

SSA disability onset date on the SSA-L810 if it is not a 20/40 DIB insured status 

case. In 20/40 DIB insured status cases, SSA will release the SSA-L810.

6.7.6 Joint Disability Freeze Decision Notices

As agreed by both agencies, two joint decision notices are furnished to the applicant in 

most instances: one from RRB and one from SSA.

For allowances, DBD prepares RR RL-210, or RL-210b, or RL-210C. SSA-L810 is also 

prepared and SSA Publication No. 05-10058 (Your Right To Question The Decision 

Made On Your Claim) is enclosed when the employee does not have a 20/40 SSA DIB 

insured status, and SS notices are entered in item 29 of Form SSA-831-U3. In 20/40 

DIB insured status cases, SSA will release the SSA-L810 and SSA Publication No. 05-

10058.

DBD examiners prepare RL-260 for RR denials. A copy of RL-260 is filed in the 

applicant's folder and sent to imaging. In addition, the DPS examiner will prepare a 

SSA-L813.1 and enclose SSA Publication No. 05-10058. A copy of that letter is 

furnished to the annuitant and GLPSC-DPB.

No copies of the SS notices are retained for the RR claim folder.

6.7.7 Receipt Of Disability Freeze G-90 In Single Coverage Or Joint Disability 

Freeze Allowance

A disability freeze G-90 will be requested sometime after Forms G-325 or SSA-831-U3 

are entered on OLDDS. Do not control for it. RBD receives the G-90s once a month via 

the GOLD system. RBD screens them to identify cases requiring additional action.

6.7.8 The Financial Interchange

In 1951, Congress enacted amendments that increased benefit levels under the 

Railroad Retirement Act (RR Act). This legislation guaranteed that benefits paid under 

the RR Act would never be less than what would have been payable if the worker’s 

railroad earrings had been credited as Social Security employment instead of RR Actcovered compensation. As part of that same legislative package, Congress established 

the Financial Interchange (FI) between the Social Security and Railroad Retirement 

systems as an additional funding source. The FI is one of the major funding sources 

that supports the RR Act trust fund.

The FI is a collective term that describes a series of legally mandated periodic fund 

transfers between the Railroad Retirement Board (RRB) and Social Security 

Administration, the RRB and Centers for Medicare and Medicaid Services, and between 

the RRB and the Treasury. The amounts transferred are the result of a complex 

statistical projection based on the scenario “What if the RR Act had never been 

enacted?”
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FI amounts are computed by the Bureau of the Actuary using statistical methods 

including large samples of RRB beneficiaries and currently employed railroad workers. 

All calculations are performed under the provisions of the Social Security Act.

When SSA concurs with the RRB’s decision to grant a JF, some or all of the benefits 

awarded are considered Social Security Equivalent Benefits (SSEB). Normally through 

the FI, the Social Security trust funds bear the cost for any benefits awarded under the 

RR Act if the benefits are considered SSEB.

When SSA does not concur with the RRB’s decision to grant a JF OR agrees to grant a 

DF but disagrees on the disability onset date, the RRB completes a unilateral freeze 

decision for the period of time of the disagreement. In these situations, none of the 

benefits are considered SSEB and, as a result, the Railroad Retirement trust fund bears 

the entire cost.

The Financial Interchange Division of the Bureau of the Actuary must keep track of the 

DF cases in the FI sample in addition to joint freeze and unilateral freeze cases. The 

Financial Interchange Division will make the appropriate queries to obtain the 

information needed for employees and widows. DBD management will periodically 

report the disabled children to the Financial Interchange Division, including the following 

information:

• claim number 

• date of birth 

• claimant’s social security number 

• DF code 

• disability onset date, and 

• date of decision

The FI is based upon the railroad employee’s claim number, not a widow’s or child’s 

social security number.

6.8 74 Act Medicare and Government Employment

6.8.1 When The 1974 Act Applies

In the 1974 RR Act, a new provision was added which provides that an individual who 

meets the insured status requirement when their disability annuity begins retains, for 

Medicare purposes only, that status as long as disability benefits are paid.

In other words any disability annuitant who meets 20/40 as of his ABD, but does not 

meet 20/40 in the month of disability onset, is not entitled to a disability freeze. The 

employee can receive a "Medicare only" rating that qualifies that employee only for 
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 47 of 56

early Medicare. Under the 1974 RR Act, for Medicare purposes only, a disability 

annuitant is deemed to have met 20/40 when their condition becomes severe enough to 

entitle them to a DIB.

6.8.2 When Government Employment Can Be Used To Establish Medicare

A. General - In some cases, claimed Federal, State and local government 

employment may be used to establish Medicare entitlement only. QCs received 

for this type of employment are called Government Employment Quarters of 

Coverage (GEQCs). They cannot be used to establish entitlement to an annuity 

or a disability freeze.

Every attempt should be made to establish Medicare based on Railroad 

Retirement (RR) earnings or Social Security (SS) wages. If this fails and the 

application shows government employment, an attempt should be made to 

establish Medicare based on government employment.

B. Federal Employment - Federal QCs awarded January 1983 or later may be used 

to establish Medicare Coverage.

In addition, a federal employee may be granted QCs for federal employment 

before January 1983 to establish Medicare coverage if:

• the employee was in an employer-employee relationship with the federal 

government at anytime during January 1983, and;

• the employee was employed by the federal government prior to January 

1983.

C. State and Local Government - State or local government QCs awarded April 

1986 or later may be used to establish Medicare only. No quarters may be 

granted for employment before April 1986.

D. DPS Examiner Action - If Medicare entitlement cannot be established in a 

disability case based on RR earnings or SS wages, further development may be 

required. The DPS examiner should check the application for an indication of 

Federal, State or local government employment. If such employment is indicated, 

a DEQY and report from The Work Number (TWN) must be requested and sent 

to Imaging. Upon viewing the DEQY, determine whether the GEQCs will provide 

Medicare coverage. Refer to RCM 3.2.13 for further details.

6.8.3 Freeze Notice

For cases in which the 1974 Act applies or government employment is used as quarters 

of coverage and the employee qualifies for early Medicare, letter RL-260b is sent to the 

employee.
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 48 of 56

6.8.4 Past Relevant Work in 1974 Act Cases

When adjudicating 1974 Act cases, the 15 year rule used in determining past relevant 

work (PRW) is to be used from the date of adjudication and not from the date last 

insured. 

6.9 Routing of Disability Freeze Cases

6.9.1 Routing Of Disability Freeze Cases When Employee Is Deceased

In cases where a disability freeze has been granted for a deceased employee and all 

disability action has been completed, send an email to the SBD-Survivor Benefits 

Division mailbox, attention: SIS, providing the RRB claim number and deceased 

employee’s name. Route the file to the survivor initial unit. This action is needed to 

determine if survivor benefits are affected by the disability freeze.

Appendices

Appendix 2 - Deemed Filing Dates Of Freeze Applications

Filed At RRB before 9-7-58

D/A Application Filed Deemed Filing Date of DF Employee's Insured 

Status Requirement

Employee died after 6-30-55 

and before 8-2-56. 

(Employees who died before 

7-1-55 could not qualify for 

DF.)

Latest of: 1-1-55; date D/A 

application was filed; date 

disabled under section Title II 

of SS Act.

Meets 6/13 QC test.

Application had been filed; 

employee was alive and 

disabled under Title II on 8-

2-56.

8-2-56 Meets 6/20 QC test.

Application filed after 8-2-56

and before 1958.

Latest of: Date D/A 

application was filed; date 

disabled under Title II of SS 

Act.

Meets 6/20 QC test.

Application filed before 

1958, and employee was 

alive on 8-28-58.

1-1-58 Does not meet 6/20 

QC test – meets 

20/40.
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 49 of 56

(Employee who died before 

8-28-58 could not qualify for 

DF under 20/40.)

Application filed 1-1-58 

through 9-6-58.

Later of the following dates 

which occurred before 7-1-58: 

Date D/A application was 

filed; date disabled under Title 

II of SS Act.

Meets QC test for 

applicable period of 

DF; or meets 20/40 

QC test.

Employee did not qualify for 

DF on basis of D/A 

application filed before 9-7-

58.

Latest of: 1-1-55; date D/A 

application was filed; date 

following last day engaged in 

SGA.

Meets QC test for 

applicable period of 

DF; or meets 20/40 

QC test.

Application filed 7-1-58 

through 9-6-58, employee 

not disabled under Title II 

before 7-1-58, or application 

filed after 9-6-58.

Date D/A filed; or if D/A 

application was filed in 

advance of eligibility, the date 

on which a letter or other 

SAME AS ABOVE document 

evidencing an intention to 

apply for D/A was received at 

an office of the Board.

D/A previously denied and 

reapplication for D/A made 

after 9-6-58.

Date on which the letter or 

other document evidencing 

intentions to SAME AS 

ABOVE reapply for D/A was 

received at an office of the 

Board.

Appendix 3 - Effect Of Filing Date And Insured Status Requirements On DF And 

DIB-O/M - Application Filed Before 12-2-64

Application 

Filing Date

DF or DIB 

Insured Status

Retroactivity of DF 

Application

DIB-O/M 

Entitlement 

Date
DCM Part 6

DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 50 of 56

DF or DIB 

filed at SSA 

before 1958.

20/40 with 6/13 

day employee has

DF effective first date ee age 

insured status and under 

disability which continued 

without interruption to date 

application was filed. No DF 

can be established beginning 

earlier than 10-1-41.

DIB effective 

application (6/20) 

50/64, after 6 

months waiting 

period. DIB-O/M 

cannot begin 

before 7-1-57

1-1-58 

Through 8-

27-58.

6/20 - if not met 

20/40 can be 

applied, provided 

the W/E was alive 

on 8-28-58, and 

had not been sent 

notice of decision 

by that date; in 

such cases see 

eligibility 

requirement as 

shown below.

No change. No change.

8-28-58 

through 8-31-

60

20/40 and fully 

insured unless, 

wage earner (W/E) 

has 6/20 and 

possible DIB 

entitlement or 

recalculation for 

months before 9-

1958

No change. 6/20 requirement 

met for DIB entitlement or DF 

recalculation for months 

before 9-1958.

9-1--58, unless

9-1-60 

through 7-1-

62

20/40 and fully 

insured. If not met 

before 10-1960, 

alternate insured 

status can be 

applied 20 QC's 

before quarter of 

disability with at 

least 6 quarters 

after 1950.

No change, unless alternate 

insured status applied. 

Earliest date DF can begin 

under alternate insured status 

is 7-1-52. Insured status is 

10-1960.

No change, 

unless alternate 

insured status 

applied. Earliest 

DF recalculation 

or DIB 

entitlement under 

alternate
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 51 of 56

7-2-62 

Through 12-

1-64

20/40 and fully 

insured.

DF can begin no earlier than 

18 months before the date the 

application was filed, providing 

that the W/E has an insured 

status and is under a disability 

which continued to the day 

application was filed. Effective 

11-1-64, the above 18-month 

restriction was removed, as 

though never in effect, if W/E 

was alive on 12-1-64 and W/E 

was continuously disabled 

from the date of filing until 12-

1-64, or the 1st day of the 

month in which he attained 

age 65 (whichever was 

earlier).

No change.

Appendix 4 - DF And DIB (OM) Legislative History

Effective Date Provisions

7-1-55 O/M increase at age 65, if DF period established.

7-1-55 Insured status for DF set at 6/13 (currently insured).

1-1-57 DIB (OM) increased to disabled employees age 50-64, after 6- month 

waiting period. Earliest entitlement date for benefits under DIB (OM) 

20/40 with 6/13, referred to as 6/20 (fully and currently insured).

1-1-57 Insured status for DF and DIB (OM) 20/40 with 6/13, referred to as 

6/20 (fully and currently insured).

9-1-58 Repeal of DIB (O/M) offset for receipt of Workmen's Compensation 

(WC) and Veterans benefits.

9-1-58 Inclusion of auxiliary beneficiaries in DIB (O/M) for months after 8/58.

9-1-58 Insured status for DF and DIB (O/M) entitlement or recalculation, for 

months after 9/58, 20/40 and fully insured.
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 52 of 56

10-1-60 Alternate insured status for W/E under disability before 1956, 10 QC's 

before quarter of disability, with 6 quarters earned after 1950. The first 

day a DF could begin under this requirement was 7-1-52. The first 

month for which DIB could be paid on this requirement was 10-1960.

10-1-60 Trial work period (TWP) under SS Act changed from 3 to 9 months.

10-1-60 DIB (O/M) terminates 2 months after the month in which the disability 

ends.

11-1-60 DIB (O/M) at any age, after 6-month waiting period. Earliest date of 

entitlement to DIB (O/M) under this requirement was 11-1-60.

7-1-61 DF could begin no earlier than 18 months before application was filed 

based on application filed based on application filed on or after 7-2-62.

11-1-64 Removed above 18-month restriction as though it had never been in 

effect if: W/E was alive on 12-1-64; and he was continuously disabled 

from the date filing until 12-1-64, or until the first day of the month in 

which he attained age 65 (whichever is earlier).

9-1-65 Regular definition of disability liberalized.

9-1-65 Special insured status for blindness before age 31.

9-1-65 Change in application requirements. A W/E may file an application for 

DF or DIB (O/M) could not be paid before 9-1-65.

9-1-65 Offset under DIB (O/M) because of receipt of periodic workmen's 

compensation, for months after 12-1965, and before the disabled 

worker attains age 62.

2-1-68 Expanded regular definition of disability and liberalized definition of 

statutory blindness.

2-1-68 Special insured status requirement for disability before age 31.

2-1-68 Liberalized retroactive filing of an application for closed periods of 

disability, when failure to file within normal 12-month period is due to 

physical or mental incapacity (this change does not extend retroactive 

payments under DIB (O/M) beyond 12 months).

2-1-68 Definition of "average current earnings" for WC offset liberalized.

1-1-75 The RR 1974 Act permits a disability annuitant who meets 20/40 as of 

his ABD but does not meet 20/40 in the month of disability onset to 
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DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 53 of 56

receive a "Medicare Only' ratings that qualifies him only for early 

Medicare even though he is not entitled to a DF.

12-1-80 Extended Medicare coverage may continue for up to 24 additional 

months but only if the disability DF is terminated solely due to SGA.

12-1-88 In accordance with SSA's extended period of eligibility (EPE) 

provisions, and individual may be granted a 36-month entitlement 

period beginning with the month immediately following the completion 

of the 9-month TWP.

1-1-91 The Omnibus Budget Reconciliation Act (OBRA) of 1990 repealed the 

more restrictive definition of disability for entitlement to disabled 

widow(er)'s benefits under the SS Act. Under the new law, vocational 

factors can also be considered for widow(er)'s remarried widow(er)'s 

and surviving divorced spouses when rating these individuals for 

Medicare under the SS Act.

1-1-92 Section 5112 of OBRA grants a TWP in every period of disability and 

provides that the disabled annuitant's TWP ends only when he/she has 

completed 9 service months within a 60 consecutive month period.

Appendix 5 - Wage Quarters Of Coverage Required For SS Fully Insured Status - 

Disability Cases

Disability Onset

Employee Born 

Before 1-2-90

Before Year Age 

62 Attained 

Employee Born 

After 1-1-30

Disability Onset 

Age 31 or later 

Year of Onset QC Required Age at Onset QC Required

1957 06 31 09

1958 07 32 10

1959 08 33 11

1960 09 34 12

1961 10 35 13

1962 11 36 14

1963 12 37 15
DCM Part 6

DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 54 of 56

1964 13 38 16

1965 14 39 17

1966 15 40 18

1967 16 41 19

1968 17 42 20

1969 18 43 21

1970 19 44 22

1971 20 45 23

1972 21 46 24

1973 22 47 25

1974 23 48 26

1975 24 49 27

1976 25 50 28

1977 26 51 29

1978 27 52 30

1979 28 53 31

1980 29 54 32

1981 30 55 33

1982 31 56 34

1983 32 57 35

1984 33 58 36

1985 34 59 37

1986 35 60 38

1987 36 61 39

1988 37 62 40
DCM Part 6

DCM Part 6 Period of Disability/Disability Freeze Revised Nov 22, 2022 Page 55 of 56

1989 38

1990 39

1991 40

Onset Before Age 31 Attained

An employee born after 1-1-30 who has disability onset before age 31 attained must, to 

have an SS fully insured status, have acquired wage QC's equal to one-half (1/2) of the 

quarters that elapsed between the quarter after he attained age 21 and the quarter 

before his disability began.

Onset In or After Year Age 62 Attained

Refer to calendar year in which age 62 attained to find required QC's.