There is an organization within Social Security called the Quality Review Board, also known internally as the Disability Quality Branch (DQB). In theory, the DQB just randomly samples determinations from DDS decisions to ensure that Social Security’s disability rules and regulations are being implemented and interpreted properly by the various state DDS agencies – a quality control function.
Recently Tim Moore wrote an excellent post in My Disability Blog regarding the Social Security Disability Quality Review Board. As a former disability examiner, Mr. Moore has extensive experience with the Quality Review Board. Based upon his observations, he concludes that the actions of the Quality Review Board may be more nefarious than its quality control function implies. He states:
there seemed to be a clear pattern that indicated that the social security administration was looking far more closely at cases that examiners had determined should be approved, and not as closely at cases that disability examiners had determined should be denied.
I have been meaning to write about the Quality Review Board for a while, but there is only anecdotal information available. This is because the SSA doesn’t tell anyone when a case goes to quality review, and when a decision is made, it is issued through the regular channels, so you can’t tell from the written decision that the DQB was involved. A DQB review is only shown by a close examination of the electronic claim file.
I have noticed the fingerprints of the DQB on my clients’ claims just 6 or 7 times. Overwhelmingly, as Tim Moore states, it has reviewed claims where benefits were granted. Some claims granted by DDS were then denied by the DQB; with other claims the DQB affirmed the grant of disability benefits. However, when it affirmed the grant of benefits, it often changed the alleged onset date for the claim.
The propensity of the DQB to mess around with onset dates is very troubling. It will affirm the granting of the application by DDS, but select a much more recent onset date than alleged by the claimant and accepted by DDS. So you are left with a partially favorable decision that is awkward to appeal, because you jeopardize ongoing benefits by appealing the onset date.
Messing around with onset dates is not quality control. It is just a different point of view on the medical evidence. In my view, it is just a way to chisel claimants (and, by extension, their attorneys). And because it is done completely behind the scenes, I find it troubling.
If you are a disability lawyer or claimant’s representative, I am curious about your experience with the Quality Review Board. Similiar to mine? Different? Please feel free to leave a comment.