Age 18 Redetermination

SSA’s Definitions of Disability: Child vs. Adult

• Children: Disability is determined by "marked and severe functional limitations." Functional abilities are compared to those of children of the same age who do not have impairments.
• Adults: The definition of disability is different for adults. Functional impairments are measured against the ability to work and perform substantial gainful activity (SGA), measured in part by an income level set annually by SSA.
• Due to these differences, an age 18 redetermination is a new medical decision based on adult standards.

The Redetermination Process

1. Written Notification. The beneficiary will receive an Age 18 Notice of Disability Redetermination from the Social Security Administration.
2. Interview. The beneficiary will have an interview with an SSA representative at the local SSA field office or by phone.
   • SSA will ask about the youth’s income and resources, past and current employment, and their current living arrangement. The SGA step of the sequential evaluation process will not apply.
   • The following forms will be completed during the interview
     • SSA-3368: Adult Disability Report
     • SSA-827: Authorization to Disclose Information to SSA This allows DDS to collect medical records to determine if the applicant’s diagnoses have persisted into adulthood.
   • As the applicant’s SOAR case manager, you can accompany them to this interview and provide important information. See SOAR Tips below!
3. Medical Eligibility. The field office will send the case to DDS. DDS will review all medical information to determine if the youth’s impairments meet the adult definition of disability.
   • DDS will consider all current impairments, including any new impairments even if they do not meet the duration requirement.
   • DDS may order consultative exams if necessary.
4. Notice of Decision. The applicant will receive a written notice of decision from SSA.
   • If the decision is favorable benefits will continue uninterrupted.
   • If the decision is unfavorable, the applicant is no longer eligible for SSI, and benefits will cease after a 2-month grace period. However, benefits may continue if the applicant appeals the decision or is granted Section 301 status .

Section 301 Status

A youth who has been deemed ineligible for SSI at age 18 redetermination may continue to receive benefits if they are participating in an approved special education or vocational rehabilitation program. When benefits continue under this program it is referred to as Section 301 status.

• The individual must have been enrolled in the program prior to the age 18 redetermination.
• SSI benefits will continue until the youth completes or leaves the program.
• Examples of approved programs include:
  • Individualized Education Program (IEP) for a young adult age 18 through 21
  • An individualized plan for employment through a Vocational Rehabilitation agency
  • An approved Plan to Achieve Self Support (PASS)
  • A written service plan with a school under Section 504 of the Rehabilitation Act
    • Supportive services using an individualized written employment plan

Filing an Appeal

• If a youth’s benefits stop at age 18 they may appeal the decision through reconsideration or an appeal to an Administrative Law Judge.
• If an appeal is filed within 10 days of the redetermination notice, SSI payments will continue while the appeal is in process.

SOAR Tips for Assisting with an Age 18 Redetermination

• Start the conversation early. When an SSI recipient is approaching age 18, begin preparing for redetermination as soon as possible. Talk about the process with the SSI recipient and (with their consent) their family and support team (teachers, health providers, parents/caregivers, etc.). Encourage them to review the SSA guide What You Need to Know about Your Supplemental Security Income (SSI) When You Turn 18.
• Collect medical evidence that documents the applicant’s disabling conditions using the SSA-827 and your agency release of information. Note: DDS will not need medical evidence back to the original onset date. Instead, focus efforts on medical evidence from the previous two years.
• Collect non-medical evidence that documents living arrangement, income and resources.
• Revise or write a Medical Summary Report (MSR) that paints a picture of the applicant and clearly shows the link between their diagnoses and limitations in the areas of physical and mental functioning.
  • Accompany the beneficiary to the redetermination interview. Bring the documentation you have collected, the MSR, SSA-3368, SSA-827, and SSA-1696 Appointment of Representative.
  • SSA will not process the redetermination more than 30 days before the beneficiary turns 18.

For more information, check out SSA's Resources for Transition Age Youth!