The Social Security Administration has brought its medical continuing disability review process back in-house, ending a period of contractor-based evaluations that disability advocates have long criticized as inconsistent and prone to errors. The shift, announced earlier this year and now fully implemented, means that SSA staff — rather than outside contractors — will make the key determinations about whether beneficiaries still meet the disability standard.
For the roughly 8 million Americans receiving Social Security Disability Insurance benefits, the change carries real consequences. Continuing Disability Reviews, known as CDRs, are periodic checks to confirm that a beneficiary's condition still prevents them from working. Beneficiaries whose conditions improve or who are found no longer disabled can have their benefits terminated — a process that has drawn sustained criticism for its speed, its medical expertise, and its outcomes.
Why the Agency Moved Away from Contractors
For years, the SSA relied heavily on contractors to conduct these medical reviews. The arrangement was intended to handle the sheer volume of reviews efficiently and to allow the agency to scale up or scale down review activity based on budget constraints. But critics, including disability rights organizations and members of Congress, argued that contractor-based reviews often lacked the nuanced understanding of complex disabilities that beneficiaries needed.
Advocates pointed to high overturn rates at the administrative law judge level as evidence that initial contractor reviews were too quick to find beneficiaries no longer disabled. A 2023 report from the Government Accountability Office found that a significant share of beneficiaries who appealed CDR-based benefit terminations to administrative law judges were successful — suggesting the initial reviews did not adequately account for the fluctuating nature of many disabling conditions.
The SSA's decision to bring the process in-house reflects a recognition, at least in part, that disability determination requires ongoing relationships with beneficiaries and a deeper understanding of how conditions evolve over time. Agency staff, advocates argue, are more likely to have the institutional knowledge needed to make accurate assessments than contractors who may have limited experience with complex disability cases.
What the In-House Process Means for Current Beneficiaries
The change affects both how reviews are conducted and how often they occur. Under the previous contractor system, the SSA's volume of CDRs fluctuated significantly based on funding levels — sometimes going years without a review for a given beneficiary. The in-house model gives the agency more direct control over the review schedule and allows it to prioritize reviews based on medical evidence rather than contractual constraints.
Under the new system, beneficiaries selected for review will interact with SSA staff rather than contractor personnel. The agency has stated that its staff will have access to the beneficiary's complete SSA file, including past determinations, medical records already on file, and earnings records. This continuity, the agency argues, should lead to more consistent and accurate decisions.
Beneficiaries who are selected for a CDR will receive a notice informing them of the review and requesting updated medical information. It is critical for beneficiaries to respond promptly with current medical records, physician statements, and any other evidence of their ongoing disability. Failure to respond can result in benefit termination without a full review of the medical evidence.
What to Expect During an In-House CDR
The in-house review process begins with a request for updated medical records from the beneficiary's treating physicians. The SSA staff reviewer — now a federal employee rather than a contractor — will evaluate whether the beneficiary's current condition(s) still meet the disability standard. This standard requires that the beneficiary have a severe physical or mental impairment that prevents them from performing substantial gainful activity and that the impairment has lasted or is expected to last for at least 12 months or result in death.
Unlike the contractor process, which sometimes relied heavily on file reviews without direct beneficiary contact, the in-house SSA reviewers are expected to request a consultative examination only when the existing medical evidence is insufficient to make a determination. The SSA has emphasized that it will not make adverse decisions solely on the basis of outdated medical information — beneficiaries will have an opportunity to provide current evidence before a final determination is made.
If the reviewer determines that the beneficiary is no longer disabled, the SSA will issue a notice of proposed termination. The beneficiary then has the right to appeal that decision, first through a reconsideration request and, if unsuccessful, through a hearing before an administrative law judge. Beneficiaries should not assume that a proposed termination is final — the appeals process has historically resulted in many reversals, particularly when beneficiaries provide comprehensive medical evidence of their ongoing limitations.
Key Differences from the Contractor Model
For beneficiaries and their representatives, the most significant difference may be in the culture of the review. Contractor reviewers were often under pressure to process a high volume of cases efficiently — a structure that, according to advocates, sometimes prioritized speed over thoroughness. SSA staff reviewers, as federal employees, operate under different performance incentives and are subject to different oversight mechanisms.
The in-house model also allows the SSA to maintain a more consistent corps of reviewers who develop expertise in specific categories of impairments. For beneficiaries with complex or rare conditions, having a reviewer who understands the specific nature of their disability — rather than applying a generic checklist — can make a meaningful difference in the outcome.
The SSA has indicated that it will be implementing additional training for its CDR reviewers, particularly in areas such as mental health conditions, chronic pain, and other impairments that are not always easily measured through objective testing. This training, advocates hope, will lead to more accurate determinations that reflect the real-world functioning of beneficiaries.
What Beneficiaries Can Do to Prepare
While the in-house review process is designed to be more thorough and fair than the contractor model, beneficiaries should not wait to be selected for a CDR before gathering their medical information. Keeping medical records organized and up to date is always a good practice for anyone with a disability benefit claim.
Beneficiaries should maintain a current summary of their medical conditions, treatments, and limitations — written in their own words and, where possible, corroborated by their treating physicians. They should also track how their conditions affect their daily functioning, including any activities they can no longer perform, any side effects from medications, and any medical appointments they attend regularly.
If a beneficiary receives a CDR notice, they should respond promptly and completely. The most common reason benefits are terminated following a CDR is not that the beneficiary's condition has improved — it is that the beneficiary failed to provide the SSA with the information it needed to make an accurate decision. Beneficiaries who need assistance gathering medical records or understanding their rights can contact a disability advocate or attorney for help.
The shift to an in-house CDR process represents an opportunity for the SSA to rebuild trust with the disability community. Whether that opportunity translates into better outcomes for beneficiaries will depend on how well the agency trains its staff, how it manages the volume of reviews, and whether it remains open to the input of advocates who have spent years pushing for a more fair and accurate review process.