Social Security Ruling (SSR) 96-1p sets out the agency’s policy in applying federal circuit court rulings that may conflict with SSA’s interpretation of its own regulations.
Sometimes a federal court of appeals may issue a decision on a case that conflicts with Social Security’s interpretation of its own regulations. However, because Social Security is a nationwide program, it will continue to follow its own interpretation of its regulations in other cases within the circuit until and unless it issues an Acquiescence Ruling (AR), setting forth its interpretation of the circuit court ruling and how it will be applied in all cases within the circuit.
The issue of applying a circuit court ruling is often a complex one because there may be differing views on the scope of a ruling and its interpretation.. Therefore, if the agency decides to acquiesce to a circuit court decisiin that conflicts with its own interpretation of agency regulations, it will analyze the decision and issue an acquiescence ruling setting forth specific directions on how to apply the decision to all cases within that particular circuit. In order to ensure uniform standards of adjudication, an AR applies to all levels if adjudication within a particular circuit.
Notwithstanding federal district court decisions that may conflict with the agency’s interpretation of the Social Security Act or regulations, the agency will continue to follow its own interpretation of agency regulations in other cases within that district court’s jurisdiction unless the district court decision directs otherwise, such as may occur in a class action. Social Security only acquiesces in circuit court decisions, and not to decisions of district courts within that circuit.
Disability claimants whose cases are decided between the interim of the date of a circuit court decision and the date of issuance if an acquiescence ruling may request to have their claim readjudicated based on a showing that applying the acquiescence ruling could change the result in their case. These claimants may seek such a readjudication without the need for filing an appeal on their claim.
This material should not be construed as legal advice for any particular fact situation, but is intended for general informational purposes only. For advice specific to any individual situation, an experienced attorney should be contacted.