Effective March 23, 2026, the Social Security Administration (SSA) issued SSR 26-1p, a policy interpretation ruling governing continuing disability reviews (CDR’s) for children under age 18 receiving Supplemental Security Income (SSI). The ruling rescinds and replaces SSR 05-03p and clarifies how adjudicators apply the Medical Improvement Review Standard (MIRS) for children.
Although SSR 26-1p does not change the substantive definition of childhood disability, it simplifies the adjudicatory framework and removes obsolete, 20-year-old, instructions that no longer apply to any current child claimant.
Background: Childhood Disability and the MIRS Framework
A child is disabled under Title XVI of the Social Security Act if they have a medically determinable impairment that results in marked and severe functional limitations and lasts or is expected to last at least 12 months or result in death. After finding a child disabled, SSA conducts periodic CDR’s to determine whether disability continues, using the three-step Medical Improvement Review Standard set out at 20 C.F.R. § 416.994a.
Why SSR 26-1p Replaced SSR 05-03p
SSR 05-03p included separate instructions based on whether a child’s comparison point decision (CPD) occurred before or after January 2, 2001. SSA acknowledged that, with the passing of time, no current child claimant could have a CPD issued before that date. This makes the pre-2001 guidance obsolete.
Elimination of Redundant Functional Equivalence Analysis
Under SSR 26-1p, functional equivalence is no longer evaluated at Step 2 of the MIRS process. Step 2 is limited to determining whether the CPD impairment still meets or medically equals the same listing used at the CPD. Functional equivalence is considered only at Step 3, where all current impairments are evaluated together.
What Has Not Changed
SSR 26-1p does not alter the statutory definition of childhood disability, the functional domains, or the ‘whole child’ approach articulated in SSR 09-1p. Children may still be found disabled when their impairments functionally equal the listings.
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