I-4-1-55.Numbering and Indexing the Administrative Record

Last Update: 9/13/05 (Transmittal I-4-15)

A. Numbering the Administrative Record

After the CRA has assembled all material in the administrative record in proper order, starting with the first page of the Exhibit List, he or she must number all pages in the upper right hand corner. The CRA must ensure that all numbers are dark and clear.

Place page numbers approximately 1 inch from the top and right side of the page. This will prevent deletion of the page numbers during reproduction.

There may be instances when the CRA must stamp the page number over printing or writing, but the CRA must avoid this whenever possible.

If the CRA discovers that, by oversight, a page has not been numbered, the unnumbered page can be identified as an “A,” “B,” etc. page. Show these pages on the index to the record and include them in the total page count for the record.

The CRA must number both sides of any document in the record which refers to the “reverse side.” This includes: Notice of Hearing, Notice of Representative Appointment, the initial determination letter, and form letters to vocational experts and/or medical experts.

If it is necessary to place a page number on a dark background, the CRA must first place white tape on the page and then place the numbers on the tape. For example, part of the Medical History and Disability Report (Form SSA-3368-BK) is shaded green. Because page numbers will not show up well if stamped directly onto this green area, the CRA must place the number on white tape.

When page numbers from prior administrative records are in a current administrative record, the CRA lines through the old page number and renumbers the page.

B. Indexing the Administrative Record

The index to the administrative record is simply a listing of each item in the record and its location. The CRA does not prepare the index until all of the material has been assembled and all of the pages have been numbered.

The index generally shows the following items in sequence:

  • “Exhibit List.”

  • Procedural material in reverse chronological order (starting with the most recent dated item and ending with the earliest dated item).

  • The “Transcript of Oral Hearing” (which appears out of date order).

  • “Exhibits.”

Number the index page at the bottom with “(i)” or “(ii)” for the second page, and date in the lower left hand corner to correspond to the date of certification of the record. If an index has two pages, the CRA types the claimant's name and account number on the second page in the same fashion used on the first page of the index.

The index describes the contents of the record and enumerates the specific legal documents comprising the procedural portion of the record. Describe each document accurately, e.g., attorney's brief, request for reopening, request for extension of time to submit additional evidence, request for additional time to file civil action, deposition of Dr. _______, statement of claimant, request for postponement of hearing, etc. Letters transmitting specific documents are a part of the document they transmit and require no separate entry.

Use the word “correspondence” only to describe letters which are not specifically categorized as part of a legal document or are of little significance.

When the ALJ or AC makes a procedural document (such as request for hearing) an exhibit, list the document in the appropriate place on the index, with the date and the notation: (See Exhibit ___).

Consider the acknowledgment date (when shown) on documents such as the request for hearing and the request for review, as the date of the request; otherwise, use the date the form was completed.

Prepare only one copy of the index and check that no items are missing; that the claimant's name and account number, etc., and all dates are correct; and that the page numbers run consecutively.

Section I-4-1-93 illustrates the format for a typical certified administrative record index. The index heading must show the claimant, wage earner, account number(s), and the name of any party acting on behalf of a minor child claimant or deceased or incapable adult claimant (e.g., Mary Doe (Substitute Party) O/B/O John Doe (Deceased) or Mary Doe (Mother) O/B/O John Doe (A Minor Child).