; or (ii) the Commissioner has failed to observe procedures required by law in connection with the closure, consolidation, or new limitation on access. . (2) Effective date The amendment made by paragraph (1) of this subsection shall apply with respect to closures and consolidations of field or hearing offices and impositions of new limitations on access to such offices occurring after the cessation of the moratorium under subsection (a) of this section. 4. GAO study on disability hearings Not later than January 1, 2019, the Comptroller General of the United States shall submit to Congress a report that describes the average length of time after a request for review of an initial adverse determination with respect to an application for a disability insurance benefit under title II of the Social Security Act has been made until a final decision is issued with respect to such application.