Aspects of Disability Decision Making: Data and Materials

ments is equal in severity and duration to a listedimpairment.In deciding the medical equivalence, regulationsrequire that adjudicators consider theopinion of program physicians or psychologists.A Social Security Ruling (SSR 86-8) was issued in1986 that was designed to clarify the application ofthe “equals” concept. Apart from a slight increasein the number of allowances made on the basis ofequaling the listing in the early 1990s, the numberof “equals” decisions has remained at less than10 percent of all allowance decisions. Failing toestablish that the individual’s impairment meetsor equals the listings does not mean that a claimwill be denied. Benefits may still be awarded if itis found that the reason an individual is not workingis because of a severe impairment. Since theseverity of the impairment must be the primarybasis for a finding of disability, an assessment ofthe individual’s medically-based functional limitationsand remaining capacities must be completedbefore a decision can be rendered at step 4 or step 5of the sequential evaluation process.Residual Functional Capacity (RFC) is anadministrative assessment requiring a thoroughanalysis of all relevant evidence. The purpose ofthe RFC assessment is to determine the extent towhich the individual’s impairment(s) reduces theability to engage in specific work-related physicaland/or mental functions. This residual capacityassessment is meant to reflect the most a personcan do, despite any limitations. Disability examinersmay participate and have input into the RFCassessment at the initial and reconsideration level;however, regulations provide that program physiciansor psychologists are responsible for theactual completion of the RFC. 4When establishing the RFC, the adjudicatormust consider limitations and restrictions imposedby all of the individual’s impairments includingany that are considered to be not severe. Whilea “not severe” impairment, by itself, would nothave more than a minimal impact on work-relatedfunction, it could, when considered in combinationwith other severe impairments, reduce therange of work an individual could do at all or preventan individual from performing past work.Adjudicator conclusions about an individual’sfunctional ability must be supported by specificmedical facts. Statements from the individual or4In the 10 prototype DDSs, “single decision maker” disabilityexaminers are permitted to adjudicate most cases without amandatory concurrence by a doctor. SSI child cases and casesinvolving a mental impairment may not be adjudicated without adoctor’s concurrence.others about functioning must also be consideredand any inconsistencies must be resolved orexplained. The RFC assessment must include awritten explanation of why any symptoms, suchas pain, that result in limitations can or cannot bereasonably accepted as consistent with the medicalevidence. Medical source opinions must be consideredand discussed in the RFC assessment andprimary importance must be given to any opinionexpressed by the individual’s treating source.When a treating source gives an opinion that discussesthe consequences or the implications of anindividual’s impairment and the opinion is supportedby the medical evidence, it must be givencontrolling weight by the adjudicator.The adjudicator must arrive at a conclusionthat expresses the individual’s physical capacityfor such activities as walking, standing, lifting andcarrying. In cases involving mental impairments,adjudicators have to consider such capabilities asthe individual’s ability to understand, to carryout and remember instructions, and to respondappropriately to supervision, coworkers, and workpressures.4. Can the individual, despite any functionallimitations imposed by a severe impairment,perform work that he or she did in the past?Once the RFC assessment is completed, adetermination must be made as to whether, consideringthe impairment-induced functional loss,the individual retains the capability to performrelevant work that he or she has done in the past15 years. At this step, the vocational issues arenarrow and do not consider the effect of age oreducational level. If the adjudicator determinesthat the individual is able to meet the physical andmental demands of any prior work, a finding willbe made that the individual is not disabled irrespectiveof age or education.If it is determined that the individual does nothave the functional capacity to perform past relevantwork, the adjudicator moves on to the fifthand final step of the process.5. Can the individual do any other type of work?At step 5, the burden is on the Social SecurityAdministration to determine whether, given theindividual’s functional abilities, there are sufficientjobs in the national economy that the person canperform. Using the RFC assessment, the adjudicatorconsults SSA’s medical-vocational guidelines,commonly known as the vocational grids. TheAspects of Disability Decision Making: Data and Materials 85