Importance of function-by-function analysis in social security disability
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Importance of a function-by-function analysis of an individual’s remaining work capacity in a social security disability case

by Melvin Cook

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Social Security Ruling (SSR) 96-8p outlines rules on determining a disability claimant’s residual functional capacity (RFC).

RFC is the person’s maximum capability of doing work-like activities on a sustained basis, meaning eight hours a day for five days a week or an equivalent work schedule.

RFC is used at steps four and five of social security’s five-step sequential evaluation process.

In this process, if a person can be found either “disabled” or “not disabled” at any step, then the evaluation does not proceed any further.

Step four considers whether a person can do their prior relevant work (PRW), either as they actually performed it, or as it is generally performed in the national economy.

Step five considers whether a person who is found not to be able to do their prior work can do any substantially gainful work existing in significant numbers in the national economy.

In assessing a person’s RFC, an adjudicator must do a function-by-function analysis of all limitations or restrictions that are supported by evidence in the file.

In doing the function-by-function analysis, an adjudicator must only consider limitations caused by a medically determinable impairment. Factors such as age, height, or body habitus (constitution, or physique) are not considered. Likewise, functional limitations that are not supported by evidence in the file are not considered.

Social security classifies work broadly by its exertional requirements. Exertional requirements are the seven strength demands of a job, which are sitting, standing, walking, lifting, carrying, pushing, and pulling. The broad categories of work encompassed by these requirements are sedentary, light, medium, heavy, and very heavy.

In assessing a person’s RFC, the function-by-function analysis is necessary before characterizing the person’s capabilities in terms of the broad exertional work categories. Failure to do so could result in errors in a decision.

For example, if a person’s capabilities are first characterized in terms of an exertional work category, an erroneous decision could be made at step four, finding incorrectly that the person cannot do their prior work as it was actually performed. This is because the person’s employer may not have required all the work functions that are typically required of similar work in the national economy. For example, suppose the person’s prior work was “medium” work as generally performed in the national economy. Suppose further that the person has an RFC that is less than medium. If the person’s employer only required performance of the job at a less than medium level, the person may still be able to perform the essential functions of this past work as it was actually performed. Without a function-by-function analysis, it will be impossible to determine whether the person could still perform the essential functions of the job as they actually performed it.

Conversely, if a function-by-function assessment is not done, it could lead to an erroneous decision of “not disabled” at step four. If certain functional limitations are overlooked, it may be mistakenly determined that the person could do their prior work as it is generally performed in the national economy.

Only after the function-by-function assessment is done may a person’s work capacity be defined in terms of the broad exertional categories.

In assessing RFC, adjudicators must consider all the evidence in the file and include a reasonable narrative discussion of the pertinent facts. This includes consideration of medical source statements, which are opinions from professional medical sources regarding a person’s limitations or restrictions.

Treating physician’s opinions are entitled to special consideration. If they are well-supported by the evidence in the file, and are not inconsistent with any substantial evidence in the file, such opinions are entitled to controlling weight.

The functions that must be assessed include the seven strength demands of a job. For example, a person may be restricted to standing and walking for 5 out of 8 hours in a work day. Or, a person may be limited to lifting only 10 lbs. or less on an occasional basis (meaning up to one-third of a work day).

An adjudicator must also assess any nonexertional limitations that are supported by evidence in the file. These include any non-strength demands of a job. These could be postural limitations (such as bending, stooping, kneeling, crouching, or crawling), manipulative limitations (such as reaching and handling), communications limitations (such as hearing and speaking), visual limitations, environmental limitations (such as inability to tolerate extreme temperatures, or dust and fumes in a work environment), and mental limitations (such as understanding and remembering instructions, responding appropriately to supervision, co-workers and the public, and adapting to routine changes in the work setting).

The function-by-function assessment is at the heart of any disability case. Functional limitations are the building blocks of a person’s RFC. If the person is limited such that they cannot do their prior work or any substantial gainful work in the national economy, they will be found disabled.

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.

Contact a Salt Lake City Attorney Committed to Protecting Your Rights

When it comes the family law and social security disability, each client and case is different. It is also important to select an attorney with the experience, skills and professionalism required to address your legal issues. To learn more, contact the Salt Lake City law offices of Melvin A. Cook and schedule an initial consultation to discuss your case.

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