TN 55 (02-10)

DI 24510.057 Sustainability and the Residual Functional Capacity (RFC) Assessment

Citations:

Sections 223(d) and 1614(a) of the Social Security Act, as amended.

Regulations No. 4, subpart P, Sections 404.1513, 404.1520, 404.1520a, 404.1545, 404.1546, 404.1560, 404.1569a, and

Appendix 2; and Regulations No. 16, subpart I, Sections 416.913, 416.920, 416.920a, 416.945, 416.946, 416.960, 416.969a; and

Social Security Ruling 96-8p.

A. Policy for Residual Functional Capacity (RFC)

RFC represents the most a claimant can do despite his or her limitations or restrictions. Ordinarily, RFC is the individual's maximum remaining ability to do sustained work activities:

  • In an ordinary work setting,

  • On a regular and continuing basis, and

  • For 8 hours a day, 5 days a week, or an equivalent work schedule.

However, if a claimant is unable to sustain a 40-hour workweek because of a severe medically determinable impairment (MDI), the adjudicator or medical consultant must discuss sustainability in the RFC.

B. Procedure for assessing the RFC

1. Claimant’s ability to sustain a 40-hour workweek

In assessing RFC, consider the claimant’s ability to perform work activities in an ordinary work setting on a regular and continuing basis and describe the maximum amount of each work-related activity the claimant can perform on a sustained basis based on the evidence available in the case record.

2. Claimant’s inability to sustain a 40-hour workweek

If a claimant is unable to sustain work activities in an ordinary work setting on a regular and continuing basis, explain why the claimant is not capable of sustaining a 40-hour workweek.

In most cases, the exertional and nonexertional limitations resulting from an MDI can be described using the functions listed in the check boxes on the RFC. (For completion of the RFC form, see DI 24510.050, DI 24510.061, and DI 24510.063 through DI 24510.065.) If the claimant is not capable of sustaining a 40-hour workweek, the check boxes should reflect the conclusions reached in the narrative portion of the RFC.

In other cases, the claimant may have limitations that prevent him or her from sustaining a 40-hour workweek which cannot be described using the functions listed in the RFC checkboxes. In these rare instances, it may not be possible to complete all of the check boxes. The adjudicator should explain in the narrative how the claimant’s MDI(s) prevents him or her from sustaining a 40-hour workweek.

3. Partial completion of the RFC

In fully favorable decisions, the adjudicative team does not have to complete every block on the RFC form (DI 24510.066A, Options to Simplify Case Processing). If a claimant is unable to sustain a 40-hour workweek:

  • Complete the check boxes that are relevant to the inability to sustain a 40-hour workweek; and

  • Provide a narrative rationale explaining how this determination that the claimant is unable to sustain a 40-hour work week was reached. (For narrative requirements, see DI 24510.057B.4. in this section.)

EXAMPLE: A claimant has exertional limitations resulting from an MDI that limit him or her to lifting and carrying 20 pounds occasionally and 10 pounds frequently, and standing and walking 2 hours in an 8-hour wor