TN 3 (07-15)

DI 28015.300 General Approach to Residual Functional Capacity (RFC) Comparison in Continuing Disability Reviews (CDRs)

A. Types of RFCs

1. Comparison point decision (CPD) RFC

The CPD RFC is the RFC assessed at the time of CPD.

2. Medical improvement review standard (MIRS) RFC

The MIRS RFC is a current assessment of only the impairment(s) present at the time of CPD. Use this RFC assessment to compare with the CPD RFC to determine if medical improvement (MI) is related to the ability to work.

3. Current RFC

A current RFC considers all impairments (both CPD and current).

B. RFC and finding of MI related to the ability to work

Find MI is related to ability to work only if the beneficiary’s RFC increased, based on changes in symptoms, signs, and laboratory findings.

CDRs may require more than one type of RFC assessment. For a detailed description of the types of RFC assessments that may be required, see DI 28015.850.

For Title XVI recipients originally allowed as children, and who attained age 18 before 08/22/96, apply the CDR evaluation process described in DI 28005.016 and DI 28005.017.

See Public Law 104-193 for Title XVI recipients originally allowed as children who attained age 18 on 08/22/96 or later located in DI 23570.001.

Certain cases require a disability redetermination instead of a CDR. If we originally allowed the individual as a Title XVI child, and there has been no age-18 disability redetermination, follow the instructions in DI 28005.003.

C. MIRS RFC

1. Current assessment of impairment(s) present at the time of the CPD

  • Consider only the impairment(s) present at the time of the CPD.

  • Consider the CPD impairments only if the file included any evidence of the alleged impairment(s) before the CPD.

2. Assumption

Assume that a limitation results from an impairment present at the time of the CPD, when:

  • A new impairment(s) began after the CPD; and

  • There is no medical basis for deciding whether a particular limitation results from an impairment present at the time of the CPD or one that began later.

EXAMPLE: An individual had a respiratory impairment at the time of the CPD and subsequently developed a cardiac impairment. It is medically impossible to determine which impairment causes this individual's shortness of breath. Assume the shortness of breath is from the impairment present at the time of the CPD (the respiratory impairment).

3. Consider age and time on the rolls when assessing an RFC

Consider age and time on the rolls when assessing an RFC if the beneficiary is over age 50 and has been receiving disability benefits for a considerable period of time. Generally, use a period of at least seven years as “a considerable period of time.”

D. CPD RFC

Compare the MIRS RFC with the CPD RFC to determine if MI is related to the ability to work. If the MIRS RFC has not increased from the CPD RFC, find MI not related to the ability to work, and continue benefits if no exception applies. If the MIRS RFC increased from the CPD RFC, find that MI is related to the ability to work and consider the remaining steps in CDR sequential evaluation process.

E. Reference

DI 28015.310 Considering Age and Time on the Rolls When Assessing Residual Function Capacity (RFC) in Continuing Disability Reviews (CDRs)


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DI 28015.300 - General Approach to Residual Functional Capacity (RFC) Comparison in Continuing Disability Reviews (CDRs) - 07/23/2015</