TN 3 (07-15)
DI 28015.315 Comparison Point Decision (CPD) Residual Functional Capacity (RFC)
A. No Reassessment
Never reassess the CPD RFC.
B. If CPD did not include an RFC assessment
If the CPD should have included an RFC assessment but does not, assign the maximum RFC consistent with an allowance.
If the CPD was based on an individualized functional assessment (IFA), see the instructions for preparation of CPD RFC assessment for Title XVI adults found disabled before age 18 in DI 28005.016 and DI 28005.017.
C. If CPD is a Title XVI childhood disability determination
For Title XVI recipients originally allowed as children and who attained age 18 before 08/22/96, apply the continuing disability review (CDR) evaluation process described in DI 28005.016 and DI 28005.017.
Certain cases require a disability redetermination instead of a CDR. If the recipient was originally allowed as a Title XVI child and no age-18 disability redetermination was done, follow the instructions in DI 28005.003.
D. One CPD RFC
Use the RFC from the CPD, whether it was recorded on a form or noted elsewhere in file. Do not substitute current judgment for that of the prior adjudicator.
E. Multiple CPD RFCs
If a CPD evaluated under the medical improvement review standard (MIRS) included multiple RFC assessments, use the CPD RFC that considered all impairments.
F. No CPD RFCs
The CPD used a medical/vocational basis but did not include an RFC assessment, or
The CPD is assumed to be medical/vocational. Assess the individual's prior RFC based on all available evidence concerning the impairment(s) and particular limitation(s) at the time of the CPD, and assign the maximum RFC consistent with the CPD, per DI 28015.005.
Although a particular level of RFC is assigned, this does not represent an independent RFC assessment.
To determine what RFC represents the approximate maximum RFC consistent with the CPD, see DI 25015.001 and DI 25020.001.
A special procedure applies if the CPD was based on an IFA, see DI 28005.016 and DI 28005.017.
G. Related Procedure
For information on how to record prior RFC assessments in the situations when there is no CPD RFC assessment, see DI 28015.855.
H. Example of a prior RFC
If the beneficiary’s age, education, and work experience were such that an RFC consistent with light work would have resulted in an allowance but an RFC for more than light work would have resulted in a denial, assign a “prior RFC" consistent with light work.