TN 3 (07-15)
DI 28015.850 Types of Residual Functional Capacity (RFC) Assessment(s) Needed
Medical improvement review standard (MIRS) continuing disability reviews (CDRs) sometimes require more than one RFC assessment.
One that considers only the comparison point decision (CPD) impairment(s) to assess “MI-related to the ability to work,” (MIRS RFC); and
Another that considers all current impairments to assess current disability, and to document the file for future CDRs if disability continues.
A. General rules of RFC assessment
Follow the general rules of RFC assessment in DI 24510.001.
Consider age and time on the rolls when appropriate.
1. MIRS RFC considers CPD impairments only
Consider only the CPD impairment(s) to prepare the current “MIRS RFC” assessment, when using RFC comparison to relate MI to the ability to work as described in DI 28015.300.
If there are no new impairments since CPD, the MIRS RFC is also the “current” RFC.
2. Current RFC considers all current impairments
If MI is related to the ability to work, assess current RFC considering all current impairments when deciding whether the beneficiary is able to do past work or other work. (See DI 28005.015B.7. and DI 28005.015B.8)
3. Referrals to DDS medical consultants and psychological consultants
In claims where we need a CPD RFC assessment, indicate the type(s) of RFC assessment needed and the date of the CPD. When requesting preparation of an RFC form showing prior RFC, discuss the case with the DDS MC/PC or provide the MC/PC with a brief description of the maximum exertional or mental work level capacity consistent with the CPD.
4. Current RFCs for future CDRs
a. When required
Document the file concerning current RFC considering all impairments (even though not needed for the current CDR) if:
You do not need this type of RFC if the beneficiary will be age 61 before the next scheduled CDR.
b. Documenting These RFCs
Because there has been no MI related to ability to work, find the beneficiary has no more current RFC or functional limitation than shown in the CPD RFC.
If the CPD RFC assessment currently applies, note this in the file, and you do not need a current overall RFC assessment in this situation.
If evidence already received shows decreased RFC since the CPD RFC, prepare a current RFC assessment considering all available evidence.