Identification Number:
DI 24510 TN 56
Intended Audience:See Transmittal Sheet
Originating Office:ORDP ODP
Title:Residual Functional Capacity (RFC)
Type:POMS Transmittals
Program:All Programs
Link To Reference:
 

PROGRAM OPERATIONS MANUAL SYSTEM
Part DI – Disability Insurance
Chapter 245 – Medical Evaluation
Subchapter 10 – Residual Functional Capacity (RFC)
Transmittal No. 56, 01/15/2020

Audience

PSC: DE, DEC;
OCO-OEIO: CR, ERE, FDE, RECONE;
OCO-ODO: DE, DEC, DS, RECONE;
OCO: ODD;
ODD-DDS: ADJ, DHU;

Originating Component

ODP

Effective Date

Upon Receipt

Background

This is a Quick Action Transmittal. These revisions do not change or introduce new policy or procedure."

Summary of Changes

DI 24510.066 Options to Simplify Case Processing

We are adding clarification to the instructions in section B. Adoption of Initial Level RFC Assessment stating:

“IMPORTANT: For EDCS reconsideration cases where the initial level RFC or MRFC can be adopted, complete an SSA-416 with the following statement:

I have reviewed all the evidence in file, and the assessment dated XX-XX-XXXX is affirmed, as written.”

DI 24510.066 Options to Simplify Case Processing

A. Partial Completion of RFC

The medical consultant or psychological consultant is responsible for assessing RFC when an RFC is required. Disability examiners may assist the medical or psychological consultant in completing the RFC form. The RFC assessment must describe what the individual can still do despite impairment-related limitations.

The adjudication team does not have to complete every block on the RFC form in fully favorable determinations. When the RFC or MRFC is completed to the point that the case is an allowance and a statement can be made to that effect, the medical or psychological consultant may sign the form without ensuring that every block on the form is completed.

Adjudicators must provide at a minimum, a summary statement reflecting RFC or MRFC on the applicable form. The summary statement must describe applicable exertional and/or nonexertional limitations and/or environmental restrictions and/or other factors pertinent to the favorable determination

B. Adoption of Initial Level RFC Assessment

The adjudicative team may adopt the RFC or MRFC prepared at the initial level of adjudication, rather than completing an entirely duplicative form.

After a complete review of all the evidence in file at the reconsideration level, the adjudicative team may conclude that the RFC or MRFC prepared for the initial determination would not be changed.

If the RFC or MRFC at the reconsideration level will be duplicative of the initial level RFC or MRFC, the adjudicative team may adopt the initial level RFC or MRFC. If there are any changes in the functional limitations, the initial level RFC or MRFC cannot be adopted; and a new RFC or MRFC will have to be prepared.

In the remarks section of the initial level RFC the following statement will be entered:

“I have reviewed all the evidence in file, and the assessment of (date) is affirmed, as written.”

IMPORTANT: For EDCS reconsideration cases where the initial level RFC or MRFC can be adopted, complete an SSA-416 with the following statement:

"I have reviewed all the evidence in file, and the assessment of (date) is affirmed, as written."

The medical or psychological consultant, who must be a different decisionmaker than the initial level medical or psychological consultant, must sign the statement including other identifying information, as appropriate, and date.

NOTE: Adopting the RFC or MRFC assessment is not the same as affirming the initial determination. When you adopt an initial level RFC or MRFC assessment, consider whether to affirm the initial determination based on the facts of the case. For instructions on affirming initial level determinations at reconsideration, see DI 27021.010 Affirmation of a Prior Disability Determination.

C. MC/PC Signature on RFC/MRFC Negates Need For MC/PC Signature on Disability Determination

A medical consultant (MC) or psychological consultant (PC) must sign the SSA-4734-BK, Physical Residual Functional Capapcity Assessment form or SSA-4734-F4-SUP, Mental Residual Functional Capacity Assessment form. If a signed RFC assessment forms the basis for the disability determination, and the RFC assessment reflects that the MC's or PC's findings complete the medical portion of the determination, the MC or PC is not required to sign the Disability Determination and Transmittal Form (SSA-831 C3/U3, SSA-832 C3/ U3, or SSA-833 C3/U3). See DI 26510.090 for procedures.


DI 24510 TN 56 - Residual Functional Capacity (RFC) - 1/15/2020