Effective Dates: 07/23/2024 - Present Previous | Next

TN 8 (07-24)

DI 25020.010 Mental Limitations

A. Policy

1. Nonexertional vs. exertional

Mental limitations are generally nonexertional, but some mental impairments (e.g., depression and conversion disorders) may also limit exertion.

2. Medical listing not met or equaled

  1. a. 

    It cannot be assumed that a failure to meet or equal one of the medical listings for mental impairments equates with the capacity to do at least unskilled work.

  2. b. 

    If a medical listing is not met or equaled, the adjudicator consider whether the individual can meet the mental demands of past relevant work (PRW) and, if not, whether they have the ability to adjust to other work considering their remaining mental and other functional capacities and vocational factors.

For information on using the SSA-2506-BK (Psychiatric Review Technique (PRT)) to evaluate steps 2 and 3 of the sequential evaluation process, see DI 24583.005.

3. Mental demands of unskilled work

  1. a. 

    The basic mental demands of competitive, remunerative, unskilled work include the abilities (on a sustained basis) to:

    • •

      Understand, carry out, and remember simple instructions;

    • •

      Make judgments that are commensurate with the functions of unskilled work (i.e., simple work-related decisions).

    • •

      Respond appropriately to supervision, coworkers, and work situations; and

    • •

      Deal with changes in a routine work setting.

  2. b. 

    A substantial loss of ability to meet any of the basic mental demands listed in DI 25020.010A.3.a, in this section.

    • •

      Severely limits the potential occupational base and thus,

    • •

      Would justify a finding of inability to perform other work even for persons with favorable age, education, and work experience.

  3. c. 

    A person who can meet all of the mental demands listed in DI 25020.010A.3.a, in this section, and has only a mental limitation(s) will almost always be capable of adjusting to other work since their potential occupational base would be the unskilled jobs at all exertional levels.

NOTE: “Substantial loss” cannot be precisely defined. It does not necessarily relate to any particular adjective, number, or percentage. In practical terms, an individual has a substantial loss of ability to perform a basic mental activity when they cannot perform the particular activity in regular, competitive employment but, at best, could do so only in a sheltered work setting where special considerations and attention are provided. This requires professional judgment, on the basis of the evidence in the file in each case. The impairment in a claim of this type may meet or equal the listed medical criteria. Therefore, before making a determination that includes vocational evaluation, the adjudicator should discuss the case with the psychological consultant (PC) to learn whether a significant part of the evidence had previously been overlooked or underrated.

EXCEPTION: In some instances where a person’s vocational profile is extremely adverse (e.g., where the person meets the lifetime commitment medical-vocational profile because they are closely approaching retirement age, have a limited education or less, and have essentially a lifetime commitment to a field of unskilled work that is now precluded by a mental impairment), a finding of “disabled” may be appropriate even though the person has only a mental limitation(s) and can meet all of the demands listed in DI 25020.010A.3.a, in this section. For more information on when the lifetime commitment medical-vocational profile applies, see DI 25010.001B.3.

B. Procedure

1. Introduction

DI 25020.010B.2 through DI 25020.010B.5, in this section, show how the 20 specific abilities listed in on the SSA-4734-F4-SUP (Mental Residual Functional Capacity Assessment (MRFC)) relate to:

  • •

    The basic mental demands of work listed in DI 25020.010A.3.a, in this section, and

  • •

    The ability to perform work at various exertional levels and for specific jobs.

NOTE: The purpose of the list of specific mental abilities before the narrative explanation sections on the SSA-4734-F4-SUP (MRFC) is to ensure that the PC has considered each of the pertinent mental activities and the claimant’s or beneficiary’s degree of limitation for sustaining these activities over a normal workday and workweek on an ongoing, appropriate, and independent basis. It is the narrative written by the PC that adjudicators use as the assessment of MRFC. Adjudicators must take the MRFC assessment and decide what significance the elements discussed in this MRFC assessment have in terms of the person’s ability to meet the mental demands of past work or adjust to other work. This must be done carefully using the adjudicator’s informed professional judgment. For more information on medical-vocational evaluation requirements, see DI 25000.000.

2. Mental abilities needed for any job

a. Understanding, carrying out, and remembering simple instructions

  • •

    The ability to remember locations and work-like procedures.

  • •

    The ability to understand and remember very short and simple instructions.

  • •

    The ability to carry out very short and simple instructions.

  • •

    The ability to maintain concentration and attention for extended periods (i.e., the approximately 2-hour segments between arrival and first break, lunch, second break, and departure).

  • •

    The ability to perform activities within a schedule, maintain regular attendance, and be punctual within customary tolerances.

  • •

    The ability to sustain an ordinary routine without special supervision.

  • •

    The ability to work in coordination with or proximity to others without being (unduly) distracted by them.

  • •

    The ability to complete a normal workday and workweek without interruptions from psychologically based symptoms and to perform at a consistent pace without an unreasonable number and length of rest periods.

b. Use of judgment

  • •

    The ability to make simple work-related decisions.

  • •

    The ability to be aware of normal hazards and take appropriate precautions.

c. Responding appropriately to supervision, coworkers, and usual work situations

  • •

    The ability to ask simple questions or request assistance.

  • •

    The ability to accept instructions and respond appropriately to criticism from supervisors.

  • •

    The ability to get along with coworkers or peers without (unduly) distracting them or exhibiting behavioral extremes.

d. Dealing with changes in a routine work setting — the ability to respond appropriately to changes in (a routine) work setting.

3. Mental abilities critical for performing unskilled work

The claimant/beneficiary must show the ability to:

  1. a. 

    Remember work-like procedures (locations are not critical).

  2. b. 

    Understand and remember very short and simple instructions.

  3. c. 

    Carry out very short and simple instructions.

  4. d. 

    Maintain attention for extended periods of 2-hour segments (concentration is not critical).

  5. e. 

    Maintain regular attendance and be punctual within customary tolerances. (These tolerances are usually strict.) Maintaining a schedule is not critical.

  6. f. 

    Sustain an ordinary routine without special supervision.

  7. g. 

    Work in coordination with or proximity to others without being (unduly) distracted by them.

  8. h. 

    Make simple work-related decisions.

  9. i. 

    Complete a normal workday and workweek without interruptions from psychologically based symptoms and perform at a consistent pace without an unreasonable number and length of rest periods. (These requirements are usually strict.)

  10. j. 

    Ask simple questions or request assistance.

  11. k. 

    Accept instructions and respond appropriately to criticism from supervisors.

  12. l. 

    Get along with coworkers or peers without (unduly) distracting them or exhibiting behavioral extremes.

  13. m. 

    Respond appropriately to changes in a (routine) work setting.

  14. n. 

    Be aware of normal hazards and take appropriate precautions.

4. Mental abilities needed to do semiskilled and skilled work

  1. a. 

    The basic abilities listed in DI 25020.010B.2, in this section, (i.e., the “abilities needed to perform any job” ) are necessary.

  2. b. 

    Often, there is an increasing requirement for understanding and memory and for concentration and persistence, i.e., the ability to:

    • •

      Understand and remember detailed instructions,

    • •

      Carry out detailed instructions, and

    • •

      Set realistic goals or make plans independently of others.

  3. c. 

    Other special abilities may be needed depending upon the type of work and specific functions it involves.

5. Degrees of mental limitations vs. specific jobs

Different jobs require different degrees of mental ability.

EXAMPLE 1: Most competitive jobs require the ability to meet basic standards of neatness and cleanliness. However, the standards that must be met vary greatly depending upon whether the job(s) being considered involve dealing with the public; or working in a factory, a coal mine, a stock yard, etc.

EXAMPLE 2: Most competitive jobs require the ability to travel to and from work and thus, would be precluded by extreme agoraphobia in which the person is incapable of leaving their home. However, a mild case of agoraphobia may not preclude the ability to travel to and from work or preclude work performed in the same (and thus, familiar) setting each day.

To Link to this section - Use this URL:
http://policy.ssa.gov/poms.nsf/lnx/0425020010
DI 25020.010 - Mental Limitations - 07/23/2024
Batch run: 10/24/2024
Rev:07/23/2024