It may be necessary to project RFC to show the claimant’s predicted functional capacity
at 12 months from the onset of disability if:
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•
the MDI does not meet or equal a listing, but continues to be severe 12 months from
onset;
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•
the MDI(s) is currently at listing level but is expected to improve, and there are
significant limitations in the ability to perform basic work activities;
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•
the claimant has a disabling MDI currently, adjudication is within 12 months of onset,
and the MDI is not expected to result in death or be disabling at the end of the 12 months; or
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•
the claimant has a disabling MDI currently, adjudication is within 12 months of onset,
and the MDI is expected to result in death or be disabling at the end of 12 months.
In certain instances, more than one RFC assessment may be necessary to address onset
and duration, although this would be unusual. For more information on situations requiring
multiple RFC assessments, see DI 24510.020C.3.
The projected effects of any type of limitation on a claimant's RFC may vary greatly,
depending on the degree of the claimant’s limitations, and you must determine those
effects by considering the facts of each individual case. Projecting RFC is a matter
of adjudicative judgment.
Example of projection of RFC:
The claimant had a skiing accident and sustained multiple broken bones, a collapsed
lung, and abrasions on 01/25/2024. You are assessing the claim on 04/03/2024, after
receiving all of the requested medical evidence.
The claimant’s condition is not of listing level; however, they are still very slow
in recuperating. You anticipate that the claimant’s current condition is much worse
than it will be on 01/24/2025.
Since their condition prevents SGA, you should project the claimant's RFC to reflect
their predicted functional capacity on 01/24/2025; i.e., 12 months from the date the
claimant first met the medical criteria for disability.
When projecting RFC in the Disability Case Processing System (DCPS) choose “12 Months
after Onset” from the “Evaluation Period” dropdown. DCPS will then automatically populate the date in the “AOD + 12 Months” section. The date in this section may be changed if necessary. Use the narrative
boxes to explain that the RFC reflects the claimant’s functioning 12 months from the
date the claimant first met the medical criteria for disability. For information on
how to complete the paper physical RFC assessment form, see DI 24510.050.
NOTE: Do not project the RFC if a claimant’s MDI(s), though severe, does not currently
prevent the claimant from engaging in SGA. In this case, a denial based on performance
of SGA or an assessment of function and of the ability to do PRW or other work is
appropriate. For an explanation of policy for projecting the RFC, see DI 24510.020A.