TN 41 (10-26)

DI 25015.020 The Effects of a Less Than Sedentary Residual Functional Capacity (RFC) on the Ability to Adjust to Other Work

CITATIONS:

Sections 223(d) and 1614(a) of the Social Security Act, as amended.
20 C.F.R. 404.1520, 404.1520a, 404.1545, 404.1546, 404.1560, 404.1562 through 404.1569a; Appendix 2 to Subpart P of Part 404 – Medical-Vocational Guidelines; and 416.920, 416.920a, 416.945, 416.946, 416.960, 416.962 through 416.969a.

Social Security Rulings (SSR) 96-9p and 96-8p.

A. Step five of the sequential evaluation process

At the fifth step of the sequential evaluation process, we determine whether an individual can adjust to other work. This analysis requires an individualized assessment and documentation of all relevant medical and vocational factors, such as:

  • •

    How the relevant case evidence was considered (see DI 24503.000);

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    The nature and extent of the limitations or restrictions (see DI 24501.006 and DI 25001.001);

  • •

    The individual's maximum remaining capacity to perform sustained work on a regular and continuing basis (see DI 24510.000);

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    The interaction of the vocational factors of age, education, and work experience (see DI 25000.000).

For information on the sequential evaluation process, see DI 22001.001.

B. Expressing RFC as a range of work

At step five of the sequential evaluation process, when the RFC is not based solely on non-exertional limitations and restrictions (e.g., mental, visual, communicative, etc.), the exertional limitations and restrictions are expressed in terms of the exertional levels of work: sedentary, light, medium, heavy and very heavy work.

An RFC for a "full range" of work at any of these exertional levels reflects the ability to perform all or "substantially all" of the unskilled occupations existing at that level and, with some exceptions, at lower levels. However, the ability to perform "substantially all" activities required in an exertional range of work does not mean the individual can perform every function without exception.

Generally, if a limitation or restriction is:

  • •

    Slight or does not involve an activity typically required in sedentary work, it will have little to no impact on the unskilled sedentary occupational base.

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    More than slight and up to significant, or involves an activity typically required in sedentary work, it could have a considerable impact on the unskilled sedentary occupational base.

IMPORTANT: Neither the Act nor our regulations and rulings define terms such as "significant" or "slight" in the context of the effect of limitations or restrictions on the unskilled sedentary occupational base. The adjudicator must consider all relevant case facts, use their judgement when evaluating the extent of the erosion to the unskilled sedentary occupational base, and document these findings in the vocational analysis in the Disability Case Processing System (DCPS).

For information on documenting the rationale, see DI 26510.001.

C. Medical-vocational guidelines

The medical-vocational guidelines, or "the grids," consist of one numbered rule (204.00) and three tables (Table No. 1, Table No. 2, and Table No. 3) of numbered rules. Each numbered rule in the tables of Appendix 2 of Subpart P of the regulations resolves the issue of ability to adjust to other work by addressing specific combinations of RFC, age, education, and past work experience.

When a rule directs a determination of not disabled, the regulations provide the evidentiary support that work exists in significant numbers in the national economy to which the individual can adjust. When a rule is used as a framework for a determination, the adjudicator must cite the evidence supporting the conclusion that the individual can or cannot adjust to other work.

The grid rules must be used as a framework for considering the extent of any erosion of the unskilled sedentary occupational base when an individual's exertional capacities:

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    Are determined to be less than what is required to perform a full range of sedentary work; or

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    Would direct a decision of "not disabled" but the individual also has a non-exertional limitation(s) that narrows the potential range of sedentary work to which they could adjust (i.e., the individual has the exertional capacity to do the full range of sedentary work, but the sedentary occupational base is reduced because of at least one non-exertional limitation).

For information on the medical-vocational guidelines, see DI 25025.000.

D. Unskilled sedentary occupational base analysis

The occupational base:

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    Consists of the unskilled occupations an individual is capable of performing considering their limitations and restrictions.

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    May be broadened by the addition of specific skilled or semiskilled occupations that an individual is capable of performing based on recent education or transferable skills.

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    Will be eroded when an individual is unable to perform a full range of sedentary work due to their assessed limitations and restrictions so that they are unable to perform substantially all of the occupations administratively noticed in Table No. 1. The extent of the erosion will depend on the nature of the limitation or restriction and whether the ability is typically required in sedentary work (see DI 25015.020E in this section).

When a finding of disabled is not possible based on the strength limitations of the RFC alone, the adjudicator must assess the degree to which any additional non-exertional limitations or restrictions could erode the occupational base for the appropriate rule in the medical-vocational guidelines. In some instances, the impact of the limitation or restriction will be so slight that it would clearly have little effect on the occupational base. In other instances, the impact of the limitation is considerably greater, resulting in a significant erosion of the occupational base. There may still be other instances in which the effect(s) of the limitation or restriction on the occupational base is less obvious and the adjudicator needs to consult a vocational specialist or vocational expert.

When the RFC does not reflect a full range of sedentary work, the adjudicator will (1) use the sedentary rule that comes closest to the claimant's medical-vocational factors of age, education, and past work experience as a framework for a determination and (2) explain in the disability case processing system (DCPS) whether the claimant's limitations or restrictions significantly erode the occupational base for sedentary work. Adjudicators may also use or cite information from SSR 83-10, 83-12, 83-14, 85-15, or 96-9p to support their judgment.

For information on:

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    The occupational base, see DI 25025.001C.2.

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    Using a rule when the individual has exertional and non-exertional limitations and restrictions, see DI 25025.020.

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    Support for a framework "not disabled" determination, see DI 25025.030.

E. Guidelines for determining the effects of certain limitations and restrictions on the unskilled sedentary occupational base

Generally, when an ability is typically not required in sedentary work (e.g., feeling objects with finger tips, crouching, climbing ropes or scaffolding, see also DI 25025.030D.3.) even a significant limitation or restriction of that ability would likely have a minimal effect on the unskilled sedentary occupational base.

When an ability is typically required in sedentary work (e.g., handling small objects or fingering), even a slight limitation could have a considerable impact on the unskilled sedentary occupational base.

1. Exertional limitations and restrictions

Exertional capacity addresses an individual's limitations of physical strength and defines their ability to perform each of the strength demands: sitting, standing, walking, lifting, carrying, pushing, and pulling. Although mental impairments are usually considered non-exertional, some conditions (e.g., depression or a conversion reaction) could affect an individual's exertional capacity, (see DI 24510.006C.6.c.)

  1. a. 

    Lifting/carrying and pushing/pulling: The full range of sedentary work involves lifting no more than 10 pounds at a time and occasionally lifting and carrying articles like docket files, ledgers, or small tools. A significant limitation or restriction in these abilities (e.g., the ability to lift or carry is limited to no more than 1 or 2 pounds on an occasional basis) would result in a considerable erosion of the unskilled sedentary occupational base. A limitation or restriction that is more than slight but less than significant (e.g., the ability to carry about 8 pounds on an occasional basis) may require the use of a vocational specialist or vocational expert to determine the effect of the limitation or restriction on the unskilled sedentary occupational base.

    Generally, a limitation or restriction in the ability to push or pull will have little effect on the unskilled sedentary occupational base (see also DI 25025.030D.2.).

  2. b. 

    Standing and walking: The primary difference between sedentary and most light work is the maximum capacity to stand and walk "occasionally." The full range of sedentary work requires the ability to stand and walk for about 2 hours of an 8-hour workday. A significant limitation or restriction in the ability to stand and walk (e.g., ability to stand and walk for no more than a few minutes during the workday) will have a considerable effect on the unskilled sedentary occupational base. A slight limitation or restriction in the ability to stand and walk (e.g., ability to stand or walk for slightly less than 2 hours of an 8-hour workday) will not, by itself, have a considerable effect on the unskilled sedentary occupational base. For a limitation or restriction that is more than slight but less than significant, consider using a vocational specialist or vocational expert.

  3. c. 

    Sitting: The full range of sedentary work requires that an individual can sit for about 6 hours of an 8-hour workday, with a morning break, a lunch period, and an afternoon break at about 2-hour intervals. A limitation or restriction in the ability to sit for about 6 hours of an 8-hour day with breaks at 2-hour intervals will have an effect on the unskilled sedentary occupational base.

    Some individuals might need to alternate the ability to sit and stand or walk (see DI 25015.020E.1.d. in this section)

    NOTE: In unusual cases, some individuals retain the ability to stand and walk but are limited in the ability to sit. If an individual is able to stand or walk for about 6 hours of an 8-hour day, and meets the other requirements for light work, there may be light occupations in the national economy they can do even if they are not able to do all of the sedentary occupations.

    For such a scenario, adjudicators must use Table 2 of the medical-vocational guidelines as a framework for a determination because the individual's capacity aligns with the requirements of light work, except they are limited in the ability to sit. While a significant limitation or restriction in the ability to sit would have a considerable effect on the unskilled sedentary occupational base, because the light occupational base is robust the inability to perform the sitting required in most sedentary occupations will generally not have a considerable effect on the unskilled light occupational base.

  4. d. 

    Alternate sitting and standing: An individual may need to alternate the sitting required in a full range of sedentary work with standing. The RFC assessment must specify the frequency of the limitation or restriction (e.g., the frequency of the need to alternate sitting and standing, and the length of time needed to stand) and document the supporting evidence. When scheduled breaks or a lunch period do not accommodate the individual's need to periodically stand due to their impairment, the occupational base for a full range of unskilled sedentary work will be eroded. The extent of the erosion will depend on the case facts, such as the frequency of the documented need to alternate sitting and standing, and the length of time needed to stand. In these situations, consulting a vocational specialist or vocational expert may be useful to determine whether the individual can adjust to other work.

  5. e. 

    Hand-held assistive device (HHAD): Most unskilled sedentary work requires only occasional lifting and carrying of small objects and a maximum lifting capacity of only 10 pounds. Additionally, the ability to use both hands to handle small objects is generally not necessary when performing the standing and walking requirements of sedentary work.

    As such, an individual who is limited to sedentary work because of an impairment affecting one lower extremity and must use an HHAD to aid in standing or walking (e.g., an unstable knee) or to reduce pain, and has no other functional limitations and restrictions, may still have the ability to make an adjustment to sedentary work that exists in significant numbers.

    Conversely, the unskilled sedentary occupational base for an individual who must use an HHAD because of significant limitations or restrictions involving both lower extremities (e.g., a neurological impairment) may be significantly eroded.

2. Non-exertional limitations and restrictions

Once we determine that an individual can meet the primary strength requirements of sedentary work, we will consider the effects of any non-exertional limitations and restrictions on the unskilled sedentary occupational base.

  1. a. 

    Postural: Limitations or restrictions related to such activities as climbing ladders, ropes, or scaffolds, balancing (e.g., on narrow, slippery, or erratically moving surfaces), kneeling, crouching, or crawling would not usually erode the occupational base for a full range of unskilled sedentary work because those activities are generally not required in sedentary work.

    However, most unskilled sedentary occupations require balancing when walking or standing on level terrain and the ability to occasionally stoop.

  2. b. 

    Manipulative: Any significant limitation or restriction of an individual's ability to handle and work with both hands will result in a significant erosion of the unskilled sedentary occupational base. Most unskilled sedentary jobs require:

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      Good use of both hands and the fingers (i.e., bilateral manual dexterity);

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      Use of the fingers for fine movements (i.e., to pick or pinch); and

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      Good use of the hands and fingers for repetitive hand-finger actions.

    When a limitation or restriction is less significant, especially if the limitation is in the non-dominant hand, it may be useful to consult a vocational specialist or vocational expert. The ability to feel the size, shape, temperature, or texture of an object by the fingertips is a function required in very few jobs and a limitation or restriction of this ability would not, by itself, significantly erode the unskilled sedentary occupational base.

  3. c. 

    Visual: Most sedentary unskilled occupations require working with small objects. If a visual limitation or restriction prevents an individual from seeing the small objects involved in most sedentary unskilled work, or if an individual is not able to avoid ordinary hazards in the workplace (e.g., boxes on the floor, doors ajar, or approaching people or vehicles) there will be a significant erosion of the sedentary occupational base. These cases may require the use of a vocational specialist or vocational expert.

  4. d. 

    Communicative: Basic communication is all that is needed to do unskilled work. If the individual retains the ability to hear and understand simple oral instructions or communicate simple information, the unskilled sedentary occupational base will not be significantly eroded.

  5. e. 

    Environmental: In general, few occupations in the unskilled sedentary occupational base require work in environments with extreme cold, extreme heat, wetness, humidity, vibration, or unusual hazards. "Hazards" such as moving mechanical parts of equipment, tools, or machinery; electrical shock; working in high exposed places; exposure to radiation; working with explosives; and exposure to toxic, caustic chemicals are unusual in unskilled sedentary work.

    Even a need to avoid all exposure to these conditions would not, by itself, have a considerable effect on the unskilled sedentary occupational base. Nearly all work environments entail some level of noise and some exposure to odors or dust. A restriction involving exposure to these conditions must be evaluated on an individual basis and the RFC must clearly explain the nature and extent of the restriction (e.g., avoid even small amounts or only excessive amounts of dust).

  6. f. 

    Mental: Generally, unskilled sedentary work requires the ability to meet the basic mental demands of competitive, remunerative, unskilled work on a sustained basis. For information on the basic mental demands of unskilled work and the effects of mental limitations or restrictions on the occupational base at any exertional level, see DI 25020.010.

    When an individual is found to have a limitation or restriction in one or more of these basic work activities, it may be useful to consult a vocational specialist or vocational expert.


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DI 25015.020 - The Effects of a Less Than Sedentary Residual Functional Capacity (RFC) on the Ability to Adjust to Other Work - 10/29/2026
Batch run: 10/29/2026
Rev:10/29/2026