TN 14 (03-24)

DI 25025.010 Using Rule 204.00 as a Framework for a Determination


Social Security Act (the Act) §§: 223(d)(2)(A) and 1614(a)(3)(B) 20 CFR §§: Part 404, Subpart P, Appendix 2, 404.1520(f), 404.1560 thru 404.1569(a), 416.920(f), and 416.960 thru 416.969(a)
Social Security Rulings (SSR): 96-9p, 85-15, 83-14, 83-12, 83-11, and 83-10

Acquiescence Rulings (AR): 01-1(3)

A. Rule 204.00 cannot direct a determination

When rule 204.00 applies, always use it as a framework for a determination of disabled or not disabled. Use rule 204.00 as a framework when finding a claimant:

  • not disabled based on an impairment that results in nonexertional limitations only; or

  • disabled based on a consideration of the claimant’s impairment-related nonexertional limitations only.

B. Examples of determinations using rule 204.00 as a framework

1. Favorable determination using medical-vocational rule 204.00 as a framework

The claimant is 35 years old with a 9th grade education. The claimant’s only work was for two years, part-time as a dishwasher. Earnings were below SGA level. The claimant alleges disability due to depression and back pain. The claimant indicates they were in special education classes in school. Purchased IQ testing and mental status exam show IQs in the low borderline range, flat affect, and psychomotor retardation. Contact with their previous employer reveals that the claimant required constant prompting to follow through on their work, which was to wash dishes for a restaurant. The claimant had a difficult time relating to the other restaurant employees who often ribbed the claimant for being slow. The restaurant fired the claimant because the claimant required excessive supervision to get their work done, the quality of their work was poor, and because they punched another employee, who the claimant perceived was making fun of them. The claimant’s mental residual functional capacity (MRFC) supports an inability to meet these basic demands of unskilled work:

  • understand, carry out, and remember simple instructions; and

  • respond appropriately to supervision, coworkers, and work situations.

Because the claimant cannot meet the basic demands of unskilled work due to their mental impairments, an allowance is appropriate using medical-vocational rule 204.00 as a framework. You do not need to consider the additional impact the claimant’s physical allegations of back pain would have on the occupation base.

2. Unfavorable determination using medical-vocational rule 204.00 as a framework

The claimant is 30 years of age with a 12th grade education and past relevant work as a clerk in a food mart. They allege disability due to anxiety and vision problems. The claimant has normal visual fields by confrontation exam and best corrected vision of 20/30 bilaterally. The claimant stopped work because they were present during a robbery at the food mart two years ago. The claimant has been too anxious to work with the public since. The claimant sees their treating physician (TP) every three months for refills on Klonopin. The claimant has never seen a counselor or had a psychiatric hospitalization. If the claimant does not take their medication, they have anxiety attacks. Their last anxiety attack was a year ago when they went to the emergency room for chest pain. The emergency room physician diagnosed the claimant with an anxiety disorder and started them on Klonopin. The physician gave the claimant information about treatment at a local mental health center, but the claimant did not follow through on the referral. Because the Klonopin helps the claimant, their TP agreed to monitor the claimant’s medication for them. TP notes indicate the claimant complains of anxiety in crowds and difficulty interacting with others despite good compliance with medication. The claimant’s TP has continued to recommend counseling, but the claimant is not comfortable with this recommendation. The medical evidence supports the claimant is unable to work with the public. The claimant retains the capacity to work with coworkers and supervisors. Because the nonexertional limitations resulting from the claimant’s mental and visual impairments do not significantly erode the unskilled occupational base, medical vocational rule 204.00 applies as a framework for a denial.

C. References for using rule 204.00 as a framework for a determination

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DI 25025.010 - Using Rule 204.00 as a Framework for a Determination - 03/06/2024
Batch run: 03/06/2024