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 impairment does not meet or equal a listing, but continues to be severe 12 months
from onset;
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•
the impairment(s) is currently at listing level but is expected to improve, and there
are significant limitations to performing basic work activities;
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•
the claimant has a disabling impairment currently, adjudication is within 12 months
of onset, and the impairment 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 impairment currently, adjudication is within 12 months
of onset, and the impairment 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 multiple RFC
assessments, see DI 24510.020C.3.
The effects of any type of limitation(s) when projecting RFC vary greatly, depending
upon the degree of the claimant’s limitations, and you must determine them based upon
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 01/25/2011. You are assessing the claim on 04/03/2011, after
receiving all of the requested medical evidence.
The claimant’s condition is not of listing level; however, he is still very slow in
recuperating. You anticipate that the claimant’s current condition is much worse than
it will be on 01/24/2012.
Since his condition prevents SGA, you should project his RFC to reflect his predicted
functional capacity on 01/24/2012; i.e., 12 months from the date the claimant first
met the medical criteria for disability.
When projecting RFC, on page 1 of the RFC Assessment form (SSA-4734-BK or SSA-4734-F4-SUP),
select the block that says “Date 12 Months After Onset” and enter the applicable date.
You must explain in your narrative that the RFC reflects the claimant’s functioning
12 months from the date the claimant first met the medical criteria for disability.
For more information on how to complete the physical RFC assessment form, see DI 24510.050.
NOTE: Do not project the RFC if a claimant’s impairment(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 ability to do past or other work is appropriate.
For an explanation of policy for projecting the RFC, see DI 24510.020A.