60RRBH25R0009 CMOS Desk Guide for Clarifying RFCS Attachment 3.pdf

Desk Guide for Clarifying Physical RFC

EXERTIONAL LIMITATIONS

Lift and/or Carry Occasionally less than 10 pounds Lift and/or Carry Frequently less than 10 pounds Stand and/or Walk less than 2 hours Sit less than 6 hours

Less Than Must Be Explained‐ Explanation of whether these limitations are slightly less or significantly less

ALTERNATE SITTING AND STANDING—DI 25015.020B.6; SSR 83‐12

The RFC assessment must be specific as to the frequency of the individual’s need to alternate sitting and standing. The explanation should contain the following:

How long can the claimant maintain the base and relief posture?

Can the claimant alternate sit/stand within scheduled breaks and lunch periods?(which is normally 2 hours)

HAND HELD ASSISTIVE DEVICE—DI 25015.020B.6

If the RFC indicates a medically required hand held assistive device for ambulation, clarify the following:

Does the medical evidence support the necessity of the assistive device?

Is the device necessary for long or short distances, uneven terrain, ascending or descending slopes?

Does the claimant use the assistive device for pain or balance?

Can the claimant lift & carry weights associated with sedentary work with the unoccupied upper extremity while maintaining balance, and using the hand held assistive device for ambulation?

PUSH/PULL (operation of hand/foot controls)—DI 25001.001B.61 & B.62

The description should include the following:

One or both extremities Upper or lower extremity Extent of the limitation in work related terms—**Never, Occasional= once up to 1/3 of an 8‐ hour work day, Frequent= 1/3 up to 2/3 of an 8‐hour workday, or Constant= 2/3 or more of an 8‐hour workday

POSTURAL DI 25020.005A.1, A.4, & A.9

Clarify any postural’s marked NEVER and those left BLANK without explanation. **On the RFC, NEVER means the claimant cannot perform an activity even once in an 8‐hour workday. Make sure the medical evidence supports the rating and provide explanation of the limitation.

ENVIRONMENTAL LIMITATIONS—DI 25020.015; DI 25001.001B.19

If the RFC indicates limitations to fumes, odors, dusts, etc., clarify if the individual could tolerate the dusts common to an office or clean factory setting?

If hazards are checked, clarify what is hazardous to the claimant in work‐related terms:

o Could the claimant work at heights, operate motorized vehicles, or work around dangerous machinery with moving parts, or sharp blades, etc.?

If the RFC indicates avoid even moderate exposure or avoid all exposure, clarification of the extent of the limitation in work‐related terms is necessary.

MANIPULATIVE LIMITATIONS—DI 25020.005 A.2, A.5 & A.8

Ask for clarification of all manipulative limitations in work related terms: —**Never, Occasional= once up to 1/3 of an 8‐hour workday, Frequent= 1/3 up to 2/3 of an 8‐hour workday, or Constant= 2/3 or more of an 8‐hour workday. Is the limitation for one extremity (right or left) or both? Is the MER detailed enough to determine the extent of limitation?

When fingering limitations are involved, it may be necessary to clarify the following:

Can the claimant button, tie shoelaces, or pick up coins without difficulty?

Could the claimant use the fingers to type or perform input duties?

Depending on the case, you may need to clarify whether the handling limitation involves the following:

Is the claimant capable of forceful grasping, gripping, or squeezing?

Can the claimant use the hand or hands to turn doorknobs?

Can the claimant bend or straighten the wrist?

Can the claimant use the hand/arm as an assist to carry, guide, push, pull, or support work materials?

Clarify if the reaching limitation is for OVERHEAD***, SHOULDER LEVEL, DESK LEVEL, or ALL DIRECTIONS

**On the RFC, NEVER means the claimant cannot perform an activity even once in an 8‐ hour workday. Make sure the medical evidence supports the rating and provide explanation of the limitation.

*** Overhead reaching limitations do not significantly erode the occupational base at any exertional level

VISUAL LIMITATIONS—DI 25020.005A.10

The RFC should explain the degree and extent of the limitation. If not, clarify the following:

Is the claimant able to work with small objects, large objects, read type written or small print?

Can the claimant avoid ordinary hazards in the workplace without being a hazard/danger to self or others while ambulating?

Can the claimant work at heights, operate motorized vehicles, or work around dangerous machinery with moving parts, or sharp blades, etc.?

COMMUNICATIVE LIMITATIONS—DI 25020.005A.3

Hearing Is the claimant able to understand speech when spoken at a slightly elevated level to receive directions or questions?

Is the claimant able to have and understand conversations with background noise present?

Can the claimant hear loud noises or hazards warnings such as a fire alarm?

Speaking The RFC should explain the claimant’s ability to produce speech that is audible, intelligible, and sustained at a sufficient rate.

Desk Guide for Clarifying Mental RFC

MENTAL LIMITATIONS—DI 25020.010

The Mental RFC narrative should address the degree of limitation for each section listed concerning the individuals mental ability to sustain activities over a normal workday and workweek.

Questions to Consider Asking RMC When Clarifying the MRFC

Can the claimant:

o Remember locations and work like procedures?

o Understand and remember very short and simple instructions?

o Carry out very short and simple instructions?

o Maintain concentration and attention for 2‐ hour periods?

o Perform activities within a schedule, maintain regular attendance, and be punctual within customary tolerances?

o Ask simple questions or request assistance?

o Accept instructions and respond appropriately to criticism from supervisors?

o Does the claimant retain ability to get along with coworkers or peers without being?

unduly distracted by them or exhibiting behavioral extremes?

o Respond appropriately to changes in a routine work setting?

UNSKILLED QUESTIONS**

Can the claimant:

o Understand, carryout, and remember short simple instructions?

o Make judgments and simple work related decisions?

o Deal with changes in a routine setting?

o Respond appropriately to supervision, coworkers, and work situations?

o Perform work that requires little or no judgment to do simple duties that he/she can learn on the job in a short period of time (i.e. 30 days or less)?

SEMI‐SKILLED QUESTIONS

Can the claimant:

o Perform detailed rather than complex duties?

o Understand and remember detailed instructions?

o Carry out detailed instructions?

o Set realistic goals or make plans independently of others?

SKILLED QUESTIONS

Can the claimant:

o Understand, carryout, and remember complex instructions?

o Understand abstract ideas and do problem solving?

o Accomplish high levels of judgment and adaptability?

o Set realistic goals and make plans independently?

**If the claimant has a MRFC consistent with capacity for no more than unskilled work and PRW ruled out, there is no issue of transferability of skills.