What Is Residual Functional Capacity (RFC)?
Residual Functional Capacity (RFC) is a tool used to assess what a claimant is physically and/or mentally capable of doing or not doing during an 8-hour workday. The Social Security Administration’s rules and regulations actually organize the grid rules by RFC levels. The first table or grouping of grid rules is for those limited to sedentary work. Although not a table, the last section of the above rules is a discussion about those claimants who are capable of performing work at the heavy and very heavy levels. Because the tables are listed by RFC level, the first question a decisionmaker must answer is which RFC level to assign to each claimant.
How Is My RFC Determined?
To determine what you are or are not capable of doing in a typical 8-hour work day, a decisionmaker often works with a medical consultant. A medical consultant is tasked with reviewing your Social Security file, which needs to contain all of your medical records and doctor opinions. You and your lawyer need to work together to make sure the decisionmaker has your complete medical file. In the event there is not enough medical evidence in your file, you may be sent to a consultative examination. The in-person (or virtual in limited circumstances) exam is with a medical doctor who is not an employee of the Social Security Administration. The doctor is an independent contractor who is tasked with providing additional information to the medical consultant, so an accurate assessment of your abilities and limitations can be made. It is in your best interest to compile additional evidence that is favorable to your claim too. Medical consultants and consultative examiners do their best to make an accurate assessment of your abilities, but mistakes happen and they can get it wrong. You can help the folks at DDS by asking one (or all) of your doctors to fill out an RFC form. If completed by a treating physician, the decisionmaker assigned to your case will have to take into account that evidence as well. Using all the information in your file, the consultant will give an opinion as to your physical and, if applicable, your mental abilities and limitations. He or she will answer questions such as how long you can sit, stand and walk. The opinion will also mention how much you are able to lift on both an occasional and a frequent basis. If a claimant has mental limitations, the opinion will contain any limitations associated with those as well.
How Is RFC Categorized?
Once an RFC has been assessed, those abilities and limitations will be placed into categories referred to as “exertional levels”. Your specific RFC might not fit perfectly into one of the categories. Generally, you will be found capable of the less strenuous category if you are between two. Occasionally; however, a decisionmaker will find that you are close enough to the more strenuous category and use that one instead. Exertional levels are defined as follows:
1. Sedentary Work
Sedentary work involves lifting no more than 10 pounds occasionally and lifting 5 pounds frequently. By its very nature, work is performed primarily in a seated position so standing and walking are generally limited to 2 hours in an 8-hour day, while sitting is required around 6 hours in an 8-hour day.
2. Light Work
The regulations define light work as lifting no more than 20 pounds occasionally and 10 pounds frequently. By its nature these are generally stand-up jobs that require standing or walking up to 6 hours a day and sitting around 2 hours per 8-hour day. There are some light jobs that can be done from a seated position. Thus, a finding of an inability to stand 6 hours might not, by itself, eliminate a claimant from the light category.
3. Medium Work
Medium work is defined as lifting 50 pounds occasionally and 25 pounds frequently. The full range of medium work requires one to stand or walk 6 hours in an 8-hour day and sit approximately 2 hours.
4. Heavy Work
Heavy work requires one to lift 100 pounds occasionally and 50 pounds frequently. Again, the full range of heavy work requires one to stand 6 hours in an 8-hour day and sit approximately 2 hours.
5. Very Heavy Work
Very heavy work is work that requires an individual to lift over 100 pounds occasionally with the same standing/walking and lifting requirements of the other non-sedentary job categories.
Use RFC to Make a Determination
RFC is then used in the 5-step decision-making process to determine whether or not a claimant is disabled. The first time an RFC is used is at Step 4, when the decisionmaker is required to determine whether or not a claimant can return to their past work. For Example: If your past work was at the light level and your RFC is at sedentary, then you cannot perform your past work. On the other hand, if your past work is at the light level and your RFC is medium, you would be able to perform your past work as you are capable of lifting more than what is required at your last job. If you can perform you last job, you will lose your disability claim. If you cannot, the decisionmaker goes to step 5. At step 5, a determination needs to be made as to whether or not there are other jobs that a claimant would be capable of performing. If there are no jobs that you are able to do, then you are disabled. The most common way to be found disabled in this way is if you would require extra breaks above and beyond normal, if you would have excessive absenteeism, or if you would be off task and unable to be productive on the job 15% of the time or more. Any of these examples would show that you would be unable to sustain a full-time job. If this is the case, you are disabled. If there are jobs that you could be capable of doing, then it is time to consult the grid rules. As mentioned earlier, the grids are organized by exertional level, starting with sedentary. After finding the exertional level that the claimant is capable of, the decisionmaker will then find the rule where the age, education and previous work history mirrors that of the claimant’s. Once the specific matching grid rule is found, the 5th or last column in the table will direct a decision of ‘disabled’ or ‘not disabled’. Available jobs or vocational expert testimony cannot alter the rule.