How Social Security Judges Your Physical or Mental Capacity (RFC) for Work
Your residual functional capacity (RFC) determines whether you are disabled and should receive disability benefits.
Before Social Security decides whether a disability applicant has a true disability that prevents work, the agency ascertains what types of activities and tasks the applicant can still do. Social Security does this by having a disability claims examiner fill out a “Residual Functional Capacity” (RFC) assessment form.
The claims examiner uses your medical records and any statements from your doctor to develop your RFC. In addition to the activities you can do, your RFC will state what you cannot do to the limitations caused by your disability. For instance, an RFC might say you can stand for up to two hours and sit for four or more hours, but you can’t operate hazardous machinery.
If you claim on your disability application that you have any kind of physical impairment, and Social Security agrees it’s severe, the agency will develop a physical RFC for you.
If you have a physical disability, your physical RFC will include the “exertional” level of work you can do: sedentary, light, medium, or heavy. Your exertional level is based on how much you can walk or stand and lift, carry, and push or pull objects.
Your physical RFC level has a huge impact on whether you’ll be granted disability benefits, for several reasons. First, Social Security has a grid of rules, designed to streamline the disability determination process, that dictate when applicants with certain RFC levels should automatically be considered disabled. For example, if you’re over 49 and limited to sedentary work (a desk job or other sit-down job), you’ll automatically be granted disability benefits unless your past work was sedentary or you have job skills or recent job training that would allow you to do sedentary work. As another example, if you’re at least 55 and limited to light work (a job such as a cashier or security guard, where you stand more than sit, but you don’t lift more than 10 to 20 pounds), you’ll automatically be granted disability benefits unless your past work was also light or you have job skills or recent job training that allow you to do light work.
Secondly, if no “grid rules” apply to your situation (say because you’re 45 years old), Social Security will compare the level of your RFC to the level of your past job. If the levels are the same, Social Security will say you can do your old job, unless your RFC also contains non-exertional limitations that prevent you from doing it. If your RFC is for lighter work than your old job was classified as, Social Security will agree that you can’t do your old job, but the agency will then see if there are any jobs at your RFC level that you can do.
Non-exertional limitations are those that don’t involve strength, such as not being able to use your fingers for manipulating objects or not being able to hear well. Non-exertional limitations are important because Social Security will use them in doing a function-by-function analysis of your old job and other potential jobs to determine whether the limitations would interfere with any of the tasks required by these jobs.
Non-exertional limitations include the inability to do any of the following (or having doctor restrictions that prevent you from doing the following):
- stoop, crouch, craw, or climb
- be exposed to temperature extremes, sunlight, fumes, or dust
- use hands to write, type, or reach or handle objects, and
- see, hear, or speak.
If you list any type of mental difficulty or emotional illness on your disability application, Social Security is required to investigate the severity of that condition. If the agency finds it to be severe, it must create a mental RFC (or MRFC) for you. A mental RFC details your ability to:
- understand, remember, and carry out instructions
- maintain attention and concentration for extended periods of time
- perform tasks on a schedule
- sustain an ordinary routine without special supervision
- make simple decisions and judgments
- interact appropriately with the public
- respond appropriately to criticism from supervisors
- get along with coworkers or peers without distracting them
- maintain socially acceptable standards of neatness and cleanliness
- respond appropriately to changes in the work setting
- tolerate normal levels of stress, and
- maintain regular attendance and be on time.
Unlike for physical RFCs, there is no set of grid rules for mental RFCs. But like a physical RFC, Social Security will compare the limitations in your mental RFC to the tasks required in your past job to see if you can do your old job. If not, Social Security will compare the mental limitations in your RFC with the requirements of other jobs in the U.S. to determine whether there are any less mentally demanding jobs you can do. If you can't do any simple, unskilled job, you'll be found disabled. Before deciding that there is a type of job you can learn to do, Social Security must consider both your physical limitations and mental limitations combined.
How You Can Help
To make sure your file contains an RFC that is detailed and properly reflects how limited your abilities are, ask your doctor to fill out a form detailing which of the above physical limitations you have. For instance, how long can you walk, how long can you stand, how long can you sit without adjusting positions, how much can you lift, can you stoop or crouch, is your hearing limited, and so on. For mental impairments, ask your doctor to specify whether your ability to do each of the above mental tasks is somewhat limited, seriously limited, or extremely limited. Read Nolo's article on getting your doctor's information into your disability file.
If you hire a disability lawyer, the lawyer will have RFC forms (called medical source statements) to send to your doctors to elicit the appropriate information for your medical condition. If you wish, you can use Nolo's lawyer directory to arrange a consultation with a disability attorney in your area.