Residual Functional Capacity Assessment for Cerebral Trauma
What Is RFC?
When your cerebral trauma is not severe enough to meet or equal a listing at Step 3 of the Sequential Evaluation Process, the Social Security Administration will need to determine your residual functional capacity (RFC) to decide whether you are disabled at Step 4 and Step 5 of the Sequential Evaluation Process.RFC is a claimant’s ability to perform work-related activities. In other words, it is what you can still do despite your limitations. An RFC for physical impairments is expressed in terms of whether the Social Security Administration believes you can do heavy, medium, light, or sedentary work in spite of your impairments. The lower your RFC, the less the Social Security Administration believes you can do.
Assessing Impairment Caused by Cerebral Trauma
RFC for individuals suffering from cerebral trauma depends on the particular impairments present. For RFC discussion applicable to individuals with epilepsy, see Residual Functional Capacity Assessment for Epilepsy; for RFC discussion applicable to individuals having suffered a stroke, see Residual Functional Capacity Assessment for Stroke.
Assessing Impairment Caused by Organic Mental Disorders
Considering organic mental disorders and other mental impairments alone, claimants with a mental RFC for the ability to perform even unskilled work will almost invariably be denied on medical-vocational grounds, with rare exceptions for claimants with more more than a limited education, who are close to retirement age, and who have a lifelong history of unskilled work which can no longer be performed. Large numbers of claimants are denied with mental RFCs for unskilled work, because the SSA can cite many jobs that require only unskilled work. A copy of SSA’s mental RFC form can be found here (link to Appendix 13 on MISS CD-ROM). SSA guidelines for mental status examinations are publicly available.An example of a more specific mental status examination, such as that required of psychiatrists or psychologists performing consultative examinations, can be found here (link to Appendix 15 on MISS CD-ROM). Of course, competent mental status examinations are as important in determining whether an impairment meets or equals a listing as for determination of a RFC.
A mental RFC is still relevant for three important reasons in any mental disorder:
- A mental RFC can lower the work skill level that a claimant would otherwise be able to perform based on education or work experience. Therefore, this lowering of skill level from skilled or semi-skilled work to unskilled work capacity can sometimes result in allowance when there is an additional physical impairment that would otherwise be considered denial under the medical-vocational guidelines in 20 CFR Part 404, Subpart P, App 2 (if the physical impairment were being considered alone). Many claimants have both physical and mental impairments.
- Mental impairments other than subaverage intellectual functioning are additionally significant, work-related impairments for purposes of listing 12.05C.
- A marked impairment in any of the abilities required for unskilled work will result in a medical-vocational allowance even in the absence of any physical impairment. These basic mental demands are required:
- Remember work-like procedures (locations are not critical).
- Understand and remember very short and simple instructions.
- Carry out very short and simple instructions.
- Maintain attention for extended periods of 2-hour segments (concentration is not critical).
- Maintain regular attendance and be punctual within customary tolerances. (These tolerances are usually strict.) Maintaining a schedule is not critical.
- Sustain an ordinary routine without special supervision.
- Work in coordination with or proximity to others without being (unduly) distracted by them.
- Make simple work-related decisions.
- Complete a normal workday and workweek without interruptions from psychologically based symptoms and perform at a consistent pace without an unreasonable number and length of rest periods. (These requirements are usually strict.)
- Ask simple questions or request assistance.
- Accept instructions and respond appropriately to criticism from supervisors.
- Get along with coworkers or peers without (unduly) distracting them or exhibiting behavioral extremes.
- Respond appropriately to changes in a (routine) work setting.
- Be aware of normal hazards and take appropriate precautions.
There are three things required for am accurate determination in an organic mental disorder claim:
- Documentation of the diagnosis per listing 12.02A.
- Thorough development of listing 12.02B and 12.02C evidence.
- Professional and specialty-competent medical evaluation of the totality of evidence.
Go back to About Cerebral Trauma and Disability.