Residual Functional Capacity Assessment for Coagulation Defects
What Is RFC?
When your coagulation defect 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 Coagulation Defects
Extremely mild cases of hemophilia that require no replacement factors and involve no history of serious bleeding would not require any restrictions to your ability to work. Those claimants who need antihemophilic globulin replacement on a regular basis still have a definite risk of bleeding with less physical trauma than normal individuals. The important point in this regard is that AHG is not given to maintain normal coagulation factor levels in the blood, but merely to increase coagulation factor activity so that the risk of bleeding is greatly diminished. For example, Factor VIII or IX activity of 10% is sufficient to suppress spontaneous bleeding.
Weakness and fatigue as limitations of exertional capacity would not be expected in hemophilia or other coagulation disorders. However, excessive bleeding from minor trauma could still be a problem. Based on this consideration, if your hemophilia is sufficiently severe to require factor replacement, your RFC probably should not exceed light work, in order to minimize the risk of injury. However, the SSA has no such official policy and SSA adjudicators in various U.S. regions probably vary considerably in how these cases are treated.
In addition to exertional restrictions, the RFC should limit exposure to activities that involve especially jarring forces to the body that would significantly increase the risk of bleeding. Trauma to be avoided includes work with sharp objects like knives or cutting blades, and work involving the possibility of substantial blunt or vibrating forces to the body. There is no question that people involved in heavy work activities have a high risk of physical injury, so those jobs should be restricted. Law enforcement officers and guards who may have physical struggles with other people would be at risk for bleeding, as would be some firefighters. To properly handle these claims, there must be close communication between the person who assesses the RFC and a vocational analyst; otherwise the claimant may be cited jobs to perform that are inappropriately hazardous.
Another common issue in hemophilia is joint damage as a result of hemarthrosis (bleeding into joints), especially in the knees. All claimants should be carefully examined for joint damage in the context of the musculoskeletal listings.
Go back to About Coagulation Defects and Disability.