ALJ must consider all a claimant’s impairments on function-by-function basis, says court
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Monday, June 3, 2019

ALJ must consider all a claimant’s impairments on function-by-function basis, says court

By Payroll and Entitlements Editorial Staff

In order to assess residual functional capacity (RFC), an ALJ must consider all of a claimant’s physical and mental impairments on a function-by-function basis and determine how they impact the claimant’s ability to work. An ALJ must provide some logical explanation of the evidence and not just list the evidence and draw a conclusion. Here, the ALJ provided too little logical explanation for the court to conduct a meaningful appellate review. Specifically, the ALJ failed to provide an explicit conclusion on how the claimant’s mental limitations would affect her ability to perform job-related tasks for a full workday. Further, the ALJ provided insufficient explanation of how she weighed the various pieces of evidence pertaining to the claimant’s mental health treatment. The ALJ also expressed the claimant’s RFC to perform light work first and then concluded that the limitations caused by her impairments were consistent with the RFC. The court concluded that stating a claimant’s RFC before conducting a function-by-function analysis is error. Finally, the ALJ’s lack of information regarding the terms "production rate" and "demand pace" as used in her decision made it difficult for the court to assess whether their inclusion in the claimant’s RFC was supported by substantial evidence. The court’s ability to conduct a meaningful review was frustrated by these RFC evaluation errors. Thus, the judgment of the district court affirming the benefits denial was vacated and the case was remanded to the agency for further proceedings (Nikki T. Thomas v. Commr., CA-4, No. 17-2215, January 15, 2019; amended February 22, 2019).

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