Tenth Circuit: Remand ordered where ALJ failed to explain rejection of medical reports
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Wednesday, June 12, 2019

Tenth Circuit: Remand ordered where ALJ failed to explain rejection of medical reports

By Payroll and Entitlements Editorial Staff

After obtaining medical opinions, the ALJ is obligated to evaluate them in assessing a claimant’s ability to perform work-related tasks. Here, the agency obtained two medical opinions. Both experts opined that the claimant had moderate limitations in mental abilities and activities. In assessing the claimant’s residual functional capacity, the ALJ agreed with the opinions, giving either significant or great weight to each. However, the claimant questioned whether the agency actually incorporated the opinions when assessing his ability to perform work-related activities. Specifically, if the ALJ decided to omit certain limitations outlined in the two medical opinions from his or her assessment, then an explanation was necessary to explain the omission. The court concluded that the agency did not incorporate parts of the opinions in assessing the claimant’s capabilities. The ALJ failed to incorporate limitations regarding the claimant’s ability to interact with coworkers and respond appropriately to changes in the usual work situation. Moreover, there was no explanation of the discrepancy between the ALJ’s assessment of mental capacity and the medical opinions. The absence of explanation required a reversal of the denial of benefits. Even if the error involving the limitation in interacting with coworkers would not have affected the outcome, the error involving responding appropriately to work situations was not harmless. Thus, the denial of benefits was reversed and the case was remanded for the agency to reconsider what the claimant could do despite his mental limitations (Billy J. Parker v. Berryhill, CA-10, No. 18-1160, April 30, 2019).

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