20 C.F.R. § 404.1545

Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments, including nonsevere impairments, when assessing residual functional capacity.

Kidd v. Commissioner, SSA · filed 2022-08-02(a)(2)

The regulations require an ALJ to consider the combined impact of all impairments, including non-severe impairments, when assessing a claimant’s RFC.

An RFC assessment must account for a claimant’s severe impairments; failure to consider them requires remand.

Colgrove v. O'Malley · filed 2022-08-11(a)(1)

Here, the ALJ failed to take into account Plaintiff’s severe impairments of edema, OSA and hypoxemia when determining the RFC. As such, remand is necessary to allow the ALJ to consider these particular impairments (edema, OSA and hypoxemia) in determining Plaintiff’s RFC.

Section 404.1545(e) requires the RFC to include limitations arising from non-severe impairments.

Wright v. Kijakazi · filed 2022-08-04(e)

Merely going beyond Step Two does not per se fix prejudice from a Step Two error. These errors are cured and become harmless if all of claimant’s limitations, including any limitations arising from any non-severe conditions are included in the RFC.

Section 404.1545(e) requires consideration of all medically determinable impairments, including nonsevere impairments, when assessing residual functional capacity.

Thoenen v. Commissioner of Social Security Administration · filed 2022-08-19(e)

This is because an ALJ must take into consideration all impairments, both severe and nonsevere, in formulating the RFC.

Section 404.1545(e) requires an ALJ to consider the limiting effects of all impairments, including nonsevere impairments, when determining residual functional capacity.

Martin v. Commissioner of the Social Security Administration · filed 2022-08-19(e)

Regulations require that an ALJ “consider the limiting effects of all [the claimant’s] impairment(s), even those that are not severe,” in determining the claimant’s RFC.

Section 404.1545(a)(2) requires an ALJ assessing residual functional capacity to consider medically determinable impairments even when they are not severe.

Hevelone v. Kijakazi · filed 2022-08-22(a)(2)

When assessing a claimant’s RFC, the ALJ must consider impairments found to be medically determinable, even if not deemed severe.

An ALJ must consider all medically determinable impairments, including non-severe physical and mental impairments, when assessing residual functional capacity.

Perry v. Commissioner of Social Security · filed 2022-08-24(a)(2)

Therefore, when determining the RFC, the ALJ must consider all medically determinable impairments, mental and physical, even those that are non-severe.

The RFC assessment must consider medically determinable impairments even when they are not severe; a step-two severity error is harmless if the ALJ considers those impairments when formulating the RFC.

Rodriguez-Feliciano v. Commissioner of Social Security · filed 2022-08-24(a)(2)

Even so, other evidence to which the ALJ cited and weighed in formulating the RFC demonstrates that Plaintiff’s mental condition was considered by the ALJ at the RFC stage, and that the ALJ’s determination was supported by substantial evidence in accordance with 20 C.F.R. § 404.1545(a)(2) (“We will consider all of your medically determinable impairments of which we are aware, including your medically determinable impairments that are not ‘severe’ . . .”).

Section 404.1545(a)(2) requires consideration of all medically determinable impairments when assessing residual functional capacity, but a mild mental impairment need not produce an RFC limitation if it does not affect the claimant’s ability to work.

Adelmeyer v. Kijakazi · filed 2022-09-01(a)(2)

An ALJ must consider the limiting effect of all impairments, including non-severe ones, in assessing a claimant’s RFC. ... That is the case here, because nothing in the record establishes Plaintiff's mental impairments have any effect on her ability to work.

An RFC assessment must consider all medically determinable impairments, including nonsevere mental impairments, and their combined effects.

Simerman v. Commissioner of Social Security · filed 2022-09-06(a)(2)

Therefore, when determining the RFC, the ALJ must consider all medically determinable impairments, mental and physical, even those that are non-severe. ... The ALJ failed to explain why Simerman’s mild mental impairments did not require RFC limitations, and she failed to properly consider the combined effects of her depression and physical symptoms.

An ALJ must consider both severe and non-severe impairments when determining residual functional capacity.

Shaw v. Kijakazi · filed 2022-08-25(a)(2)

Even though substantial evidence supports the ALJ’s finding that plaintiff’s IBS is not severe, the ALJ is still required to consider all of plaintiff’s impairments—both severe and non-severe—when determining the RFC.

Section 404.1545(a)(2) requires the RFC assessment to consider all medically determinable impairments together, including those that are not severe.

Colon v. Saul · filed 2022-08-26(a)(2)

Indeed, under the regulations, an ALJ is required to assess all of a claimant's medically determinable impairments – including those that are not severe – in combination when making the subsequent RFC determination.

Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments, including non-severe impairments, together when assessing residual functional capacity.

Hand v. Saul · filed 2022-08-26(a)(2)

Indeed, under the regulations, an ALJ is required to assess all of a claimant's medically determinable impairments – including those that are not severe – in combination when making the subsequent RFC determination. ... Therefore, regardless of whether Hand’s conditions were erroneously considered non-severe impairments at step two, the Court is of the opinion that the RFC assessment is not supported by substantial evidence.

Section 404.1545(e) requires an ALJ to consider limitations from a medically determinable impairment when assessing residual functional capacity, even if the impairment is not severe.

Burton v. Commissioner of Social Security · filed 2022-09-01(e)

Moreover, even assuming the ALJ was correct Plaintiff’s cervical condition was not severe, the ALJ was nonetheless required to consider the limitations caused by this medically determinable condition when assessing Plaintiff’s RFC.

An RFC assessment must consider nonsevere mental impairments, but may omit mental limitations when those impairments do not interfere with basic work activities.

Satterwhite v. Kijakazi · filed 2022-09-09(a)(2)

A fair reading of the ALJ’s decision is that the omission of mental limitations from the RFC reflects the conclusion that the impairments would not interfere with the ability to perform basic work activities, which the ALJ reached at step four after considering Plaintiff’s ability to complete tasks, the medical record, and Plaintiff’s reported daily activities.

Section 404.1545(a)(2) requires consideration of medically determinable impairments, including nonsevere mental impairments, when assessing residual functional capacity.

Garcia v. Commissioner of Social Security · filed 2022-09-14(a)(2)

However, the ALJ’s assessment at step two did not relieve him of the requirement to discuss Plaintiff’s mental health impairments in formulating the RFC.

Section 404.1545(a)(2) requires an ALJ to consider non-severe impairments when assessing residual functional capacity, but does not require a limitation for every such impairment.

Dudek v. Commissioner of Social Security · filed 2022-09-09(a)(2)

But the law only requires the ALJ to evaluate non-severe impairments in the RFC analysis, not to include limitations in the RFC.

Section 404.1545(a)(2) requires consideration of all medically determinable impairments when assessing residual functional capacity, including impairments found non-severe at step two.

Swinson v. Saul · filed 2022-09-09(a)(2)

In making this assessment, the ALJ considers all the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.

Section 404.1545 requires an ALJ to consider the limiting effects of medically determinable impairments, including nonsevere impairments, when assessing residual functional capacity.

Stroops v. Commissioner Social Security Administration · filed 2022-09-20

Even if an impairment is not severe, the ALJ must still consider its limiting effect when formulating the claimant’s RFC.

Section 404.1545(a)(2) requires an ALJ to consider functional limitations from non-severe impairments when assessing residual functional capacity.

Bedasie v. Commissioner of Social Security · filed 2022-09-17(a)(2)

Because the ALJ failed to account for any functional limitations associated with Plaintiff’s CTS in determining Plaintiff’s RFC, the Court remands the case.

Section 404.1545 requires an ALJ to consider all impairments together when assessing residual functional capacity, including non-severe impairments.

Houghton v. Commissioner of Social Security · filed 2022-09-20(a)(2)

The ALJ was required to consider all impairments in the aggregate in constructing an RFC, regardless of the severity of any individual impairment.

Section 404.1545 requires an RFC assessment to account for credible limitations from non-severe impairments, but abnormal findings do not necessarily require additional work restrictions.

Lett v. Kijakazi · filed 2022-09-26

Moreover, the abnormal results do not require greater limitations than the ALJ’s RFC determination which included non-exertional limitations. In her decision, the ALJ thoroughly discussed Plaintiff’s heart related conditions. While she did not find them severe, she included them in her discussion of Plaintiff’s impairments that affected Plaintiff’s RFC.

Section 404.1545(a)(2) requires the RFC assessment to consider all medically determinable impairments, including those that are not severe.

Pratt v. Kijakazi · filed 2022-09-28(a)(2)

Courts frequently find that an ALJ’s error at Step Two in failing to find a particular impairment severe does not require reversal where the ALJ considers all of a claimant’s impairments, severe and non-severe, in his or her subsequent analysis. ... Because it appears that the ALJ considered all of Plaintiff’s impairments, severe and non-severe, in assessing Plaintiff’s RFC, the Court finds no reversible error.

Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Rivera v. Saul · filed 2022-09-27(a)(2)

In making this assessment, the ALJ considers all the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis. ... This step two error calls into question the completeness of the ALJ’s RFC assessment and undermines the support for his conclusions at steps four and five of the sequential evaluation process.

Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments, including nonsevere mental impairments, when assessing residual functional capacity.

Drullinger v. Commissioner, Social Security Administration · filed 2022-10-03(a)(2)

In assessing a claimant’s RFC, an ALJ must “consider the combined effect of all of the claimant’s medically determinable impairments, whether severe or not severe.” Wells v. Colvin, 727 F.3d 1061, 1065 (10th Cir. 2013); see 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2).

Section 404.1545(a)(2) requires an RFC assessment to consider all medically determinable impairments, including non-severe impairments.

Baker v. Saul · filed 2022-09-29(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis. 20 C.F.R. §§404.1545(a)(2), 416.945(a)(2).

Section 404.1545(a)(2) requires an ALJ to consider limitations from non-severe impairments when assessing residual functional capacity; a conclusory assertion that they were considered is insufficient.

Oram v. Kijakazi · filed 2022-10-20(a)(2)

Regardless, I do not find that the discussion in these sections provides the consideration contemplated by 20 C.F.R. § 404.1545(a)(2) and SSA Ruling 96-8p.

Section 404.1545 requires an RFC assessment to consider both severe and non-severe impairments when evaluating the claimant’s ability to sustain work activities.

Turner v. Commissioner of Social Security · filed 2022-11-09

The RFC is a holistic assessment of the claimant’s medical impairments, both severe and non-severe, that evaluates the claimant’s ability to perform physical or mental work activities on a sustained basis, notwithstanding limitations for collective impairments. ... The ALJ still considered Plaintiffs non-severe dysthymia in making the RFC determination.

An ALJ determining residual functional capacity must consider the limiting effects of all impairments, including non-severe impairments.

Smethurst v. Kijakazi · filed 2022-11-21(e)

In determining an RFC, an ALJ is required to consider the limiting effects of all of a claimant’s impairments, even those that are found to be non-severe.

Section 404.1545 requires the ALJ to consider limitations from both severe and non-severe medically determinable impairments when assessing residual functional capacity.

(SS) Kimball v. Commissioner of Social Security · filed 2022-11-30(a), (e)

An ALJ must consider the limiting effects of both severe and non-severe medically determinable impairments when determining the RCF.

Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including non-severe mental and physical impairments, when determining residual functional capacity.

Blankenship v. Commissioner of Social Security · filed 2022-12-07(a)(2)

When determining the RFC, the ALJ must consider all medically determinable impairments, mental and physical, even those that are non-severe. 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2); see also Craft v. Astrue, 539 F.3d 668, 676 (7th Cir. 2008).

Section 404.1545(e) requires an RFC to account for limitations arising from non-severe impairments.

Royal v. Kijakazi · filed 2022-12-07(e)

The prejudice of a Step Two error is cured and becomes harmless only if all of the claimant’s limitations, including any limitations arising from any non-severe conditions, are included in the RFC.

Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Dunn v. Saul · filed 2022-12-12(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable ... impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis. 20 C.F.R. §§404.1545(a)(2), 416.945(a)(2).

An RFC challenge based on an omitted nonsevere impairment fails when no evidence shows that the impairment meaningfully affects functional capacity.

SMITH v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-12-27(e)

I note that by the end of Theresa S.’s discussion of her claim that the ALJ erred at Step 2 by finding her diabetes not to be severe, her position morphs into an RFC/Step 4 argument, asserting that the ALJ failed “to consider both severe and nonsevere impairments in assessing a claimant’s RFC.” (Pl. Br. at 47-48 (citing 20 C.F.R. § 404.1545(e)). This argument is meritless given the sheer lack of evidence to support Theresa S.’s claim that her diabetes affects her functional capacity in any meaningful way.

An RFC assessment must consider limitations from all impairments, including mild or non-severe limitations found at step two.

HERNANDEZ v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-12-19(a)(1)

As an initial matter, the ALJ, in her RFC determination, “must consider limitations and restrictions imposed by all of an individual’s impairments,” including any mild or non-severe limitations found at step two.

Section 404.1545 requires an ALJ to consider severe and non-severe medically determinable impairments together when assessing residual functional capacity.

CARTWRIGHT v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-01-03(a)(2)

Not only that, but the Court has also considered that the ALJ ultimately resolved step-two of the five-step evaluation in Plaintiff’s favor and clearly considered evidence of Plaintiff’s non-severe impairments with her severe impairments in his determination of her RFC. (R. 18, 23, 26).

Section 404.1545 requires the ALJ to consider all relevant evidence, including non-severe impairments, when assessing residual functional capacity and to explain how those impairments factor into the assessment.

Scott v. Commissioner of Social Security · filed 2023-01-04(a)(1), (a)(2)

However, even if the evidence supported the conclusion that Plaintiff’s anxiety and depression are non-severe and cause only mild limitations, the ALJ still needed to explain how these conditions and Plaintiff’s other psychiatric symptoms factored into the RFC.

Section 404.1545(e) requires the ALJ to consider the limiting effects of severe and non-severe impairments when assessing residual functional capacity; the ALJ need not expressly discuss every symptom when the decision shows it was considered.

Brewer v. Commissioner, Social Security Administration · filed 2023-01-09(e)

Nevertheless, the ALJ remains obligated to consider both severe and non-severe impairments in developing a given claimant’s RFC. 20 C.F.R. § 404.1545(e) (“[W]e will consider the limiting effects of all your impairment(s), even those that are not severe, in determining your residual functional capacity.”). ... The ALJ considered all symptoms in making his RFC determination, and characterized nausea as such a symptom earlier in his decision. Without anything more, remand is unwarranted.

An RFC assessment must consider limitations from non-severe impairments.

VeRost v. Commissioner of Social Security · filed 2023-01-09(a)(2)

Even though the ALJ reasonably concluded that plaintiffs mental limitations were non-severe, plaintiff is correct that the ALJ was still required to consider those limitations when formulating the RFC.

Section 404.1545(a)(2) requires the ALJ to consider severe and non-severe impairments together when assessing residual functional capacity.

Acosta-Diaz v. Commissioner of Social Security · filed 2023-01-10(a)(2)

The ALJ was required under 20 C.F.R. § 404.1545(a)(2) to consider all of Plaintiff’s impairments whether severe or non-severe in order to determine their combined effect on Plaintiff’s RFC.

Section 404.1545(a)(2) requires an ALJ to consider the limiting effects of all impairments, including nonsevere ones, when assessing residual functional capacity.

(SS) Kniffen v. Commissioner of Social Security · filed 2023-01-20(a)(2)

An ALJ must consider the limiting effect of all impairments, including those that are non-severe, in assessing a claimant’s RFC.

Section 404.1545(a)(2) requires the ALJ to consider all impairments and their consistency with the medical evidence when determining residual functional capacity.

Valadez v. Social Security · filed 2023-01-18(a)(2)

In formulating a claimant’s RFC, the ALJ must consider all impairments and the extent to which the impairments are consistent with medical evidence. 20 C.F.R. § 404.1545(a)(2).

Section 404.1545(e) requires the ALJ to consider the limiting effects of all impairments, including those that are not severe, when assessing residual functional capacity.

Plocki v. Commissioner of Social Security · filed 2023-01-24(e)

The ALJ must consider the limiting effects of all of the claimant’s impairments, including those that are not severe, in assessing the RFC. 20 C.F.R. §§ 404.1545(e), 416.945(e); SSR 96-8p.

An RFC assessment must consider all of the claimant’s impairments, including those that are not severe.

Wolvin v. Kijakazi · filed 2023-01-24(a)(2)

In making the RFC finding the ALJ must consider all of the claimant’s impairments, including impairments that are not severe. 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2).

Section 404.1545(a)(2) requires the ALJ to assess residual functional capacity based on all impairments, including those that are not severe.

Eastman v. Saul · filed 2023-01-30(a)(2)

At step four, the ALJ must determine the claimant’s residual functional capacity to work based on all impairments, including impairments that are not severe. 20 C.F.R. § 404.1520(e), § 404.1545(a)(2).

Section 404.1545(a)(2) requires an ALJ to consider limitations from all impairments, including those that are not severe, when assessing residual functional capacity.

Sullivan III v. Commissioner of Social Security · filed 2023-02-01(a)(2)

In determining an individual’s RFC and later posing a hypothetical to a VE that includes the RFC, the ALJ “must consider limitations and restrictions imposed by all of an individual’s impairments, even those that are not ‘severe.’” SSR 96-8P, 1996 WL 374184 at *5; see also 20 C.F.R. § 404.1545(a)(2); Swindle v. Sullivan, 914 F.2d 222, 226 (11th Cir. 1990) (stating “the ALJ must consider a claimant’s impairments in combination” (citing 20 C.F.R. § 404.1545; Reeves v. Heckler, 734 F.2d 519, 525 (11th Cir. 1984))).

Section 404.1545(a)(2) requires an RFC assessment to account for limitations from both severe and non-severe impairments.

Blenker v. Commissioner of Social Security · filed 2023-01-26(a)(2)

In addition, the ALJ properly evaluated all of Plaintiff’s impairments, severe and non-severe, in the remainder of his decision. See Parker-Grose v. Astrue, 462 F. App'x 16, 18 (2d Cir. 2012) (“An RFC determination must account for limitations imposed by both severe and non-severe impairments.”); 20 C.F.R. § 404.1545(a)(2).

Section 404.1545(a)(2) requires an ALJ to consider the effects of severe and nonsevere impairments on a claimant’s functional capacity.

Miller v. Commissioner of Social Security Administration · filed 2023-02-24(a)(2)

Whether Miller’s visual impairment was “severe” is irrelevant, considering that the regulations require that the ALJ consider the impact of both severe and nonsevere impairments on Miller’s functional capacity.

An ALJ must consider the limiting effects of all medically determinable impairments, including nonsevere impairments, when assessing residual functional capacity.

Alls v. Social Security Administration · filed 2023-02-27(a)(2), (e)

The ALJ is required to consider the limiting effects of all the claimant’s medically determinable impairments—including those that are not severe—in determining the claimant’s RFC.

Section 404.1545(e) requires the ALJ to consider the limiting effects of all impairments, including those that are not severe, when determining residual functional capacity.

Zigila v. Commissioner of the Social Security Administration · filed 2023-02-13(e)

Even non-severe impairments are to be considered in the RFC determination discussion. Regulations require that an ALJ “consider the limiting effects of all [the claimant’s] impairment(s), even those that are not severe,” in determining the claimant’s RFC. 20 C.F.R. § 404.1545(e); see also SSR 96–8p (“In assessing RFC, the adjudicator must consider limitations and restrictions imposed by all of an individual's impairments, even those that are not ‘severe.’ ”).

Section 404.1545(a)(2) requires the ALJ to consider medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Sampedro v. Kijakazi · filed 2023-02-15(a)(2)

As argued by Plaintiff, the ALJ must consider both severe and non-severe impairments when determining the RFC.

Section 404.1545 requires an RFC assessment to consider all medically determinable impairments, including those found non-severe.

Holden v. Commissioner of Social Security Administration · filed 2023-02-23(a)(1)–(2)

Therefore, if an ALJ determines that a claimant has medically determinable impairments, severe or not, it is harmful error if the ALJ fails to mention them when assessing the RFC.

Section 404.1545(e) requires an ALJ to consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Ingerson v. Commissioner, Social Security Administration · filed 2023-02-27(e)

The ALJ stated in her decision that she “considered all of the claimant’s medically determinable impairments, including those that are not severe, when assessing the claimant’s residual functional capacity.” [Doc. 8-2 at 16 (emphasis added)]. Indeed, the ALJ was required to do so. See 20 C.F.R. § 404.1545(e); Grotendorst v. Astrue, 370 F. App’x 879, 883 (10th Cir. 2010).

Section 404.1545 requires the ALJ to consider non-severe mental limitations when assessing residual functional capacity, but mild limitations need not result in explicit mental restrictions.

Neyerlin v. Commissioner of Social Security · filed 2023-02-23(a)(2)

As long as the ALJ considered Plaintiffs non-severe mental limitations in making his RFC determination, a finding of mild limitations in two functional areas at step three did not obligate the ALJ to include any mental restrictions in the RFC.

An RFC assessment must consider obesity, but a finding that obesity is severe does not by itself require obesity-related limitations in the RFC.

Walker v. Kijakazi · filed 2023-02-24(a)(2)

Contrary to Ms. W.’s argument, the ALJ was not required to include obesity-related limitations in Ms. W.’s RFC merely because he found obesity to be a severe impairment at step two.

Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments, including those that are not severe, when calculating residual functional capacity.

Norman v. Commissioner of Social Security · filed 2023-03-06(a)(2)

The Commissioner’s regulations require an ALJ to consider all medically determinable impairments, including those that are not severe, when calculating the claimant’s RFC at step four. 20 C.F.R. § 404.1545(a)(2).

Section 404.1545(a)(2) requires the ALJ to consider functional limitations supported by the evidence, including those from impairments not found severe.

(SS) Dalton v. Commissioner of Social Security · filed 2023-03-13(a)(2)

In doing so she considered all functional limitations established by the reliable evidence, not just the ones identified as severe. See 20 C.F.R. § 404.1545(a)(2).

Section 404.1545(a)(2) requires an ALJ to consider all impairments, including nonsevere impairments, when assessing residual functional capacity.

Vaccarino v. Commissioner of Social Security · filed 2023-03-21(a)(2)

Although an ALJ need not determine whether every alleged impairment is “severe” at step two, the ALJ must consider all impairments, regardless of severity, in conjunction with one another in performing the latter steps of the sequential evaluation.

Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments when assessing residual functional capacity, including non-severe impairments.

Spataro v. Commissioner of Social Security · filed 2023-03-15(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at Step 2 of his or her analysis. 20 C.F.R. §§404.1545(a)(2), 416.945(a)(2).

Section 404.1545 requires an ALJ to consider all impairments, including non-severe impairments, when assessing residual functional capacity.

Letourneau v. Commissioner of Social Security · filed 2023-03-16(a)(2)

Given that the ALJ was required to consider all of Plaintiff’s impairments, severe and non-severe, in assessing her RFC, the ALJ’s failure to do so here constitutes error necessitating remand.

Section 404.1545 requires an ALJ to consider limitations from non-severe impairments when assessing residual functional capacity and to explain the omission of limitations the ALJ has found.

HOENE v. KIJAKAZI · filed 2023-03-21(a)(2), (e)

Failure to incorporate such limitations—without explanation—was erroneous and warrants remand.

Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments when assessing residual functional capacity, including impairments found nonsevere at step two.

Corbitt v. Kijakazi (CONSENT) · filed 2023-03-29(a)(2)

At the fourth step of the sequential evaluation process, an ALJ must consider all medically determinable impairments, not just the “severe” impairments identified at step two.

Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments when assessing residual functional capacity, including non-severe impairments.

Wilder v. Kijakazi · filed 2023-03-24(a)(2)

In making this assessment, the ALJ considers all the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.

An RFC assessment must consider all medically determinable impairments, including non-severe impairments.

Maymi v. Kijakazi · filed 2023-03-24(a)(2)

In making this assessment, the ALJ considers all the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.

Section 404.1545(a)(2) requires consideration of limitations from non-severe impairments when assessing residual functional capacity, but does not require including limitations the record does not support.

(SS) Diana Guzman v. Commissioner of Social Security · filed 2023-03-28(a)(2)

The record reflects that the ALJ considered all of the evidence related to Plaintiff’s mental impairments at step four before deciding that inclusion of limitations based on those impairments in the RFC was not warranted.

Section 404.1545(a)(2) requires the ALJ to consider both severe and non-severe impairments when determining residual functional capacity.

Johnston v. Kijakazi · filed 2023-03-28(a)(2)

This error is especially pronounced here given that the ALJ’s failure to properly consider Plaintiff’s severe impairments at Step 2, apparently foreclosed the ALJ from considering the symptoms of those impairments at subsequent Steps. ... (requiring the ALJ to consider severe and non-severe impairments in determining the claimant’s RFC).

Section 404.1545 requires an RFC assessment to consider limitations from both severe and nonsevere impairments.

Buck v. Commissioner of Social Security · filed 2023-03-29

The ALJ considers impairments that are both “severe” and “not severe”, see 20 C.F.R. § 404.1545, “based on all the relevant medical and other evidence in [the claimant’s] case record,” 20 C.F.R. § 404.1520(e). ... Because the Commissioner will need to re-evaluate those opinions on remand, the ALJ should also re-evaluate plaintiff’s RFC to determine whether he has any additional restrictions.

The ALJ must consider the effects of nonsevere mental limitations when assessing residual functional capacity and explain how the evidence supports the assessment.

Hays v. Commissioner of Social Security · filed 2023-03-31(a)(2)

Therefore, the Court FINDS the ALJ adequately discussed its RFC assessment, including the effect of all Plaintiff’s mental limitations, and the support for that RFC in the evidence.

Section 404.1545(a)(2) requires an ALJ to consider non-severe impairments when assessing residual functional capacity.

Martinez v. Commissioner of Social Security · filed 2023-03-30(a)(2)

The Court agrees with the Commissioner that the ALJ properly considered the impact of Mr. Martinez’s headaches and insomnia when making her RFC determination.

Section 404.1545(a)(2) requires the ALJ to consider the limiting effects of all impairments, including non-severe impairments, and related symptoms when assessing residual functional capacity.

Dunphy v. Commissioner of the Social Security Administration · filed 2023-03-31(a)(2)

The ALJ must consider the limiting effects of an individual’s impairments, even those that are non-severe, and any related symptoms.

Section 404.1545(a)(2) requires an ALJ to consider all limitations when assessing residual functional capacity, including those from non-severe impairments.

Andrick v. Commissioner of Social Security Administration · filed 2023-04-20(a)(2)

An ALJ must consider all limitations when assessing a claimant’s RFC, even if those limitations are found to be non-severe. 20 C.F.R. § 404.1545(a)(2).

Section 404.1545(a)(2) requires an ALJ to consider nonsevere medically determinable impairments when assessing residual functional capacity, but does not require the ALJ to specifically address each one.

Hundley v. Commissioner of Social Security · filed 2023-04-27(a)(2)

The Fourth Circuit has explained that “neither our caselaw nor the regulations explicitly require” an ALJ to “specifically address” a claimant’s non-severe impairments in an RFC assessment. Britt, 860 F. App’x at 262. “The judge is only required to consider these non-severe impairments.” Id. (emphasis in original). Here, it is clear from the opinion that ALJ considered Plaintiff’s knee impairment in the RFC after deeming it non-severe at step two.

In assessing residual functional capacity, an ALJ must consider all impairments, including those found not severe at step two.

Henson v. Commissioner of Social Security · filed 2023-05-01(a)(2)

Notably, when the ALJ assesses the Plaintiff’s residual functional capacity—defined as his ability to do physical and mental work activities on a sustained basis despite limitations from his impairments—the ALJ must consider all of Plaintiff’s impairments, including impairments he found were not severe at step two.

Section 404.1545(a)(2) requires an ALJ to consider nonsevere mental impairments when determining residual functional capacity and explain why any mild limitations require no RFC restriction.

Coulter v. Commissioner of Social Security · filed 2023-05-10(a)(2)

An ALJ may properly determine that mild limitations found during the Paragraph B analysis do not translate into functional limitations within the RFC. But an ALJ must provide a basis for understanding how they made that determination.

Section 404.1545 requires the ALJ to consider non-severe mental impairments when assessing RFC, but does not require a mental limitation when the evidence supports none.

MAY v. KIJAKAZI · filed 2023-04-26(a)(2)

Because the ALJ adequately addressed the mental health treatment evidence in the record in concluding that the functional impact of Plaintiff’s mental health impairment was so slight that it did not require inclusion in the RFC assessment or the hypothetical posed to the VE, tr. at 26, I find no error in the ALJ’s analysis.

Section 404.1545 does not require specific articulation of how an ALJ considered non-severe impairments when assessing residual functional capacity.

Finley v. Commissioner of the Social Security Administration · filed 2023-04-26

The regulations do not require specific articulation about how an ALJ is to have considered non- severe impairments in the RFC.

Section 404.1545(a)(2) requires an ALJ assessing residual functional capacity to consider all medically determinable impairments supported by the record, including non-severe impairments.

MENSCH v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-05-08(a)(2)

When assessing a claimant’s RFC, an ALJ must consider all of the claimant’s medically determinable impairments which are supported by the record, including those considered non-severe.

Section 404.1545(a)(2) requires the RFC assessment to consider all medically determinable impairments, including nonsevere ones; omitting an impairment at step two is harmless when the ALJ considers its functional effects in the RFC.

(SS)Her v. Commissioner of Social Security · filed 2023-06-08(a)(2)

This further confirms that it was not harmful error that the ALJ did not mention CRPS by name at step two, because the ALJ considered the objective effects from this condition in assessing the RFC.

An ALJ may omit RFC limitations for mild, nonsevere mental impairments when the decision sufficiently explains why those limitations are unnecessary.

Zalusky v. Saul · filed 2023-06-08

In light of the ALJ’s citation to this evidence, the Court finds that the ALJ has sufficiently explained her decision not to incorporate any non-exertional limitations into the RFC to account for Claimant’s mild mental impairments.

Section 404.1545 requires an ALJ to consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

NORRIS v. SAUL · filed 2023-05-25(a)(2)

An ALJ must consider all a claimant’s medically determinable impairments in assessing a claimant’s RFC, including impairments that are not severe. 20 C.F.R. § 404.1545.

Section 404.1545(a)(2) requires an RFC to include limitations from all medically determinable impairments, including non-severe impairments.

McCune v. Commissioner of Social Security · filed 2023-05-26(a)(2)

A claimant’s RFC includes limitations for all medically determinable impairments, including non-severe impairments. 20 C.F.R. § 404.1545(a)(2).

An ALJ may omit limitations for a non-severe mental impairment from an RFC assessment when the ALJ adequately explains the omission.

ETZE v. KIJAKAZI,ACTING COMMISSIONER OF SOCIAL SECURITY · filed 2023-05-26(c)

The ALJ adequately explained her reasoning for failing to include any limitations related to Ms. Etze’s non-severe mental impairment in her RFC assessment and hypothetical question upon which she relied.

An RFC assessment must consider all medically determinable impairments, including non-severe impairments, and failure to fully consider their impact requires reversal.

Devlin v. Commissioner of the Social Security Administration · filed 2023-05-31(a)(2)

In crafting a claimant’s RFC, ALJs “must consider all medically determinable impairments . . . even those that are not considered ‘severe.’” Craft, 539 F.3d at 676 (citing 20 C.F.R. §404.1545(a)(2), (b), (c)). ... The ALJ’s failure to fully consider the impact of these non-severe impairments is reversible error. The ALJ must consider these non-severe impairments, and explain how he did so, on remand.

Section 404.1545(e) requires the RFC assessment to consider all medically determinable impairments, including those found non-severe.

Stauffer v. Commissioner of Social Security · filed 2023-06-12(e)

Moreover, the ALJ’s RFC reflects that he considered all of Plaintiff’s medically determinable impairments, including her non-severe mental impairments, at subsequent steps in the sequential evaluation process.

Section 404.1545(a)(2) requires an RFC assessment to consider all medically determinable impairments, including those found non-severe.

Bigler v. Commissioner Social Security Administration · filed 2023-06-12(a)(2)

Thus, even if the ALJ had properly concluded that plaintiff’s mental impairments were non-severe, they must be factored into the RFC, which did not occur in this case.

An RFC must account for limitations from nonsevere impairments, but supported findings of no more than mild mental limitations need not produce additional restrictions.

Phelps v. Commissioner of Social Security · filed 2023-06-26(a)(2)

To be sure, “[a] RFC determination must account for limitations imposed by both severe and nonsevere impairments.” Parker-Grose v. Astrue, 462 F. App’x 16, 18 (2d Cir. 2012). But where, as here, substantial evidence supports the ALJ’s determination that Plaintiffs mental impairments caused no more than mild limitations in four broad areas and are, therefore, non-severe, additional mental restrictions in the RFC are not warranted.

Section 404.1545(a)(2) requires consideration of all medically determinable impairments, including nonsevere impairments, when assessing residual functional capacity.

Steiner v. Commissioner of Social Security · filed 2023-07-05(a)(2)

“An error at step two—either a failure to make a severity determination regarding an impairment, or an erroneous determination that an impairment is not severe—can be harmless error if the ALJ continues the analysis and considers all impairments in [his] RFC determination.” Sech v. Comm’r of Soc. Sec., No. 7:13-CV-1356, 2015 WL 1447125, at *3 (N.D.N.Y. Mar. 30, 2015); see 20 C.F.R. § 404.1545(a)(2) (“We will consider all of your medically determinable impairments of which we are aware, including your medically determinable impairments that are not ‘severe’ … when we assess your [RFC].”). ... Here, the record shows that the ALJ properly considered Plaintiff’s nonsevere impairments when determining Plaintiff’s RFC.

Section 404.1545(a)(2) requires an RFC assessment to account for all medically determinable impairments, including non-severe mental impairments.

Kelley v. Social Security Administration, Commissioner of · filed 2023-06-21(a)(2)

First, the ALJ failed to follow the procedures set forth in the regulations, which state that all medically determinable impairments, severe and non-severe alike, must be accounted for in the RFC assessment.

Section 404.1545 requires an RFC assessment to account for all of a claimant’s impairments and the functional limitations supported by the evidence.

(SS) Garcia v. Commissioner of Social Security · filed 2023-06-23

In an RFC assessment, the ALJ must include all of a claimant’s impairments. 20 C.F.R. §§ 404.1545, 416.945; Bray v. Comm’r of Soc. Sec. Admin., 554 F.3d 1219, 1228 (9th Cir. 2009). ... Based on the foregoing, the Court finds the ALJ properly incorporated the functional limitations supported by the properly-weighted medical evidence into the RFC determination, and explained her basis for rejecting the one-to-two step tasks limitation, based on substantial evidence in the record.

Section 404.1545(a)(2) requires an ALJ to consider both severe and non-severe impairments when determining residual functional capacity.

Negron v. Kijakazi · filed 2023-06-27(a)(2)

An ALJ must consider both a claimant’s severe and non-severe impairments in determining a claimant’s RFC. 20 C.F.R. § 404.1545(a)(2); 20 C.F.R. § 416.945(a)(2); De Leon v. Sec’y of Health & Human Servs., 734 F.2d 930, 937 (2d Cir. 1984). ... As such, the court concludes that the ALJ properly assessed the plaintiff’s RFC related to her bipolar disorder and borderline personality disorder.

Section 404.1545(a)(2) requires an ALJ to consider non-severe impairments when assessing residual functional capacity.

Cooke v. Commissioner of Social Security · filed 2023-07-07(a)(2)

An ALJ is required to consider a claimant’s non-severe impairments in assessing the RFC.

In assessing residual functional capacity, the ALJ must consider all impairments, including those found nonsevere; doing so makes an error in labeling an impairment at step two harmless.

Figueroa v. Commissioner of Social Security · filed 2023-07-18(a)(2)

Once a case advances beyond step two, the ALJ must consider all impairments, severe or not, at the remaining steps. ... Because the ALJ considered all Ms. Figueroa’s impairments—including her migraine headaches—in determining whether she could work and with what limitations, any error by the ALJ in failing to identify Ms. Figueroa’s migraine headaches as severe was harmless.

An ALJ must consider the limiting effects of all impairments, including nonsevere impairments, when determining residual functional capacity.

Matlock v. SSA · filed 2023-07-18(e)

Rather, “the pertinent inquiry is whether the ALJ considered ‘the limiting effects of all [claimant’s] impairment(s), even those that are not severe in determining [the claimant’s] residual functioning capacity.’” Id. (alterations in original) (quoting 20 C.F.R. § 404.1545(e)). ... Matlock has failed to identify what additional limitations should have been set forth given his radiculopathy, and the ALJ did consider and account for his reported symptoms and related treatment in the RFC finding.

Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including nonsevere impairments, when assessing residual functional capacity.

Ali v. Commissioner of Social Security · filed 2023-07-26(a)(2)

“An error at step two—either a failure to make a severity determination regarding an impairment, or an erroneous determination that an impairment is not severe—can be harmless error if the ALJ continues the analysis and considers all impairments in [his] RFC determination.” Sech v. Comm’r of Soc. Sec., No. 7:13-CV-1356, 2015 WL 1447125, at *3 (N.D.N.Y. Mar. 30, 2015); see 20 C.F.R. § 404.1545(a)(2) (“We will consider all of your medically determinable impairments of which we are aware, including your medically determinable impairments that are not ‘severe’ … when we assess your [RFC].”).

Section 404.1545(e) requires an ALJ to consider the limiting effects of all impairments, including non-severe impairments, when assessing residual functional capacity.

Cavens v. Commissioner of Social Security · filed 2023-07-18(e)

Therefore, if an ALJ errs when assessing severity, the pertinent inquiry is whether the ALJ considered the “limiting effects of all [claimant’s] impairment(s), even those that are not severe, in determining [the claimant’s] residual functional capacity.” 20 C.F.R. § 404.1545(e).

Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Bonk v. Kijakazi · filed 2023-07-25(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.

An RFC assessment must consider all medically determinable physical and mental impairments, including non-severe impairments.

Boger v. Commissioner of Social Security · filed 2023-08-01(a)(2)

When determining the RFC, the ALJ must consider all medically determinable impairments, mental and physical, even those that are non-severe.

Section 404.1545 requires consideration of non-severe impairments in assessing residual functional capacity, but mild mental limitations need not be included as functional restrictions.

Lewis v. Commissioner of Social Security · filed 2023-08-02(a)(2)

Because the ALJ found Ms. Lewis had only mild limitations, the ALJ did not have to account for such limitations in the RFC assessment.

Section 404.1545(a)(2) requires an ALJ to consider the combined effect of all medically determinable impairments, including nonsevere impairments, when assessing residual functional capacity.

Stone v. Commissioner of Social Security Administration · filed 2023-08-08(a)(2)

“In h[er] RFC assessment, the ALJ must consider the combined effect of all medically determinable impairments, whether severe or not.” Id. at 1069 (citing 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2)). ... Here, as in Suttles, the ALJ explicitly acknowledged the proper legal standard, AR 860, and she considered Plaintiff’s mental impairments.

Section 404.1545 requires consideration of the limiting effects of all impairments, including nonsevere impairments, when assessing residual functional capacity.

Barth v. Commissioner of Social Security · filed 2023-08-21(a)(2), (e)

Instead, the pertinent inquiry is whether the ALJ considered the “limiting effects of all [the claimant’s] impairment(s), even those that are not severe, in determining [the claimant’s] residual functional capacity.” 20 C.F.R. §§ 404.1545(a)(2), (e); 20 C.F.R. §§ 416.945(a)(2), (e).

Section 404.1545(a)(2) requires the ALJ to consider nonsevere impairments when assessing residual functional capacity; failure to account for them requires remand.

Braun v. Commissioner of Social Security · filed 2023-08-22(a)(2)

Remand is required if the ALJ fails to account for the claimant’s nonsevere impairments when determining the RFC.

Section 404.1545(e) requires consideration of the limiting effects of all impairments, including nonsevere impairments, when determining residual functional capacity.

Stewart v. Social Security Administration · filed 2023-08-22(e)

This is because, after step two, the ALJ considers the combined effect of all impairments (severe or not). Brescia v. Astrue, 287 F. App’x 626, 629 (10th Cir. 2008) (unpublished);4 see also 20 C.F.R. § 404.1545(e)5 (“we will consider the limiting effects of all your impairment(s), even those that are not severe, in determining your residual functional capacity”). ... Here, the ALJ found multiple other impairments to be severe (R. 24-25) and, as noted below, continued to consider Plaintiff’s diabetes at other steps of the evaluation (R. 29, 32-34).

Section 404.1545 requires an ALJ to consider work-related limitations from all impairments when assessing residual functional capacity, including impairments found non-severe.

Dinkins, Jr. v. Commissioner of Social Security · filed 2023-08-07(a)(2)

Even if the ALJ was correct that Plaintiff’s carpal tunnel syndrome was non-severe, he was still required to consider the limits the condition caused on Plaintiff’s ability to perform basic work related tasks. 20 C.F.R. § 404.1545 (all impairments must be considered, “even those that are not severe,” when determining RFC); SSR 96-8p (ALJ must consider limitations and restrictions imposed by all of the claimant’s impairments, including non-severe impairments); Golembiewski v. Barnhart, 322 F.3d 912, 918 (7th Cir. 2003).

Section 404.1545(a)(2) requires the RFC assessment to consider the combined effect of all medically determinable impairments, including those that are not severe.

Brinkley v. Social Security Administration · filed 2023-08-17(a)(2)

When assessing the RFC, “the ALJ must consider the combined effect of all of the claimant’s medically determinable impairments, whether severe or not severe.” ... The ALJ’s discussion demonstrates she considered evidence of Plaintiff’s diagnoses of GAD and anxiety, PTSD, OCD, bipolar disorder, depression, borderline personality disorder, and Plaintiff’s experiencing delusional thinking. ... Thus, the Court finds no merit to Plaintiff’s argument.

Section 404.1545 requires an RFC assessment to consider all relevant evidence of a claimant’s ability to work, including the effects of nonsevere impairments.

HOWARD v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-08-24(a)-(b)

An RFC is an assessment based on all the relevant evidence of a claimant’s ability to work despite her impairments, even if those impairments were not deemed severe.

An RFC determination must account for limitations imposed by both severe and nonsevere impairments.

De Cordova v. Commissioner of Social Security · filed 2023-09-07(a)(2)

The ALJ did not err in his RFC determination because he considered the limitations imposed by both severe and non-severe impairments. See Parker-Grose v. Astrue, 462 F. App’x 16, 18 (2d Cir. 2012) (“A[n] RFC determination must account for limitations imposed by both severe and nonsevere impairments.” (citing 20 C.F.R. § 404.1545(a)(2) and 20 C.F.R. § 416.945(a)(2))).

Section 404.1545(e) requires the ALJ to consider limitations from all impairments, including those that are not severe, when assessing residual functional capacity.

Wilson v. Commissioner of Social Security · filed 2023-08-23(e)

Rather, the ALJ considers the limitations and restrictions imposed by all of a claimant’s impairments, even those that are not severe, when assessing the RFC. ... For the reasons discussed above, the ALJ erred when evaluating Plaintiff’s migraine impairment and did not sufficiently consider Plaintiff’s symptoms and limitations from this impairment when assessing the RFC. This error was not harmless because it resulted in an RFC determination that did not include all of the limitations supported by the record.

An ALJ must consider all medically determinable impairments when assessing residual functional capacity, including impairments found non-severe at step two.

Kenyon v. Kijakazi · filed 2023-08-30(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.

An ALJ must consider limitations from non-severe impairments when assessing residual functional capacity, but need include only limitations supported by the medical record.

Banks v. Saul · filed 2023-08-24(a)(2)

Additionally, “while an ALJ must consider limitations and restrictions imposed by an individual’s impairments, even those that are non-severe, the RFC need only incorporate limitations supported by the claimant’s medical record.”

Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Fillmore v. Kijakazi · filed 2023-09-07(a)(2)

Instead, as required by 20 C.F.R. § 404.1545(a)(2), “the ALJ must consider the combined effect of all medically determinable impairments, whether severe or not,” when determining the claimant’s RFC.

Section 404.1545 requires an ALJ to consider all impairments when assessing residual functional capacity, including impairments found nonsevere at step two.

Taylor v. Kijakazi · filed 2023-09-07(a)(1)-(2), (e)

Under governing law, an ALJ must consider the impact of all impairments on a claimant’s residual functional capacity, whether they were deemed severe or not severe at step two.

An ALJ must consider limitations from all impairments when assessing residual functional capacity, including impairments found to be nonsevere.

TROYCHECK v. KIJAKAZI · filed 2023-09-18(a)(2)

Accordingly, merely because the ALJ did not find Plaintiff’s edema to be a severe impairment does not mean that this condition could not still have affected Plaintiff’s RFC.

An ALJ assessing residual functional capacity must consider all medically determinable impairments, including those that are not severe.

Keller v. Kijakazi · filed 2023-09-19(a)(2)

When considering a claimant’s RFC, an ALJ must consider “all medically determinable impairments including [] medically determinable impairments that are not ‘severe.’” 20 C.F.R. § 404.1545(a)(2).

Section 404.1545 requires an RFC assessment to include medically determinable impairments even when they are not severe.

Hernandez v. O'Malley · filed 2023-09-12(a)(2), (e)

To the contrary, non-severe medically determinable impairments must be included in the RFC along with the severe ones.

Section 404.1545 requires an ALJ to account for limitations from medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Negron v. Commissioner of the Social Security Administration · filed 2023-09-12

Where an ALJ finds in a claimant’s favor at step two, even if he or she erroneously concluded that some of the claimant’s other impairments were non-severe, the error is harmless if the sequential evaluation process continues beyond step two and the functional limitations associated with the impairment are accounted for in the RFC. ... However, the error is not harmless where, as here, the ALJ has found an impairment not medically determinable. Unlike a non-severe impairment, a non-medically determinable impairment is not considered in assessing the claimant’s RFC. ... This step two error calls into question the completeness of the ALJ’s RFC assessment and undermines the support for his conclusions at steps four and five of the sequential evaluation process.

An RFC assessment must consider all of a claimant’s impairments, including those that are not severe.

Pine v. Kijakazi · filed 2023-09-14(a)(3)

The ALJ must base the RFC findings on “all of the relevant medical and other evidence,” and must consider all of the claimant’s impairments, including those that are not severe.

Section 404.1545(a)(2) requires an ALJ to consider non-severe impairments when assessing residual functional capacity and to explain how their limitations are accounted for.

Gallucci v. Kijakazi · filed 2023-09-15(a)(2)

This includes consideration not only of a claimant’s severe impairments, but also of a claimant’s non-severe impairments as well. 20 C.F.R. § 404.1545(a)(2); Parker-Grose v. Astrue, 462 Fed. Appx. 16, 18 (2d Cir. 2012) (summary order). ... However, this statement does not obviate the ALJ’s duty to fully account for and explain a claimant’s severe and non-severe limitations when formulating a claimant’s RFC at step four. ... This failure constitutes legal error and grounds for remand.

Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments, including non-severe ones, when assessing residual functional capacity.

Linval v. Commissioner of Social Security · filed 2023-09-19(a)(2)

When making an RFC determination, an ALJ must consider both severe and non-severe impairments. ... Here, the ALJ’s RFC analysis is devoid of any discussion of Plaintiff’s carpal tunnel syndrome, or of finger and hand manipulation limitations.

An ALJ need not assign a specific RFC limitation to every impairment found severe.

Flowers v. Commissioner of Social Security · filed 2023-09-20

This argument also fails because Plaintiff cites and the Court finds no authority for the proposition that an ALJ must associate each impairment found to be severe with a specific limitation in the ALJ’s RFC finding.

Section 404.1545(a)(2) requires consideration of severe and non-severe impairments when assessing residual functional capacity, but substantial evidence may support including no limitation for a particular impairment.

Das v. Commissioner Social Security · filed 2023-09-21(a)(2)

The ALJ must consider both severe and non-severe impairments when assessing an individual’s RFC and the limitations considered as part of it. 20 C.F.R. § 404.1545(a)(2). Das’s argument that additional limitations needed to be included in her RFC fails because of the inconsistent evidence in the record regarding Das’s anemia and heavy menses.

Section 404.1545(a)(2) requires consideration of all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Davis v. Social Security Administration, Commissioner of · filed 2023-09-21(a)(2)

If an ALJ finds that a claimant has at least one severe impairment, they must proceed with the remainder of the sequential analysis and consider all of the claimant’s impairments when determining their RFC, including non-severe impairments.

Section 404.1545 requires an RFC assessment to consider all relevant evidence, including non-severe mental limitations, and to explain the resulting RFC.

Glines v. Commissioner of Social Security · filed 2023-09-25(a)(1)

But his Step 2 conclusion is not an RFC conclusion. The ALJ need not copy and paste each fact he considered at Step 2 into his RFC analysis, but he does need to support his RFC conclusion. The ALJ has provided some of the information he considered and given his answer, but he failed to show his work sufficiently. The ALJ’s decision must therefore be reversed and remanded for further proceedings.

Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Mull v. Commissioner of Social Security · filed 2023-09-26(a)(2)

In making this assessment, the ALJ considers ... all the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.

Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Stoner v. Commissioner of Social Security · filed 2023-09-27(a)(2)

In making this assessment, the ALJ considers all the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis.

Section 404.1545(a)(2) requires the ALJ to consider limitations from non-severe impairments when determining residual functional capacity.

Daniels v. Commissioner of Social Security · filed 2023-10-12(a)(2)

Moreover, even assuming arguendo that the ALJ had properly concluded that plaintiff’s mental impairments were non-severe, remand would nonetheless be appropriate, for the purpose of redetermining plaintiff’s RFC in a manner that takes his mental health limitations into account.

Section 404.1545(a)(2) requires an ALJ to consider medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

MCSWEENY v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-10-16(a)(2)

The Court will remand for the ALJ to expressly consider how Plaintiff’s IBS and mental health impairments impact her RFC.

Section 404.1545(a)(2) requires an RFC assessment to consider medically determinable mental impairments even when they are non-severe.

Owen v. Social Security Administration · filed 2023-10-17(a)(2)

On remand, the ALJ should consider Plaintiff’s non-severe mental impairments and include a narrative discussion in the RFC assessment addressing whether Plaintiffs mental impairments, combined with her physical impairments, result in any mental limitations in the Plaintiff's RFC.

An RFC assessment must consider non-severe mental impairments, but may omit mental functional limitations when the evidence supports doing so.

Peterson v. Social Security Administration · filed 2023-10-17(a)(2)

The Court finds the ALJ’s analysis of the reviewing psychologists’ opinions was adequate and supports the ALJ’s decision not to include mental functional limitations in the RFC.

When an ALJ considers non-severe mental impairments and finds only mild limitations, § 404.1545(a)(2) does not require an in-depth discussion of those impairments in the RFC assessment.

AYGUN v. COMMISSIONER OF SOCIAL SECURITY · filed 2023-10-25(a)(2)

The record as a whole indicates that Judge Loewy thoroughly examined the plaintiff’s mental limitations. In Step 2, the ALJ found that they warrant no more than a mild limitation in the four functional areas. That being the case, the ALJ did not need to provide an in-depth analysis of mental impairments in the RFC assessment.

An ALJ may satisfy the duty to consider nonsevere impairments in assessing residual functional capacity by discussing them elsewhere in the decision and relying on medical evaluations that analyze them.

Collier v. SSA · filed 2023-10-31(a)(2)

While the ALJ may not have explicitly considered these mental limitations in her RFC calculation, the fact she referenced these limitations multiple times in her decision and relied on providers’ evaluations that did analyze these impairments indicates that there is no error on these grounds.

Section 404.1545(a)(2) requires the ALJ to consider all medically determinable impairments, including nonsevere impairments, when assessing residual functional capacity.

Sedgwick v. Social Security Administration, Commissioner of · filed 2023-11-16(a)(2)

If an ALJ finds that a claimant has at least one severe impairment, they must proceed with the remainder of the sequential analysis and consider all of the claimant’s severe and non-severe impairments when determining their RFC.

An RFC assessment must consider all medically determinable impairments, including those found nonsevere.

Morris v. Social Security Administration · filed 2023-11-21(a)(2)

Indeed, the ALJ was charged with considering in his RFC assessment the combined effect of all medically determinable impairments, whether severe or not. See 20 C.F.R. § 404.1545(a)(2).

Section 404.1545 does not require an ALJ to explain specifically how non-severe impairments were considered in the residual functional capacity assessment.

Shead v. Commissioner of the Social Security Administration · filed 2023-10-31

The regulations do not require specific articulation about how an ALJ is to have considered non-severe impairments in the RFC.

An RFC assessment must consider non-severe impairments and explain a finding that identified mental limitations cause no work-related restrictions.

Whiteneck v. Commissioner of Social Security · filed 2023-11-02(a)(2)

Further, the ALJ is required to provide an explanation if he determined that Plaintiff’s mental limitations did not result in work-place restrictions.

Section 404.1545 does not require an ALJ to give a specific explanation of how non-severe impairments were considered in the residual functional capacity assessment.

Lingenfelter v. Commissioner of the Social Security Administration · filed 2023-11-09

The regulations do not require specific articulation about how an ALJ is to have considered non-severe impairments in the RFC.

Section 404.1545 requires an ALJ to consider the effects of all impairments when assessing residual functional capacity, including impairments found nonsevere at step two.

Zuk v. Commissioner of Social Security · filed 2023-11-06(a)(1)-(2), (e)

Under governing law, however, an ALJ must consider the impact of all impairments on a claimant’s RFC, whether they were deemed severe or not severe at step two.

An ALJ must consider the effects of nonsevere medically determinable impairments when assessing residual functional capacity.

Ridenour v. Commissioner of Social Security Administration · filed 2023-11-30(a)(2)

While Plaintiff’s complaints about her headaches may have been “made on only a few occasions, and in medical records that appear toward the end of the adjudicated period,” they were significant enough to require an analysis of their impact on Plaintiff’s RFC.

An ALJ must consider all medically determinable impairments when assessing residual functional capacity, including impairments that are not severe.

McQuay v. Commissioner of Social Security · filed 2023-12-21(a)(2)

The ALJ must consider all of a claimant’s medically determinable impairments, including those that are not “severe.” ... Without more, substantial evidence supports the ALJ’s decision as to consideration of Plaintiff’s medically determinable impairments and limitations from them.

An ALJ must account for limitations from both severe and nonsevere impairments when assessing residual functional capacity.

Alston v. Commissioner of Social Security · filed 2023-12-28

But in formulating a claimant’s RFC, the ALJ “must account for limitations imposed by both severe and non[-]severe impairments.” ... Here, in formulating Shamara’s RFC, the ALJ explicitly addressed both her severe physical impairments and her nonsevere mental impairments.

Section 404.1545(a)(2) requires consideration of non-severe impairments when assessing residual functional capacity, but an omission is harmless when those impairments cause no functional limitations.

Spinato v. Commissioner of Social Security · filed 2023-12-11(a)(2)

But “[f]or an impairment of any kind to be included in the [RFC] analysis, it must cause or at least contribute to physical or mental limitation or restriction of a specific functional capacity.” Sherman, 2015 WL 5838454, at *5; see also 20 C.F.R. § 404.1545(a) (referring to limitations as those “cause[d]” by a claimant’s impairments and any related symptoms). Spinato does not point to any limitations here. ... To the extent that the ALJ erred by not explicitly restating his step two findings of no limitations at step three, that error was harmless.

Section 404.1545(e) requires an ALJ assessing residual functional capacity to consider the limiting effects of all impairments, including those that are not severe.

Deacon v. Kilolo Kijakazi, Commissioner of Social Security · filed 2023-12-21(e)

In evaluating a claimant’s RFC, the ALJ must consider the limiting effects of all impairments, even those that are not severe. 20 C.F.R. §§ 404.1545(e), 416.945(e); see also Assessing Residual Functional Capacity in Initial Claims, SSR 96–8p, 1996 WL 374184, at *5 (S.S.A. July 2, 1996).

Section 404.1545 requires the ALJ to consider all impairments, including non-severe mental limitations, when assessing residual functional capacity.

Arce v. Commissioner of Social Security · filed 2024-01-03(a)(2)

To support her conclusion that Arce could perform work in the national econ- omy—including that of order clerk, telephone information clerk, and charge account clerk—the ALJ had to consider all the duties of that work and evaluate Arce’s ability to perform those duties de- spite all her impairments, severe and non-severe.

Section 404.1545(a)(2) requires the ALJ to consider non-severe impairments when formulating the RFC; a boilerplate statement that the RFC reflects earlier findings is insufficient without further discussion.

GUNN v. KIJAKAZI · filed 2023-12-05(a)(2)

It is inconsistent with regulations requiring the ALJ when formulating the RFC to “consider” all impairments, even non-severe ones, and at odds with the only circuit-level decision addressing the viability of such a statement.

When assessing residual functional capacity, the ALJ must consider all medically determinable impairments, including non-severe ones.

Capalaces v. Kijakazi · filed 2024-01-08(a)(2)

In making this assessment, the ALJ considers all of the claimant’s medically determinable impairments, including any non-severe impairments identified by the ALJ at step two of his or her analysis. 20 C.F.R. §404.1545(a)(2). ... Moreover, even if the ALJ erred in determining that Capalaces’ psychological impairments were not severe, the error was harmless because the ALJ clearly and thoroughly considered Capalaces’ psychological impairments at each subsequent step in his analysis. The ALJ’s analysis in fashioning the RFC clearly and thoroughly weighed Capalaces’ statements about his symptoms, the mental health treatment records, and the medical opinions of Dr. Shah, Dr. Ross, and Dr. Gold.

Section 404.1545(a)(2) requires consideration of all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Beene v. Social Security Administration · filed 2024-01-10(a)(2)

Moreover, “the ALJ must consider the combined effect of all of the claimant’s medically determinable impairments, whether severe or not severe.” ... Thus, the Court finds the ALJ properly considered Plaintiff’s non-severe mental limitations in the RFC.

Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments, including non-severe impairments, when assessing residual functional capacity.

Phillips v. Commissioner of Social Security Administration · filed 2024-01-24(a)(2)

An ALJ must consider all medically determinable impairments, including impairments that are not severe, in assessing residual functional capacity. 20 C.F.R. § 404.1545(a)(2).

Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments, including those that are not severe, when formulating residual functional capacity.

Jones v. O'Malley · filed 2024-01-29(a)(2)

That said, when formulating the RFC, an ALJ must consider “all . . . medically determinable impairments,” including “medically determinable impairments that are not ‘severe[.]’ ” 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2). ... Here, in formulating the RFC, the ALJ not only acknowledged Plaintiff’s allegations regarding his inability to work due to chronic pain in his knees, neck, and back, but also reviewed and incorporated detailed medical records regarding his chronic pain into the RFC analysis.

An ALJ must consider nonsevere mental impairments when determining residual functional capacity and explain why identified limitations are omitted.

Rivera v. Kijakazi · filed 2024-02-01(a)(2)

The ALJ erred by either not including mental limitations in the RFC or in explaining why Plaintiff’s mental impairments were not limiting.

Section 404.1545(e) requires an ALJ to consider limitations from all impairments, including those found nonsevere at step two, when determining residual functional capacity.

Bartels v. Commissioner of Social Security · filed 2024-02-06(e)

That is because in determining a plaintiff's residual functional capacity and ability to work later in the sequential process, the ALJ must consider even the impairments found not to be “severe” at step two.

An RFC may account for a non-severe impairment through a relevant limitation even when the ALJ does not expressly name that impairment in the RFC discussion.

Umpierre-Garcia v. Commissioner of Social Security · filed 2024-01-31(a)(1)

Here, the ALJ did consider Plaintiff’s non-severe asthma while formulating the RFC, albeit implicitly, by including the following limitation in Plaintiff’s RFC: “occasionally involve concentrated exposure to pulmonary irritants like dusts, fumes, odors, chemical irritants, poor ventilation, and humidity.” Tr. 27. While the ALJ does not explain why this specific limitation was included in Plaintiff’s RFC, it could be reasonably inferred that it was included to account for Plaintiff’s non-severe asthma.