20 C.F.R. § 404.1545

An ALJ may formulate a residual functional capacity without medical opinion evidence when the record supports its limitations.

Lowman v. Commissioner of Social Security · filed 2023-08-08

What is more, the ALJ did not need opinion evidence to craft the limitations in the RFC.

An ALJ may assess residual functional capacity without a supporting medical opinion if substantial evidence supports the assessment.

Lewis v. Kijakazi · filed 2023-08-17

As an initial matter, Defendant is correct that an ALJ is not required to use a medical opinion to support an RFC.

An ALJ assesses residual functional capacity from all relevant medical and other evidence; the assessment need not match any particular physician’s opinion.

Richardson v. Kijakazi · filed 2023-08-29(a)(3)

An ALJ’s RFC determination, however, need not precisely reflect any particular physician’s assessment.

An ALJ must explain why material limitations from a medical opinion found persuasive were omitted from the residual functional capacity assessment.

Bedore v. Kijakazi · filed 2023-09-18

Given the absence of any explanation for why the ALJ omitted this limitation from the RFC despite finding Dr. Scher’s opinion persuasive, the Court cannot determine whether the decision to omit this limitation from the RFC was supported by substantial evidence.

An ALJ determines residual functional capacity from all relevant record evidence and need not adopt every limitation in a medical opinion.

Parsley v. Social Security Administration · filed 2023-09-29(a)(1)

As a general matter, an ALJ is charged with determining a claimant’s RFC based on all the relevant evidence in the claimant’s record. ... Thus, it was not per se error for the ALJ to exclude some limitations from the state agency psychological consultants’ opinions from the RFC.

An RFC need not exactly match medical opinions, but the ALJ must explain material departures from restrictions the ALJ accepted.

Tibbets v. Kijakazi · filed 2023-11-08

Though the Commissioner is correct that the ALJ’s RFC finding is not required to match the doctors’ findings exactly, the RFC must be “consistent with restrictions identified in the medical testimony.” Stubbs-Danielson, 539 F.3d at 1174. As discussed above, “occasional” is not consistent with “brief.” Because the ALJ failed to adequately explain the underlying basis for arriving at this RFC determination, his findings and opinions are not supported by substantial evidence.

Section 404.1545(a)(3) requires an ALJ to consider medical source opinions when assessing residual functional capacity.

Whitsell v. Kijakazi · filed 2023-11-30(a)(3)

An ALJ must consider opinions from medical sources in forming the RFC. See 20 C.F.R. §§ 404.1545(a)(1), (3), 404.1527(d)(2). ... With the above analysis, the ALJ properly formed a logical bridge from the narrative and medical evidence to Eric’s mental RFC assessment, and it is also not the role of the Court to reweigh the above evidence.

Section 404.1545 permits an ALJ to give a medical opinion limited weight while accounting for its supported limitations in the RFC assessment.

Ode v. Commissioner of Social Security · filed 2024-03-18(a)

Irrespective of the terminology used by the ALJ, whether it be “great weight,” “little weight,” “some weight,” or “no weight,” the relevant inquiry is whether the ALJ in fact incorporates or accounts for the limitations assessed by the medical professional in the RFC, as opposed to basing the RFC upon his or her own lay interpretation of the medical evidence.

An ALJ may assess residual functional capacity from all relevant evidence without matching a particular medical opinion.

(SS) Galindo v. Commissioner of Social Security · filed 2024-03-25(a)(3)

That assertion however is refuted by the regulations which state that the RFC need not mirror a particular opinion, it is an assessment formulated by the ALJ based on all relevant evidence.

An RFC assessment need not include an examining psychologist’s proposed work limitations when substantial evidence supports rejecting them.

Bessette v. Commissioner of Social Security · filed 2024-04-22(a)(1)

In this instance, the ALJ still provided substantial evidence—primarily Plaintiff’s testimony as to her activity level—supporting the ALJ’s conclusion that Dr. Mozer’s limitations should not be incorporated into the RFC assessment.

An ALJ may assess an RFC that differs from a medical opinion found persuasive if substantial evidence supports the assessment.

Lomnick v. Social Security Administration, Commissioner · filed 2024-08-08(a)(3)

In formulating an RFC, the ALJ considers a claimant’s “ability to meet the physical, mental, sensory, and other requirements of work.” 20 C.F.R. § 404.1545(a)(4). To do this, the ALJ examines all relevant medical and other evidence, including “any statements about what [the claimant] can still do that have been provided by medical sources,” as well as “descriptions and observations” by the claimant, his family, his neighbors, his friends, or others, of his limitations, including limitations resulting from pain. Matos, 2022 WL 97144 at *5; 20 C.F.R. § 404.1545(a)(3). ... Therefore, even if the RFC in this case differs from the medical opinions of Dr. Jordan and Dr. Laboy, it is nonetheless proper so long as it is supported by substantial evidence.

Section 404.1545 allows an ALJ to express a credited medical opinion’s limitations in different terms if the RFC remains consistent with that opinion.

Johnson v. Commissioner Social Security Administration · filed 2024-08-14

An ALJ’s RFC does not need to be identical to a credited medical opinion, it need only be consistent with it.

An ALJ must account for functional limitations in a persuasive medical opinion when assessing residual functional capacity or explain why an omitted limitation was not adopted.

Carey v. O'Malley · filed 2024-09-19(a)(1)

On remand the ALJ should consider all of the functional limitations in Dr. Cunningham’s opinion and should either incorporate those limitations into the RFC or explain why an excluded limitation was not adopted.

An RFC assessment need not include every limitation from a medical opinion the ALJ finds persuasive when the RFC accounts for the claimant’s limitations.

HEBERT v. O'MALLEY · filed 2024-09-25(a)(3)

Accordingly, because ALJ Robinson’s RFC implicitly accounts for Plaintiff’s mental limitations and there is no requirement that ALJ Robinson include findings of medical opinions which she found persuasive, there is no basis for remand.

An ALJ assessing residual functional capacity must consider all relevant evidence but need not incorporate limitations from a medical opinion properly rejected as unpersuasive.

Franks v. Commissioner of Social Security Administration · filed 2024-09-26(a)

As discussed above, the ALJ also properly evaluated PA Medeiros’s opinion and rejected it as unpersuasive. Accordingly, he was not obligated to incorporate that opinion into the RFC.

An ALJ assessing residual functional capacity must explain a conflict between the RFC and a medical opinion the ALJ found persuasive.

Potter v. O'Malley · filed 2024-10-15(a)(1)

However, the ALJ was required to explain how the mental limitations in the RFC accurately reflect Plaintiff’s mental abilities. See SSR 96-8p, 1996 WL 374184, at *7. The Court finds that the ALJ’s RFC provision that Plaintiff “could have occasional exposure to changes in the routine work setting” conflicts with Dr. Sagawa’s opined limitation to simple changes, implemented gradually. In contravention of SSR 96-8p, the ALJ provided no explanation for the conflict between Dr. Sagawa’s persuasive opinion and Plaintiff’s RFC.

Section 404.1545(a)(3) requires an ALJ to account for medical sources’ statements about what a claimant can still do when assessing residual functional capacity, but those statements do not themselves establish that capacity.

Wallis v. Commissioner of Social Security Administration · filed 2024-10-16(a)(3)

Second, as Plaintiff states, 20 C.F. R. § 404.1545(a)(3) requires that an ALJ, in assessing a claimant’s RFC, incorporate “any statements about what you can still do that have been provided by medical sources, whether or not they are based on formal medical examinations.” But while the ALJ’s calculation of the RFC must account for medical sources’ “statements about what [a claimant] can still do,” this does not mean these individual statements are equivalent to the claimant’s RFC.

An RFC assessment may express a medical source’s limitations in different words when the resulting restrictions are meaningfully equivalent.

Rundblad v. O'Malley · filed 2024-12-03(a)(1)

The Court therefore concludes that the RFC determination adequately incorporated Dr. Toll’s medical opinion.

An ALJ must base the RFC on all relevant evidence and explain why a limitation from a medical opinion found persuasive is omitted.

Odell v. O'Malley · filed 2025-02-27(a)(3)

If the ALJ did not mean to adopt Dr. Thompson’s limitation on prolonged repetitive activities, he was required to say so clearly and explain why such a limitation was not necessary. The ALJ did not do so here.

Section 404.1545 permits an ALJ to express medical source limitations in vocational terms when the RFC adequately accounts for them.

White v. Commissioner of Social Security · filed 2025-03-18(a)(1)

Notably, the ALJ’s translation of this restriction does not conflict with the psychologists’ recommendation—or otherwise justify a reversal of the decision.

An RFC determination need not match medical opinion evidence exactly if it is consistent with the record as a whole.

Yorio v. Commissioner of Social Security · filed 2025-03-26

An ALJ’s RFC determination need not perfectly correspond with opinion evidence, so long as it is consistent with the record as a whole. ... Moreover, the RFC was partially consistent with the opinions of Dr. LaBarber and Dr. Nickolova.

An ALJ must address a medical opinion that conflicts with the residual functional capacity assessment or explain why the opinion was omitted.

Aragon v. Commissioner, Social Security Administration · filed 2025-03-21

Because the RFC did not account for this potential limitation and the ALJ did not explain how Dr. Madsen’s opinion factored into his decision, the case must be remanded for further proceedings.

Section 404.1545(a)(3) requires consideration of relevant medical opinions when assessing residual functional capacity, but an ALJ need not include limitations from an opinion found unsupported and inconsistent with the record.

De La O v. King · filed 2025-08-05(a)(3)

As such, the ALJ’s negative supportability and consistency findings serve to explain why he did not include in the RFC the specific limitations found by Medina; no further explanation was required.

Section 404.1545(a)(3) requires the ALJ to determine residual functional capacity from all relevant evidence; finding a medical opinion persuasive does not require adopting every limitation it proposes.

Thomas v. Bisignano (CONSENT) · filed 2025-09-16(a)(3)

The ALJ determines RFC “based on all of the relevant medical and other evidence.” ... Yet, there is no requirement an ALJ adopt every limitation from persuasive opinions.

An ALJ who finds medical opinions persuasive must account for their assessed limitations in the residual functional capacity or give a supported explanation for omitting them.

Twiggs v. Commissioner of Social Security · filed 2025-09-22

Because the ALJ found the consultants’ opinions persuasive, but neither incorporated the attendance-related limitations into Plaintiff’s RFC nor explained their omission, the RFC is not supported by substantial evidence.

An ALJ assessing residual functional capacity need not adopt a medical opinion’s wording verbatim when the RFC reflects equivalent limitations.

Good · filed 2025-12-22(a)(3)

The ALJ was not bound to adopt the verbatim language from Dr. Dennis.

Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations; an opinion lacking specific functional limits may be too vague to inform that assessment.

Hollis · filed 2026-01-07(a)(1)

These opinions lack the specificity required for the ALJ to determine “the most [Plaintiff] can still do despite [Plaintiff's] limitations.” 20 C.F.R. §§ 404.1545(a)(1). Therefore, the ALJ’s assessment that the opinion was vague is not erroneous.

An RFC may express medical limitations in functional terms without repeating a medical opinion verbatim when it remains consistent with the limitations in the record.

DeClue · filed 2026-01-29(a)

An ALJ’s RFC need not reflect medical testimony verbatim, and instead “adequately captures restrictions . . . where the assessment is consistent with restrictions identified in the medical testimony” and the record. ... The ALJ’s RFC is thus consistent with, and thus properly translates, Dr. Robinson’s medical testimony.

An RFC assessment need not include every limitation recommended in a medical opinion when substantial evidence supports the assessment.

Deborah S. v. Commissioner of Social Security · filed 2026-03-19(a)(3)

Here, while Claimant has identified that the RFC finding contains no stooping limitations, Claimant has not identified how the ALJ’s RFC finding conflicts with the medical opinion. Merely leaving out one of the recommendations in an opinion does not create a conflict by default.

Section 404.1545 permits an ALJ to rely on medical opinions issued before surgery when the claimant’s condition has not significantly deteriorated or changed.

Favors · filed 2026-03-24

Therefore, because Plaintiff's condition did not significantly deteriorate or change since Drs. Liu, Schwab, Lawrence, and Ehlert’s opinions were issued, their opinions were not stale, and the ALJ was entitled to rely on them.

Residual functional capacity must be supported by consideration of relevant medical opinion evidence; overlooking a treating physician’s assessment of workplace abilities can leave it without substantial support.

Black v. Berryhill · filed 2019-09-24(a)

For the foregoing reasons, the undersigned finds that, the ALJ’s decision does not adequately address or explain the reasons for discounting the opinions given in Dr. Zevallos’s April 7, 2015, evaluation. See Reece, 834 F.3d at 908. Therefore, the ALJ’s RFC determination lacks substantial support.

An RFC assessment cannot stand when the ALJ leaves unresolved a conflict between a medical opinion found persuasive and the sitting capacity stated in the RFC.

Miller v. Saul · filed 2023-02-08(a)(1)

The ALJ did not reconcile his conclusion that Plaintiff is able to sit for up to 6 hours in an 8 hour workday with Dr. Taylor’s contrary conclusion. Accordingly, the Court is unable to determine whether the RFC was supported by substantial evidence on the record as a whole. The Court therefore remands the matter for further proceedings to resolve the conflict.

Section 404.1545(a)(3) requires the ALJ to evaluate medical evidence when assessing residual functional capacity; an ALJ may do so without a medical opinion when the record permits.

Winans v. Commissioner of Social Security · filed 2023-11-15(a)(3)

Far from prohibiting ALJs from directly evaluating medical evidence, the law requires it.

An RFC assessment must address evidence that a claimant needs frequent or lengthy restroom breaks; proximity to a restroom alone does not account for those limitations.

HARDIN v. SAUL · filed 2020-09-18(a)

It is difficult to see how this record could support no restrictions in Plaintiff’s RFC regarding the number and duration of restroom breaks she may need. Being situated relatively close (but not particularly close) to a restroom does not sufficiently address the issue.

Section 404.1545 requires an RFC to address the frequency and duration of necessary restroom breaks when those breaks affect the claimant’s ability to work.

Giddens v. Saul · filed 2022-02-15(a)(1)

Here, the ALJ included a limitation that Plaintiff must work within a 5-minute walk to a restroom, but failed to specify the duration and frequency of the restroom breaks. The case must be remanded for the ALJ to provide further explanation as to Plaintiff’s restroom breaks in the RFC and hypotheticals posed to the VE.

Section 404.1545(a)(1) requires an RFC to account for supported limitations from all impairments, including nonsevere ones; ready access to a bathroom does not account for frequent unscheduled bathroom breaks.

Coffman v. Kijakazi · filed 2022-08-25(a)(1)

The problem is that ready access to a bathroom does not account for the need to take frequent unscheduled breaks to use the bathroom.

Section 404.1545 requires an RFC assessment to consider whether a claimant’s restroom needs would cause work-preclusive time off task; ready access to a restroom alone may be insufficient.

Cecce v. Commissioner of Social Security · filed 2023-07-27(a)

Considering the specific facts of this case, I find that, although the ALJ concluded that plaintiff would require “ready access to restroom facilities,” he should also have evaluated whether plaintiff’s interstitial cystitis could be accommodated by customary breaks or whether her symptoms would cause her to be off-task to a degree that could be work preclusive. That omission was error that requires remand.

Section 404.1545(a) requires an ALJ who includes ready restroom access in a residual functional capacity assessment to consider and explain how the frequency of restroom use affects the claimant’s ability to work.

Bunch v. Commissioner of the Social Security Administration · filed 2024-09-06(a)

Ultimately, the Court agrees with the Magistrate Judge that, under the specific facts of this case, it was incumbent upon the ALJ to consider and explain the potential effect on Plaintiff’s RFC related to the frequency with which Plaintiff required “ready access” to the restroom.

Section 404.1545(a)(1) requires an RFC assessment to account for limitations supported by relevant evidence, including bathroom needs, and to explain omitted limitations.

Chamorro v. O'Malley · filed 2024-10-09(a)(1)

Having failed to explain how she confronted the multiple sources addressing Jenell’s bathroom needs, the court finds that the ALJ did not supply substantial evidence to support the physical RFC.

Section 404.1545 does not require findings on the frequency and duration of bathroom breaks merely because a claimant has a severe gastrointestinal impairment when the RFC includes no bathroom access limitation.

Snyder v. Commissioner of Social Security · filed 2024-12-09

These cases thus do not control here where no such limitation was included in the RFC and no clarification as to the duration or frequency of bathroom breaks is necessary.

An RFC can account for a severe impairment through estimated time off task for bathroom breaks, even if that time falls within what employers ordinarily tolerate.

Maluchnik v. O'Malley · filed 2025-02-10(a)(1)

A claimant’s RFC is the maximum work that he can perform despite any limitations. ... The mere fact that the amount of extra time plaintiff needs to use the bathroom falls within the tolerance permitted by most employers does not mean the ALJ made no accommodation for the Crohn’s impairment.

Section 404.1545(a) permits an RFC assessment to include supported bathroom-break limits without a meticulous explanation of how the ALJ chose their number and frequency.

Oglesby v. Commissioner of Social Security Administration · filed 2025-07-21(a)

Although, as an unpublished opinion, Owens does not establish binding precedent, the court considers it persuasive in concluding the provision the ALJ included for bathroom breaks was sufficient to satisfy the applicable rules and regulations. The Fourth Circuit did not suggest in Dowling or Owens that an ALJ needs to do more than “evaluate the frequency at which [the claimant] need[s] to use the bathroom and analyze how that restriction impact[s] her ability to work.” In other words, the Fourth Circuit has not required an ALJ explain in meticulous detail how he arrives at the number and frequency of bathroom breaks he includes in the RFC assessment.

An RFC assessment must account for a claimant’s supported need for unscheduled bathroom breaks or give a reason supported by substantial evidence for omitting that limitation.

Mueller v. Saul · filed 2020-07-20(a)(2)

The court agrees with Mueller that it was error for the ALJ to omit from the RFC assessment her need to take unscheduled bathroom breaks. Accordingly, on remand the ALJ should make a finding as to whether Mueller requires at least one unscheduled work break each day to use the restroom and, if so, either include in the RFC assessment her need for such a break or provide a good reason supported by substantial evidence for omitting such a limitation.

Section 404.1545(a)(1) measures residual functional capacity by the most a claimant can do despite limitations; an ALJ need not include an expert’s suggestions about the setting in which the claimant would perform best.

Bisignano · filed 2026-06-02(a)(1)

This argument fails because what the expert psychologists suggested in their narrative explanations are not RFC findings, which are based on the “most [a claimant] can . . . do despite [his] limitations.” ... Thus, there was no need for the ALJ to include such suggestions in her hypothetical to the VE or in the RFC on which her decision is based.

An ALJ must explain how the evidence was weighed and the residual functional capacity was determined, but need not account for step-three findings in that assessment.

Laswell v. Social Security Administration · filed 2022-07-25

The requirement at step four is to explain how the ALJ weighed evidence and fashioned the RFC. SSR 96-8p, 1996 WL 374184, at *7. This does not encompass a requirement to account for the step-three findings, which have a different purpose in the sequential evaluation process.

An RFC assessment need not mechanically incorporate limitations found at step three or explain their omission.

Madrid v. Social Security Administration · filed 2022-07-26

The Court rejects the argument that an ALJ must either mechanically mirror step-three findings in the RFC, or explain the omission.

Section 404.1545(a)(1) assesses limitations affecting what a claimant can do in a work setting; difficulty commuting does not make an RFC inadequate when driving is excluded from the claimant’s job duties.

Riedinger v. Commissioner of Social Security · filed 2020-09-22(a)(1)

To the extent that Plaintiff suggests that the ALJ’s RFC assessment is inadequate because Plaintiff would still need to drive to and from work (dkt. # 8 at 13-14) and could experience symptoms during this commute, a disability determination addresses whether a claimant can perform job requirements in a work setting. See, e.g., 20 C.F.R. § 404.1545(a)(1) (defining RFC to account for a claimant’s “physical and mental limitations that affect what [the claimant] can do in a work setting”). As the ALJ excluded driving from Plaintiff’s job duties, the ALJ fully accounted for Plaintiff’s difficulties with driving as it pertains to Plaintiff’s ability to perform work.

An RFC assessment must explain how the evidence supports the claimant’s capacity for a stated level of work and any additional limitations.

Bailey v. Commissioner of Social Security Administration · filed 2020-09-22(a)

After review, however, the Court agrees with the Magistrate Judge not only that the ALJ failed to cite to the “few medical records” that were inconsistent with Dr. Rojugbokan’s opinion, but also that the ALJ failed to provide sufficient logical explanation to support his RFC assessment by not adequately explaining how the evidence upon which he relied supports an RFC for light work with additional nonexertional limitations.

Section 404.1545 requires an RFC to account for all limitations supported by medical and other relevant evidence.

Rodriguez v. Saul · filed 2021-02-05

The RFC must accommodate all of a claimant’s limitations that are supported by the medical evidence and other relevant nonmedical evidence.

Section 404.1545 does not require an ALJ to incorporate ADA accommodations into a residual functional capacity assessment.

(SS)Henry v. Commissioner of Social Security · filed 2021-02-16

The Social Security regulations do not require that the ALJ incorporate ADA accommodations into the residual functional capacity assessment.

Section 404.1545(a)(1) focuses an RFC assessment on specific functional abilities, so a temporary workers’ compensation percentage rating without vocational content has little value.

Lugo v. Commissioner of Social Security · filed 2021-03-09(a)(1)

... these percentage rankings had little value for determining Plaintiff’s specific functional abilities, which is the point of assessing an RFC. See 20 C.F.R. § 404.1545(a)(1).

Section 404.1545 allows an ALJ to assess residual functional capacity using limitations supported by the record and to omit properly rejected evidence or subjective complaints.

Schoenhoeft v. Saul · filed 2021-02-26(a)(1)

In making an RFC determination, the ALJ may consider those limitations for which there is support in the record and need not consider properly rejected evidence or subjective complaints.

Section 404.1545(a) requires an RFC assessment to explain how a claimant’s impairments affect relevant work functions; a symptom evaluation alone does not suffice.

Patterson v. Commissioner of Social Security Administration · filed 2021-03-10(a)

Rather, the Court finds that remand is required here because it is clear from a review of the ALJ’s decision that the ALJ simply treated the RFC evaluation as one and the same as a symptom evaluation, and nowhere does the ALJ including any narrative discussion to explain how Plaintiff’s impairments impact her ability to perform the relevant work functions, thereby frustrating this Court’s meaningful review.

Section 404.1545 requires an ALJ to assess what a claimant can do despite impairments and symptoms based on all relevant evidence.

Watkins v. Commissioner of Social Security · filed 2021-03-23(a)(1)

To determine a claimant’s RFC, an ALJ makes an assessment based on all the relevant evidence of record as to what a claimant can do in a work setting despite any physical or mental limitations caused by the claimant’s impairments and related symptoms. 20 C.F.R. § 404.1545(a)(1).

Residual functional capacity measures the most a claimant can still do despite limitations; tentative recommendations about ideal work conditions need not be included.

Basl v. Commissioner Social Security Administration · filed 2021-03-24(a)

The “residual functional capacity is the most [a claimant] can still do despite [his] limitations,” not the conditions under which he would function best. 20 C.F.R. §§ 404.1545(a), 416.945(a). The ALJ was not required to incorporate Dr. Gomez’s equivocal recommendations, nor her suggestions for maximizing Plaintiff’s success, into the RFC.

Section 404.1545(a) defines residual functional capacity as the most a claimant can do after considering all impairments; unsupported concentration and absenteeism limitations need not be included.

Zajac v. Commissioner of Social Security · filed 2021-03-29(a)

A claimant’s RFC is the most that the claimant can do after considering the effects of all impairments on the ability to perform work-related tasks. 20 C.F.R. §§ 404.1545(a), 416.945(a). ... That is what the ALJ did in this case when she concluded that the evidence failed to support additional limitations for concentration and absenteeism. Accordingly, this claim of error is rejected.

Section 404.1545(a) assesses the most work a claimant can still do after considering all impairments; a claimed limitation need not be included when the record does not support it.

Brooks v. Commissioner of Social Security · filed 2021-03-29(a)

A claimant’s RFC is the most that the claimant can do after considering the effects of all impairments on the ability to perform work-related tasks. 20 C.F.R. §§ 404.1545(a), 416.945(a). ... The ALJ’s determination of Plaintiff’s RFC without inclusion of leg elevation sufficient to preclude sedentary work is supported by substantial evidence.

An RFC assessment must properly consider documented mental limitations; dismissing significant mental health symptoms as normal without adequate explanation can require remand.

Eller v. Commissioner of Social Security · filed 2021-04-14

The Court cannot be sure that the ALJ properly considered Ms. Eller’s mental limitations when her severe symptoms noted in mental health treatment were so casually dismissed as “normal” examinations. This error may affect the RFC analysis, the assessment of Ms. Eller’s treating psychiatrist, and the hypothetical given to the VE. This error requires remand.

Residual functional capacity turns on the functional limitations caused by an impairment, rather than the impairment alone.

Sickmiller v. Commissioner of Social Security · filed 2021-03-30(a)

Moreover, it is the functional limitations caused by the impairment, not the impairment itself, that affects the Plaintiff’s ability to work. See 20 C.F.R. § 404.1545(a); McCruter v. Bowen, 791 F.2d 1544, 1547 (11th Cir. 1986) (severity of impairment must be measured in terms of their effect on the ability to work, not just in terms of deviation from purely medical standards of bodily imperfection or normality).

Section 404.1545 requires an RFC to include limitations supported by the record; restrictions based on reasonably rejected symptom testimony need not be included.

Washington v. Saul · filed 2021-04-07(a)(1)

An RFC assessment need only incorporate limitations that are supported by the record.

An RFC assessment must address limitations resulting from a claimant’s impairments and explain the exclusion of an opined limitation.

Howes v. Kijakazi · filed 2021-04-27(a)

In forming the RFC, the ALJ failed to discuss how the TBI and the alleged associated headaches were represented in the RFC. ... Second, the ALJ failed to state why the opined limitations resulting from the pulmonary impairments were excluded from the RFC determination.

An RFC limiting the frequency of social interaction does not necessarily account for a persuasive medical opinion limiting the kind of interaction a claimant can manage; the ALJ must explain the omission or how the RFC accommodates it.

Redd v. Commissioner of Social Security · filed 2021-05-17

Because the ALJ’s limitation would allow Plaintiff to interact with the public and all of his coworkers (not just a small group) up to one-third of the time, it does not address the concerns raised in Dr. Straight’s limitations. Accordingly, remand is required to allow the ALJ to explain why he found Dr. Straight’s opinions persuasive but failed to include her limitations or to explain how the RFC accommodated those limitations.

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

Perry v. Saul · filed 2021-04-29(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) requires the ALJ to consider all relevant evidence and medically determinable impairments when assessing residual functional capacity.

Bluford v. Commissioner of Social Security Administration · filed 2021-05-07(a)

She should consider all the relevant evidence and account for all the claimant’s medically- determinable impairments in the RFC assessment. 20 C.F.R. § 404.1545(a). ... The court finds substantial evidence supports the ALJ’s RFC assessment, given her explanation for the limitations included and rejected and the harmless error in her failure to address evidence that arguably supported additional postural restrictions.

Section 404.1545(a)(2) requires an ALJ to consider all medically determinable impairments when assessing residual functional capacity; an earlier analysis incorporated by reference can satisfy that requirement.

COLANGELO v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-05-10(a)(2)

This discussion and incorporation by reference is sufficient to satisfy the requirement that the ALJ consider all of the Plaintiff’s impairments in formulating 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.

Pierce v. Saul · filed 2021-05-13(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 requires the ALJ to account for limitations from a severe impairment when assessing residual functional capacity.

Wearley v. Commissioner Social Security Administration · filed 2021-05-17(a)(3)

Because the ALJ found the functional bowel disorder to be severe, the ALJ was required to include limitations related to the bowel disorder in the RFC finding.

Section 404.1545(a)(3) requires limitations from symptoms such as pain to be factored into the residual functional capacity assessment.

Springfield v. Social Security Administration Commissioner · filed 2021-05-25(a)(3)

Limitations resulting from symptoms such as pain are also factored into the assessment.

When an ALJ credits a medical opinion requiring close proximity to a restroom, an RFC providing only an onsite restroom does not accurately reflect that limitation.

Daigneau v.Kijakazi · filed 2021-06-08(a)

The ALJ’s RFC determination that Plaintiff’s “workplace should have a restroom available onsite,” AR 18, does not accurately reflect Dr. Stevick’s opinion that Plaintiff must maintain close proximity to a restroom, AR 74.

Section 404.1545(a)(2) requires the ALJ to consider all of a claimant’s impairments when assessing residual functional capacity.

Ray v. Commissioner, Social Security Administration · filed 2021-05-21(a)(2)

The ALJ's opinion shows that he complied with 20 C.F.R. § 404.1545(a)(2) in considering all of Ray's impairments, and under both severity standards, substantial evidence supports his findings that Ray's mental impairments were not severe.

Section 404.1545 requires the ALJ to consider the claimant’s impairments and related symptoms when assessing residual functional capacity; an assessment supported by a comprehensive review of the medical record may be upheld.

Quiroz v. Saul · filed 2021-06-04(a)(2)

The ALJ undertook a comprehensive review of Quiroz’s entire medical record and found that he had the RFC to do “light work” with some limitations.39 Substantial evidence supports this conclusion and I find no RFC error.

Section 404.1545(a) requires an RFC assessment to consider physical and mental abilities, symptoms, and other limitations that may affect sustained work.

Green v. Saul · filed 2021-06-16(a)

“In making a [RFC] determination, the ALJ must consider a claimant’s physical abilities, mental abilities, symptomology, including pain and other limitations which could interfere with work activities on a regular and continuing basis.” Pardee, 631 F. Supp. 2d at 210 (citing 20 C.F.R. § 404.1545(a)). ... In light of the ALJ’s analysis of plaintiff’s medical history, the relevant medical opinions, and plaintiff’s activities of daily living, this court concludes that her RFC determination was supported by substantial evidence, as summarized below.

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

Sheare v. Saul · filed 2021-06-14(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.

In assessing residual functional capacity, an ALJ must consider all of a claimant’s medically determinable impairments, individually and together.

Houston v. Commissioner of Social Security Administration · filed 2021-06-25(a)(2)

The ALJ bears the responsibility for assessing a claimant’s RFC based on all of the relevant evidence, and must consider all of a claimant’s medically determinable impairments, both individually and in combination.

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

Thompson v. Social Security Administration · filed 2021-07-01(e)

In reaching a determination regarding the claimant’s RFC, the ALJ must consider the limiting effects of all of the claimant’s impairments, not only those found to be “severe” at step two.

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

Geary v. Saul · filed 2021-06-15(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 two of his or her analysis.

Section 404.1545(a) requires an RFC assessment to account for how mental impairments affect a claimant’s ability to attend work and complete tasks.

Shure v. Saul · filed 2021-06-21(a)

Because the ALJ’s determination of Plaintiff’s RFC is not supported by substantial evidence, the Court will remand the case for determination of Plaintiff’s RFC taking into consideration the complications such as absenteeism caused by his mental impairments.

Section 404.1545(a)(2) requires an RFC assessment to consider medically determinable impairments even when they are not severe.

Collora v. Saul · filed 2021-06-24(a)(2)

Courts frequently find an ALJ’s exclusion of a particular impairment as severe does not require reversal where the ALJ considers all of a claimant’s impairments in his or her subsequent analysis. ... This analysis demonstrates that the ALJ adequately considered the limitations attributable to Plaintiff’s headaches, whether or not he found them to be a severe impairment.

An RFC must account for functional limitations from all impairments, including those that are not severe.

Trujillo v. Kijakazi · filed 2021-06-16(a)(1)-(2), (e)

An RFC must include an individual’s functional limitations or restrictions as a result of all of her impairments -- even those that are not severe (see 20 C.F.R. § 404.1545(a)(1)-(2), (e)) -- and must assess her “work-related abilities on a function-by-function basis.”

Section 404.1545(a)(2) requires the ALJ to consider all impairments when assessing residual functional capacity, including their combined effects.

JONES v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-06-22(a)(2)

The ALJ considers all impairments in this analysis, not just those deemed to be severe. 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2); SSR 96-8p. ... The ALJ also expressly considered Plaintiff’s obesity in combination with her asthma and sleep apnea, finding that Plaintiff’s “file does not contain evidence that her obesity alone has caused her to be unable to work, nor does it show that in conjunction with her other impairments, it has disabled her.” (R. 26–27.) Therefore, this Court concludes that the ALJ sufficiently considered Plaintiff’s obesity.

Section 404.1545 permits an RFC finding without an express discussion of each manipulative function when the ALJ adequately connects the evidence to the physical limitations found.

JACKSON v. KIJAKAZI · filed 2021-07-19(b)

Here, although the ALJ did not include in his decision an express function-by-function discussion of Plaintiff’s manipulative abilities (see Tr. 20-26), the ALJ’s decision nevertheless supplies the necessary “accurate and logical bridge,” Woods, 888 F.3d at 694 (internal quotation marks omitted), between the evidence and his findings that Plaintiff’s cervical degenerative disc disease (“DDD”) and bilateral CTS (A) qualified as severe (see Tr. 14) but (B) did not cause limitations greater than the lifting requirements of light work with, inter alia, “frequent reaching, handling, fingering, pushing, pulling, and operating of hand controls” (Tr. 19).

Section 404.1545 requires an RFC assessment to consider all relevant evidence and account for all medically determinable impairments, including those that are not severe.

Phillips v. Commissioner, Social Security Administration · filed 2021-07-12(a)(1)–(2)

However, the RFC must be assessed based on all of the relevant evidence and must account for “all of [the claimant’s] medically determinable impairments ... including [claimant’s] impairments that are not ‘severe.’” 20 C.F.R. § 404.1545(a)(1)–(2).

Section 404.1545 requires the residual functional capacity assessment to consider both severe and non-severe impairments.

HALM v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-07-19(a)(2)

The ALJ then proceeded to consider the Plaintiff’s severe and non-severe impairments (including Plaintiff’s neck, ankle, and right shoulder pain) in the evaluation process and in determining Plaintiff’s RCF.

Section 404.1545(a)(1) requires the ALJ to consider all medically determinable impairments, severe and non-severe, after a claim survives Step 2.

Dixon v. SSA · filed 2021-07-23(a)(1)

If there is at least one medically determinable, severe impairment, the claim survives and the ALJ must consider all medically determinable impairments, severe and non-severe, in the remaining steps of the analysis. 20 C.F.R. § 404.1545(a)(1).

Section 404.1545(a)(1) requires an RFC assessment based on all relevant evidence of what a claimant can still do despite limitations, including the work impact of episodic vision loss.

Grindey v. Saul · filed 2021-07-15(a)(1)

The RFC is “the most [one] can still do despite [his or her] limitations” and represents an assessment “based on all the relevant evidence.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... The ALJ makes no assessment of the duration of Plaintiff’s episodes of visual loss and the time off-task they cause. ... The ALJ’s RFC is not supported by substantial evidence nor is the ALJ’s hypothetical to the VE.

An RFC assessment must address evidence of a claimant’s functional limitations and explain why handling and fingering restrictions are omitted.

Hernandez v. Saul · filed 2021-07-26(a)(1)

Given the significant testimony of Plaintiff concerning her fingering and handling restrictions, as well as the medical records of Plaintiff’s history of procedures and care for her shoulders, elbows and hands, the ALJ should have specifically addressed why handling and fingering manipulative limitations were not included in Plaintiff’s RFC in the ALJ’s decision.

Section 404.1545 requires an RFC assessment to account for a claimant’s physical and mental impairments when identifying work the claimant can perform.

SPOONER v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-08-05

Moreover, the ALJ took Plaintiff’s physical and mental impairments into account when assessing the Plaintiff’s RFC for light work, limiting her work conditions in terms of exertion, allowable tasks, environment, and interaction with co-workers.

Section 404.1545(a)(3) requires consideration of a claimant’s alleged functional limitations when assessing residual functional capacity.

Harkness v. Commissioner of Social Security Administration · filed 2021-08-10(a)(3)

Accordingly, the Magistrate Judge concluded that “[t]he ALJ’s RFC assessment reflects his thorough consideration of Plaintiff’s allegations as to shortness of breath and fatigue in accordance with 20 C.F.R. § 404.1545(a)(3) and §416.945(a)(3) and SSR 16-3p,” and that, contrary to Plaintiff’s contention, the ALJ “addressed Plaintiff’s ability to perform relevant functions” and provided “specific reasons for the restrictions he included in the RFC assessment and rational explanations for having declined to assess further restrictions.” ... The court adopts the Report, ECF No. 23, and incorporates it herein by reference.

An ALJ must consider all of a claimant’s impairments, including nonsevere impairments, when assessing residual functional capacity.

Wanner v. Kijakazi · filed 2021-08-23(a)(2)

In making the RFC finding the ALJ must consider all of the claimant’s impairments, including impairments that are not severe.

An RFC assessment must consider all medically determinable impairments together, including impairments found not severe at step two.

FRIDAY v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-08-31(a)(2)

This is because the RFC assessment must take into consideration all of a claimant’s medically determinable impairments in combination, including those that the ALJ has found to be severe, as well as those that the ALJ has not deemed to be severe at step two.

Section 404.1545 requires an RFC assessment to consider the medical evidence and reflect the claimant’s physical, mental, and environmental restrictions.

Anderson v. Commissioner of Social Security · filed 2021-09-13(a)(1), (a)(3)

The RFC must consider all of the medical evidence in the record, and must reflect all of the claimant’s physical, mental, and environmental restrictions. 20 C.F.R. § 404.1545(a)(1) and (3). ... Because the ALJ properly addressed and considered Plaintiff’s limitations in interacting with others in the RFC, the ALJ’s decisions is supported by substantial evidence.

An RFC assessment must explain how the evidence supports the work capacity assigned.

Shores v. Commissioner of Social Security Administration · filed 2021-09-20(a)

In other words, the Court agrees with the Magistrate Judge that the ALJ did not build the required logical bridge from the medical evidence to the conclusion that Plaintiff can perform light work, and the Court finds that the Commissioner’s objections do nothing to alter this finding.

Section 404.1545(a)(1) requires the ALJ to consider limitations caused by a condition when formulating residual functional capacity; the ALJ need not specifically discuss every diagnosis.

Cone v. Commissioner of the Social Security Administration · filed 2021-09-17(a)(1)

The ALJ need only consider the resultant functional limitations arising from the conditions, if any, to formulate Plaintiff’s RFC. See 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). Thus, the ALJ’s failure to specifically address certain impairments in his discussion of the RFC is not, by itself, error.

Section 404.1545 defines residual functional capacity as the most a claimant can do despite her impairments and requires the ALJ to consider all impairments and their consistency with the medical evidence.

Barringer v. Commissioner of Social Security · filed 2021-09-21(a)(1), (a)(2), (e)

And although Plaintiff does not challenge her RFC determination directly, to the extent Plaintiff claims the ALJ erred because the RFC she formulated differs from the limitations Drs. Lamm and Clark identified, this is meritless. A claimant’s RFC is the most work she can do despite any limitations caused by her impairments. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). In formulating a claimant’s RFC, the ALJ must consider all impairments and the extent to which the impairments are consistent with medical evidence.

Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations.

Durham v. Saul · filed 2021-09-21(a)(1)

One’s RFC is the “most you can still do despite your limitations.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).

Section 404.1545(a) requires an ALJ to consider a claimant’s physical, mental, sensory, and other work abilities when assessing residual functional capacity.

Johnson v. Kijakazi · filed 2021-09-21(a)

The ALJ failed to adequately explain the basis for plaintiff's medium-work RFC. In determining a claimant’s residual functional capacity, an ALJ must consider the claimant’s “ability to meet the physical, mental, sensory, and other requirements of work.” 20 C.F.R. § 404.1545(a).

Section 404.1545(a) describes residual functional capacity as a claimant’s work-related abilities despite limitations.

Cronin v. Commissioner of Social Security · filed 2021-09-21(a)

A claimant’s RFC is an indication of an individual’s work-related abilities despite their limitations. See 20 C.F.R. §§ 404.1545(a).

Section 404.1545(a) defines residual functional capacity as the most a claimant can still do despite limitations.

BALAS v. COMMISSIONER OF SOCIAL SECUIRTY · filed 2021-09-21(a)

RFC refers to the most a claimant can still do despite his/her limitations. 20 C.F.R. §§ 404.1545(a), 416.945(a).

Section 404.1545 permits an ALJ to assess residual functional capacity from the record as a whole, even when the assessment does not exactly match any medical source’s opinion.

Holl v. Commissioner of Social Security · filed 2021-09-22

It is well-settled that an ALJ is tasked with “weigh[ing] all of the evidence available to make an RFC finding that [is] consistent with the record as a whole,” even if that finding does not perfectly correspond with any of the opinions of cited medical sources.

Section 404.1545 does not require additional RFC limitations for a severe impairment when the ALJ explains, with record support, why they are unnecessary.

Stephenson v. Social Security Administration, Commissioner of · filed 2021-09-21(a)(1)

The Court finds that the ALJ appropriately considered Plaintiff’s IBS as a severe impairment and detailed why additional limitations were not necessary in the RFC determination.

Section 404.1545(a) requires an ALJ assessing residual functional capacity to consider physical and mental abilities, symptoms, and other limitations that may interfere with sustained work.

Rouse v. Kijakazi · filed 2021-09-29(a)

For the reasons outlined below, the ALJ’s RFC determination was proper and based on substantial evidence in the record. ... “In making a residual functional capacity determination, the ALJ must consider a claimant’s physical abilities, mental abilities, symptomology, including pain and other limitations which could interfere with work activities on a regular and continuing basis.” Pardee, 631 F. Supp. 2d at 210 (citing 20 C.F.R. § 404.1545(a)).

A medical diagnosis alone does not establish a functional limitation for residual functional capacity purposes.

Morelock v. Social Security Administration, Commissioner of · filed 2021-09-30(e)

But the diagnosis or treatment of a mental impairment does not necessarily establish its severity in the disability context. See, e.g., Higgs v. Bowen, 880 F.2d 860, 863 (6th Cir. 1988) ("The mere diagnosis of [an impairment], of course, says nothing about the severity of the condition."); 20 C.F.R. § 404.1545(e) (providing that, in order to prove disability, evidence must establish functional limitations, not just medical diagnoses).

Section 404.1545(a) assesses how symptoms limit a claimant’s ability to perform work-related activities.

Probus v. Commissioner of Social Security · filed 2021-10-01(a)

Rather, the relevant inquiry is the degree to which the symptoms impede functioning with respect to work-related activities. See 20 C.F.R. § 404.1545(a).

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

(SS) Moy v. Commissioner of Social Security · filed 2021-10-08(a)(2)

However, the Commissioner is correct that any step two error is immaterial because the ALJ must consider all limitations in assessing a claimant’s RFC through “a narrative discussion describing how the evidence supports each conclusion, citing specific medical facts . . . and nonmedical evidence . . . .” Bradley v. Colvin, No. 2:15-cv-1026-EFB, 2016 WL 5395956, at *3 (E.D. Cal. Sept. 26, 2016) (quoting SSR 69-8p); 20 CFR § 404.1545(a)(2) (2017); ECF No. 15 at 7; ECF No. 21 at 7.

An RFC assessment need not include claimed limitations the ALJ finds incredible or unsupported by the record.

Ayers v. Commissioner of Social Security · filed 2021-10-12(a)

The ALJ was not required to include limitations in the RFC assessment that the ALJ found to be incredible or not supported by the record.

Section 404.1545 requires a separate assessment of mental limitations when determining residual functional capacity at step four; step-three findings cannot substitute for it.

Tyler v. Social Security Administration · filed 2021-10-18

The Court agrees in part: The Commissioner may not use the step-three findings (regarding whether the claimant meets a listing for mental impairments) as a substitute for a proper analysis at step four in determining the RFC.

A residual functional capacity assessment must account for credited limitations requiring rest or time off task during the workday.

MATTEO v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-10-13(a)(1)

If the ALJ did credit the doctors’ opinions that Ivana M. would need to rest and be off-task during the workday, that fact was not included in his RFC analysis, nor in the initial hypothetical he put to the vocational expert. (AR 78–79.) Because this fact, which tends to show that Ivana M. would be unable to work in any occupation, was not included, the RFC analysis fails the substantial-evidence test.

Residual functional capacity must account for the effect of a claimant’s likely absences on the ability to sustain work.

Ayala v. Commissioner of Social Security · filed 2021-10-14(a)(1)

The result of this analysis was the inclusion of a one-day/month potential absence as a non-exertional limitation in Plaintiff’s RFC. Therefore, the ALJ complied with his obligation to evaluate the impact that potential absenteeism would have on Plaintiff’ ability to sustain a job and the Court must affirm even when evidence in the record could potentially support a different conclusion.

Section 404.1545(a) defines residual functional capacity as the most a claimant can still do despite limitations.

Walters v. Commissioner of Social Security · filed 2021-10-19(a)

A claimant’s RFC is “the most the claimant can still do despite the claimant’s limitations.” 20 C.F.R. § 404.1545(a).

Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations, based on all relevant evidence.

(SS) Borges v. Commissioner of Social Security · filed 2021-10-20(a)(1)

The RFC is “the most [one] can still do despite [his or her] limitations” and represents an assessment “based on all the relevant evidence.” 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1).

Section 404.1545(a) defines residual functional capacity as the most a claimant can still do in a work setting despite her limitations.

Aponte v. SAUL · filed 2021-10-25(a)

A claimant’s RFC reflects “the most [she] can still do [in a work setting] despite [her] limitations.” 20 C.F.R. §§ 404.1545(a). ... The ALJ provided substantial evidence to support the limitations he imposed to accommodate Aponte’s severe impairments.

Section 404.1545(a) defines residual functional capacity in terms of a claimant’s work-related abilities despite limitations; the assessment considers the record evidence.

Lumpkin v. Commissioner of Social Security · filed 2021-10-27(a)

The RFC determination sets out an individual’s work-related abilities despite his or her limitations. ... In reaching his conclusions as to the severity of Lumpkin’s impairments and her RFC, the ALJ considered all of the record evidence — including medical opinions, treatment notes and Lumpkin’s subjective statements.

Section 404.1545(a) defines residual functional capacity as the most a claimant can still do despite limitations.

BOICE v. SAUL · filed 2021-11-01(a)

RFC refers to the most a claimant can still do despite his/her limitations. 20 C.F.R. §§ 404.1545(a), 416.945(a).

Section 404.1545 defines residual functional capacity as the most a claimant can do despite impairments, based on all relevant evidence.

Bowen v. SSA · filed 2021-11-02(a)(1), (a)(3)

RFC is an administrative finding, based on all relevant evidence, as to the most a claimant can do despite his impairments.

An RFC restriction to simple tasks does not account for a claimant’s limitation in concentration, persistence, or pace.

Perry v. Commissioner of Social Security · filed 2021-11-02(a)

In formulating Plaintiff’s RFC, the ALJ accounted for his moderate difficulties in maintaining concentration, persistence or pace, if at all, by limiting him to “simple, routine, repetitive tasks.” (Tr. 17). Even if supported by substantial evidence, a limitation to work with simple tasks does not “account for a limitation in concentration, persistence or pace.”

An RFC may account for stress-related limitations through restrictions on task complexity, public contact, and work pace.

Radford v. Commissioner of the Social Security Administration · filed 2021-10-29(a)(1)

And, assuming Plaintiff’s headaches are exacerbated by stress, the ALJ’s RFC for light work limited to simple tasks and instructions, only occasional public contact, and a non-production rate pace adequately accounted for this limitation.

An RFC assessment must address limitations from a severe impairment or explain why that impairment produces none.

HILDRETH v. COMMISSIONER OF SOCIAL SECURITY · filed 2021-11-19(a)(1)

However, as Plaintiff points out, after identifying sleep apnea as a severe impairment at step two, the ALJ never again considered Dr. Clinton’s undated opinion regarding the impact of sleep apnea on Plaintiff’s ability to function—or, indeed, any limitations related to sleep apnea—nor did the ALJ, when crafting the RFC, otherwise explain why no limitations apparently resulted from that severe impairment.

An RFC assessment must account for all reasonable limitations supported by the evidence.

ULMER v. SAUL · filed 2021-12-20

Additionally, Ms. Ulmer’s medical opinion testimony recommended limitations which were less restrictive than the limitations the ALJ ultimately suggested, indicating that the ALJ had been careful to ensure that Ms. Ulmer’s RFC incorporates all reasonable limitations.

Residual functional capacity must be redetermined on remand when the ALJ reweighs medical opinions and reassesses symptom statements, unless the claim is resolved at step three.

Schumacher v. O'Malley · filed 2021-12-01(a)

Since the ALJ has been instructed to reweigh the medical opinions and readdress Plaintiff’s symptoms statements, a new RFC determination and a new step five determination will be required upon remand if the case is not settled at step three.

Section 404.1545(a)(1) requires an RFC assessment based on functional limitations supported by the record; differing diagnoses alone do not require additional restrictions.

Jones v. Social Security Administration · filed 2022-01-05(a)(1)

To the extent the diagnoses contain inconsistencies, their conflict does not compel a more restrictive RFC where none of the medical reports would call for it and where plaintiff has adduced no evidence of additional impairment beyond the diagnosis.

Residual functional capacity measures sustained work ability despite impairments, and the ALJ must consider limitations caused by those impairments.

Hartz v. Kijakazi · filed 2022-01-28(a)(1)

An individual’s residual functional capacity is their ability to do physical and mental work activities on a sustained basis despite limitations from their impairments. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). ... As such, substantial evidence does not support the ALJ’s decision and remand is necessary for the ALJ to properly consider the limitations created by Plaintiff’s left knee impairment.

Section 404.1545 requires the ALJ to consider subjective complaints when assessing residual functional capacity and explain why the assessment omits limitations based on them.

Williams Jr. v. Saul · filed 2022-02-11(a)

While the ALJ does not need to account for all of Plaintiff’s limitations, the ALJ failed to adequately explain why there are no limitations in the RFC that account for any of Plaintiff’s subjective complaints.

An RFC must include the claimant’s limitations that are credited and supported by substantial evidence.

Oakes v. Commissioner Social Security Administration · filed 2022-02-01(a)

Consequently, the ALJ’s RFC included all those limitations found credible and supported by substantial evidence, and the ALJ did not err in formulating the RFC.

An RFC accounts for supported work-related limitations arising from a claimant’s impairments.

(SS) Hogan v. Commissioner of Social Security · filed 2022-02-02(a)

Thus, the ALJ did in fact include work-related limitations in the RFC consistent with the nature and intensity of Plaintiff's limitations.

An RFC must account for supported limitations from light-triggered migraines, or the ALJ must explain why a light restriction is rejected.

Helsinger v. Kijakazi · filed 2022-02-08(a)(1)

Despite this evidence, the ALJ does not include a limitation for light in the RFC, nor does he address why he is rejecting such a limitation. Thus, remand is required on this basis.

Section 404.1545(a) requires an ALJ assessing residual functional capacity to consider physical and mental abilities, symptoms, and limitations that may interfere with regular work activities.

Crowell v. Commissioner of Social Security · filed 2022-02-23(a)

“In making a residual functional capacity determination, the ALJ must consider a claimant’s physical abilities, mental abilities, [and] symptomology, including pain and other limitations which could interfere with work activities on a regular and continuing basis.” Id. (citing 20 C.F.R. § 404.1545(a)).

Section 404.1545(a)(1) requires an RFC assessment to account for supported work limitations or explain why they were excluded.

Jackson v. Saul · filed 2022-02-24(a)(1)

For the same reasons explained above in Section IV(A), the Court agrees that the ALJ had a duty to acknowledge the consultants’ determination that Claimant retains only “the mental capacity for unskilled (1-2 step) work,” (R. 103, 115), and to either explain why he did not credit the limitation or to incorporate the limitation into the RFC and hypothetical questions to the VE.

An ALJ considers medical opinions when assessing residual functional capacity and must reconsider that assessment when errors in evaluating those opinions affect it.

Pierson v. Commissioner of Social Security · filed 2022-03-04

Because the ALJ considers the medical opinions of treating, examining, and non-examining treating sources in determining a claimant’s RFC, the Court directs that on remand the ALJ should reconsider the Plaintiff’s RFC. 20 C.F.R. § 404.1545.

An omitted residual functional capacity limitation is harmless when the jobs identified at step five do not require the restricted activity.

Mooneyhan v. Commissioner of Social Security Administration · filed 2022-03-15

An error in failing to include a more restrictive limitation as to crawling or balancing would only be prejudicial if the recommended step-five occupations would be precluded by Plaintiff’s inability to do such things.

In assessing residual functional capacity, an ALJ’s failure to discuss an alleged impairment expressly can be harmless when the ALJ considers evidence addressing it and the claimant shows no resulting work limitation.

Hogue v. SSA · filed 2022-03-16

Although the ALJ failed to explicitly evaluate Ms. Hogue’s alleged neck issues, the Court finds this to be harmless error because (1) the ALJ generally addressed the issue through his review of the medical record as a whole; (2) the ALJ relied on experts who explicitly opined on Ms. Hogue’s alleged neck issues; and (3) Ms. Hogue failed to show how her neck issues negatively affected her ability to complete light work.

An RFC assessment must consider evidence of a claimant’s symptoms and their effects on the claimant’s ability to work.

Nail v. Kijakazi · filed 2022-03-21(a)

He ignored medical evidence corroborating Nail’s continuing headaches, did not discuss or consider the effects of Nail’s continuing headaches on his ability to work, and adopted opinion evidence that did not evaluate Nail’s headaches. His RFC assessment is therefore not supported by substantial evidence.

Section 404.1545(a) allows an RFC assessment without a medical opinion addressing each alleged limitation.

Brooker v. Social Security Administration, Commissioner of · filed 2022-03-23(a)

A medical opinion is not required regarding each limitation a claimant alleges.

Section 404.1545 permits an ALJ to assess residual functional capacity from the record as a whole without adopting one medical opinion in full.

(SS) Hayes v. Commissioner of Social Security · filed 2022-03-24

The ALJ was not required to pick one medical opinion and adopt it in full. Instead, based on the record as a whole, the ALJ developed the RFC.

Section 404.1545 requires an RFC assessment to account for a claimant’s visual limitations supported by medical testimony.

Kirsch v. Kijakazi · filed 2022-03-28

Plaintiff contends that the ALJ failed to adequately account for the ME’s testimony regarding Plaintiff’s visual limitations in the RFC assessment “in violation of SSR 96-8p [and] 20 CFR § 404.1545.”78 The Court agrees.

Section 404.1545 requires an RFC assessment to consider physical, mental, and other functional limitations, including the effects of symptoms.

Mongelli v. Social Security · filed 2022-04-12(b)-(d)

When making an RFC assessment, the ALJ must consider “functional limitations and restrictions that result from an individual’s medically determinable impairment or combination of impairments, including the impact of any related symptoms.” ... These functions include physical (standing, sitting, walking, lifting, carrying, pushing, pulling), mental (understanding, remembering, carrying out instructions, and responding to supervision), and other abilities that may be affected by impairments (seeing, hearing, ability to tolerate environmental factors). See SSR 96-8P; see also 20 C.F.R. § 404.1545(b)-(d); 20 C.F.R. § 416.945; Cichocki, 729 F.3d at 176.

An RFC assessment may exclude claimed limitations that lack evidentiary support in the medical record.

DESAI v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-06-22(a)

A lack of evidentiary support in the medical record is a legitimate reason for excluding Plaintiff’s claimed limitations from her RFC.

Section 404.1545 permits an RFC assessment supported by the medical record that accounts for the claimant’s physical and mental limitations.

BAILEY v. COMMISSIONER OF SOCIAL SECURITY · filed 2022-06-27

The limitations the ALJ imposed were more restrictive than the findings presented by the DDS psychologists. (R. 73−79, 86−91.) Plaintiff has not demonstrated that the RFC should have been further limited, and “the record provides substantial support for [the ALJ’s] decision.” Malloy, 306 F. App’x at 764. This Court will therefore affirm.

An ALJ must explain how documented impairments are addressed in the residual functional capacity assessment so the decision can be meaningfully reviewed.

Ray v. Commissioner of Social Security · filed 2022-08-15(a)(1)

Accordingly, the ALJ’s error at step two was compounded, rather than mitigated, in the RFC discussion because the Court cannot engage in meaningful review when an ALJ fails to adequately lay out his reasons.

An RFC need not include a leg-elevation limitation when the evidence does not establish that the claimant needs one.

Cottrell v. Commissioner of Social Security · filed 2022-09-08(a)(1)

Plaintiff’s own testimony does not establish she needs elevation for edema; rather, her testimony is that it is more comfortable for her to elevate her legs when she is sitting. The ALJ’s election not to place an elevation requirement in the RFC is supported by substantial evidence.

Section 404.1545 requires an RFC assessment to reflect manifested impairments and related symptoms; a diagnosis alone cannot support a functional limitation.

Allen v. Commissioner of Social Security · filed 2022-09-12

Further, Plaintiff's fibromyalgia diagnosis cannot alone support Dr. LaGrant's opinion because an RFC must be based on the individual's manifested impairments and related symptoms, not merely the existence of certain medical conditions.

Section 404.1545(a)(4) requires an RFC assessment to evaluate a claimant’s ability to meet the physical, mental, sensory, and other requirements of work.

Johnson v. Social Security Administration, Commissioner · filed 2022-09-15(a)(4)

At step four of the sequential analysis the ALJ formulates a claimant’s RFC by assessing his or her “ability to meet the physical, mental, sensory, and other requirements of work.” 20 C.F.R. §§ 404.1545(a)(4), 416.945(a)(4).

Section 404.1545(a)(1) bases residual functional capacity on impairments and related symptoms that affect what a claimant can do in a work setting.

Guth v. Commissioner of Social Security · filed 2022-09-09(a)(1)

A claimant’s RFC is based on “impairment(s), and any related symptoms, such as pain, [that] may cause physical and mental limitations that affect what [the claimant] can do in a work setting.” 20 C.F.R. § 404.1545(a)(1). ... In summary, the ALJ did not err in finding Mr. Guth capable of light work with additional limitations, and the RFC was supported by substantial evidence.

An RFC assessment must account for the claimant’s limitations; unexplained conflicts with persuasive medical opinions can require remand.

Cook v. Kijakazi · filed 2022-09-09(a)(1)

Because the ALJ did not explain how any material inconsistencies or ambiguities in the evidence were considered and resolved, the Court cannot determine whether the RFC correctly incorporated all of Ms. Cook’s limitations.

Residual functional capacity is based on all relevant medical and other evidence, and the ALJ must explain the assessment well enough for a court to trace its reasoning.

Sherrod v. Kijakazi · filed 2022-09-12(a)(3)

The court can trace the ALJ’s reasoning in formulating the RFC, which is supported by substantial evidence, and it is not the court’s role to reweigh the evidence.

Residual functional capacity is the most a claimant can still do despite limitations and is assessed using all relevant evidence.

(SS) Medina v. Commissioner of Social Security · filed 2022-09-12(a)(1)

The RFC is “the most [one] can still do despite [his or her] limitations” and represents an assessment “based on all the relevant evidence.”

In determining residual functional capacity, the ALJ considers medical source statements and all other record evidence; a severe impairment does not by itself require an additional functional limitation.

Barnes v. Commissioner of Social Security · filed 2022-09-12(a)(3)

In determining a claimant’s RFC, the ALJ considers medical source statements and all other evidence of record. 20 C.F.R. § 404.1545(a)(3). ... That is, the fact that an impairment is found to be severe does not dictate its limiting effects.

Section 404.1545(a) requires an RFC assessment to consider a claimant’s physical and mental abilities, symptoms, and other limitations that could interfere with regular work activities.

Russell v. Commissioner of Social Security · filed 2022-09-12(a)

A claimant's RFC represents a finding of the range of tasks he or she is capable of performing notwithstanding the impairments at issue. See 20 C.F.R. §§ 404.1545(a), 416.945(a). An RFC determination is informed by consideration of a claimant's physical and mental abilities, symptomology, including pain, and other limitations that could interfere with work activities on a regular and continuing basis.

Section 404.1545(c) requires the ALJ to consider evidence of mental limitations that may affect a claimant’s ability to work.

Conner v. Kijakazi · filed 2022-09-13(c)

In order to understand a person’s functional limitations an ALJ must consider evidence including observations, opinions, or conclusions by mental health providers on such matters as the individuals ability to cope with stress, the ability to relate to other people, and the ability to function in a group or work situation; and the Social Security regulations state that a limited ability to carry out certain mental activities, including limitations in understanding, remembering, and responding appropriately to supervision and coworkers, may reduce a person’s ability to work, as such mental activities are critical to work performance. 20 C.F.R. § 404.1545(c); SSR 85-16.

Section 404.1545 assesses what a claimant can do in a work setting despite limitations from medically determinable impairments.

VanWieren v. Commissioner of Social Security · filed 2022-09-13

RFC is a medical assessment of what an individual can do in a work setting in spite of functional limitations and environmental restrictions imposed by all of his medically determinable impairments. 20 C.F.R. §§ 404.1545 and 416.945. ... In reaching the RFC, the ALJ considered plaintiff’s medical records commencing from May 26, 2018, reviewed the opinions of Jessica Manning, Ph.D., Rebecca Haggerty, D.O., Dr. Heasley, and George Starrett, Ed.D., and explained how the records and opinions resulted in the RFC.

Section 404.1545 treats residual functional capacity as an assessment of what a person can do in a work setting despite limitations from medically determinable impairments.

Neubecker v. Commissioner of Social Security · filed 2022-09-13

RFC is a medical assessment of what an individual can do in a work setting in spite of functional limitations and environmental restrictions imposed by all of his medically determinable impairments. 20 C.F.R. §§ 404.1545 and 416.945. ... Upon reviewing the record, the Court finds that the RFC, which restricts plaintiff to a limited range of sedentary work activities, is supported by substantial evidence.