Statute Annotations › Federal › 20 C.F.R. § 404.1545

20 C.F.R. § 404.1545

Residual functional capacity: the cases that interpreted this section

Jurisdiction
Federal
Case notes
6,798
Cited in passing
2,872
Citing cases indexed
11,963
Case dates
1981–2026
Screened through
2026-06-18
Checked for later law changes
2026-10-20
Courts' treatment: live
No reviewed case has held this section invalid, preempted, superseded or repealed.
This reflects what the reviewed cases said, not legislative action: a later amendment or repeal by the legislature would not appear here unless a reviewed case discussed it.

9,670 citing cases reviewed of 11,963 in the citation index: 6,798 interpreted the section (annotated below), 2,872 cited it only in passing. Cases filed after 2026-06-18 may not have been reviewed yet.

Have a situation under 20 C.F.R. § 404.1545?

These notes show how courts have ruled. Ask about your specific facts and see which of these rulings apply, with citations you can check.

Scope of RFC assessment

Section 404.1545 requires an RFC assessment of a claimant’s physical and mental ability to work; supported medical source assessments can help explain the resulting limitations.

Williams v. Massengill · filed 2025-07-24

The ALJ permitted meaningful review by incorporating the RFC assessment of persuasive sources into the ALJ’s own RFC assessment as to Plaintiff’s physical and mental limitations.
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Section 404.1545(a) requires the ALJ to consider all credible, supported limitations when assessing residual functional capacity.

(SS) Rodriguez v. Commissioner of Social Security · filed 2025-07-31(a)

In determining the RFC, the ALJ must consider all limitations, severe and non-severe, that are credible and supported by substantial evidence in the record. ... Thus, the ALJ sufficiently supported the RFC with reference to the medical record.
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An RFC must account for assessed limitations, but it need only be consistent with them, not identical to them.

Castaneda v. Commissioner of Social Security · filed 2025-09-10(a)

Importantly, the RFC needs only be consistent with, rather than identical to, the opined limitations. The RFC’s limitation to simple, repetitive work is consistent with Dr. Bonilla’s findings of mild to moderate impairments in the various mental functioning areas.
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Section 404.1545 permits an RFC assessment to account for moderate social limitations through simple, routine tasks and occasional interaction with the public and coworkers when substantial evidence supports that assessment.

Jennifer W. v. Commissioner of Social Security · filed 2025-09-16(a)

Here, the ALJ found plaintiff moderately limited in interacting with others, which she translated into an RFC for “simple, routine tasks” and occasional interactions with “the public and coworkers.” ... Thus, plaintiff's assessed RFC was adequately explained and grounded in substantial evidence.
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Section 404.1545 requires the ALJ to consider limitations from a claimant’s impairments when assessing residual functional capacity.

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

Although Plaintiff cites some evidence of migraine headaches, including the “intractable” type, see Pl.’s Mem. at 6 (citations omitted), the ALJ’s Decision makes clear that she adequately considered Plaintiff’s complaints about the migraine headaches and accepted them only to the extent consistent with the RFC.
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Section 404.1545(a)(2) does not require an additional RFC restriction when the claimant identifies no further work-related limitation supported by the record.

Smallwood-Wolf v. Commissioner of Social Security · filed 2025-09-24(a)(2)

Plaintiff’s inability to identify flaws with the ALJ’s treatment of the clinical record and her failure to identify any further restrictions in the RFC renders her argument null.
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Section 404.1545 requires an RFC assessment to account for a claimant’s supported mental limitations.

Fauble v. Commissioner of Social Security · filed 2025-09-30(a)

The ALJ’s decision explained why those limitations accounted for Plaintiff’s difficulties associated with her mental impairments and is supported by substantial evidence.
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An RFC assessment may omit claimed limitations when substantial evidence supports the ALJ’s finding that the symptoms do not occur as frequently as alleged.

Lyons v. Bisignano · filed 2025-09-29(a)(3)

In view of this supported finding, the ALJ did not err in omitting RFC limitations relating to being off task or absent from work.
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An RFC limit to simple, routine tasks does not account for a persuasive medical opinion limiting the claimant to one- and two-step tasks.

Cruz v. O'Malley · filed 2025-09-30

Cruz brings an issue before us that, while formally unsettled89 in the Third Circuit, is generally found to require remand: whether an RFC limiting a claimant to “simple, routine tasks” is sufficient to account for a persuasive medical opinion’s limitation to “one- and two-step tasks.”90 We conclude it is not.
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An RFC assessment must account for supported functional limitations, including those associated with obesity, using the medical record and claimant testimony.

Abudayyeh v. Bisignano · filed 2025-09-30(a)(1)

Overall, the ALJ considered the possible limitations of functioning that can be exacerbated by obesity, including postural functions, ability to manipulate objects, tolerate extreme conditions, and fatigue, using the evidence available in the medical record and through Plaintiff’s testimony as discussed above. The Court is satisfied that the ALJ has built a logical bridge between the evidence in the record and her RFC determination.
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Section 404.1545 requires an RFC assessment to account for limitations supported by the record when determining what a claimant can still do despite impairments.

Justin H. v. Bisignano · filed 2025-10-27

But beyond Dr. Sharokhi’s opinion and the statements of Plaintiff’s father, both of which the Court has already determined the ALJ appropriately considered, Plaintiff does not offer, nor does the record support, a finding that any limitations imposed by Plaintiff’s injury for any period before January 1, 2020 were not already adequately accounted for in ALJ Reason’s RFC assessment.
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A mental residual functional capacity assessment is sufficient when it has a valid explanation grounded in the evidence and considers the claimant’s workplace demands in context.

O'Malley · filed 2025-10-29

Instead, the evaluation of a claimant’s ability to undertake the mental demands of the workplace will be viewed in the factual context of the case, and a mental RFC is sufficient if it is supported by a valid explanation grounded in the evidence.
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An RFC assessment need not include a restroom accommodation when the record does not support a need for one.

Andrews · filed 2025-10-24(a)(3)

Here, while the ALJ did not specifically explain why Claimant did not require an accommodation in the RFC for bathroom breaks or close proximity to a restroom, the record here is not replete with evidence that such accommodations may be necessary.
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Section 404.1545 requires an RFC assessment to account for documented functional limitations, including difficulties with instruction, task completion, and attention.

Turnpaugh · filed 2025-12-11

Without some explanation of how the RFC limitations accommodate these challenges––such as Mr. Turnpaugh’s need for repetitive and continual instruction, his difficulty completing tasks essential for independent living, his problems with motivation and sustaining attention, and his tendency to become easily overwhelmed–– the Court cannot trace the path of the ALJ’s reasoning.
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Residual functional capacity need not account for a public transportation restriction unless the claimant shows that it affects her ability to perform work.

Sanchez · filed 2026-01-02(a)(1)

The ALJ’s failure to discuss Dr. Owen’s moderate restriction on the ability to use public transportation is not grounds for reversal where Plaintiff has not otherwise shown how it affects the finding that she can perform jobs in the national economy.
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Section 404.1545(a)(1) requires an ALJ to assess residual functional capacity when the claimant has not been found disabled at step three.

Brendel · filed 2026-02-25(a)(1)

Because ALJ Koclanes did not find James conclusively disabled at step three, he had to assess James’s RFC to determine whether he could return to his past work or adjust to other work. See 20 C.F.R. § 404.1545(a)(1).
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Section 404.1545 requires an RFC assessment to consider relevant evidence and include only credibly established limitations.

SHAH · filed 2026-02-27(a)

And, at bottom, the RFC need only include “credibly established” limitations.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations; it does not require an additional restriction for every impairment.

O'Brien · filed 2026-03-02(a)(1)

Further, because “RFC is defined as the most a claimant can still do despite his or her physical or mental limitations,” Martise, 641 F.3d at 923 (emphases added) (citation omitted), nothing mandated that the ALJ specifically include further limitations from O’Brien’s migraines in the RFC, see, e.g., 20 C.F.R. § 404.1545(a)(1) (“Your [RFC] is the most you can still do despite your limitations.”).
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Section 404.1545(a)(1) defines residual functional capacity as what a claimant can still do despite limitations caused by impairments.

Griest · filed 2026-03-04(a)(1)

RFC is defined as “that which an individual is still able to do despite the limitations caused by his or her impairment(s).”
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Section 404.1545(a)(1) defines residual functional capacity as what a person can do despite mental and physical limitations.

JONES · filed 2026-03-09(a)(1)

The RFC is a measure of what an individual can do despite his mental and physical limitations. 20 C.F.R. § 404.1545(a)(1); see also SSR 96-8p (stating the RFC is "an assessment of an individual's ability to do sustained work-related physical and mental activities in a work setting on a regular and continuing basis").
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations.

Barker · filed 2026-03-10(a)(1)

Residual functional capacity is defined as “the most you can still do despite your limitations.” 20 C.F.R. § 404.1545(a)(1).
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Residual functional capacity is the most a claimant can still do despite limitations; the determination must be supported by the evidence.

Estrada · filed 2026-03-12(a)(1)

An individual’s residual functional capacity (“RFC”) is the most an individual can still do despite his or her limitations. 20 C.F.R. § 404.1545(a)(1). ... Having done so the Court does not find any legal error and has determined that the ALJ’s RFC determination is supported by substantial evidence.
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Residual functional capacity measures what a claimant can still do despite limitations and is based on all relevant medical and other evidence.

Alexandra S. v. Bisignano · filed 2026-03-12(a)(1)–(4)

The RFC (residual functional capacity) is “the most [the claimant] can still do despite [her] limitations,” and is developed in consideration of a claimant’s “ability to meet the physical, mental, sensory, and other requirements of work” based on “all of the relevant medical and other evidence.” 20 C.F.R. § 404.1545(a)(1)–(4).
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An RFC assessment adequately accounts for concentration, persistence, and pace limitations when it reflects the substance of the psychological consultants’ supported findings.

Shirk · filed 2026-03-13

While the wording is not identical, the ALJ’s RFC reflects the substance of the consultants’ findings about the CPP limitations.
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Section 404.1545 assesses work capacity; mild mental limitations found at step two do not automatically require corresponding limitations in the RFC.

D.S.A. v. Commissioner of Social Security · filed 2026-03-13

The term “limitations” as used in step two when applying the paragraph B criteria to mental impairments does not have the same meaning as “limitations” when discussing a claimant’s RFC.
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An ALJ assessing residual functional capacity must explain the assessed limitations with specific references to record evidence.

Moore · filed 2026-03-16

Finally, for reasons that follow, see II.C.-D., infra, the 2024 ALJ Decision fails to “provide appropriate rationale with specific references to evidence of record in support of the assessed limitations” in its reconsideration of Plaintiff’s residual functional capacity.
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Residual functional capacity is the most a claimant can do in a work setting despite limitations.

Roberson · filed 2026-03-16(a)(1)

The RFC assessment is a finding concerning the most that a claimant can do in a work setting despite his limitations. 20 C.F.R. § 404.1545(a)(1).
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An RFC adequately accounts for cervical limitations when it incorporates related restrictions supported by the record.

Napier · filed 2026-03-23(a)(1)

Thus, the ALJ considered Plaintiff’s limited range of motion in his neck and incorporated the related limitations that he found to be supported by the record evidence into the RFC. (A.R. 24–25.) Accordingly, the ALJ adequately considered Plaintiff’s cervical limitations in the RFC.
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Section 404.1545(c) requires consideration of work-related mental limitations; an RFC may express them as simple, unskilled work and specific limits on contact with others when the record makes those terms clear.

Drummond v. Astrue · filed 2012-09-10(c)

The court finds that the ALJ applied the correct legal standard to assess mental RFC, and that substantial evidence in the record supports his finding. Contrary to Plaintiffs assertion otherwise, the mental limitations assessed by the ALJ are functional limitations, even the limitation to simple, unskilled work.
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An ALJ may assess residual functional capacity from the medical record without obtaining an updated medical expert opinion.

Strauss v. Berryhill · filed 2020-03-25

The record indicates that the ALJ carefully considered Strauss’s medical record to determine her residual functional capacity for work. The ALJ was under no obligation to seek further medical expert advice for the very reason that “experienced ALJs can draw their own conclusions based on accurate medical information.”
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An ALJ assessing residual functional capacity must consider all relevant evidence, including medical records, examination observations, and descriptions of the claimant’s limitations.

SIDERIAS v. SAUL · filed 2022-09-20(a)

Relevant evidence includes “medical records, observations made during formal medical examinations, descriptions of limitations by the claimant and others, and observations of the claimant’s limitations by others.” Fargnoli, 247 F.3d at 41 (citing to 20 C.F. R. § 404.1545(a)).
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An ALJ must base residual functional capacity on all relevant evidence, including impairment-related absences, and consider the entire relevant period.

Moistner v. Commissioner of Social Security · filed 2024-03-27(a)(1)-(5)

The ALJ must base the RFC on all relevant evidence in the record, including the claimant’s descriptions of his limitations and symptoms, objective medical evidence, medical opinions, other medical evidence, evidence from non-medical sources, and prior administrative medical findings. See 20 C.F.R. § 404.1545(a)(1)-(5). ... The ALJ apparently did not consider these absences and certainly did not explain his decision not to account for them in the RFC.
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Section 404.1545(a) defines residual functional capacity as what a claimant can do despite physical and mental limitations.

Fisher v. O'Malley · filed 2024-03-29(a)

RFC is defined as the most a Plaintiff can do despite her limitations, including both physical and mental limitations. 20 C.F.R. § 404.1545(a). ... Thus, the ALJ properly considered both the medical and non-medical evidence, and substantial evidence supports the ALJ’s RFC assessment.
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Section 404.1545 defines residual functional capacity as the most a claimant can do despite impairments and calls for assessing their effects on the claimant’s ability to work.

Zimmermann v. O'Malley · filed 2024-08-19

RFC is defined as the most one can do despite one’s impairments. 20 C.F.R. §§ 404.1545, 416.945. ... Plaintiff next argues her pain and obesity should have been given more credence, but the ALJ explicitly (and adequately) considered both in combination when formulating Plaintiff’s RFC.
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Medication side effects

Section 404.1545(a)(3) requires the ALJ to consider all relevant medical and other evidence when assessing residual functional capacity, including limitations caused by needed medication.

Ramos v. Saul · filed 2020-09-25(a)(3)

The determination of a residual functional capacity is the ALJ’s “sole responsibility,” Taylor v. Astrue, 706 F.3d 600, 602-03 (5th Cir. 2012), and the ALJ considers all relevant medical and other evidence in making that determination, see 20 C.F.R. § 404.1545(a)(3). Such an assessment should account for any limitations or restrictions caused by side effects from needed medications.
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Residual functional capacity reflects what a claimant can still do despite limitations, including limitations caused by treatment.

Rabey v. Kijakazi · filed 2021-09-20(a)(1)

The ALJ is instructed to consider “all of the relevant evidence in the case record” including the “effects of treatment” such as “limitations or restrictions imposed by the mechanics of treatment.”
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An RFC assessment need not account for alleged medication side effects when the claimant provides no objective evidence that she experiences them.

Hubbard v. Kijakazi, Acting Commissioner of the Social Security Administration · filed 2023-04-06(a)

Plaintiff does not point to any objective evidence that she experiences any side effects, so the ALJ was not required to consider whether the Plaintiff experienced them.
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Applicability to SSDI and SSI

Section 404.1545 governs residual functional capacity for Social Security Disability Insurance claims; the identical § 416.945 applies to Supplemental Security Income claims.

COULOMBE v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER · filed 2020-11-24

Those regulations govern Social Security Disability Insurance (SSDI), which is governed by Part 404 of title 20 of the C.F.R. However, Ms. C. applied for Supplemental Security Income, which is governed by Part 416 of title 20 of the C.F.R. See Recommended Decision at 1 (“On Plaintiff’s application for supplemental social security benefits. . . ”). Even though the regulations at-issue, 20 C.F.R. § 404.1545 and 20 C.F.R. § 416.945 are identical, the correct citation is § 416.945.
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Section 404.1545 governs residual functional capacity assessments for Title II disability benefits claims.

Custodio v. Saul · filed 2022-06-22

The ALJ was thus correct to cite to 20 C.F.R. § 404.1545.
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Section 404.1545 governs residual functional capacity assessments for Title II claims.

Lynn v. Commissioner of Social Security · filed 2022-08-12

Accordingly, 20 C.F.R. § 404.1545 is the pertinent regulation on the residual functional capacity that relates to title II claims.
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Duty to develop medical record

Section 404.1545(a)(3) requires the ALJ to develop the claimant’s medical history and obtain a consultative examination when necessary to determine residual functional capacity.

Kirby v. Saul · filed 2021-03-15(a)(3)

In some cases, this duty requires the ALJ to obtain additional medical evidence, such as a consultative examination of the claimant, before rendering a decision. 20 C.F.R. § 404.1545(a)(3) (“before we make a determination that you are not disabled, we are responsible for developing your complete medical history, including arranging for a consultative examination(s) if necessary….”). ... A consultative examination is not warranted when, as is the case here, the ALJ can properly determine the RFC from the medical evidence provided.
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Section 404.1545(a)(3) requires the claimant to provide evidence for the RFC assessment, while the ALJ must make reasonable efforts to obtain the medical reports needed to assess functional limitations.

Conboy v. Commissioner of Social Security · filed 2021-04-21(a)(3)

Furthermore, the Commissioner’s regulations provide that a claimant is responsible for providing evidence upon which to base an RFC assessment. See 20 C.F.R. §§ 404.1512(a); 416.912(a) and 404.1545(a)(3); 416.945(a)(3). ... Because the ALJ failed to obtain competent medical opinion(s) that contained functional limitations on which he could base Plaintiff’s physical RFC finding, the ALJ failed in his affirmative duty to adequately develop the record, and his physical RFC finding was not supported by substantial evidence.
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Section 404.1545(a)(3) does not require an ALJ to obtain additional medical evidence to assess RFC when the existing record provides a sufficient basis.

Niemann v. Saul · filed 2021-05-25(a)(3)

As reviewed below, the medical record provides a substantial basis for the RFC and the ALJ was not required to obtain additional evidence.
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Section 404.1545(a)(3) does not require further development of the record when the available evidence is sufficient to assess a claimant’s capacity for work.

Madry v. Kijakazi · filed 2021-09-14(a)(3)

To the extent plaintiff contends that the ALJ did not properly develop the record, the record contained more than sufficient information for the ALJ to make an informed determination regarding plaintiff’s capacity to sustain work, including disability, function, and work background reports; over 1400 pages of medical records from the relevant period; and the transcript from the hearing.
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Section 404.1545(a)(3) requires the agency to develop a claimant’s complete medical history and arrange a consultative examination when necessary.

Walls v. Commissioner of Social Security · filed 2021-09-30(a)(3)

See 20 C.F.R. §404.1545(a)(3) (“However, before we make a determination that you are not disabled, we are responsible for developing your complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help you get medical reports from your own medical sources.”). ... After review of the decision in light of the medical records and other records before the ALJ, the ALJ did not err by failing to order a consultative mental examination.
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Section 404.1545(a)(3) requires the agency to develop a claimant’s complete medical history before finding the claimant not disabled; an updated medical opinion is unnecessary when the record has no evidentiary gap causing unfairness or clear prejudice.

Coke v. Commissioner of Social Security · filed 2021-10-27(a)(3)

See 20 C.F.R. §404.1545(a)(3) (“However, before we make a determination that you are not disabled, we are responsible for developing your complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help you get medical reports from your own medical sources.”). ... Plaintiff also has not shown any evidentiary gaps in the record that resulted in unfairness or clear prejudice. Considering the evidence as a whole, the Court finds the ALJ fulfilled her duty to develop the record.
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An RFC determination cannot be upheld when missing medical records prevent a proper evaluation of the claimant’s limitations.

(SS) Montoya v. Commissioner of Social Security · filed 2021-11-17(a)

A claimant’s residual functional capacity is “the most [a claimant] can still do despite [her] limitations.” 20 C.F.R. §§ 404.1545(a), 416.945(a); ... As discussed above, the ALJ erred in by not developing the record related to Plaintiff’s arthritis, which impacts the review of the remaining evidence—such as Plaintiff’s subjective complaints—and formulation of the RFC. ... Therefore, the Court is unable to find the RFC determination was proper.
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Section 404.1545(a)(3) requires the agency to develop a claimant’s complete medical history and arrange a consultative examination when necessary; an examination is unnecessary when the record is sufficient to decide the claim.

Valero v. Commissioner of Social Security · filed 2021-11-10(a)(3)

See 20 C.F.R. §404.1545(a)(3) (“However, before we make a determination that you are not disabled, we are responsible for developing your complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help you get medical reports from your own medical sources.”). ... After review of the decision and given the medical records and other records before the ALJ, the ALJ did not err by failing to order a consultative mental examination.
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Section 404.1545(a)(3) requires the agency to develop a claimant’s complete medical history before finding the claimant not disabled, including obtaining relevant prior claims files when necessary.

Cruz v. Commissioner of Social Security · filed 2022-03-04(a)(3)

See 20 C.F.R. §404.1545(a)(3) (“However, before we make a determination that you are not disabled, we are responsible for developing your complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help you get medical reports from your own medical sources.”). ... After review of the decision, the ALJ erred by failing to develop the record further when he did not obtain the prior application files.
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Section 404.1545(a)(3) requires the agency to develop a claimant’s complete medical history before finding the claimant not disabled, including arranging a consultative examination if necessary.

Thomas v. Commissioner of Social Security · filed 2022-03-07(a)(3)

See 20 C.F.R. §404.1545(a)(3) (“However, before we make a determination that you are not disabled, we are responsible for developing your complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help you get medical reports from your own medical sources.”). ... After review of the decision and given the medical records and other records before the ALJ, the ALJ did not err by failing to develop the record further, such as by failing to order a consultative medical examination.
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The ALJ must develop the claimant’s medical history before finding the claimant not disabled and obtain a consultative examination when necessary to assess mental limitations.

Milburn v. Kijakazi · filed 2022-03-31(a)(3)

Thus, upon remand, the ALJ is ordered to obtain a consultative examination to determine the extent of Plaintiff’s mental limitations. Upon receipt of the consultative examination, the ALJ must re-evaluate Plaintiff’s mental limitations and reformulate the RFC.
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Section 404.1545(a)(3) places the burden of proving residual functional capacity on the claimant and requires the ALJ to develop the claimant’s medical history and make reasonable efforts to obtain reports from the claimant’s medical sources.

Ambrose v. SAUL · filed 2022-09-19(a)(3)

While a claimant bears the burden of proving his RFC, before making a determination that a claimant is not disabled, the ALJ is “responsible for developing [the claimant’s] complete medical history, . . . making every reasonable effort to help you get medical reports from your own medical sources.” 20 C.F.R. § 404.1545(a)(3). ... The rejection of these opinions did not leave an impermissible evidentiary gap.
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Section 404.1545(a)(3) requires the agency to develop a claimant’s complete medical history, arrange a consultative examination if necessary, and make every reasonable effort to obtain medical reports from the claimant’s own sources.

Harley v. Commissioner of Social Security · filed 2023-02-21(a)(3)

See 20 C.F.R. § 404.1545(a)(3), 20 C.F.R. § 416.945(a)(3) (“However, before we make a determination that you are not disabled, we are responsible for developing your complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help you get medical reports from your own medical sources.”). ... Here, the ALJ satisfied his duty to develop a full record by obtaining and reviewing medical records, State Agency decisions, and multiple consultative examinations as well as considering other evidence of record.
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Section 404.1545(a)(3) requires the agency to develop the claimant’s medical history, but an ALJ need not order a consultative examination when the record permits an informed decision.

Williams v. Commissioner of Social Security · filed 2023-02-22(a)(3)

See 20 C.F.R. § 404.1545(a)(3) (“However, before we make a determination that you are not disabled, we are responsible for developing your complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help you get medical reports from your own medical sources.”).1 While an ALJ has this duty, he “is not required to order a consultative examination as long as the record contains sufficient evidence for the administrative law judge to make an informed decision.” Ingram v. Comm’r of Soc. Sec. Admin., 496 F.3d 1253, 1269 (11th Cir. 2007). ... After review of the decision and given the medical records and other records before the ALJ, the ALJ did not err by failing to order a consultative examination.
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Section 404.1545(a)(3) requires the ALJ to make reasonable efforts to develop a sufficient record for assessing residual functional capacity.

Lori v. Commissioner of Social Security Administration · filed 2023-03-16(a)(3)

The regulations impose two competing obligations in the submission and development of disability claims: (i) the claimant must prove his claim by providing a record complete and detailed enough for the Commissioner to make a disability determination; and (ii) the ALJ has an obligation to make reasonable efforts to develop a sufficient record upon which to make a disability determination. 20 C.F.R. § 404.1512(a)-(b); 20 C.F.R. § 404.1545(a)(3).
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Section 404.1545(a)(3) requires a sufficiently developed record of how an impairment affects the claimant’s ability to work before residual functional capacity can be assessed.

Rivera v. Commissioner of Social Security · filed 2023-04-21(a)(3)

On the existing record, we simply have no best — or even good — estimate of how frequently Rivera should be expected to experience seizures while working at any future job. Given that, the ALJ had an obligation to develop the record further.
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An ALJ need not include a medical examiner’s proposed limitations in the residual functional capacity if the record as a whole does not support them.

Calvillo v. Kijakazi · filed 2023-04-24

While Dr. Patel may have diagnosed Calvillo with additional limitations, the ALJ is not required to incorporate any limitations into the RFC that he did not find the record as a whole supported.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite limitations and requires an assessment based on all relevant evidence.

(SS) Jimenez v. Commissioner of Social Security · filed 2023-04-27(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.”
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Section 404.1545(a)(3) requires the ALJ to determine residual functional capacity based on all relevant medical and other evidence.

Venezia v. Commissioner of Social Security Administration · filed 2023-05-01(a)(3)

“That determination is made ‘based on all of the relevant medical and other evidence,’ 20 C.F.R. § 404.1545(a)(3), and in doing so the ALJ must ‘evaluate the persuasiveness of medical opinions,’ 20 C.F.R. § 404.1520c(a)[.]” Tansy v. Comm’r of Soc. Sec. Admin., No. CV-21-1873-PHX-SMB (JFM), 2022 WL 16752321, at *9 (D. Ariz. Sept. 22, 2022). That is what the ALJ did here, in concluding that Dr. Grove’s opinions were unsupported by his treatment notes and inconsistent with the greater record and Plaintiff’s activities.
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Section 404.1545 requires an ALJ to assess residual functional capacity using all relevant evidence in the claimant’s case file.

Sullivan v. Commissioner of Social Security · filed 2023-05-01(a)(1)

An ALJ must assess a claimant’s RFC based on all the relevant evidence in a claimant’s case file.
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The claimant is generally responsible for providing the evidence used to assess residual functional capacity.

Smith v. Commissioner of Social Security · filed 2023-05-02(a)(3)

The claimant is generally responsible for providing the evidence that the Commissioner will use to make an RFC finding. 20 C.F.R. § 404.1512(a)(1); 20 C.F.R. § 404.1545(a)(3) (“In general, you are responsible for providing the evidence we will use to make a finding about your residual functional capacity.”).
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Section 404.1545(a)(3) requires an ALJ to assess residual functional capacity using all relevant medical and other evidence.

Jensen v. Kijakazi · filed 2023-05-05(a)(3)

ALJs are responsible for assessing a claimant’s RFC “based on all of the relevant medical evidence and other evidence.” 20 C.F.R. §404.1545(a)(3), §404.1546(c); see Fanta v. Saul, 848 F App’x 655, 658 (7th Cir. 2021) (emphasizing that an ALJ has the final responsibility for determining a claimant’s RFC and is not required to adopt any doctor’s particular opinion.) “In determining an individual’s RFC, the ALJ must evaluate all limitations that arise from medically determinable impairments, even those that are not severe, and may not dismiss a line of evidence contrary to the ruling.”
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A residual functional capacity assessment must reflect the most a claimant can do despite his limitations, and a consultant’s opinion based on a significantly incomplete record cannot provide substantial evidence to support it.

Clark v. P Kilolo Kijakazi, Acting Commissioner, Social Security Administration · filed 2023-05-10(a)(1)

An opinion provided by a state agency reviewing consultant cannot provide substantial evidence to support an ALJ's residual functional capacity assessment if the opinion was based on a significantly incomplete record.
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A residual functional capacity assessment lacks substantial evidence when it relies on consultants’ opinions that did not account for material later treatment records and opinions.

Clark v. US Social Security Administration, Commissioner · filed 2023-05-10(a)(1)

A claimant’s residual functional capacity is the most a clamant can do despite the functional limitations caused by his impairments. 20 C.F.R. § 404.1545(a)(1). ... Because Drs. Warren and Stenslie did not review the more recent treatment records and opinions, their opinions cannot provide substantial evidence to support the ALJ’s residual functional capacity assessment.
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Section 404.1545(a)(3) requires the ALJ to assess the evidence when determining a claimant’s residual functional capacity, including descriptions of limitations and medical reports.

Kalinich v. Kijakazi, Acting Commissioner of SSA · filed 2023-05-17(a)(3)

The regulations provide that the ALJ must assess all the evidence, including the claimant’s and others’ descriptions of the limitations, and medical reports, to determine what capacity the claimant has for work despite his or her impairments. 20 C.F.R. § 404.1545(a)(3) and 416.945(a)(3). ... Here, the Court finds that the ALJ’s RFC is not supported by substantial evidence.
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Section 404.1545(a)(3) requires the ALJ to develop a complete medical history, including arranging a consultative examination when necessary.

Espino v. Commissioner of Social Security · filed 2023-06-21(a)(3)

An ALJ is responsible for developing the complete medical history, including arranging for a consultative examination if necessary.
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Section 404.1545(a)(3) requires a consultative examination to develop the record when it is necessary to assess residual functional capacity.

(SS) Scott v. Commissioner of Social Security · filed 2023-08-17(a)(3)

Plaintiff has not demonstrated that it was necessary for the ALJ to ... arrange for a consultative exam.
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Section 404.1545(a)(3) requires development of the claimant’s medical history, but a consultative examination or further expert review is unnecessary when the record provides sufficient evidence to assess residual functional capacity.

McQuillin v. Commissioner of Social Security · filed 2023-08-23(a)(3)

Substantial evidence supports the ALJ’s RFC assessment, and substantial evidence supports the ALJ’s decision not to return the file to the State Agency consultants for an updated review of the entire file, order a consultative examination, or obtain medical expert testimony.
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Section 404.1545(a)(3) does not require an additional medical opinion before an ALJ assesses residual functional capacity when the evidence is sufficient to determine the claimant’s limitations.

Gill v. Commissioner of Social Security · filed 2023-09-25(a)(3)

Although the reviewing physicians found insufficient information to provide an opinion, as discussed above, the ALJ reviewed additional evidence – none of which contained objective medical evidence requiring a medical opinion.
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Section 404.1545(a)(3) can require an ALJ to obtain medical opinion evidence when assessing residual functional capacity would otherwise require interpreting raw medical data or leave a critical body of objective evidence unaddressed.

Tomlin v. Commissioner of Social Security · filed 2024-04-12(a)(3)

Thus, the situation here is not one where the ALJ was required to interpret “raw medical data” or where a critical body of objective medical evidence was not accounted for in the face of “significant evidence of potentially disabling conditions.”
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Section 404.1545(a)(3) does not require an ALJ to obtain additional medical evidence for an RFC assessment when the existing record provides a sufficient basis.

Jones v. Kijakazi · filed 2024-07-23(a)(3)

Consequently, this Court concludes that the ALJ had sufficient bases for reaching her RFC determination, and she thus was not obliged to obtain more medical evidence.
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Section 404.1545(a)(3) requires the agency to develop the record for the period relevant to a disability claim before denying benefits.

Farid v. Commissioner of Social Security · filed 2024-09-11(a)(3)

Even though true, the ALJ never clearly informed Plaintiff of this fact, Plaintiff was not represented by counsel or a representative, and if this period was of “primary importance,” the ALJ had the duty to develop the record for this relevant period and direct questions to this period.
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Section 404.1545(a)(3) requires the agency to develop a claimant’s complete medical history and to resolve material discrepancies when necessary to determine disability.

Carathers v. Social Security Association, Commissioner of · filed 2024-09-26(a)(3)

Additionally, the ALJ has a duty to develop the record. See 20 C.F.R. § 404.1545(a)(3) ("[W]e are responsible for developing your complete medical history, including arranging for a consultative examination(s) if necessary . . . ."). Such a duty is particularly important where there is a clear and material discrepancy in the record. ... The Court also finds that the ALJ did not develop the record in accordance with the regulations on a fundamentally important issue in this case that was clearly muddled.
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Section 404.1545(a)(3) does not require an ALJ to obtain another medical opinion when the evidence is not a critical body of evidence requiring further development.

Shade v. Commissioner of Social Security · filed 2025-02-24(a)(3)

These few pieces of evidence are not a “critical body of evidence” that would require a medical opinion or further development of the record.
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Section 404.1545(a)(3) places responsibility on claimants to provide evidence for an RFC assessment and on ALJs to develop the medical history; an ALJ need not develop the record further when it is sufficient to assess RFC.

Yellowman v. Commissioner of Social Security Administration · filed 2025-03-10(a)(3)

Because of this additional evidence, in conjunction with the medical record reviewed by the DDS physicians, the record was sufficient for the ALJ to make a residual functional capacity determination, and the ALJ had no duty to develop the record further.
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Section 404.1545(a)(8) requires the ALJ to make reasonable efforts to obtain a claimant’s medical records; giving counsel opportunities to submit missing records can satisfy that duty.

Yunke v. Commissioner of Social Security · filed 2025-03-31(a)(8)

The ALJ is “responsible for developing [a claimant’s] complete medical history ...and making every reasonable effort to help [a claimant] get medical reports from [their] own medical sources.” 20 C.F.R. § 404.1545(a)(8) (citing §§ 404.1512(d) through (e)); see 42 U.S.C. § 423(d)(5)(B). ... Under these facts, the ALJ properly discharged his duty to develop the administrative record.
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Section 404.1545(a)(3) requires the ALJ to develop the medical record sufficiently to assess residual functional capacity, including arranging a consultative examination when necessary.

Bonney v. Bisignano · filed 2025-09-30(a)(3)

After it became clear that Dr. Douglas had not and would not provide a medical source opinion, the ALJ nonetheless had an affirmative, non-adversarial duty to order a consultative examination or make other efforts to expand the record as to Plaintiff’s RFC.
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Section 404.1545(a)(3) recognizes the ALJ’s duty to develop the record when assessing residual functional capacity; new evidence that is not critical does not require another medical-source opinion.

Dishman · filed 2025-11-14(a)(3)

However, both the regulations and case law recognize the ALJ has a duty to develop the record. ... This August 26, 2025 lung screen was not a critical body of objective medical evidence that required the ALJ to obtain a new medical- source opinion.
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Section 404.1545(a)(3) requires the ALJ to develop the record further when evidence is ambiguous or inadequate for evaluation.

Kelly · filed 2026-01-20(a)(3)

The ALJ is obligated to adequately develop the record at step four, even though the plaintiff has the burden of proving she cannot perform her past relevant work as generally performed. 20 C.F.R. § 404.1545(a)(3); Crane v. Shalala, 76 F.3d 251, 255 (9th Cir. 1996). However, the obligation to develop the record “is triggered only when there is ambiguous evidence or when the record is inadequate to allow for proper evaluation of the evidence.” ... Thus, the ALJ did not have an obligation to inquire further, and the VE’s testimony supported the ALJ’s finding that Plaintiff could perform past relevant work as generally performed.
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Section 404.1545(a)(3) requires the ALJ to develop the medical record sufficiently to assess residual functional capacity, including seeking medical reports and arranging a consultative examination when necessary.

Krish · filed 2026-01-26(a)(3)

The ALJ was required to obtain information necessary to make an accurate assessment of Plaintiff’s impairments and RFC. The ALJ is “responsible for developing [the claimant’s] complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help [the claimant] get medical reports from [the claimant’s] own medical sources.” 20 C.F.R. § 404.1545(a)(3).
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Section 404.1545(a)(3) requires an ALJ to develop the record further when significant medical evidence bearing on functional capacity is not accounted for by a medical opinion.

Gonzales v. Commissioner of Social Security · filed 2022-03-18(a)(3)

Accordingly, the Court finds that the ALJ erred by failing to further develop the record under 20 CFR § 404.1545(a)(3).
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Environmental limitations

Section 404.1545(d) requires an ALJ to account for work-related limitations caused by environmental factors when assessing residual functional capacity.

Mull v. Saul · filed 2021-03-26(d)

When a medically determinable impairment stemming from environmental factors affects a claimant’s work-related abilities, the ALJ must account for those limitations in the residual functional capacity. § 404.1545(d).
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do despite impairments and related symptoms.

Jordan v. Commissioner, Social Security Administration · filed 2021-06-03(a)(1)

By definition, a claimant’s RFC is the most the claimant can still do despite the claimant’s impairments and any related symptoms. 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1) (2020).
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An RFC may omit environmental limitations when substantial evidence, including medical evidence, supports their omission.

Marshall v. Kijakazi · filed 2021-09-28(a)(1)

After careful review of the entire record, although it is a somewhat close question, the Court finds substantial evidence, including medical evidence, to support the ALJ’s decision not to include environmental limitations in the RFC.
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Attendance limitations

An ALJ need not separately analyze absenteeism or off-task time when no expert or treating source identifies limitations that conflict with the residual functional capacity assessment.

Bisignano · filed 2026-04-08

With no expert or treating source opining either to greater concentration/persistence limitations or to absenteeism or off-task time, there is no error in the ALJ’s approach.
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Section 404.1545(c) treats a claimant’s capacity for attendance as part of residual functional capacity.

Wilson v. Social Security Administration · filed 2021-09-24(c)

Ms. Wilson’s capacity for attendance is part of her RFC.
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Section 404.1545(a)(1) concerns a claimant’s ability to work despite limitations; an absenteeism limit need not be included in the RFC when the record does not support the claimed frequency of absences.

Bentz v. Commissioner of Social Security Administration · filed 2021-11-02(a)(1)

The RFC determination sets out an individual’s work-related abilities despite his or her limitations. See 20 C.F.R. § 404.1545(a)(1). ... the ALJ specifically found that the record did not support a finding that Bentz would exceed an average of once per month in absences.
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An RFC off-task limitation must be connected to substantial evidence, but an unexplained limitation is harmless when no credited evidence shows work-precluding time off task.

Cruz v. Kijakazi · filed 2021-12-06

Although the ALJ failed to connect his nine percent off-task limitation to the evidence, the error was harmless because Tanya C. has not pointed to evidence that she would be off task at a rate that would preclude work.
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Section 404.1545 requires an RFC assessment to account for work limitations caused by impairments, including intermittent periods when pain would leave a claimant off task or absent.

Sides-Allen v. Saul · filed 2022-01-28(a)(1)

Because the ALJ discounted Plaintiff’s symptom testimony regarding his chronic abdominal pain, which is well-documented and well-supported in the record, it failed to properly determine his RFC by not accounting for the intermittent periods where Plaintiff would be off task or absent due to his inability to move or get out of bed because of the pain.
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An RFC assessment for a claimant with migraines must address how variable symptoms may affect work attendance.

Gould v. Kijakazi · filed 2022-02-23(a)(1)

On remand, the ALJ must reassess Gould’s RFC and specify how the variable nature of her migraines may affect her absenteeism if she were subject to sustained, fulltime employment.
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Section 404.1545(a) requires the RFC to reflect absences caused by an impairment when those absences limit the claimant’s ability to work.

Williams v. Kijakazi · filed 2022-03-18(a)

The record evidence shows plaintiff cannot perform sustained work functions during her migraine headache episodes; therefore, the RFC would have had to reflect the need for absences.
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Section 404.1545 permits an RFC assessment to omit treatment-related tardiness when the claimant has not shown that treatment cannot be scheduled around full-time work.

Lobmaster v. Kijakazi · filed 2022-05-03

Plaintiff has failed to demonstrate that his sessions could not be arranged to accommodate a full-time competitive employment schedule. ... Because the ALJ based his RFC assessment upon review of all the credible, relevant evidence of record, and the RFC is supported by some medical evidence, it will not be disturbed.
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An RFC assessment must include sufficient attentional, attendance, and scheduling limitations supported by the evidence, or explain their omission.

Rivers v. Saul · filed 2022-07-22(a)

The Court agrees with Plaintiff that the ALJ committed error by neglecting to include sufficient attentional, attendance-related or schedule-related limitations in the RFC, or at the very least, explaining why he did not do so.
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Section 404.1545 permits an RFC finding without an absence limitation when substantial evidence shows that treatment compliance would prevent the hospitalizations causing those absences.

Brejtfus v. Commissioner of Social Security · filed 2023-07-24(a)

Substantial evidence supports the ALJ’s reasoning that if Plaintiff complied with her medications and therapy, these involuntary commitments would lessen or at best abate and would not interfere with Plaintiff’s work schedule. As a result, substantial evidence supports the ALJ’s RFC findings.
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Section 404.1545 does not require an RFC to include an off-task limitation for narcolepsy when substantial evidence supports omitting it.

Melsness v. Kijakazi · filed 2023-09-15(a)(1)

Taken together, these facts constitute substantial evidence to support the ALJ’s decision not to include a limitation for excess “off task time” in Plaintiff’s RFC.
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Residual functional capacity measures work a claimant can do despite impairment-related limitations; speculative future absences for medical appointments do not establish an additional limitation.

Malak v. Commissioner of Social Security · filed 2024-03-22(a)(1)

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). ... Similarly, there is nothing in the record here to suggest that Plaintiff’s appointments could be scheduled only during working hours. The Court also cannot endorse Plaintiff’s speculation about future absences based solely on her past medical appointments.
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Section 404.1545(a)(1) supports an absenteeism limitation for medical appointments only when the appointments are necessary and unavoidably cause work absences.

Crow v. Commissioner of Social Security · filed 2024-07-18(a)(1)

However, because the RFC reflects “the most [a claimant] can still do,” 20 C.F.R. § 404.1545(a)(1) (emphasis added), frequent medical appointments will not justify absenteeism limitations unless the appointments are necessary; and unavoidably result in work absences.
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Section 404.1545(a)(4) does not require an RFC assessment to incorporate a vocational expert’s general testimony about off-task time or absenteeism when it does not address the claimant’s specific functioning.

Cox III v. O'Malley · filed 2025-07-30(a)(4)

Moreover, even though the ALJ contemplated Plaintiff’s absenteeism, a VE’s testimony about absenteeism is “not required to be incorporated into the RFC” because such testimony “is a statement of the vocational expert’s general observation and experience and does not pertain to [the claimant’s] specific functioning.” Vicki M. o/b/o Monte H. v. Comm’r of Soc. Sec., No. MKD-17-0437, 2019 WL 438480, at *8 (E.D. Wash. Feb. 4, 2019) (citing 20 C.F.R. § 404.1545(a)(4)). As such, the ALJ did not err by failing to incorporate the VE’s testimony regarding off-task time and absenteeism into the RFC assessment.
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Section 404.1545(a)(4) does not require an ALJ to include a vocational expert’s general estimates of off-task time or absenteeism in the RFC when they do not describe the claimant’s specific functioning.

Slaubaugh v. O'Malley · filed 2025-07-31(a)(4)

Even though the ALJ contemplated Plaintiff’s absences, a VE’s testimony about absenteeism is “not required to be incorporated into the RFC” because such testimony “is a statement of the vocational expert’s general observation and experience and does not pertain to [the claimant’s] specific functioning.” Vicki M. o/b/o Monte H. v. Comm’r of Soc. Sec., No. MKD-17-0437, 2019 WL 438480, at *8 (E.D. Wash. Feb. 4, 2019) (citing 20 C.F.R. § 404.1545(a)(4)). As such, the ALJ did not err by failing to incorporate the VE’s testimony regarding off-task time and absenteeism into the RFC.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can do despite physical or mental limitations; an absenteeism restriction need not be included when the evidence does not support one.

Timms v. Berryhill · filed 2020-01-16(a)(1)

RFC is “the most [a claimant] can still do despite” his or her physical or mental limitations. 20 C.F.R. § 404.1545(a)(1). ... For these reasons, this Court concludes the ALJ did not err in not including a restriction in plaintiff’s capacity to maintain normal attendance in full-time work.
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An ALJ need not include a vocational expert’s general testimony about off-task time or absenteeism in the RFC when it does not describe the claimant’s specific functioning.

Constantine v. Kijakazi · filed 2024-08-22(a)(4)

As it has before, the Court finds no error in the ALJ’s refusal to incorporate into the RFC the VE’s testimony regarding off-task time and unscheduled absences.
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An RFC assessment need not incorporate a vocational expert’s general testimony about absenteeism when that testimony does not address the claimant’s specific functioning.

Cooper v. Kijakazi · filed 2024-08-23(a)(4)

Even though the ALJ contemplated Plaintiff’s unscheduled absences, a VE’s testimony about absenteeism is “not required to be incorporated into the RFC” because such testimony “is a statement of the vocational expert’s general observation and experience and does not pertain to [the claimant’s] specific functioning.” Vicki M. o/b/o Monte H. v. Comm’r of Soc. Sec., No. MKD-17-0437, 2019 WL 438480, at *8 (E.D. Wash. Feb. 4, 2019) (citing 20 C.F.R. § 404.1545(a)(4)). As such, the ALJ did not err by failing to incorporate the VE’s testimony regarding off-task time and unscheduled absences into the RFC.
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Treatment needs during work

Section 404.1545 requires an ALJ assessing residual functional capacity to consider whether recurring treatments limit a claimant’s ability to work.

Matherly v. Commissioner of Social Security · filed 2022-03-09(a)(1)

Because Mr. Matherly’s frequent usage of the nebulizer and the inhaler could affect his ability to work, the ALJ was required to consider that limitation.
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Residual functional capacity must account for treatment needs that may prevent work on a regular and continuing basis.

Chase v. Saul · filed 2022-03-18(a)

The ALJ made no findings regarding the frequency of Plaintiff’s medical appointments, the ability to schedule outside working hours, or the potential that the frequency would be ongoing. Because Plaintiff’s treatment history demonstrates the potential of exceeding those thresholds, the ALJ erred in failing to consider or discuss Plaintiff’s treatment needs when determining Plaintiff’s RFC.
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Medical appointments do not require an absenteeism restriction in a residual functional capacity assessment without evidence that they would cause the claimant to miss entire workdays.

Bricker v. Commissioner of Social Security Administration · filed 2022-03-22

It is wholly unclear why single session counseling appointments or appointments with a primary care physician regarding medication refills would require Plaintiff to miss an entire day of work. ... For reasons the Court has already stated, the ALJ permissibly rejected the additional restriction of excessive absences in the RFC.
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An RFC assessment need not include a continuous oxygen requirement when later evidence shows the claimant did not continuously need oxygen.

Davis v. Kijakazi · filed 2022-03-30(a)

In her objections, plaintiff argues that the ALJ erred by failing to include plaintiff’s additional limitations of 1) needing supplemental oxygen and 2) needing a rolling walker or wheelchair in the RFC. ... However, as already noted, plaintiff was later noted to not continuously need supplemental oxygen. (Tr. 2077-80). Therefore, the court discerns no meaningful justification for remand on that basis.
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Section 404.1545 requires an RFC assessment to account for time spent on medically necessary treatments when the record supports that limitation.

Palmer v. Commissioner of Social Security · filed 2022-09-15

Based on the testimony, it appears that plaintiff’s use of the nebulizer would be work-preclusive, i.e., assuming that plaintiff used the nebulizer every six hours, he would have at least one 35-minute treatment during each 8-hour workday. Given this record, the RFC should have accounted for these treatments.
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Section 404.1545 requires an ALJ to consider the effects of treatment, including restrictions caused by the treatment itself, when assessing residual functional capacity.

Terry v. Kijakazi (CONSENT) · filed 2022-09-16(a)(3)

Of course, an ALJ must still consider the effects of a claimant’s treatment in conjunction with the other evidence of record, including any restrictions imposed by the mechanics of treatment.
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Section 404.1545(a)(1) defines residual functional capacity as the most a claimant can still do in a work setting despite physical or mental limitations.

Gould v. KIJAKAZI · filed 2022-09-16(a)(1)

The RFC is the most a claimant can still do in a work setting despite the claimant’s physical or mental limitations. ... As set forth above, the RFC is supported by substantial evidence.
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Section 404.1545 governs the assessment of residual functional capacity; an RFC determination may be upheld when based on a fully and fairly developed record.

Bathe v. Kijakazi · filed 2022-09-19

Having reviewed the entire record, the Court finds that the AL] made a proper RFC determination based on a fully and fairly developed record.
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Section 404.1545(a)(4) directs the ALJ to consider a claimant’s ability to meet the physical, mental, sensory, and other requirements of work when assessing residual functional capacity.

Morefield v. Saul · filed 2022-09-19(a)(4)

The ALJ determines the individual’s “ability to meet the physical, mental, sensory, and other requirements of work.” 20 C.F.R. § 404.1545(a)(4). ... The ALJ also adequately followed the requirements of the Regulations when formulating the RFC assessment and sufficiently explained why the medical opinions supported her RFC determination.
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An RFC can account for supported medical appointment needs by limiting work to hours outside regular business hours while allowing a regular, continuing work schedule.

Childs v. Kijakazi · filed 2023-10-25(a)(1)

The RFC requirements do not necessitate such guidance: according to SSR 96-8p, the RFC should reflect an individual’s ability to “do sustained work activities in an ordinary work setting on a regular and continuing basis,” that is, eight hours a day for five days a week or an equivalent work schedule. SSR 96-8p, 61 Fed. Reg. 34474, 34475 (July 2, 1996). The ALJ’s RFC and related hypothetical sufficiently incorporate this requirement by clearly stating that the available work, which by definition meets the eight hour a day, five days a week requirement of SSR 96-8p, must be performed outside of regular business hours.
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An ALJ need not account for medical appointments in residual functional capacity without evidence that their frequency, scheduling, or duration would cause missed work.

Carsten v. O'Malley · filed 2024-03-13(a)

Because Plaintiff does not cite to any evidence in the record demonstrating that the frequency, scheduling, or duration of her medical appointments would require her to miss two or more days of work every month, the ALJ did not err by not evaluating the frequency of her medical appointments.
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In assessing residual functional capacity, an ALJ must consider whether treatment for medically determinable impairments, including non-severe impairments, affects a claimant’s ability to attend work.

DAILEY v. KIJAKAZI · filed 2024-12-13(a)(2)

The ALJ’s decision does not address how any of this treatment—whether for a non-severe alcohol use disorder or for the other impairments that she found to be severe—impacted Mary Jean D.’s ability to be present at work as frequently as required, consistent with the VE’s testimony.
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Section 404.1545 requires an RFC assessment to account for medically required treatment that restricts a person’s ability to work on a regular and continuing basis.

Gonzalez v. Social Security Administration, Commissioner of · filed 2025-01-16

As explained above, the requirement for IVIG infusions in this case is a restriction caused by Plaintiff’s myasthenia gravis within the meaning of § 404.1545.
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Section 404.1545 excludes time spent attending medical appointments from the RFC assessment because appointments are not functional limitations caused by medically determinable impairments.

Malak v. Commissioner of Social Security · filed 2025-03-18

We hold that a claimant’s medical appointments and whether those appointments affect the claimant’s ability to work are not appropriate factors for the ALJ to consider when addressing the claimant’s RFC.
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Section 404.1545(a)(3) requires an ALJ assessing residual functional capacity to consider a claimant’s reported limitations alongside medical evidence, including supported treatment needs.

Masters · filed 2025-12-02(a)(3)

In omitting discussion of Claimant’s undisputed nebulizer treatments and their impact on her functional ability, ALJ Foster sheds doubt on the validity of the RFC and overlooks evidence that potentially supports a more restrictive RFC or disability finding.
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Harmless RFC errors

An error in an RFC limitation is harmless when it does not affect the ultimate disability determination.

Lanham v. Commissioner Social Security Administration · filed 2022-03-28

The ALJ’s perceived error in construing Plaintiff’s RFC, which would eliminate the Marker job, is therefore inconsequential to the non-disability determination.
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An ALJ must assess a claimant’s physical work functions when determining residual functional capacity, but an insufficiently detailed assessment is harmless if a fuller analysis would not change the result.

Beach v. Kijakazi · filed 2022-09-23(b)

Accordingly, any failure by the ALJ to perform a function-by-function analysis, where, as here, there is no evidence that more robust analysis would lead to a different result, constitutes harmless error.
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An omitted limitation in a residual functional capacity assessment is harmless if including it would not change the disability determination.

COWHER v. KIJAKAZI · filed 2024-06-24

In this particular context, the ALJ’s alleged error is harmless if the outcome of Cowher’s claim—i.e., a finding that she was not disabled—would have been the same even if the limitation she argues warranted inclusion in her RFC had, in fact, been included. Such is the case here.
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An RFC assessment must account for relevant medical evidence, but an inadequately explained conflict with a medical opinion is harmless if resolving it would not change the disability decision.

Holstein v. Dudek (CONSENT) · filed 2025-03-11(a)(3)

Because the ALJ failed to adequately explain and address the conflict between the RFC and a medical opinion she found partially persuasive, the ALJ’s RFC determination is not supported by substantial evidence. ... Although the ALJ’s unclear explanation for omitting “short” from the RFC is an error, it does not alter the ALJ’s ultimate conclusion that Plaintiff can perform a significant number of jobs in the national economy. Thus, the ALJ’s RFC determination is harmless error which does not warrant reversal.
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Step-three limitations and RFC

Section 404.1545 requires the ALJ to assess RFC from the record evidence, but a marked step-three social interaction limitation does not automatically require more restrictive social interaction limits in the RFC.

Healey v. Kijakazi · filed 2022-08-29(a)(3)

Although a limitation to superficial social contact can also be found to accommodate a moderate limitation in social functioning, see, e.g., Carver v. Colvin, 600 F. App’x 616, 620 (10th Cir. 2015), there is no requirement that an ALJ assess more restrictive social interaction limitations in the RFC to account for a step-three “marked” limitation in interacting with others. The ALJ in this case did what was required under the regulations: he considered the record evidence and assessed RFC limitations that accounted for Plaintiff’s mental impairments and social interaction symptoms supported by the record (Tr. 25–31).
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Section 404.1545(a) requires an RFC to reflect limitations supported by the record, but does not require greater visual limitations based on allegations the evidence does not support.

Fellner v. Kijakazi · filed 2022-09-23(a)

The ALJ recognized Plaintiff’s visual limitations, but the collective findings support no greater limitation than as stated in the RFC.
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Section 404.1545 requires an ALJ to include a supported need for frequent breaks in the residual functional capacity assessment or explain its omission.

Evanoff v. Commissioner of Social Security · filed 2022-11-07

On remand, the ALJ must include a limitation for frequent and significant breaks in the RFC or specifically explain why she has not.
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An RFC assessment determines what a claimant can still do despite limitations and is distinct from deciding whether an impairment meets a Listing.

SHIFFLER v. SAUL · filed 2022-11-04(a)(1)

As the Commissioner notes, however, the analysis of whether an impairment rises to the level of a Listing is not the same as an RFC assessment.
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Section 404.1545 requires an ALJ to explain how the RFC limitations account for a claimant’s impairments.

Wharton v. Kijakazi · filed 2022-12-19

However, the ALJ failed to explain how or why any of these limitations are sufficient to compensate for Plaintiff’s “severe” impairment of migraines.
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Section 404.1545 requires an RFC assessment to account for functional limitations arising from a claimant’s need to monitor blood sugar.

Stoker v. Commissioner Social Security Administration · filed 2022-12-20

Because the ALJ omitted that medical need and possible related limitations from Plaintiff’s RFC, the vocational expert’s testimony that plaintiff could work as a bus driver is not supported by substantial evidence.
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Section 404.1545 requires an RFC assessment to account for supported limitations caused by a claimant’s impairments, including chronic diarrhea.

Moss v. Kijakazi · filed 2023-03-02

The RFC determined by the ALJ does not account for limitations due to chronic diarrhea.
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An RFC allowing ready access to a restroom must address the need for additional breaks when their frequency and duration could affect the ability to work.

Penley v. Commissioner of Social Security · filed 2023-03-10(a)

Under these circumstances, however, providing that Plaintiff have “ready access to a restroom,” without more, fails to provide meaningful information about Plaintiff’s work limitations and abilities.
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Residual functional capacity need not include additional limitations for intermittent symptoms when the evidence shows the claimant can manage them without a sustained effect on her ability to work.

Keller v. Commissioner of Social Security Administration · filed 2023-07-21(a)(1)

And, while Plaintiff had two serious flare-ups close together, she was otherwise able to effectively manage her intermittent symptoms at home. There was thus no reason for the ALJ to add accommodations for Plaintiff’s pancreatic symptoms to his RFC of light work.
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Section 404.1545(a) requires the ALJ to assess the most a claimant can do despite limitations and include all functional limitations supported by the record.

Staton v. Social Security · filed 2023-09-08(a)

The ALJ is responsible for determining a plaintiff’s RFC, which is the most a claimant can do despite existing limitations. 20 C.F.R. § 404.1545(a), 404.1546(c). 416.945(a). The RFC assessment must include all of the claimant’s functional limitations supported by the record. ... Here, the Court finds that the ALJ did not err because the RFC does not conflict with Dr. Wood or Dr. Kaur’s opinions.
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An RFC must account for supported functional limitations or explain, with reasons supported by substantial evidence, why they were rejected.

(SS) Nanney v. Commissioner of Social Security · filed 2023-11-28(a)

Based on the foregoing, the Court finds the RFC limiting Plaintiff to understanding, remembering, and carrying out simple instructions, maintaining concentration, persistence, and pace for 2-hour intervals, occasionally interacting with coworkers and the general public, and adapting to simple workplace changes, does not account for Dr. Bonilla’s findings of moderate limitations in Plaintiff’s ability to complete a normal workday/work week and the likelihood of emotional deterioration. The ALJ’s failure to either provide reasons, supported by substantial evidence, to reject those limitations, particularly as to her ability to attend a workday/work week, or to properly incorporate those limitations into the assessed RFC, constitutes error.
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An RFC may omit proposed limitations when substantial evidence supports their omission.

Johnson v. O'Malley · filed 2024-01-09(a)(1)

Thus, I find that the ALJ did create a logical bridge from the record evidence to his conclusions and that his decision not to include light sensitivity and additional rest break limitations in the RFC was supported by substantial evidence.
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Section 404.1545 requires the ALJ to consider severe and non-severe impairments but include in the RFC only limitations that affect the claimant’s ability to work.

Harrington v. SSA · filed 2024-02-05(a)

Although Harrington is correct that the ALJ must consider both severe and non-severe limitations, the ALJ must only include in the RFC limitations found to affect plaintiff’s ability to work.
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An RFC need include only limitations the ALJ finds credible and supported by the record.

McGhee v. Commissioner of Social Security · filed 2024-03-06(a)

And because an ALJ “is only required to include in the residual functional capacity those limitations he finds credible,” the Undersigned finds no error here.
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Section 404.1545 governs assessment of residual functional capacity; an ALJ must explain the evidentiary basis for a limitation included in that assessment.

Swift v. Commissioner, Social Security Administration · filed 2024-03-29

However, the ALJ’s failure to articulate the evidentiary basis of his moderate noise limitation requires the Court to remand this matter so the ALJ can explain the evidentiary basis for the limitation.
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An ALJ assessing residual functional capacity must account for credited concentration limitations or explain why they are rejected.

Robertson v. Commissioner of Social Security · filed 2024-11-07(a)

An individual’s RFC should be assessed based upon all relevant evidence in the record. Id. ... Here, as in Mischler, both the state agency consultants and the ALJ found Plaintiff had moderate limitations in concentrating, persisting or maintaining pace. Therefore, the ALJ should have either included those concentration limitations in his hypothetical to the Vocational Expert, or alternatively, rejected such conclusions/evidence and explained why he did not find them to be persuasive.
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An ALJ may omit a claimed limitation from the residual functional capacity assessment when substantial evidence supports its omission.

Thomas v. Commissioner of Social Security · filed 2024-12-30(a)

The undersigned disagrees because substantial evidence supports the omission of such a limitation in the RFC.
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An RFC must account for supported limitations affecting a claimant’s ability to complete a workday or workweek, unless the ALJ gives reasons supported by substantial evidence for excluding them.

(SS) Mathews v. Commissioner of Social Security · filed 2025-01-17(a)

A claimant’s RFC is “the most [the claimant] can still do despite [his or her] limitations.” 20 C.F.R. § 404.1545(a); 20 C.F.R. § 416.945(a). ... The ALJ’s failure to provide reasons, supported by substantial evidence, to reject those limitations, particularly as to her ability to attend a workday/work week and likelihood for emotional deterioration, or to properly incorporate those limitations into the assessed RFC, constitutes error.
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Section 404.1545 requires an RFC assessment to include limitations supported by the medical record and permits excluding unsupported limitations.

Locke v. O'Malley · filed 2025-02-10

An ALJ’s RFC assessment must incorporate all of Plaintiff’s limitations supported by the medical record, 20 C.F.R. § 404.1545, and conversely, the RFC need not include limitations that are not supported by the record.
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Section 404.1545 does not require an ALJ to automatically carry Step Three limitations into the residual functional capacity assessment.

Hubbard-Robinson v. Commissioner of Social Security · filed 2025-02-27

Nothing in the regulations requires an ALJ to adopt their Step Three limitations in the subsequent RFC assessment.
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Section 404.1545(a) requires an RFC to include all credible symptom allegations and limitations that have not been properly rejected.

Lacerda · filed 2025-10-14(a)

This argument indicates a flawed understanding of RFC requirements, which must include all credible symptom allegations and limitations that have not been properly rejected. 20 C.F.R. §§ 404.1545(a), 416.945(a).
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Evidence predating the alleged onset date

Section 404.1545(a)(3) allows an ALJ to consider relevant medical evidence that predates the alleged disability onset date when assessing residual functional capacity.

Lalanne v. Saul · filed 2022-08-29(a)(3)

The regulations do not preclude analysis of evidence that predates the alleged onset date.
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Social interaction limitations

Section 404.1545 requires an ALJ who assigns different RFC limits for interactions with the public, supervisors, and co-workers to explain and support the distinction.

Edmister · filed 2026-03-31

To the extent an ALJ distinguishes between the groups with whom a claimant can interact, he must explain and provide support for that distinction. ... The ALJ failed to provide such support or explanation here.
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A mental residual functional capacity may account for social limitations by restricting interaction with supervisors and coworkers and eliminating public interaction when the record supports those limits.

Combs v. Saul · filed 2022-09-15(c)

While Plaintiff may have some difficulty interacting with others, the ALJ’s mental RFC sufficiently accounts for her social limitations as understood through the objective evidence in the record by restricting her to only “occasional [and] superficial” interaction with supervisors and coworkers at a maximum, and no interactions whatsoever with the public.
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An RFC limiting social contact to occasional interactions does not account for a limitation to superficial interactions, because frequency and quality of contact differ.

Huffman v. Commissioner of Social Security · filed 2022-09-30(a)(1)

But the two terms are not interchangeable. While “occasional contact” refers to the quantity of time spent with individuals, “superficial contact” goes to the quality of the interactions. And so limiting Plaintiff to “occasional contact” does not, in fact, ensure that any job duties would be “sufficiently ‘superficial.’” The ALJ’s conclusion that Plaintiff is capable of occasional interactions, without including a limitation that restricts him to superficial interactions, constitutes reversible error.
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An RFC finding must account for credited social limitations and explain how those limitations permit the stated level of workplace interaction.

Bangert v. Kijakazi · filed 2024-12-06(a)(1)

Moreover, the ALJ fails to explain how a moderately-severe or moderate limitation on Plaintiff's ability to interact with others would allow for “frequent” interaction with supervisors and co-workers.
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An RFC limit to occasional interaction does not account for a limit to superficial interaction.

Renfrow v. Commissioner of Social Security Administration · filed 2024-12-18(a)

The Court disagrees that occasional interaction (a quantitative limitation) accounts for a limitation to superficial interaction (a qualitative limitation).
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Section 404.1545(a)(1) requires an RFC assessment to account for limitations in the work a claimant can perform, including supported limits on interaction with supervisors.

Epperson v. O'Malley · filed 2025-01-08(a)(1)

A claimant’s RFC is the maximum work that she can perform despite any limitations. 20 C.F.R. § 404.1545(a)(1); SSR 96-8p. ... Viewing the record as a whole, the ALJ failed to identify substantial evidence supporting his conclusion that plaintiff is capable of unlimited interaction with supervisors despite her moderate social limitations.
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A residual functional capacity assessment may describe a superficial social-interaction limit as allowing simple exchanges of information or instructions without detailed ongoing interactions.

Rogers v. Commissioner of Social Security · filed 2025-09-08

But a simple exchange of information or instructions, especially where, as here, it is “without detailed ongoing interactions with others,” is not inconsistent with relating superficially with coworkers and supervisors.
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Notes 6301–6450 of 6,798, oldest cases first.

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