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Post by bartleby on Oct 23, 2014 7:25:53 GMT -5
hal3000, I totally agree. Unfortunately, I have seen some Judges that hesitate to get a ME because they feel they don't have enough medical knowledge to ask competent questions. Unfortunately again, these are the exact Judges that need an ME. I am not suggesting to get rid of the legal/judicial model of public administration, I think it needs to be updated. Using Doctors at the initial and reconsideration phase of the process is a waste IF the record has not been developed. I would rather see the Doctors used at our level as you suggest. Many, I think 10, states have gotten rid of the recon phase and I think that is a good idea as it is nothing but a waste of time, effort, and money as it adds nothing usable to the record. I think the Agency should include how to use an ME in the initial Judge training as it can be very beneficial when needed.
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Post by ssalawman on Oct 23, 2014 8:23:41 GMT -5
No one will dispute the fact that the pay rate has decreased. Lies, damn lies and statistics, aside. It has gone down. The issue, ssalawman, is why. From your initial post you posited there has been some edict from the commissioner to pay less cases. Despite the evidence, you said. So, while it is easy to show a pay rate decline (which I assume you offer as some sort of res ipsa proof of your theory), I still await your supporting evidence. Where is this edict written? Was it spoken at some meeting, training session or conference call? What I have seen is an agency recognizing that past pushes to reduce the hearing backlog has led to many cases getting paid without regard to policy compliance. Why? Because it is easier and faster to pay leading to more dispositions. You cite the concerted effort to reduce the less than sed rfc pays. Perhaps it would surprise you to know that, by policy, a less than sed rfc was always supposed to be rare. That's always been the case. But in the great push for numbers, many judges simply relied on a less than sed rfc without sufficient evidence to support it and ssr 96-9p to pay the cases. I've seen rfc findings along the lines of "can't persist for 8 hours". That's not even an rfc, much less policy compliant. Now, ask yourself this: Is it wrong to not pay a claim if following policy and regs means it doesn't qualify to be paid just because some noncompliant judge might have paid it in the past? I suppose, if your position is a determination to comply with policy and the law leads to a reduction in the pay rate and is therefore a nefarious plot to not pay people, we are at an impasse. I just haven't seen it, heard it or read it and it goes against every iota of training I've just completed. If there is such a plot, I'd think the aljs would have to be in on it. Now, I do agree that a judge that denies 90% is doing a disservice to the same degree that is done by one paying that percentage. But, there has long been appeals council and court oversight of denials. Pay cases have long been without that review. Remedying that deficiency is an area that has been the subject of some recent edicts. As it should be. Of course there is no smoking gun of a written edict from anyone at the Agency to pay less cases but circumstantial evidence certainly supports that it has taken place. The statistics support this. I have had conversation with long term ALJs who are feeling the pressure to deny more cases and several folks involved with training new ALJs have used words like "indoctrination" to describe what the Astrue Judges are being taught. I have not seen these so called "noncompliant" Judges who don't follow policy and the regs and were just paying down the back log as SSA would have the populous believe. I have, however, run into a large number of ALJs who fail to follow policy when denying claims. This type of Judge has been on the increase in recent years. There appears to be a certain type of personality SSA is looking to hire as ALJs now. Those who come from a bureaucratic background, have likely never had any involvement with real world issues with the presentation of a case or the practice of law. These folks are much easier to indoctrinate with a mindset that all claimant's and reps are liars and cheats. This mentality then finds its way into how they evaluate claims and there you have your decreased pay rate. I would also suggest that SSA is hiring younger folks as ALJs who see the Corp as an easy career move, no worries of billable hours, no partners to please, a decent salary and good benefits. These folks are willing to buy in to the mentality SSA is pushing so they can get and keep the position. The FIT template, and its boilerplate, has also resulted in many a decision to deny being written with nothing more than conclusory statements to support the denial and no evaluation of the evidence. All you need to do is read a few of Judge Posner's 7th Circuit opinions to see how this boilerplate is being applied improperly by the Agency. Thankfully the courts are still there to help push back against the Agency and protect claimants and their right to a fair and supported decision.
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Post by bartleby on Oct 23, 2014 9:21:24 GMT -5
ssalawman, Just from my own perspective, the low pay outliers I have seen have for a great deal been ex-prosecutors, district attorneys, or local magistrate judges. I don't know how this fits into your scheme, but there does seem to be a propensity for these to deny more cases. It seems to me that liberals have a higher pay rate than some. I also think older Judges seem to pay a few more cases than the young ones. As I have said before, the combination of the Act, Reg's, policies, Hallex, POMS, daily advice from above, leads to much confusion and they are almost impossible to implement across the board in every case. One tries to incorporate as much as possible from all of these directives, but it still often comes down to a judgment call. As long as there are personalities involved and so many differing directives, there will be a wide latitude of decisions rendered. It's not black and white, it is the slightest scintilla one way or the other... I truly don't think management cares if we pay or deny, they just want them moved along as quickly as possible. A few weaker Judges may have succumbed to the constant pressure by paying most of them as it is easier to do. In 20 years, I have never seen management get involved with paying or denying a case and anybody on this board will tell you that I am not an Agency hack, far from it. Management has many problems, but skewing the pay or non-pay is not one of them. As usual, JMHO, but experienced opinion.
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Post by funkyodar on Oct 23, 2014 9:31:18 GMT -5
Of course there is no smoking gun of a written edict from anyone at the Agency to pay less cases but circumstantial evidence certainly supports that it has taken place. The statistics support this. I have had conversation with long term ALJs who are feeling the pressure to deny more cases and several folks involved with training new ALJs have used words like "indoctrination" to describe what the Astrue Judges are being taught. I have not seen these so called "noncompliant" Judges who don't follow policy and the regs and were just paying down the back log as SSA would have the populous believe. I have, however, run into a large number of ALJs who fail to follow policy when denying claims. This type of Judge has been on the increase in recent years. There appears to be a certain type of personality SSA is looking to hire as ALJs now. Those who come from a bureaucratic background, have likely never had any involvement with real world issues with the presentation of a case or the practice of law. These folks are much easier to indoctrinate with a mindset that all claimant's and reps are liars and cheats. This mentality then finds its way into how they evaluate claims and there you have your decreased pay rate. I would also suggest that SSA is hiring younger folks as ALJs who see the Corp as an easy career move, no worries of billable hours, no partners to please, a decent salary and good benefits. These folks are willing to buy in to the mentality SSA is pushing so they can get and keep the position. The FIT template, and its boilerplate, has also resulted in many a decision to deny being written with nothing more than conclusory statements to support the denial and no evaluation of the evidence. All you need to do is read a few of Judge Posner's 7th Circuit opinions to see how this boilerplate is being applied improperly by the Agency. Thankfully the courts are still there to help push back against the Agency and protect claimants and their right to a fair and supported decision. So, let's look at these statements. "Of course there is no smoking gun...." So, the evidence I have been awaiting is admittedly nonexistent. "I have had conversation with long term ALJs who are feeling the pressure to deny more cases..." Perhaps the pressure they are feeling is to be policy compliant? To put less emphasis on meeting dispositional numbers and more on making a correct and quality decision? Change can be hard. "indoctrination to describe what the Astrue Judges are being taught." Having just went through the New ALJ training I can attest that I neither felt like I was being indoctrinated into any nefarious plan nor asked to do any thing more than review the evidence, provide a fair hearing then apply the policy to the facts. As a "Colvin Judge" ( I suppose), I have not once been told that I need to watch how many I pay or deny. Simply that I should comply with policy and be able to support my finding, whether favorable or unfavorable to the claimant, with the evidence. As to you proposition that the agency is seeking out bureaucratic youngsters with no real world experience so they can more easily manipulate their thinking....that, sir, is utter and unrefined BS. I just spent four weeks at new ALJ training with some of the most intelligent and variously experienced people I have ever had the honor to meet. That group included people with vast litigation experience, experience repping claimants, ALJ experience with other fed or state agencies, prosecutors, JAG corp members, people with medical backgrounds, people with extensive criminal defense backgrounds, former immigration lawyers.... If anything, an even quick perusal of almost any thread on this borad will dispell your delusion that the agency is somehow hiring easily indoctrinated insiders. Quite the opposite. And, as to the allegation that the new judge's relative youth means they are more condusive to taking the easy road....please. For one, I didn't see any new ALJs that would fall into the wet behind the ears category. For two, I would say the likelihood (while admittedly that, like you, I can't back this up with any evidence) that an older hire that thinks of this job as a sweet, low impact semi-retirement is the more apt to just go with a flow is quite high. Perhaps that's why so many of the "long time ALJs" you mention are upset that they now have oversight of their pay cases. Now, I actually agree with some of your statements on the FIT templates and boilerplate language. Too many writers and judges rely on it when it is not even applicable or to fill in for actual legal findings/argument. That is one of the things that I am most hopeful for with the changes. eBB can, if used properly, alleviate some of that. And, hiring better writers (which is allegedly one of the goals of the centralization of writer units, though not sure I can agree with that yet) will undoubtedly help. I will go out on a limb and guess you, ssalawman, are a rep and are upset that you don't win as many cases as you once did. As a former med mal attorney that suffered through tort reform, I feel your pain. But, I was told a long time ago that "pigs get fat, hogs get slaughtered." The wine and cheese days of signing up a claimant, meeting them for the first time at the hearing and hoping to get lucky with a judge that finds less than sed 90% of the time and pays you and the claimant are slowly coming to an end. As the judges become more policy compliant, the rep bar is gonna have to adjust.
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Post by ssalawman on Oct 23, 2014 13:19:24 GMT -5
It cuts both ways, ssalawman. An ALJ's decision must be upheld so long as it is supported by substantial evidence. if more than a scintilla and less than a preponderance of the evidence supports the RFC, and that RFC yields jobs, then that's enough to deny a claim and be upheld on appeal. Agreed Hopefalj, it does go both ways and some outcomes we all just have to live with. Thankfully, about 50% of the time the federal courts are asked to review an ALJ decision they find that the ALJ either didn't satisfy that burden or failed to comply with Agency policy and regulations in doing so.
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Post by Orly on Oct 23, 2014 14:28:05 GMT -5
The standard has been a preponderence of evidence at the ALJ level since 2009 when the Agency amended the CFR. I don't have the time to cite all the different amended CFR so below is the Final Rule announcement in the Federal Register. See: www.gpo.gov/fdsys/pkg/FR-2008-12-18/html/E8-30056.htmThe HALLEX I-3-3-4 provision cited above by SSALAWMAN re substantial evidence is a HALLEX provision specific to the Appeals Council in deciding whether to grant review in the first place. This is a more deferential standard because the AC is a reviewing body and don't get to see the claimant face to face and make credibility determinations. www.socialsecurity.gov/OP_Home/hallex/I-03/I-3-3-4.htmlIf the AC decides to grant review, then the AC decision on the merit is also decided by a preponderance of the evidence standard.
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Post by sealaw90 on Oct 23, 2014 14:55:29 GMT -5
"The standard has been preponderence of evidence at the ALJ level since 2009 when the Agency amended the CFR." Thank you Orly, and here I thought when reading these posts this morning that I was the idiot. Preponderance of evidence is the basic standard for most in-person federal administrative hearings designed to provide due process to individuals. This is regardless of the agency involved, although I KNOW there are exceptions, so please don't start shouting out each one. I've watched the evolution of APA protections and evidentiary standards for several agencies. Yes, there are different standards depending on the statute or regulation involved. I just figured since I was an outsider, I shouldn't have assumed the evidentiary standard being applied. I've been getting to know the HALLEX, SSA regs, and other fun stuff to read while I wait for the email from Bob, but I hadn't really thought about the evidentiary standard as a big issue. Now if you could also send out a redacted fall 2014 transfer list, I'd be eternally grateful Orly!
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Post by Gaidin on Oct 23, 2014 16:58:37 GMT -5
Really? I'm lost in your "logic." I look at the "How Am I doing?" tool as constant reminders to get cases moving and to get the dipsositions/scheduled hearings numbers up. It seems to me to only be concerned with making sure the numbers are met (with the possible exception of the AC feedback tab). And everyone knows it is easier to make the numbers by paying cases. So, care to explain how one could possible make the leap that such a tool encourages the denial of cases? Especially such as to support your initial position that the Commissioner wants cases denied despite the evidence? Are you saying the evidence doesn't support ALJ's denying more claims? 2011 ALJs allowed 58%, 2012 ALJs allowed 52%, 2013 ALJs allowed 48%. I'm sorry I am just getting around to commenting on this but I haven't had time until now. Ssalawman you expect people to believe your statistics based on 3 years worth of data. I am certain that there is data going back much further than 3 years. Is it possible that the 58% above was the outlier? What about the idea that the recent change to the burden of proof took more time for judges to adjust to it? You yourself seemed to be unaware that the standard had even changed. I'm really not trying to flame you but I have a lot of trouble with weak stats and no additional evidence being used to smear a group of lawyers and judges because you're not making as much money as you used to.
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Post by cougarfan on Oct 23, 2014 18:28:14 GMT -5
For what it's worth, I am an Astrue judge. The only thing I have been told is to 1) follow the law, 2) make a decision, and 3) don't look back. I'm not a bureaucrat by experience, I am a former claimant rep (SSA and WC) for 15 years and a couple years representing insurance carriers in WC claims. I've been surprised at my "pay rate." I think the pay rate is skewed because it includes dismissals for those who never show, it includes claims that have no business being at the hearing level (which the reps don't see b/c they don't take the case). I had the opportunity to rehear the cases for an ALJ who resigned and left before signing some decisions. He was generally more "liberal" in awarding benefits than I am; that doesn't mean I think he was "noncompliant" it means that we assessed credibility, weighed opinions, and interpreted the evidence differently. I do not think that is unique to ALJs at ODAR.
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Post by bartleby on Oct 23, 2014 18:41:15 GMT -5
Wait, what? Are you saying there is no uniformity among Judges??? Joking, Cougarfan, I totally agree. You just don't pick the top of the class without getting a lot of educated, egotistical, confident, characters. We are and we are proud of it. If most of us weren't mustangs, we wouldn't be where we are. Just saying...
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Post by cougarfan on Oct 23, 2014 21:36:37 GMT -5
LOL. Exactly Bartleby; although I'm sure you're not talking about me being egotistical! . (Although I'm pretty sure our group sup might agree with you if you were calling me egotistical. )
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Post by x on Oct 23, 2014 22:48:58 GMT -5
Funky, can you cite authority for your proposition that policy always has been that a less-than-sed RFC should be rare? Truly interested. Thanks. No one will dispute the fact that the pay rate has decreased. Lies, damn lies and statistics, aside. It has gone down. The issue, ssalawman, is why. From your initial post you posited there has been some edict from the commissioner to pay less cases. Despite the evidence, you said. So, while it is easy to show a pay rate decline (which I assume you offer as some sort of res ipsa proof of your theory), I still await your supporting evidence. Where is this edict written? Was it spoken at some meeting, training session or conference call? What I have seen is an agency recognizing that past pushes to reduce the hearing backlog has led to many cases getting paid without regard to policy compliance. Why? Because it is easier and faster to pay leading to more dispositions. You cite the concerted effort to reduce the less than sed rfc pays. Perhaps it would surprise you to know that, by policy, a less than sed rfc was always supposed to be rare. That's always been the case. But in the great push for numbers, many judges simply relied on a less than sed rfc without sufficient evidence to support it and ssr 96-9p to pay the cases. I've seen rfc findings along the lines of "can't persist for 8 hours". That's not even an rfc, much less policy compliant. Now, ask yourself this: Is it wrong to not pay a claim if following policy and regs means it doesn't qualify to be paid just because some noncompliant judge might have paid it in the past? I suppose, if your position is a determination to comply with policy and the law leads to a reduction in the pay rate and is therefore a nefarious plot to not pay people, we are at an impasse. I just haven't seen it, heard it or read it and it goes against every iota of training I've just completed. If there is such a plot, I'd think the aljs would have to be in on it. Now, I do agree that a judge that denies 90% is doing a disservice to the same degree that is done by one paying that percentage. But, there has long been appeals council and court oversight of denials. Pay cases have long been without that review. Remedying that deficiency is an area that has been the subject of some recent edicts. As it should be.
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Post by funkyodar on Oct 24, 2014 6:25:16 GMT -5
x,
Check out App 2 to Subpart P of CFR 404. Specifically, 201.00(4).
"(4) “Sedentary work” represents a significantly restricted range of work, and individuals with a maximum sustained work capability limited to sedentary work have very serious functional limitations. Therefore, as with any case, a finding that an individual is limited to less than the full range of sedentary work will be based on careful consideration of the evidence of the individual's medical impairment(s) and the limitations and restrictions attributable to it. Such evidence must support the finding that the individual's residual functional capacity is limited to less than the full range of sedentary work."
Now, does that say "rare"? Not excatly. It is significantly more detailed and directing in regard to evidence needed than the other exertional definitions within the App. But, it has been interpreted even more restrictively:
"SSR 96-9p: POLICY INTERPRETATION RULING TITLES II AND XVI: DETERMINING CAPABILITY TO DO OTHER WORK--IMPLICATIONS OF A RESIDUAL FUNCTIONAL CAPACITY FOR LESS THAN A FULL RANGE OF SEDENTARY WORK
PURPOSE: To explain the Social Security Administration's policies regarding the impact of a residual functional capacity (RFC) assessment for less than a full range of sedentary work on an individual's ability to do other work. In particular, to emphasize that:
1.An RFC for less than a full range of sedentary work reflects very serious limitations resulting from an individual's medical impairment(s) and is expected to be relatively rare. (emphasis Funky's)
2.However, a finding that an individual has the ability to do less than a full range of sedentary work does not necessarily equate with a decision of "disabled." If the performance of past relevant work is precluded by an RFC for less than the full range of sedentary work, consideration must still be given to whether there is other work in the national economy that the individual is able to do, considering age, education, and work experience. CITATIONS (AUTHORITY): Sections 223(d) and 1614(a) of the Social Security Act (the Act), as amended; Regulations No. 4, sections 404.1513(c), 404.1520, 404.1520a, 404.1545, 404.1546, 404.1560, 404.1561, 404.1562, 404.1563 through 404.1567, 404.1569, 404.1569a; appendix 1 of subpart P, section 12.00; appendix 2 of subpart P, sections 200.00 and 201.00; Regulations No. 16, sections 416.913(c), 416.920, 416.920a, 416.945, 416.946, 416.960, 416.961, 416.962, 416.963 through 416.967, 416.969 and 416.969a."
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Post by Deleted on Oct 24, 2014 7:28:22 GMT -5
I think the above statement about claimant's reps making less is probably true. One rep we have in my area has complained loudly about the fact that with the backlog down and processing time decreasing, the amount of back pay has dropped precipitously. That cuts into the bottom line. Other changes I have noticed in the past two years: two/three years ago the big disability firms were paying lawyers to fly to every little SSA outpost for a hearing. I always wondered how they could make money doing that. I think the answer was that they were selective about the cases they took, i.e. over 50 high percentage cases. That business model has changed. Now, the big firms seem to be paying local reps a $500 appearance fee and taking anything that walks in the door, or I guess, calls the 1-800 number. I'm doing more denials of represented cases than I used to because of that.
So, selective representatives mean more claimants who can’t get representation and drop out of the process, meaning a higher average pay rate. Less selective representatives means more clear denials coming to hearing and a lower average pay rate? Just part of a complex equation.
I recall a time in private practice when tort reform passed in my State. The big defense firms were laying off whole floors of associates. Bad, bad, time to be a lawyer. In a similar vein, I think the SSA business model may just be changing, with resulting frustration.
Personally, I love and use less than sedentary a lot. Even if I'm not supposed to. Frequently, it is the answer that makes the most sense in a given case. Yesterday I had a woman in excess of 350 lbs., on portable oxygen (COPD), chronic edema, cellulitis, with diabetes, among a host of other health issues. She was a train wreck. Because of her age, she didn't grid out at sedentary, and she didn't meet any of the remaining listings. If I had been incautious, the VE would have placed her in a prior job. But. The truth is she was unemployable and not capable of maintaining full time employment. An RFC hypothetical that supposed she was limited to standing and walking only a few minutes during the workday made sense. SSA may want that to be relatively rare, but in my Deep South jurisdiction, it is common to see a claimant with the deadly trifecta: Obesity, Diabetes, Heart Disease and/or COPD. Common. So, like I said, changing business models of a complex business.
The article that started this conversation really glossed over many of those complex variables.
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Post by ssalawman on Oct 24, 2014 8:51:44 GMT -5
To respond to a previous suggestion that my view of SSA is a result of making less money in recent years, such a comment is just wrong. I am actually making more money now than ever before. I believe this to be the result of hard work and an unwillingness to accept defeat. While other reps have felt the hardship that decreased pay rates have resulted in, I have seen an increase. This is due in part to expanding our involvement in cases, now getting involved in more applications, as well as the pursuit of more cases into federal court and the award of EAJA fees. I guess I shouldn't be complaining about ALJs rendering unsupported decisions as that is the bread and butter of my existence. Please keep it up.
And I am thankful for the reminder of the evidence standard. I had my head in a federal court brief for a few days and was focused on the substantial evidence standard. My apologies for misstating things and I have edited my posts to remove the misinformation.
For those big firms that are now paying local reps the $500 appearance fee, I would be concerned about OGC knocking on my door as without a few petition that $500 is an unapproved fee.
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Post by bartleby on Oct 24, 2014 9:37:27 GMT -5
Ssalawman, according to our policies, the fee goes to the main named rep or the one with ERE, not the appearing rep. Both names must be on the 1696. The appearing rep receives whatever the main rep and they decide. If the fee agreement says $6,000.00 and the main rep gets $6,000.00, the main rep paying the appearing rep $500.00 is a contractual matter between the two reps and not our concern. Trust me, OGC has plenty of things to do other than get involved in contract law between two reps.. It's no different than a firm having a staff attorney appear that is receiving a salary.. On the other hand, "fee splitting" may or may not be a concern with the local BAR, but..
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Post by aljsouth on Oct 27, 2014 11:20:29 GMT -5
Sir is correct in the agency policy. Please remember that if both signed the agreemnt you simply approve the fee agreement [assuming no other issues]. The agency pays into the account provided in the 1695, but this is NOT an ALJ issue.
If one rep waives but not the other rep, then note this in the approval of the fee agreement. Don't rule as to percenages, this is not your issue.
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Post by valkyrie on Oct 27, 2014 13:47:00 GMT -5
I think Cougarfan and Bartleby nailed it. SSAlawman has an overactive imagination. For his increased denial conspiracy to be true, it would require ODAR to have a grand plan, the grand plan must work the way ODAR intended, and the plan would involve the ALJ Corps behaving in some kind of uniform behavior. Its so crazy that it just, might, work...
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Post by x on Oct 27, 2014 20:49:07 GMT -5
Huh. Interesting phraseology. Makes no sense that a less-than-sed RFC would be rare -- how many people are limited to sed but able to climb ladder/rope/scaffold without limitation? But taking it to mean that less-than-sedentary allowance is expected to be relatively rare, how often do you see a rule of law expressed as a statistical prediction or preference? What is the fact-finder's state of mind to be at the moment of decision -- "This person is disabled, but that would give me a relatively-non-rare percentage of less-than-sed allowances this week/month/year?" x, Check out App 2 to Subpart P of CFR 404. Specifically, 201.00(4). "(4) “Sedentary work” represents a significantly restricted range of work, and individuals with a maximum sustained work capability limited to sedentary work have very serious functional limitations. Therefore, as with any case, a finding that an individual is limited to less than the full range of sedentary work will be based on careful consideration of the evidence of the individual's medical impairment(s) and the limitations and restrictions attributable to it. Such evidence must support the finding that the individual's residual functional capacity is limited to less than the full range of sedentary work." Now, does that say "rare"? Not excatly. It is significantly more detailed and directing in regard to evidence needed than the other exertional definitions within the App. But, it has been interpreted even more restrictively: "SSR 96-9p: POLICY INTERPRETATION RULING TITLES II AND XVI: DETERMINING CAPABILITY TO DO OTHER WORK--IMPLICATIONS OF A RESIDUAL FUNCTIONAL CAPACITY FOR LESS THAN A FULL RANGE OF SEDENTARY WORK PURPOSE: To explain the Social Security Administration's policies regarding the impact of a residual functional capacity (RFC) assessment for less than a full range of sedentary work on an individual's ability to do other work. In particular, to emphasize that: 1.An RFC for less than a full range of sedentary work reflects very serious limitations resulting from an individual's medical impairment(s) and is expected to be relatively rare. (emphasis Funky's) 2.However, a finding that an individual has the ability to do less than a full range of sedentary work does not necessarily equate with a decision of "disabled." If the performance of past relevant work is precluded by an RFC for less than the full range of sedentary work, consideration must still be given to whether there is other work in the national economy that the individual is able to do, considering age, education, and work experience. CITATIONS (AUTHORITY): Sections 223(d) and 1614(a) of the Social Security Act (the Act), as amended; Regulations No. 4, sections 404.1513(c), 404.1520, 404.1520a, 404.1545, 404.1546, 404.1560, 404.1561, 404.1562, 404.1563 through 404.1567, 404.1569, 404.1569a; appendix 1 of subpart P, section 12.00; appendix 2 of subpart P, sections 200.00 and 201.00; Regulations No. 16, sections 416.913(c), 416.920, 416.920a, 416.945, 416.946, 416.960, 416.961, 416.962, 416.963 through 416.967, 416.969 and 416.969a."
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Post by funkyodar on Oct 28, 2014 8:06:07 GMT -5
Exactomondo
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