The Social Security Administration (SSA) maintains a Blue Book of disabilities. This includes a number of mental conditions and psychological disorders. If you do not meet the criteria for a Blue Book listing, you may need a mental residual functional capacity (RFC) assessment. You will need to include this form in your Social Security Disability Insurance (SSDI) claim. If you have any questions about RFC assessments, reach out to our team at Keefe Disability Law at any time.
What Is a Mental RFC Assessment?
One of the SSA’s tools for deciding whether or not to approve an SSDI application is a RFC. It evaluates an applicant’s ability to work given their symptoms. A mental RFC looks specifically at a person’s mental state and ability. It asks a simple question. Given their symptoms, are they able to maintain a full-time job?
This is essentially the same as a standard residual functional capacity assessment. The difference is it focuses on mental function. It looks at what restrictions or limitations a person may have given their medical condition. Based on this rating, the SSA can determine what work, if any, the applicant may be capable of doing.
A mental RFC becomes relevant if an applicant has been diagnosed with a mental condition but does not meet the criteria of a Blue Book listing. At that point, the SSA may request a mental RFC. The applicant may also choose to submit a mental RFC with their initial claim. This is Form SSA-4734-F4-SUP, typically completed by a psychologist or psychiatrist.
How Does It Differ From a Physical RFC?
A physical RFC assesses a person’s physical ability to work. It assesses exertion levels, non-exertional limits, and other work characteristics. With a physical RFC, the SSA refers to Grid Rule Tables to determine SSDI eligibility. A person over the age of 49 who is deemed limited to sedentary work automatically qualifies for disability benefits. It factors for age, education, and past work experience.
By contrast, a mental RFC does not have a corresponding grid. Instead, it includes doing a function-by-function analysis of what the applicant can and cannot do. There are no set rules with a mental RFC for deciding if the SSA approves someone for benefits. The more severe your symptoms, the more likely the SSA will approve your application.
What Does a Mental RFC Involve?
If you do not meet the criteria for a single listing in the Blue Book, you may still qualify for disability benefits. When filling out a mental RFC, describing all your symptoms and mental conditions can bolster your case. Your depression symptoms may not qualify on their own, but the compounded impact of PTSD or anxiety might. The assessment looks at your ability to perform daily tasks and work functions.
Completing a mental RFC usually involves meeting with a psychologist or psychiatrist. They do a line-by-line rating of your mental abilities. This rating describes if you can continue in your previous line of work. It also considers if you can pivot to different jobs, given the limitations of your condition.
Sometimes, the administrative law judge (ALJ) at your disability hearing may ask a medical expert to evaluate your RFC instead. This expert may or may not be a psychologist or psychiatrist, necessarily. It may be your family doctor. A supportive mental RFC can be vital to winning an SSDI appeal.
A mental RFC involves Form SSA-4734-F4-SUP. A psychologist or psychiatrist most commonly completes this form. While the applicant’s doctor may fill it out too, a report from a mental health specialist can carry more weight with the SSA. Form SSA-4734-F4-SUP starts with the Heading for the claimant and claim identification data.
Section I is Summary Conclusions. In it, the medical or psychological consultant (MC/PC) offers their analysis and conclusions about functional limitations. They also assess the adequacy of documentation to support these conclusions.
Section I lists 20 mental function areas across four core areas: understanding and memory, sustained concentration and persistence, social interaction, and adaptation. For each of these, the MC/PC can describe the applicant as:
- Not significantly limited
- Moderately limited
- Markedly limited
- No evidence of limitation in this category
- Not ratable on available evidence
Understanding and Memory
This category refers to someone’s ability to understand, remember, and carry out complex instructions. You may need to remember how to use certain equipment. A job may also require you to learn specific terms or solve certain problems. An applicant should be able to explain a work procedure to a colleague.
Sustained Concentration and Persistence
This category refers to someone’s ability to maintain attention and concentration for an extended period of time. You need to be able to focus on the task and hand and see it through to completion. Part of this evaluation involves looking at how well you are able to ignore distractions. It also means consistently showing up to work on time.
This category refers to someone’s ability to interact with other people. This includes interactions with customers, as well as coworkers and supervisors. Your condition may limit your social functioning. Examples include handling conflicts, accepting feedback, or understanding social cues. A mental RFC will take this into account.
Adaptation and Self-Management
This fourth category refers to a person's ability to manage themselves and adapt to situations. It asks whether you are able to maintain a routine without supervision. Are you able to make simple decisions, respond to work-setting changes, and tolerate normal stress levels? Some psychological conditions undermine a person’s ability to maintain a calm mental state through periods of stress or uncertainty. Personal hygiene falls under this category, too.
Remarks (Section II)
Section II is for the MC/PC’s remarks on Section I items. In particular, they discuss what evidence is needed to support their ratings.
Functional Capacity Assessment and Signature
Finally, Section III is for the Functional Capacity Assessment and MC/PC signature. This is where the consultant offers their mental RFC conclusion. They explain how they came to that conclusion. They also talk about the extent to which these limitations would prevent the applicant from being effective in a work setting. Severity can be described as none, mild, moderate, marked, or extreme. The discussion is in narrative format, presenting a complete picture of the mental RFC. It cannot offer speculation in areas that lack sufficient evidence.
Qualifying for SSDI With a Mental RFC Assessment
You may not qualify for SSDI benefits based on Blue Book listing criteria. But, the complete picture offered by a thorough mental RFC assessment can tip the scales in your favor. The SSA looks at your supporting medical documentation. It looks at how the totality of your symptoms contributes to your inability to work.
The assessment points toward whether you can perform simple, detailed, or complex work. This is the skill level. If your mental RFC prevents you from working, you may qualify for disability benefits. Your RFC can also rule out jobs that may aggravate your symptoms. For example, if you have debilitating social anxiety, the mental RFC would recommend against jobs in the service industry.
A complete mental RFC report details how your condition impacts your daily life and ability to work. It can significantly boost your chances of SSDI approval.
How to Prepare for Your Assessment
Navigating the complexity of SSDI applications with the SSA can be daunting. You may need a mental residual functional capacity assessment to support your claim. To guide you through this process, turn to the experienced team at Keefe Disability Law. John Keefe and I have helped many clients get the disability benefits they need and deserve.
It is important that your mental RFC is detailed and accurately reflects your limitations. Our skilled SSDI attorneys have RFC forms ready to send to your doctor. If you do not already have a psychologist or psychiatrist who can help you, we can gladly connect you with a medical expert to fill out a mental RFC form. Gathering this vital evidence is critical to a successful SSDI claim.