Residual Functional Capacity Assessment for Hearing Impairments
What Is Residual Functional Capacity (RFC)?
If your hearing impairment is not severe enough to meet or equal a listing at Step 3 of the Sequential Evaluation Process, the Social Security Administration will need to determine your residual functional capacity (RFC) to decide whether you are disabled at Step 4 and Step 5 of the Sequential Evaluation Process.
RFC is a claimant’s ability to perform work-related activities. In other words, it is what you can still do despite your limitations. An RFC for physical impairments is expressed in terms of whether the Social Security Administration believes you can do heavy, medium, light, or sedentary work in spite of your impairments. The lower your RFC, the less the Social Security Administration believes you can do.
Hearing Impairment and Residual Functional Capacity
Although profound deafness in one ear and good hearing in the other is considered to be a “not severe” impairment, most claimants have bilateral sensorineural hearing loss, especially as a result of a lifetime of exposure to loud sounds without adequate hearing protection. If you have good speech discrimination and a better ear pure tone average (PTA) of 40 dB or less, the Social Security Administration will generally find that your hearing impairment is “not severe.”
However, there is no definite medical policy regarding what pure tone average threshold with good discrimination the Social Security Administration would consider “not severe.” Despite the lack of policy, the Social Security Administration would be on medically questionable grounds with a finding that a pure tone average of 50 dB or more in the better ear is “not severe.” Also, speech discrimination of less than 75% should be considered a significant and work-related impairment, although there is no regulatory basis for this position.
Generally, the following values can be used as guidelines for speech discrimination scores:
- 100 – 90% – excellent – normal discrimination
- 89 – 75% – good – slight difficulty sometimes, such as on telephone
- 74 – 60% – fair – moderate difficulty most of the time
- 59 – 40% – poor – difficulty in following conversation
- < 40% – very poor – severe difficulty in conversation most of the time
These discrimination guidelines are not formal Social Security Administration policy because there is no such policy. Also, terms like “mild” or “good” are necessarily arbitrary to some extent, and therefore vary a little in the medical literature. Informed medical and vocational judgment is required for evaluating these claims.
The Residual Functional Capacity may contain some general statement expressing limitation in ability to hear. However, the person establishing the medical (Residual Functional Capacity) part of the determination should communicate clearly to the adjudicator about the vocational determination regarding the functional severity of the hearing deficit. There is a big difference functionally between a person who has a better ear at a 50 dB average hearing threshold with 80% discrimination, and one who has a better ear average hearing loss of 70 dB with a discrimination score of 45%. The former will have minimal functional loss, while the latter cannot do work requiring any significant verbal communication in regard to either speaking or hearing. Social Security Administration vocational analysts generally have little difficulty in citing jobs for hearing-impaired claimants, but one important fact may be overlooked by the Social Security Administration: when a person has near-total deafness, he or she cannot hear verbal warnings and the sounds of dangerous machinery. Therefore, there should be limitations in working around hazardous machinery when hearing impairment could pose a risk to oneself or co-workers.
Another issue is fluctuating hearing loss, as may occur with Meniere’s disease. You might argue that work-related limitations should be based on the worst hearing test results documented in your file. However, there is no Social Security Administration medical policy supporting this position.