Residual Functional Capacity Assessment for Multiple Sclerosis
What Is RFC?
If your multiple sclerosis 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.
Limitations on Lifting and Walking
When assessing your RFC, the Social Security Administration should consider the weight that you are able to lift and carry. To be able to do medium work, which requires you to lift and carry up to 50 lbs and stand and walk 6 to 8 hours daily, you should have no more than very modest deficits in strength, coordination, and balance.
If you have some difficulty in walking on your heels and toes, or squatting and arising, during medical examination, you might still be able to do light work (lifting no more than 20 lbs and still standing and walking 6 to 8 hours daily). But you probably would not realistically be able to do even light work if you cannot walk on your heels and toes while carrying no weight during a physical.
In evaluating upper extremity function, the Social Security Administration should consider whether you have insufficient strength to operate arm or leg controls more than occasionally in the affected limbs.
Of course, all factors have to be considered: whether your muscles appear weak and limp on exam or spastic (in spasm), whether you are overweight etc. Thus, your RFC could be reduced to sedentary work requiring no more than 2 hours standing and walking daily. If you also have significant upper extremity dysfunction, you would be disabled under a listing.
If both your legs are impaired, and your upper extremities are functionally intact, the impairment will meet Listing 11.09A and you will be disabled if your gait and station are impaired to a significant degree—that is, if you cannot stand and walk 6 to 8 hours daily, and you have a problem standing because of balance sufficient for sedentary work. If gait and station are fully functional for sedentary work, except for enough stamina or strength to stand and walk for more prolonged periods, and your upper extremity function is fully intact, then you are capable of a sedentary work RFC.
Limitations on Activities of Daily Living
You—or family members—should be asked in detail about your ability to carry out activities of daily living (ADL). Of particular interest is your ability to walk up and down steps, the speed at which you walk, and how easily you tire. If you cannot walk a block, you certainly cannot stand and walk 6 to 8 hours daily. You should also be asked what tasks you could do before your stroke that you cannot do now. Can you dress without assistance? Manipulative functions are important. Can you turn a doorknob? Can you pick up coins and button shirts?
High-quality description of your ADLs is very important.
Other Issues Relevant to the Listings and RFC
Certain important issues should also be kept in mind regarding meeting or equaling the listing, or determination of RFC:
- The Social Security adjudicator is likely to under-rate allegations of fatigue.
- The Social Security adjudicator may fail to develop your claim for a mental impairment, unless you specifically mention in your application for social security disability benefits that you are depressed. Because of the frequent presence of depression in MS, failure to ask the claimant specifically about depression or other mental problems is a mistake.
- The Social Security adjudicator may not be aware that exertion can increase the severity of MS signs and symptoms, quite apart from the issue of fatigue.
- The Social Security adjudicator is very likely to be unaware that hot environments, or getting hot from overexertion, can precipitate a worsening of signs and symptoms in MS. Consequently, appropriate environmental restrictions, such as avoiding work at temperatures over 75° F, are not given.
- The Social Security adjudicator may not appreciate the overall severity of a combination of impairments that should result in a finding of equivalent severity to the listing.
- The Social Security adjudicator is likely to not adequately appreciate the debilitating effect of severe bowel or bladder incontinence.