PURPOSE: To clarify the manner in which the medical-vocational rules in Appendix 2 of Subpart P, Regulations No. 4, address the issue of capability to do other work, and to provide definitions of terms and concepts frequently used in evaluating disability under the medical-vocational rules.
CITATIONS (AUTHORITY): Sections 223(d)(2)(A) and 1614(a)(3)(B) of the Social Security Act; Regulations No. 4, Subpart P, sections 404.1505(a), 404.1520(f)(1), 404.1545, 404.1560-404.1561, 404.1563-404.1569, and Appendix 2; and Regulations no. 16, Subpart I, sections 416.905(a), 416.920(f)(1), 416.945, 416..960-416.961, and 416.- 963-416.969.
PERTINENT HISTORY: Under the sequential evaluation process for evaluating disability, if it is determined that an individual is not engaging in substantial gainful activity (SGA) and has one more severe medically determinable impairments which do not meet or equal the Listing of Impairments but prevent him or her from performing past relevant work, evaluation of the individual's capability to do other work becomes necessary (see SSR 82-56, PPS-81, The Sequential Evaluation Process). In this, the fifth and last step in the process, the individual's residual functional capacity (RFC) in conjunction with his or her age, education, and work experience, are considered to determine whether the individual can engage in any other substantial gainful work which exists in the national economy. (See the glossary at the end of the policy statement for definitions of terms and concepts commonly used in medical-vocational evaluation -- e.g., RFC.)
To increase the consistency and promote the uniformity with which disability determinations are made at this step at all levels of adjudication, the regulations for determining disability were expanded in February 1979. Appendix 2 was provided to establish specific numbered table rules for use in medical-vocational evaluation.
Each numbered rule in the appendix resolves the issue of capability to do other work by addressing specific combinations of the factors(i.e., RFC, age, education, and work experience) that determine capability to do work other than that previously performed. The criteria for each factor contained within a rule are defined in the regulations. Resolution of the issue of capability to do other work is indicated in the "Decision" column (i.e., "Disabled" or "Not disabled") for the particular rule.
In using the rules of Appendix 2, we compare an individual's circumstances, as indicated by the findings with respect to RFC, age, education, and work experience, to the pertinent rule(s). Where the findings regarding each factor coincide with the criteria for the corresponding factor in a rule, that rule applies and directs a decision of "Disabled" or "Not disabled." Where one or more of the criteria of a rule are not met, no decision is directed; instead, the rules are used, in conjunction with the definitions and discussions in the text of the regulations, as guidance for decisionmaking.
Specific questions have arisen as to how we determine that the criteria of a rule are met and, where the criteria are not met, how we use the rules as a framework for decisionmaking. This Program Policy Statement (PPS) reviews and clarifies considerations underlying the rules to provide the necessary foundation for other PPS's that address issues about using the rules to adjudicate claims. (See the cross-reference section at the end of the PPS).
POLICY STATEMENT: In making disability determinations and decisions at the last step of the sequential evaluation process, emphasis continues to be given to medical considerations. The rules of Appendix 2 assure that appropriate weight is afforded to the severity of the impairment within the context of medical-vocational evaluation to determine capability to do other work. For that purpose, RFC (i.e., what work-related activities an individual can do despite the impairment(s)) is used to determine the maximum sustained capability for work. RFC is considered a factor affecting ability to adjust to work other than that previously performed. Capability to do other work is determined by considering the interaction of RFC with the other factors affecting vocational adaptability, i.e., age, education, and work experience. Education and work experience may also reflect acquired skills that can be used in skilled or semiskilled work other than that previously performed.
Work Capability as Established by RFC Alone
-- the Occupational Base
In Appendix 2, work in the national economy is classified exertionally as sedentary, light, medium, heavy or very heavy. (Although the tables containing the specific numbered rules, i.e., Tables No. 1, 2, and 3, are limited to the sedentary, light, and medium levels of work, respectively, there is a specific rule pertaining to heavy and very heavy work, rule 204.00.) Each functional level is defined (in accordance with terms used by the United States Department of Labor) by the extent of its requirements in the primary strength activities of sitting, standing, walking, lifting, carrying, pushing, and pulling.
The rules of Appendix 2 use exertional capabilities (i.e., those required to perform the primary strength activities) to identify maximum sustained work capability. Under each rule, the capability considered is limited to that necessary to perform sustained work on a regular basis at the particular level of exertion.
The rules within a table are based on the same RFC. In each rule, the remaining exertional capabilities must be sufficient to allow performance of substantially all (nearly all) of the primary strength activities defining the particular level of exertion (i.e., sedentary, light, or medium). Also, the combined exertional capabilities do not allow performance of exertional levels beyond that in question.
Accordingly, the RFC determines a work capability that is exertionally sufficient to allow performance of at least substantially all of the activities of work at a particular level (e.g., sedentary, light, or medium), but is also insufficient to allow substantial performance of work at greater exertional levels. Sedentary exertional demands are less than light, which are, in turn, less than medium. In addition, RFC generally represents an exertional work capability for all work at any functional level(s) below that used in the table under consideration.
The exertional requirements of work at a particular functional level are the same regardless of whether the work is skilled, semi-skilled, or unskilled. Therefore, RFC alone never establishes the capability for skilled or semiskilled work. Ability to perform skilled or semiskilled work depends on the presence of acquired skills which may be transferred to such work from past job experience above the unskilled level or the presence of recently completed education which allows for direct entry into skilled or semiskilled work. However, as noted in SSR 82-41, PPS-67, Work Skills and Their Transferability as Intended by the Expanded Vocational Factors Regulations Effective February 26, 1979, a person's RFC may prevent the transferability of skills.
Unskilled work may be performed by individuals with no work skills or no work experience. However, as shown in the table rules, individuals may not be expected to make a vocational adjustment to unskilled work in certain circumstances. A final requirement in determining an occupational base under the rules within a table is that the RFC reflects no impairment-caused limitation affecting performance of other then exertional activities, i.e., no nonexertional limitation. Thus, the only impairment-caused limitations considered in each rule are exertional limitations. Accordingly, the RFC considered under each rule reflects the presence of nonexertional capabilities sufficient to perform unskilled work at the pertinent exertional levels.
The RFC addressed in a rule establishes the presence of an occupational base that is limited to and includes a full range (all or substantially all) of the unskilled occupations existing at the exertional level in question. The base established by the RFC also ordinarily includes all those occupations at any lower exertional level(s).
When the medical-vocational rules were promulgated, administrative notice was taken of the fact that it was possible to identify at the unskilled level, approximately 200 sedentary occupations; approximately 1,600 sedentary and light occupations; and approximately 2,500 sedentary, light and medium occupations, each representing numerous jobs in the national economy. (By "administration notice" we mean our recognition that various authoritative publications identify occupations which exist in the national economy; these sources are listed in sections 404.1566 and 416.966 of the regulations.) Thus, as related to RFC, the occupational base considered in each rule consists of those unskilled occupations identified at the exertional level in question. (The base may be enhanced by the addition of specific skilled or semiskilled occupations that an individual can perform by reason of his or her education or work experience.
The Issue of Work Adjustment
In the situations considered in the numbered table rules (those indicating decisions of "Disabled" as well as "Not disabled"), an individual has the RFC to perform a full range of the unskilled occupations relevant to the table. Each of these occupations represents numerous jobs in the national economy. However, the individual may not be able to adjust to those jobs because of adverse vocational factors.
The issue of whether a work adjustment is possible involves a determination as to whether the jobs whose requirements can be met provide an opportunity for adjusting to substantial and gainful work other than that previously performed. Accordingly, the issue of work adjustment is determined based on the interaction of the work capability represented by RFC (the remaining occupational base) with the other factors affecting capability for adjustment -- age, education, and work experience.
Each numbered rule in Appendix 2 includes an administrative evaluation which determines whether a work adjustment should be possible. In each instance, the issue is decided based on the interaction between the person's occupational base as determined by RFC with his or her age, education, and work experience.
The ultimate question in the medical-vocational evaluation of the capability to do other work is whether work that an individual can do functionally and vocationally exists in the national economy. Whether work exists in the national economy for any particular individual depends on whether there is a significant number of jobs (in one or more occupations) with requirements that the individual is able to meet, considering his or her remaining physical and mental abilities and vocational qualifications.
The occupational base that is determined to be available based on RFC alone consists of a full range of occupations, each of which represents numerous jobs in the national economy. Where a rule indicates that a work adjustment is expected, a reasonable opportunity exists for adjusting to work other than that previously performed. (Rules which include the transferability of a person's work skills to skilled or semiskilled occupations within his or her RFC (or use of recent education for direct entry into such work) impose specific skilled or semiskilled occupations upon the unskilled occupational base.) Conversely, where the rules determine that a work adjustment is not expected, no reasonable opportunity exists for adjusting to substantial work. Thus, where the criteria of a rule are met, the issue as to the existence of work in the national economy for that individual is resolved. While there is no requirement to cite unskilled occupations where the criteria of a rule are met, specific examples of skilled or semiskilled occupations will be cited where a rule determines that a work adjustment above the unskilled level is expected.
The definitions of terms and related concepts provided in this glossary are to be used when an individual's capability to do other work is determined under the provisions of Appendix 2 of the regulations. The definitions are based on the regulations, the vocational reference material noted in section 200.00(b) of Appendix 2, and the adjudicative experience of the Social Security Administration.
Broad World of Work. Work which exists at all exertional levels. It may include skilled and semiskilled work as well as unskilled work.
Environmental Conditions. Extremes of temperature, humidity, noise, vibration, fumes, odors, toxic conditions, dust, poor ventilation, hazards, etc.
Exertional Activity. One of the primary strength activities (sitting, standing, walking, lifting, carrying, pushing, and pulling) defining a level of work.
Exertional Capability. A capability required to perform an exertional activity.
Exertional Limitation. An impairment-caused limitation which affects capability to perform an exertional activity.
Exertional Level (Level of Exertion) A work classification defining the functional requirements of work in terms of the range of the primary strength activities required. The primary strength activities specifically associated with the sedentary, light, and medium levels of exertion are set forth in sections 404.1567 and 416.967 of the regulations.
The following elaborations of the activities needed to carry out the requirements of sedentary, light, and medium work are based on the same resource materials noted in section 200.00(b) of Appendix 2. They may be used by decisionmakers to determine if an individual has the ability to perform the full range of sedentary, light, or medium work from an exertional standpoint.
Full Range of Work. All or substantially all occupations existing at an exertional level.
> Limited to. Does not exceed.
Maximum Sustained Work Capability. The highest functional level a person can perform on a regular work basis -- sedentary, light, medium, heavy, or very heavy work.
Nonexertional Impairment. Any impairment which does not directly affect the ability to sit, stand, walk, lift, carry, push, or pull. This includes impairments which affect the mind, vision, hearing, speech, and use of the body to climb, balance, stoop, kneel, crouch, crawl, reach, handle, and use of the fingers for fine activities.
Nonexertional Limitation. An impairment-caused limitation of function which directly affects capability to perform work activities other than the primary strength activities.
Nonexertional Restriction (Environmental Restriction). An impairment-caused need to avoid one or more environmental conditions in a workplace.
Occupational Base. The number of occupations as represented by RFC, that an individual is capable of performing. These "base" occupations are unskilled in terms of complexity. The regulations take notice of approximately 2,500 medium. light, and sedentary occupations; 1,600 light and sedentary occupations; and 200 sedentary occupations. Each occupation represents numerous jobs in the national economy. (In individual situations, specific skilled or semi-skilled occupations may be added to the base.)
Range of Work. Occupations existing at an exertional level.
Residual Functional Capacity. A medical assessment of what an individual can do in a work setting in spite of the functional limitations and environmental restrictions imposed by all of his or her medically determinable impairment(s). RFC is the maximum degree to which the individual retains the capacity for sustained performance of the physical-mental requirements of jobs.
Skilled Level. A work classification whereby work is defined according to skill requirements. The requirements of the different skill levels are set forth in section 404.1568 and 416.968 of the regulations as follows:
Substantially All Activities. Nearly all (essentially all) of the activities required in an exertional range of work.
Vocational Factors: An Individual's Age, Education, and Work Experience
EFFECTIVE DATE: Final regulations providing the Medical-Vocational Guidelines were published in the Federal Register on November 28, 1978, at 43 FR 55349, effective February 26, 1979. They were rewritten to make them easier to understand and were published on August 20, 1980, at 45 FR 55566. The policies in this PPS are also effective as of February 26, 1979.
CROSS-REFERENCES: Program Operations Manual System, Part 4 (Disability Insurance State Manual Procedures), sections DI 2380E, 2382.1, 2382.2, 2384, and 2388A through E; SSR 83-11, PPS-102, Capability to Do Other Work -- The Exertionally Based Medical-Vocational Rules Met; SSR 83-12, PPS-103, Capability to Do Other Work -- The Medical-Vocational Rules as a Framework for Evaluating Exertional Limitation Within a Range of Work or Between Ranges of Work; SSR 83-13, PPS-104, Capability to Do Other Work -- The Medical-Vocational Rules as a Framework for Evaluating Solely Nonexertional Impairments; and SSR 83-14, PPS-105, Capability to Do Other Work -- The Medical-Vocational Rules as Framework for Evaluating a Combination of Exertional and Nonexertional Impairments.
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