DI 28015: Relating Medical Improvement to the Ability to Work - Title II and Adult Title XVI Beneficiaries
TN 3 (07-15)
Except as noted below, follow the usual procedures for completing RFC forms, including Form SSA-4734-F4- SUP in cases involving a mental impairment(s), see DI 24510.001. Enter a remark on each form to indicate the type of assessment reflected.
A. Current RFC with no new impairment(s) since comparison point decision (CPD)
Prepare one RFC assessment and enter the following remark, “This form shows RFC as of (enter current date), considering all impairments. Evidence does not show any new impairment(s) since the decision dated (enter date of CPD).”
B. Current RFC with new impairment(s) since CPD
1. Forms preparation
Prepare two RFC forms, one for the CPD impairments and the second for the new impairments.
2. Consider prior impairments only - for medical improvement review standard (MIRS) RFC
On the form showing current RFC considering only the prior impairment(s) (the “MIRS RFC”), include the remark, “This form shows RFC as of (enter current date), considering only the impairment(s) present as of (enter date of the CPD).”
3. Consider all impairments - for current RFC
On the form showing current RFC considering all impairments, include the remark, “This form shows RFC as of (enter current date), considering all impairments.”
4. Related procedure - for current RFC
Assume that a limitation results from impairment present at the time of CPD, if there is no medical basis for deciding whether a limitation comes from a prior impairment. For further instructions on assuming the limitations, see DI 28015.300C.1.b.
C. Procedure for CPD RFC
For limitations on when to do an RFC assessment, see DI 28015.315.
When needed, this type of RFC assessment may be either:
noted administratively in the file; or
recorded on an RFC form to take into account the beneficiary’s particular limitations (at the assigned level of RFC).
When using a form for this purpose, include the remark: “This form shows RFC as of the decision dated (enter date of CPD), considering all impairments present at that time. This form shows maximum capacity consistent with that decision, but not necessarily an independent assessment.”