How Social Security Uses Mental RFC Forms to Decide Disability Cases

One of the most important factors in the disability determination process involves assessing your residual functional capacity, or “RFC.” Your RFC is a set of restrictions on the kinds of job tasks you can perform. If you’re applying for benefits due to a mental health condition, Social Security will assess your mental restrictions and mark down your limitations in a mental RFC evaluation form. 

A typical mental RFC form is several pages long and contains questions about how well you’re able to do work-related tasks. The form will usually ask a question and then provide a range of options for a doctor to choose from that best describes their opinion on your mental limitations. These questions are often divided into several broad categories known as “functional domains.” Understanding and memory, concentration and persistence, social interaction, and adaptation are examples of mental functional domains. 

Mental RFC forms are often completed by doctors who work with Social Security to determine disability claims, but you can (and probably should) ask your own doctors to fill one out and submit it along with your medical records. Below is a partial sample of what a blank mental RFC form that you give your doctor might look like, specifically the section on functional limitations:

Please evaluate the patient’s functioning in the associated areas by marking the word that best describes the degree of limitation.

• The ability to remember and carry out simple instructions.
  ___None     ___Mild     ___Moderate      ___Marked      ___Extreme
• The ability to maintain concentration, persistence, and pace for extended periods.
  ___None     ___Mild     ___Moderate      ___Marked      ___Extreme
• The ability to interact appropriately with the general public.
  ___None     ___Mild     ___Moderate      ___Marked      ___Extreme
• The ability to tolerate normal levels of stress. 
  ___None     ___Mild     ___Moderate      ___Marked      ___Extreme

These four questions don’t comprise the entirety of the mental RFC assessment, but they’re representative of the types of questions asked on the form. The possible answers range from “none” to “extreme” in order to reflect Social Security’s own language when evaluating the degree to which you’re limited in these mental domains. The agency defines these terms as follows: 

• “None” means that the doctor thinks that your ability to function independently in that area on a sustained basis isn’t limited. 
• “Mild” means that the doctor thinks you have slight limitations in that area but are otherwise able to function independently on a sustained basis.
• “Moderate” means that you have a “fair” ability to function independently in this area. 
• “Marked” means that you have significant difficulty independently completing tasks in this functional domain. 
• “Extreme” means that you can rarely, if ever, sustain independent functioning in that area.

The more severe your mental health symptoms are, the more likely your limitations will be considered marked or extreme (and therefore more likely to be disabling). Here’s how: 

• Moderate limitations can be tricky to evaluate because they’re right in the middle of the functional range, which could leave disability adjudicators on the fence about your case.
• Marked limitations in multiple areas can be useful in eliminating jobs involving those mental tasks and, in some cases, can be enough to qualify you automatically for benefits under a disability listing.
• Extreme limitations are more severe than marked. Depending on the functional domain, even having just one extreme limitation in your mental RFC may be enough to meet a listing or rule out all full-time work.

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Meeting a listing or having an RFC that is “incompatible with competitive employment” are the two main methods by which people qualify for disability benefits. The restrictions in your mental RFC will help Social Security decide whether you can do any jobs or meet a listing. Somebody with an extreme limitation in tolerating normal workplace stresses due to PTSD may meet the requirements of listing 12.15 for trauma-related disorders, for example. Another person who struggles to  finish their work on time because they have ADHD and are easily distracted may exceed employer tolerances for “off-task” behavior. 

Having your treating doctor or therapist complete a favorable mental RFC form can greatly strengthen your disability case. Social Security values the opinions of psychiatrists and psychologists who’ve seen you regularly and can provide special insight into your mental health. So, for example, if a consulting doctor for the agency says that you only have mild mental health limitations but you provide an RFC form from a psychiatrist you’ve seen for years saying that you have marked to extreme limitations in the same functional areas, Social Security is likely to think that your regular doctor’s opinion is more representative of your limitations.

For your doctor’s RFC form to be persuasive, they must be aware of the extent of your limitations, and the RFC form must be an accurate representation of what they know. You may want to schedule an appointment to discuss these limitations with your doctor, but the completed form should reflect their opinion and only their opinion. Don’t expect to fill out the form yourself and get your doctor to sign—Social Security can tell when a doctor is just rubber-stamping a patient’s opinion.

It also helps to have your doctor address any “weak spots” in your application, like evidence of medication mismanagement or substance abuse. Don’t give up if you’ve submitted a favorable mental RFC from your doctor and still received a denial, however. Few people are approved at first, and you’ll have better luck discussing the RFC with an administrative law judge at a disability hearing.