TN 4 (05-23)
A.How do we evaluate medically determinable mental impairments at steps 2 and 3 of the sequential evaluation process?
We use a special technique called the PRT when evaluating mental impairments in adults under Part A of the Listing of Impairments. Using the PRT helps us:
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Identify the need for additional evidence to determine impairment severity;
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Consider and evaluate functional limitations of the mental disorder(s) relevant to the ability to work; and
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Organize and present findings in a clear, concise, and consistent manner.
We use the PRT at steps 2 and 3 of the sequential evaluation process to determine whether a medically determinable mental impairment(s) is severe and, if so, whether the mental impairment(s) meets or medically equals a listed impairment. The PRT is used at all levels of the administrative review process.
NOTE: Do not use the PRT to evaluate mental disorders in children under Part B of the Listing of Impairments. The PRT is used to evaluate mental disorders for persons under age 18 when using Part A of the Listing of Impairments.
We use the PRT by following these steps:
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First, determine whether the person has a medically determinable mental impairment(s) (see DI 24583.005C);
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Second, rate the degree of functional limitation resulting from the mental impairment(s) (see DI 24583.005D);
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Third, determine the severity of the mental impairment(s) (see DI 24583.005E);
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Fourth, determine whether the mental impairment(s) meet or medically equals a listed impairment (see DI 24583.005F); and
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Fifth, document the application of the PRT (see DI 24583.005G).
We evaluate the pertinent symptoms, signs, and laboratory findings to determine whether the person has a medically determinable mental impairment. We must specify the symptoms, signs, and laboratory findings that substantiate the presence of the impairment(s) on a standard document. For more information about the standard document, see DI 24583.005G. For more information about establishing medically determinable impairments generally, see DI 24501.020.
Assessment of functional limitations is a complex and highly individualized process that requires consideration of multiple issues and all relevant evidence to obtain a longitudinal picture of the person's overall degree of functional limitation. We consider all relevant and available clinical signs and laboratory findings, the effects of symptoms, and how functioning may be affected by factors including, but not limited to, chronic mental disorders, structured settings, medication, and other treatment.
We rate the degree of functional limitation based on the extent to which the impairment(s) interferes with the person's ability to function independently, appropriately, effectively, and on a sustained basis in a work setting. We consider such factors as the quality and level of overall functional performance, any episodic limitations, the amount of supervision or assistance required, and the settings in which the person is able to function. For more information about the evidence and factors to consider when rating the degree of functional limitation, see DI 34001.032 (12.00C through F of the adult mental disorders listings).
We rate the degree of functional limitation in four broad areas of mental functioning:
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Understand, remember, or apply information;
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Interact with others;
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Concentrate, persist, or maintain pace; and
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Adapt or manage oneself.
These four areas of mental functioning are commonly referred to as the “paragraph B criteria.” For a description of the paragraph B criteria, see DI 34001.032 (12.00E of the adult mental disorders listings).
We rate the degree of limitation in the paragraph B criteria using the following five-point scale: none, mild, moderate, marked, and extreme. The rating of extreme on the scale represents a degree of limitation that is incompatible with the ability to do any gainful activity. For more information about how to use the paragraph B criteria to evaluate mental disorders, see DI 34001.032 (12.00F of the adult mental disorders listings).
After rating the degree of functional limitation resulting from the impairment(s), we determine the severity of the mental impairment(s). If the degree of limitation in the areas of mental functioning are “none” or “mild,” we generally conclude that the impairment(s) is not severe, unless the evidence otherwise indicates that there is more than a minimal limitation in the ability to do basic work activities. For example, in some cases with multiple “mild” ratings, we may still find there is a severe impairment. For more information about the rating scale, see DI 34001.032 (12.00F of the adult mental disorders listings).
F.How do we determine whether the mental impairment(s) meets or medically equals a listed impairment?
If the mental impairment(s) is severe, we next determine whether it meets or medically equals a listed mental disorder. We compare the medical evidence of record about the mental impairment(s) and the rating of the degree of functional limitation with the criteria of the appropriate listed mental disorder. For the adult mental disorders listings, see DI 34001.032. For more information on determining medical equivalence for mental impairments, see DI 24583.010.
If we find that the mental impairment(s) neither meets nor medically equals a listed impairment, we then assess the person’s mental residual functional capacity (MRFC) and proceed to steps 4 and 5 of the sequential evaluation process. For more information about the MRFC, see DI 24510.060.
We document the application of the PRT by recording the presence or absence of the listing criteria and the rating of the degree of functional limitation on a standard document. A PRT rationale should provide a description of the symptoms, signs, and laboratory findings substantiating the mental impairment, including, but not limited to, mental status examination findings, a summary of the longitudinal history of the disorder, and an assessment of the consistency of the evidence of record.
NOTE: When determining medical equivalence, the rationale may require additional information. For more information about medical equivalence, see DI 24508.010 and DI 24583.010.
At the initial and reconsideration levels of the administrative review process, the standard document is the Psychiatric Review Technique Form (PRTF) or an approved electronic equivalent such as the Disability Case Processing System (DCPS) or the Electronic Claims Analysis Tool (eCAT).
The medical or psychological consultant (MC or PC) has overall responsibility for assessing medical severity. The disability examiner may assist in preparing the PRTF. However, the MC or PC must review and sign the document to attest that it is complete and that they are responsible for its content, including the findings of fact and any discussion of supporting evidence.
For determinations that are less than fully favorable, the Disability Determination Services (DDS) must make every reasonable effort to have the medical portion of the case review conducted by a psychological consultant (a psychiatrist or psychologist). If the signed PRTF reflects that the MC or PC’s findings complete the medical portion of the determination, the MC or PC is not required to sign the SSA-831 (Disability Determination and Transmittal).
In reconsideration determinations, a different MC or PC (other than the MC or PC who signed the PRTF for the initial determination) may adopt the initial level PRTF without completing a new PRTF if the evidence does not warrant change in the initial determination in any way. Enter the following statement in Section IV (Consultant’s Notes) of the initial level PRTF: “I have reviewed all the evidence in file, and the PRTF of (date) is affirmed, as written.” This statement must be signed, dated, and annotated with the specialty code by the MC or PC.
IMPORTANT: For EDCS reconsideration cases where the initial level PRTF can be adopted, complete an SSA-416 with the following statement: "I have reviewed all the evidence in file, and the PRTF prepared by (MC or PC) on (date) is affirmed, as written."
At the hearing level and the AC level where the AC issues a decision, we document application of the PRT in the written decision. The written decision must:
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Incorporate the pertinent findings and conclusions based on the PRT;
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Show the significant history, including examination and laboratory findings, and the functional limitations that were considered in reaching a conclusion about the severity of the mental impairment(s); and
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Include a specific finding as to the degree of limitation in each of the areas of mental functioning.
The PRT is used when a disability hearing officer makes a reconsideration determination during the CDR evaluation process to assess the severity of mental impairments and, where applicable, to determine whether the mental impairment meets or medically equals one of the adult mental disorders listings. For more information about the use of the PRT in CDRs, see DI 28010.140. For more information about the Medical Improvement Review Standard (MIRS) and mental impairments, see DI 28010.135. For more information about advisory PRTs, see DI 29025.001.
When a disability hearing officer makes a reconsideration determination, the determination must document the application of the PRT, incorporating the disability hearing officer’s pertinent findings and conclusions based on the PRT. For more information about disability hearing officer decisions, see DI 33015.020.
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DI 24501.020 Establishing a Medically Determinable Impairment (MDI)
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DI 24508.010 Impairment or Combination of Impairments Equals a Listing – Medical Equivalence
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DI 24510.060 Mental Residual Functional Assessment
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DI 24583.010 Determining Medical Equivalence for Mental Impairments
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DI 28010.135 Medical Improvement Review Standard (MIRS) Issues in Adult and Child Cases Involving Mental Impairments
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DI 28010.140 Psychiatric Review Technique Form (PRTF) (SSA-2506-BK) in Continuing Disability Reviews (CDRs) for Adult Mental Disorders Listings
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DI 29025.001 Disability Determination Services (DDS) Action When Fully Favorable Reconsideration Determination Is Not Issued
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DI 33015.020 Writing the Disability Hearing Officer’s (DHO’s) Decision
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DI 34001.032 Mental Disorders (Listing of Impairments – Current Part A Listings)