A client recently retained me after receiving an inital denial of his Social Security disability claim. He over 55 years old, and can no longer do his past relevant work, partly due to knee and ankle problems resulting from an old injury.
I have reviewed the disability claim file, and he was denied disability because a doctor at DDS reviewed his medical records and assessed an RFC for medium work.
Now, this particular claimant has more functional limitations than just his exertional impairments. But since he is over the age of 55, the quickest route to victory at Reconsideration is to persuade Social Security that a medium exertional RFC is too much for this claimant. At the sedentary or the light exertional level, a claimant over the age of 55 grids "disabled" under medical-vocational rule 201.06 or 202.06.
What does medium work require? Medium work means lifting up to 25 pounds frequently (from 1/3 to 2/3 of the day) and up to 50 pounds occasionally (up to 1/3 of a day). See 20 C.F.R. 404.1567(c). Medium work means being on your feet for most of a workday. Also, the full range of medium work requires both frequent stooping and frequent crouching. See Social Security Ruling 83-14.
My new client cannot do these things. To win at Reconsideration, the medical evidence of record must demonstrate his fuctional limitations.