Latest / FLG Disability Insights / When Simple Work Doesn’t Explain a Two-Step Task Limit
Transcript
- Can a disability decision call the work simple—and still miss the limitation that matters most? In one recent Social Security case, the answer was yes. Welcome to FLG Disability Insights. I’m Nick Feden of Feden Law Group. Rayner applied for Social Security Disability Insurance and Supplemental Security Income. Two medical sources discussed her ability to follow short instructions. Dr. John David Gavazzi assessed her as able to perform one- and two-step routine tasks in a stable environment. Dr. John Vigna used less precise language, referring to at least simple one- and two-step instructions. The administrative law judge found both opinions persuasive and discussed them together. But when the judge described Rayner’s residual functional capacity—what she could still do despite her impairments—the decision said she could perform simple, repetitive, routine tasks. It did not include the specific one- and two-step restriction. And it did not explain why that restriction was left out. That omission mattered at the final stage of the analysis. The judge relied on jobs such as kitchen helper, dining room attendant, and cook helper. Those jobs required reasoning level two. The court treated the task limit at issue as corresponding to reasoning level one. So the label simple work did not resolve whether the jobs actually fit the medical limitation the judge had credited. The court sent the case back for a new administrative hearing. It explained that an administrative law judge does not have to adopt every limitation in a medical opinion. But if a specific restriction is omitted after the opinion is found persuasive, the decision needs a reason supported by substantial evidence. A later explanation offered by the Commissioner could not fill the gap because the judge had not made that distinction in the decision. This was a remand, not an award of benefits, and the court did not decide that Rayner was disabled. It also did not create a rule that every moderate concentration problem requires a one- or two-step limit. The practical takeaway is to compare the medical opinions, the residual functional capacity, the questions asked of the vocational expert, and the actual demands of the jobs identified. Words like simple and routine can sound reassuringly precise while hiding a meaningful mismatch. Visit FedenLawGroup dot com and try FLG Case Analyst Beta. Get a full report generated by an attorney-trained, cutting-edge AI model, then connect with our firm about your next step. This podcast provides general information, not legal advice. Every claim depends on its own facts and applicable law. I’m Nick Feden. Thanks for listening to FLG Disability Insights.