Wendy Woehrmann v. Frank J. Bisignano, Commissioner of Social Security

Summary

The court reverses and remands the Commissioner of Social Security’s denial of Wendy Woehrmann’s application for Disability Insurance Benefits. The court holds that the administrative law judge did not adequately explain the supportability and consistency of the medical opinion evidence as required by 20 C.F.R. § 404.1520c. The court does not reach Woehrmann’s remaining arguments.

Holdings

1. The ALJ erred by failing to explain adequately how the medical opinions and prior administrative medical findings were supported by objective evidence and consistent with the record, as required by 20 C.F.R. § 404.1520c(b)(2).
2. The ALJ may not formulate an RFC and then assess medical opinions merely by whether they support that preexisting RFC; the ALJ must independently evaluate the medical opinions before formulating the RFC.
3. The appropriate remedy was reversal and remand for further administrative proceedings and reconsideration of the medical opinion evidence, rather than an immediate award of benefits.

Questions Presented

1. Whether the ALJ adequately evaluated the supportability and consistency of the medical opinions and prior administrative medical findings under 20 C.F.R. § 404.1520c.
2. Whether the ALJ's failure to independently explain the supportability and consistency of the medical opinions constituted reversible error.
3. Whether the case should be remanded for reconsideration of the medical opinion evidence rather than for an immediate award of benefits.

Disposition

reversed_and_remanded