Heather Ann H. v. Commissioner of Social Security

Summary

The document is a Memorandum-Decision and Order from the U.S. District Court for the Northern District of New York reviewing the denial of Heather Ann H.'s applications for disability insurance and supplemental security income benefits. The court upheld the Commissioner's decision, granting the Commissioner's cross-motion for judgment on the pleadings and denying the plaintiff's motion. The court concluded that the administrative law judge's residual functional capacity assessment and evaluation of the medical opinions were supported by substantial evidence.

Holdings

1. The ALJ adequately conducted an individualized assessment of plaintiff's mental RFC and accounted for work-related stress through restrictions to simple tasks, limited social interaction, simple work-related decisions, and occasional work changes.
2. The ALJ did not err by declining to include additional or greater RFC restrictions for time off task or absenteeism because the RFC and the ALJ's findings reasonably reflected mild-to-moderate limitations supported by the record.
3. The ALJ adequately articulated the supportability and consistency of Dr. Pareek's and Dr. Shapiro's opinions as required by 20 C.F.R. § 416.920c, and substantial evidence supported the resulting RFC.

Questions Presented

1. Whether the ALJ conducted the individualized assessment required by SSR 85-15 and adequately accounted for plaintiff's ability to handle work-related stress in the RFC.
2. Whether the ALJ's RFC adequately accounted for alleged limitations in concentration, persistence, pace, time off task, and absenteeism.
3. Whether the ALJ adequately explained the supportability and consistency factors when evaluating the opinions of Dr. Pareek and Dr. Shapiro.
4. Whether the Commissioner's decision was supported by substantial evidence and applied the correct legal standards.

Disposition

affirmed