Substantial loss related to basic mental activities

POMS DI 25020.010 A.3.b. discusses the evaluation of substantial loss of ability to meet the basic mental demands of competitive, remunerative, unskilled work at any exertional level:

“Substantial loss” cannot be precisely defined. It does not necessarily relate to any particular adjective, number, or percentage. In practical terms, an individual has a substantial loss of ability to perform a basic mental activity when he/she cannot perform the particular activity in regular, competitive employment but, at best, could do so only in a sheltered work setting where special considerations and attention are provided. This requires professional judgment, on the basis of the evidence in file in each case.

The sedentary occupational base

POMS DI 25015.020 B. explains that sedentary work represents a significantly restricted range of work.

Individuals who are limited to no more than sedentary work by their medical impairments have very serious functional limitations. For the majority of individuals who are age 50 or older and who are limited to the full range of sedentary work by their medical impairments, the vocational rules require a conclusion of “disabled”. For younger individuals, non-exertional limitations and the occupational base must be considered.

The term "occupational base" means the approximate number of occupations that an individual has the RFC to perform, considering all exertional and non-exertional limitations and restrictions. A full range of sedentary work includes all or substantially all of the approximately 200 unskilled sedentary occupations administratively noted in the regulations. If an individual is unable to perform the full range of sedentary work, the occupational base will be eroded by the additional limitations and restrictions.

Vocational impact of substantial loss

POMS DI 25015.020 B.7. provides the following guidance about the vocational impact of “substantial loss” of the ability to sustain basic work-related activities:

Mental limitations or restrictions: A substantial loss of ability to meet any one of several basic work-related activities on a sustained basis (i.e., 8 hours a day, 5 days a week, or an equivalent work schedule), will substantially erode the unskilled sedentary occupational base and would justify a finding of “disabled.”

The following mental activities are generally required by competitive, remunerative, unskilled work:

  • Understanding, remembering, and carrying out simple instructions.
  • Making judgments that are commensurate with the functions of unskilled work – i.e., simple work-related decisions.
  • Responding appropriately to supervisors, co-workers and usual work situations. Dealing with changes in a routine work setting.

Vocational impact of less than substantial loss

POMS DI 25015.020 B.7. provides the following additional guidance about the vocational impact of “less than substantial loss” of the ability to sustain basic work-related activities:

A less than substantial loss of ability to perform any of the above basic work activities may or may not significantly erode the unskilled sedentary occupational base. The individual’s remaining capacities must be assessed and a judgment made as to their effects on the unskilled occupational base considering the other vocational factors of age, education and work experience. When an individual has been found to have a limited ability in one or more of these basic work activities, it may be useful to consult a vocational resource.