
What is a Residual Function Capacity Assessment Used for in Long-Term Disability Claims?
April 12, 2023
When an employee submits a long-term disability claim to their employer, it is not uncommon for the insurer to require the employee to undergo an examination by a physician or specialist. These exams can take many forms and frequently include assessments. One assessment often used by disability insurers is the Residual Function Capacity assessment, or “RFC”.
An RFC assesses the extent to which an individual’s medical impairment, including related symptoms such as pain, may cause physical or mental limitations. These restrictions may affect the employee’s capacity to do work-related physical and mental activities.
RFCs often assess an employee’s maximum remaining ability to do sustained work activities, in an ordinary work setting, on a regular and continuing basis. Simply stated, the RFC measures an employee’s ability to be gainfully employed.
A recent long-term disability case in Colorado reviewed the findings of an employee’s Residual Function Capacity assessment when the court was considering whether to award the employee long-term disability benefits. In that case, the employee was suffering from rheumatoid arthritis, fibromyalgia and the related symptoms associated with both diseases.
The employee worked for Hewlett Packard as an IT Customer Service Representative, meaning he was constantly typing and engaging with customers on the phone. The employee’s doctor, a rheumatologist, completed a Residual Function Capacity. From the RFC, the doctor found objective symptoms that included joint warmth, reduced grip strength, sensory changes, impaired sleep, swelling and muscle spasms. Testing also showed weakness in the arms and legs, muscle stiffness, decreased range of motion and chest pain. Significantly, the doctor concluded that his patient did not appear to be exaggerating his symptoms.
When the employee sued his disability insurer for long-term disability benefits, the court noted the findings of the RFC study in its opinion. The employee’s doctor relied in part on the findings of the RFC when listing the employee’s restrictions. Better still, the court questioned the findings of the insurer’s experts who concluded the employee could function at work despite substantial restrictions being in place. This decision by the court illustrates how functional assessments like the Residual Function Capacity evaluation performed here can play an important role in establishing a long-term disability claim.
If you wish to read the court’s decision, it is available on the court’s docket. See Johnson v. Hewlett Packard Enters. Co., No. 9-cf-01878-RBJ, 2021 WL 2254965, at *9 (D. Colo. June 3, 2021).