Manso-Pizano V. Sec'y HHS

Date:

At Step 4, the ALJ is entitled to credit the claimant's own description of her past work and her functional limitations, but the ALJ has some burden independently to develop the record. Citing Santiago, 944 F.2d 1 (1st Cir. 1991). Remand. Illegibility of non-trivial parts of medical record, combined with identifiable diagnoses and symptoms indicating more than a mild impairment, alerted ALJ to need for expert guidance regarding the extent of the claimant's RFC to perform her past employment. Case remanded. With a few exceptions, an ALJ, as a lay person, is not qualified to interpret raw data in a medical record. Where claimant sufficiently put her inability to perform her past work in issue, the ALJ must measure the claimant's capabilities, and ordinarily an expert's RFC evaluation is essential unless the extent of functional loss, and its effect on job performance, would be apparent even to a lay person. Ventricular tachycardia, frequent PVCs, sinus tachycardia, arterial hypertension