“Implicit-Accounting” in Disability Adjudication:
Eleventh Circuit Confirms ALJs May Address Moderate Social and Adaptive Limitations Without Mirroring Them Verbatim in the RFC
Patterson v. Commissioner, Social Security Administration, 23-13317 (11th Cir. Aug. 14, 2025)

1. Introduction

Alejandro Ricardo Patterson sought Supplemental Security Income (SSI) alleging disability due to autism spectrum disorder/Asperger’s syndrome, avoidant personality disorder, depression, anxiety, and substance abuse. After an Administrative Law Judge (ALJ) deemed several impairments non-severe and denied benefits, the District Court for the Middle District of Florida affirmed. Patterson appealed, contending that the ALJ’s Residual Functional Capacity (RFC) failed to incorporate:

• (i) social limitations in interacting with co-workers and supervisors, and
• (ii) adaptive limitations acknowledged at step-three of the sequential evaluation.

The Eleventh Circuit, sitting on the non-argument calendar, affirmed in a per curiam opinion. The Court articulates what this commentary calls the “Implicit-Accounting Principle”: where substantial evidence shows that moderate limitations found under the Psychiatric Review Technique (PRT) only warrant specific, narrower restrictions, an ALJ may satisfy her duty by implicitly addressing those limitations in the RFC—without restating every sub-component verbatim.

2. Summary of the Judgment

Applying de novo review for legal errors and “substantial evidence” review for factual findings, the Eleventh Circuit held:

1. The ALJ properly rated Patterson’s limitations in “interacting with others” and “adapting or managing oneself” as moderate under the PRT at steps two and three.
2. The regulations did not require the ALJ to identify separately each of the three sub-categories of “others” (public, co-workers, supervisors).
3. The ALJ’s RFC—which limited Patterson to “no more than occasional interaction with the general public” and to “simple, routine, repetitive tasks with a reasoning level not exceeding 2”—implicitly accommodated the moderate social and adaptive limitations.
4. Substantial evidence—including treating-source opinions showing no significant difficulty with co-workers or supervisors—supported the RFC.
5. Consequently, the vocational expert’s testimony based on that RFC constituted substantial evidence that jobs (routing clerk, electrical accessories assembler, marker) existed in the national economy, and the denial of benefits stood.

3. Analysis

3.1 Precedents Cited and Their Influence

• Winschel v. Commissioner of Social Security, 631 F.3d 1176 (11th Cir. 2011) – Established that the PRT findings and the RFC analysis are “distinct yet related” and that mental limitations identified at steps two/three must be considered in the RFC or explained away. – The panel relied on Winschel to justify the notion that an ALJ may implicitly account for limitations in the RFC and associated hypotheticals to the vocational expert (VE).
• Samuels v. Acting Commissioner of Social Security, 959 F.3d 1042 (11th Cir. 2020) – Recited for the standard of review (ALJ decision is Commissioner’s final decision when Appeals Council denies review).
• Raper v. Commissioner of Social Security, 89 F.4th 1261 (11th Cir. 2024) – Quoted for the definition of “substantial evidence.”

By harmonizing Patterson’s arguments with Winschel, the Court underscored that express incorporation of every PRT limitation is not mandatory—so long as the decision demonstrates logical linkage and substantial evidentiary support.

3.2 Legal Reasoning of the Court

1. Regulatory Framework – The five-step sequential evaluation (20 C.F.R. §404.1520/§416.920) situates the PRT at steps two & three and the RFC at steps four & five. – PRT functional areas include “interacting with others” and “adapting or managing oneself,” defined in Appendix 1. – The RFC is “the most” a claimant can do—it is not a listing of every diagnosed limitation.
2. No Duty to Disaggregate Sub-Categories at PRT Stage – Regulations require rating a “broad functional area,” not each sub-slice. Thus, failing to single out “co-workers” and “supervisors” was not error.
3. Implicit Accounting Doctrine – When the RFC restricts interaction with the general public, the ALJ “implicitly concluded” that limitations with co-workers/supervisors were minimal. – The doctrine derives from Winschel, allowing implicit accommodation so long as logical explanation and substantial evidence exist.
4. Substantial Evidence Assessment – One treating physician found Patterson could communicate and follow commands normally. – Another opined Patterson was “not significantly limited” in getting along with co-workers/peers. – Although conflicting evidence existed, the Court emphasized that it does not re-weigh evidence or make credibility findings.
5. Adaptive Limitation Addressed by Simplified Task Restriction – Limiting claimant to “simple, routine, repetitive tasks” with a low reasoning level reduced environmental change and stress, thereby controlling adaptive demands.

3.3 Potential Impact of the Decision

This opinion, though “unpublished,” is persuasive within the Eleventh Circuit and instructive elsewhere. Its key implications include:

• Administrative Practice: ALJs can defend RFC findings that partially track PRT ratings if the written decision explains why narrower restrictions suffice.
• Litigation Strategy: Claimants’ counsel should develop a record demonstrating vocationally significant limitations with each social-interaction subgroup; otherwise, the ALJ may lawfully omit them.
• Judicial Economy: Courts are signaled to uphold ALJ decisions where implicit reasoning is supported; they need not demand line-by-line replication of PRT findings.
• Substantial-Evidence Threshold Clarified: The case emphasizes that minimal yet consistent medical opinions can constitute substantial evidence versus competing subjective reports.

4. Complex Concepts Simplified

• Residual Functional Capacity (RFC): A work-related profile summarizing what tasks, physical or mental, a claimant can still perform despite impairments.
• Psychiatric Review Technique (PRT): A regulatory tool requiring ALJs to rate mental functioning in four areas; it guides but does not control the RFC.
• Moderate Limitation: A “fair” level of difficulty (neither mild nor marked). It signals some functional loss but not an outright work preclusion.
• Substantial Evidence: “More than a scintilla”—such that a reasonable person would accept it. It is a low appellate threshold; the court cannot substitute its judgment.
• Non-Argument Calendar: An appellate docket category where oral argument is deemed unnecessary, often involving settled law or clear record support.

5. Conclusion

Patterson v. Commissioner refines the interplay between step-three PRT findings and step-four/five RFC determinations. The Eleventh Circuit’s message is concise: an ALJ’s duty is to accommodate real functional loss, not to parrot diagnostic labels. Where medical evidence demonstrates that moderate mental limitations justify only targeted restrictions—here, occasional public contact and simple work—those restrictions implicitly satisfy the regulatory mandate. Going forward, the “Implicit-Accounting Principle” will guide disability adjudicators and litigants in crafting, challenging, and defending RFC findings in the Eleventh Circuit and beyond.