Clarifying Medical Opinion and Other Medical Evidence Under the SSA’s 2017 Regulatory Framework

Introduction

Dennis Jones v. Leland Dudek (Seventh Circuit, April 21, 2025) addresses a pivotal question under the Social Security Administration’s (SSA) 2017 revisions to its medical‐evidence regulations: how to distinguish “medical opinions” from “other medical evidence,” and what evaluation an Administrative Law Judge (ALJ) must give each category.

Background:

• Dennis Jones, a 42-year-old grocery cashier, applied for disability benefits based on congenital hemiparesis and chronic pain.
• The SSA denied benefits. At hearing, ALJ Fuentes found Jones capable of “light work” with limitations and relied in part on Dr. James Runke’s report.
• Dr. Runke’s report included objective findings and a “clinical impression” limiting Jones to 20 hours per week—raising the issue whether that “impression” qualified as a medical opinion requiring a persuasiveness evaluation.

Key Issue: Did the ALJ err by failing to treat and evaluate Dr. Runke’s clinical impression as a “medical opinion” under 20 C.F.R. §§ 404.1513(a)(2) & 416.913(a)(2)? Parties: Plaintiff‐Appellant Dennis Jones vs. Acting Commissioner Leland Dudek.

Summary of the Judgment

The Seventh Circuit held:

• Dr. Runke’s clinical impression—that Jones could work “about 20 hours per week maximum”—constituted a “medical opinion” under the 2017 SSA regulations, because it spoke to what the claimant “can still do.”
• However, that opinion addressed an issue “reserved to the Commissioner”—namely, whether Jones could perform “regular or continuing work.”
• Because medical opinions on issues reserved to the Commissioner need not be evaluated for persuasiveness, the ALJ had no obligation to articulate supportability and consistency findings for Dr. Runke’s statement.
• The Circuit affirmed the district court’s judgment denying benefits.

Analysis

1. Precedents Cited

• 20 C.F.R. §§ 404.1513(a), 404.1520c & 416.913(a), 416.920c (2017) – Governing distinctions among objective medical evidence, medical opinions, and other medical evidence; directives on “persuasiveness” factors.
• SSR 96-9p – Defines “regular and continuing basis” work (8 hours/day, 5 days/week).
• Staheli v. Commissioner (10th Cir. 2023) – Held that medical opinions must address claimant’s ability to perform specific demands of work activities.
• Chenery doctrine – Limits courts to administrative rationales actually relied upon at the time of decision. The Court distinguished this context because the SSA regulations themselves exempt certain opinions from any persuasiveness evaluation.

2. Legal Reasoning

The Court’s reasoning unfolded in three steps:

1. Categorization as Medical Opinion: The 2017 regulation defines “medical opinion” as a “statement from a medical source about what you can still do despite your impairment(s)….” Dr. Runke’s limitation to 20 hours/week falls squarely within that definition.
2. Issue Reserved to the Commissioner: Regulations exempt from persuasiveness analysis any medical opinion on issues “reserved to the Commissioner,” including whether a claimant is “able to perform regular or continuing work.” Dr. Runke’s conclusion about weekly work hours is effectively a decision on that very issue.
3. No Persuasiveness Evaluation Required: Because the ALJ could not, under the regulations, evaluate for supportability and consistency an opinion on an issue reserved to the Commissioner, the ALJ did not err by omitting such analysis.

3. Impact

• Clarifies that any medical opinion about the claimant’s ability to engage in full-time work—even if couched in functional terms—amounts to an opinion on an issue reserved to the Commissioner and requires no persuasiveness articulation.
• Encourages ALJs to carefully categorize medical evidence but reassures them that no Chenery violation arises from relying on the regulation’s express exemptions.
• Guides practitioners to distinguish between functional opinions (medical opinion) and purely diagnostic or historical findings (other medical evidence), and to anticipate when persuasiveness factors will or will not apply.
• May influence future appeals in other circuits wrestling with similar ambiguities in the 2017 rulemaking.

Complex Concepts Simplified

• Residual Functional Capacity (RFC): A claimant’s maximum sustained work capabilities, e.g., light work with additional restrictions.
• Consultative Examiner: A physician or specialist engaged by SSA to perform an examination and report findings to the agency.
• "Medical Opinion" vs. "Other Medical Evidence":
  • Medical Opinion: Address what claimant “can still do” (e.g., limits on sitting, standing, lifting).
  • Other Medical Evidence: Medical history, diagnoses, prognoses, and observations about the nature/severity of impairments.
• Issues Reserved to the Commissioner: Ultimate decisions on disability status and ability to perform regular work are the agency’s province, not the treating physician’s.
• Persuasiveness Factors: ALJs normally must evaluate medical opinions for “supportability” (evidence backing the opinion) and “consistency” (alignment with the record), unless exempted by regulation.

Conclusion

Dennis Jones v. Dudek clarifies a critical tension inherent in SSA’s 2017 regulatory revision: while the revised definition of “medical opinion” is broad enough to encompass any physician statement about what a claimant can still do, the regulation simultaneously shields opinions on ultimate issues of disability and work capacity from persuasiveness scrutiny. This decision solidifies that shield and provides practitioners and ALJs with a clear rule: functional medical opinions on full-time work capacity need not be weighed for supportability or consistency. The ruling thus refines the administrative evaluation process, reinforces the agency’s authority over ultimate disability determinations, and sets a guiding precedent for similar disputes nationwide.