From Moderate Limits to Logical Bridges: Moy v. Bisignano Clarifies the RFC Standard for Concentration, Persistence, and Pace

1. Introduction

The Seventh Circuit’s decision in Ferida Moy v. Frank Bisignano, No. 24-1461 (7th Cir. July 2 2025) addresses the critical question of how an Administrative Law Judge (ALJ) must translate documented mental-health limitations—specifically “moderate” limitations in concentration, persistence, or pace (often abbreviated “CPP”)—into a residual functional capacity (RFC) finding that is both logically coherent and adequately supported by evidence.

Plaintiff–appellant Ferida Huskic Moy, a Bosnian war survivor suffering from severe post-traumatic stress disorder (PTSD), applied for disability insurance benefits and supplemental security income after experiencing worsening hallucinations, panic attacks, and flashbacks that impeded her ability to work. The ALJ acknowledged moderate CPP limitations but nonetheless concluded Moy could perform work “at a consistent production pace,” a finding the district court upheld. On appeal, the Seventh Circuit vacated the judgment and remanded, holding that the ALJ failed to build the required “logical bridge” between Moy’s CPP limitations and the RFC.

2. Summary of the Judgment

The court reversed the district court’s affirmance and remanded to the Commissioner.
It held that declaring a claimant with moderate CPP limitations capable of working “at a consistent production pace” is a non-sequitur unless the ALJ supplies a reasoned explanation linking the evidence to that conclusion.
The Seventh Circuit reaffirmed its CPP line of cases (Crump, Varga, Lothridge) and extended them by stressing:
- An ALJ may not rely on vocational-expert (VE) testimony elicited through hypotheticals that omit or neutralize identified CPP deficits.
- The record in Moy’s case actually suggested absenteeism and off-task behavior well above employer tolerances, underscoring the logical gap.

3. Analysis

3.1 Precedents Cited and Their Influence

The opinion canvasses—and harmonizes—numerous Seventh Circuit precedents:

Crump v. Saul, 932 F.3d 567 (7th Cir. 2019) – An ALJ must include all CPP-related restrictions in hypotheticals to the VE. Moy extends Crump by labeling an ALJ’s mere assertion of a “consistent production pace” accommodation as facially insufficient without support.
Varga v. Colvin, 794 F.3d 809 (7th Cir. 2015) and Yurt v. Colvin, 758 F.3d 850 (7th Cir. 2014) – Require that CPP limits found at Step Three must be accounted for in the RFC and VE hypotheticals.
Lothridge v. Saul, 984 F.3d 1227 (7th Cir. 2021) – Warned against internal inconsistencies when an ALJ finds moderate CPP limits but provides no matching RFC constraints; Moy repeatedly cites Lothridge.
O'Connor-Spinner v. Astrue, 627 F.3d 614 (7th Cir. 2010) – Established the “accurate and logical bridge” metaphor. Moy concretizes that bridge by deeming a “consistent pace” finding, unsupported by reasoning, structurally unsound.
Pavlicek v. Saul, 994 F.3d 777 (7th Cir. 2021) – Affirmed that moderate CPP need not always disable, but only where the ALJ adequately explains how other RFC limits compensate. The court contrasts that accepted rationale with the absence of such explanation here.

3.2 The Court’s Legal Reasoning

Standard of Review: De novo review of the district court; “substantial evidence” deference to the ALJ, tempered by the duty to identify an adequate “logical bridge.”
Identification of the Error:
- The ALJ acknowledged “moderate” CPP deficits yet stated, “To account … I provided that she can work at a consistent production pace.” The Seventh Circuit labeled this a “non-sequitur.”
- The VE testified that ≥2 unscheduled absences per month or ≥15 % off-task time would eliminate work. Evidence showed Moy’s therapy frequency and symptomology likely exceeded those tolerances—yet the ALJ never addressed that mismatch.
Resulting Holding: An ALJ must either (a) include concrete off-task or absenteeism limits (or equivalent restrictions) in the RFC, or (b) thoroughly explain why none are necessary despite moderate CPP findings. Simply declaring an ability to sustain “consistent production pace” does not suffice.

3.3 Potential Impact

Moy’s decision carries substantial practical and doctrinal consequences:

ALJ Training & Templates: Many ALJs rely on boiler-plate language (“simple, routine tasks,” “consistent pace”) when addressing CPP limitations. Moy signals that such stock phrasing—absent a tailored justification—will trigger remand.
Vocational Expert Practice: VE testimony must be tethered to hypotheticals reflecting all CPP restrictions, including specific absenteeism/off-task parameters when suggested by the record.
Claimant Advocacy: Moy equips claimants’ counsel with a clear citation for challenging ALJ decisions that gloss over mental-health-related pace limitations.
Administrative Efficiency: The SSA may need to modify regulations, HALLEX templates, and adjudicator guidance to reduce rework caused by “logical bridge” errors identified in Moy and predecessor cases.
Persuasive Authority Nationwide: While binding only in the Seventh Circuit (Illinois, Indiana, Wisconsin), the opinion will likely be cited in other circuits confronting similar CPP-RFC disputes.

4. Complex Concepts Simplified

Residual Functional Capacity (RFC): A work-related assessment of what a claimant can still do (physically and mentally) despite impairments, expressed in specific vocational terms (e.g., lifting limits, social interaction, off-task time).
Concentration, Persistence, or Pace (CPP): An umbrella mental-function domain used by SSA to evaluate how well a person can maintain attention, stay on task, and sustain work-rate over a full workday/week. “Moderate” means noticeable but not necessarily disabling difficulty.
Logical Bridge Requirement: Courts require ALJs to explain, in non-conclusory prose, how they moved from raw evidence to ultimate conclusions. Think of it as the “connect-the-dots” obligation in judicial review.
Vocational Expert (VE) Hypotheticals: Questions posed to a VE at the hearing that mirror a claimant’s limitations; the VE identifies jobs that remain feasible. If the hypothetical omits a limitation, the resulting job list is tainted.
Substantial Evidence: A deferential evidentiary standard meaning “such relevant evidence as a reasonable mind might accept as adequate.” But absence of a logical bridge can render otherwise “adequate” evidence legally insufficient.

5. Conclusion

Moy v. Bisignano crystallizes a pivotal principle: an ALJ who acknowledges moderate CPP limitations must do more than recite a boiler-plate assertion that the claimant can still maintain a “consistent production pace.” Without a firmly constructed logical bridge—demonstrating why or how those mental-health limitations do not undermine sustained work performance—the decision cannot stand.

By reinforcing and refining a decade’s worth of Seventh Circuit doctrine, the opinion serves both as a roadmap for meticulous RFC analysis and a cautionary tale against superficial treatment of mental impairments. Future disability adjudications, particularly within the Seventh Circuit, must accordingly incorporate explicit absenteeism and off-task findings—or robust explanations for their omission—whenever moderate CPP deficits surface in the record.