Introduction

In David A. Ball v. Social Security Administration, Commissioner, No. 24-12496 (11th Cir. Apr. 4, 2025) (per curiam) (unpublished), the Eleventh Circuit affirmed the denial of Supplemental Security Income (SSI) benefits to David Ball. The appeal turned on two focused questions under the post‑2017 Social Security regulations governing medical evidence:

• Whether a nurse practitioner’s treatment‑plan activity restrictions (e.g., “no lifting, pushing, or pulling” over ten pounds) constitute a “medical opinion” that an Administrative Law Judge (ALJ) must evaluate for persuasiveness under 20 C.F.R. § 416.920c; and
• Whether the ALJ adequately addressed the “supportability” factor when finding a consultative psychologist’s severe mental‑limitations opinion unpersuasive, notwithstanding the ALJ’s failure to use the term “supportability.”

The court held that the nurse practitioner’s statements were “other medical evidence,” not “medical opinions,” and therefore did not trigger the ALJ’s § 416.920c articulation duty. It further held that the ALJ sufficiently addressed “supportability” by explaining how the psychologist’s own clinical findings undercut her severe limitations—confirming that there are “no magic words” required to satisfy § 416.920c’s articulation rule.

Parties: Plaintiff–Appellant, David A. Ball; Defendant–Appellee, the Commissioner of the Social Security Administration. Panel: Circuit Judges Jordan, Luck, and Wilson. Decision: Affirmed.

Summary of the Opinion

The Eleventh Circuit affirmed the district court’s judgment upholding the Commissioner’s denial of SSI benefits. At step four of the five‑step disability framework, the ALJ determined Ball retained the residual functional capacity (RFC) for light work with certain limitations, and at step five relied on vocational expert testimony to identify jobs existing in significant numbers that Ball could perform.

On appeal, Ball raised two errors:

• Nurse Practitioner Keahey’s restrictions. Ball argued the ALJ failed to rationally address NP Cherie Keahey’s 2019 notes prescribing “no lifting, pushing, or pulling” over ten pounds. The Eleventh Circuit held those statements were part of a treatment plan and did not constitute a “medical opinion” under 20 C.F.R. § 416.913(a)(2) because they did not speak to what the claimant could still do in a work setting “despite” his impairments. As “other medical evidence,” they did not require a § 416.920c persuasiveness analysis.
• Dr. Nichols’s opinion supportability. Ball argued the ALJ failed to articulate the “supportability” of clinical psychologist Dr. June Nichols’s opinion that Ball had severe psychological limitations. The court held that, although the ALJ did not use the term “supportability,” the decision adequately explained that Dr. Nichols’s own findings (e.g., adequate fund of knowledge, good judgment and insight, ability to understand and carry out short, simple instructions, socially appropriate behavior) did not support her severe limitations. Citing Raper v. Commissioner, the court reiterated that “no magic words” are required to comply with the regulation.

With both arguments rejected, the court affirmed.

Detailed Analysis

Factual and Procedural Posture

Ball applied for SSI on June 9, 2020, alleging disability as of that date due to bulging discs. The ALJ found severe impairments (degenerative disc disease, depression, obesity) but concluded at steps four and five that he could perform a reduced range of light work and that jobs existed in significant numbers that he could perform (filters assembler, poly packer/heat sealer, final inspector). The Appeals Council denied review.

Before the ALJ, Ball relied on:

• NP Keahey’s notes (Nov./Dec. 2019). A treatment plan advising a low‑sodium/low‑fat diet, 20–30 minutes of daily walking, no lifting/pushing/pulling over ten pounds, medication adherence, lumbar imaging, and follow‑up.
• Dr. Nichols’s consultative opinion. Severe mental limitations inconsistent with sustaining attention/concentration for two hours, maintaining routine without special supervision, or interacting appropriately with supervisors/co‑workers.

The ALJ referenced the Keahey records for pre‑onset symptoms but did not analyze the lifting/pushing/pulling admonitions as a medical opinion. The ALJ found Dr. Nichols’s severe limitations unpersuasive given her own clinical observations.

Precedents and Authorities Cited, and Their Role

• Doughty v. Apfel, 245 F.3d 1274 (11th Cir. 2001). Establishes that when the Appeals Council denies review, the ALJ’s decision is the Commissioner’s final decision for judicial review. Sets the procedural posture for appellate review.
• Winschel v. Commissioner of Social Security, 631 F.3d 1176 (11th Cir. 2011). Restates the “substantial evidence” standard—more than a scintilla; such relevant evidence as a reasonable person would accept. Guides the deference owed to the ALJ’s fact‑finding.
• Raper v. Commissioner of Social Security, 89 F.4th 1261 (11th Cir. 2024). Two important points: (1) legal issues are reviewed de novo; and (2) “no magic words” are required in the ALJ’s articulation of reasons for discounting medical opinions. The court leverages Raper to reject the argument that the ALJ must explicitly use the word “supportability.”
• Schink v. Commissioner of Social Security, 935 F.3d 1245 (11th Cir. 2019). Defines RFC as an assessment of what a claimant can still do despite impairments. Anchors the step‑four task of the ALJ under 20 C.F.R. § 416.945(a)(1).
• Buckwalter v. Acting Commissioner of Social Security, 5 F.4th 1315 (11th Cir. 2021). Emphasizes the ALJ’s duty to consider all relevant medical and other evidence and to explain the handling of opinion evidence. This decision bridges pre‑ and post‑2017 frameworks and supports the general articulation requirement.
• Regulations:
  • 20 C.F.R. § 416.920(a)(4): The five‑step sequential evaluation.
  • 20 C.F.R. § 404.1520(a)(4): Cross‑reference confirming the sequential framework.
  • 20 C.F.R. § 416.945(a)(1): RFC defined and the duty to consider all relevant evidence.
  • 20 C.F.R. § 416.913(a)(2)–(3): Defines “medical opinions” versus “other medical evidence.” The court’s classification of NP Keahey’s notes hinges on these definitions.
  • 20 C.F.R. § 416.920c: Factors for evaluating medical opinions (supportability, consistency, relationship, specialization, other) and the articulation duty for the two “most important” factors.
  • 20 C.F.R. § 416.967(b): Defines “light work,” the baseline used in the ALJ’s RFC.

Legal Reasoning

1) Treatment‑Plan Restrictions Are Not “Medical Opinions” Under § 416.913(a)(2)

The court draws a sharp distinction between:

• Medical opinions: Statements about what the claimant can still do despite impairments and whether the claimant has work‑related limitations (e.g., lifting/carrying, sitting/standing, attention/concentration) framed in vocational terms; versus
• Other medical evidence: Clinical findings, diagnoses, treatment plans, prognoses, and judgments about impairment severity not expressed as “what the claimant can still do” in a work context.

NP Keahey’s admonitions—“no lifting, pushing, or pulling” greater than ten pounds—appeared within a broader treatment plan that included diet, exercise, imaging, medication adherence, and follow‑up. The Eleventh Circuit characterized these statements as health‑management instructions, not an assessment of Ball’s vocational capacity “despite” impairment. Because they were not “medical opinions,” the ALJ had no duty under § 416.920c to evaluate their persuasiveness or articulate supportability/consistency findings regarding them.

Two additional features support this classification:

• Context and purpose. The restrictions are embedded in a prescriptive plan (akin to “doctor’s orders”) rather than a vocational assessment tied to the demands of competitive employment.
• Temporal posture. They were recorded approximately six months before the alleged onset date. While the panel did not rely on timing as a dispositive ground, the pre‑onset timing underscores why the ALJ referenced these notes only to describe symptom onset rather than to define work capacity.

2) “Supportability” Can Be Adequately Articulated Without Using the Word

The regulations make “supportability” and “consistency” the two most important factors in assessing the persuasive value of medical opinions. “Supportability” asks whether the medical source’s own objective evidence and explanations support the opined limits.

Here, the ALJ explained that Dr. Nichols’s severe mental limitations were not supported by her own clinical observations that Ball:

• Had an adequate fund of knowledge;
• Exhibited good judgment and insight; and
• Could understand, remember, and carry out very short and simple instructions, maintain socially appropriate behavior, and adhere to basic standards of neatness and cleanliness.

The court held this is a paradigmatic “supportability” analysis—even though the ALJ did not use the term—because it compares the internal evidentiary basis of the opinion to the severity of the opined limitations. Citing Raper, the court reaffirmed that there are “no magic words” required for compliance. Substantial evidence supported the ALJ’s determination.

Notably, Ball challenged only “supportability.” Although § 416.920c(b)(2) also requires articulation of “consistency,” the panel confined its ruling to the argument presented and found the articulation of supportability sufficient.

Impact and Practical Consequences

Although unpublished and therefore non‑precedential, Ball provides clear guidance for practitioners in the Eleventh Circuit:

• Classification matters. Treatment‑plan activity restrictions—particularly when phrased as generalized health advice—will likely be treated as “other medical evidence,” not “medical opinions.” They do not, by themselves, compel an ALJ to perform a § 416.920c persuasiveness analysis.
• Frame provider statements in vocational terms. If counsel wants the ALJ to treat a provider’s statement as a “medical opinion,” the statement should expressly address what the claimant can still do “despite” impairments in terms of the demands of work (e.g., lift/carry limits stated in occasional/frequent terms over an 8‑hour day; sit/stand/walk tolerances; concentration/persistence/pace over at least two‑hour segments; need for off‑task time; absenteeism expectations).
• “No magic words” suffices for articulation. The ALJ can satisfy the “supportability” articulation requirement by explaining, in substance, why a source’s own findings do or do not support the opined limitations. Explicitly labeling the discussion “supportability” is not required.
• Light work versus treatment‑plan limits. A treatment instruction like “no lifting over 10 pounds” may appear to undercut an RFC for light work (which can entail up to 20 pounds occasionally and 10 pounds frequently), but Ball indicates that unless such a statement is couched as a vocational capacity assessment, the ALJ is not obligated to treat it as a medical opinion or to reconcile it as such.
• Pre‑onset evidence may receive limited weight. Even when pre‑onset records are considered, ALJs may reference them for background without treating them as dispositive of vocational capacity during the relevant period.
• Strategic documentation. For claimants with both physical and mental impairments, commissioning a detailed functional capacity evaluation (FCE) or a narrative opinion that links objective findings to specific, work‑related limitations can be pivotal under § 416.913(a)(2) and § 416.920c.

Complex Concepts Simplified

• Five‑Step Sequential Evaluation (20 C.F.R. § 416.920):
  • Step 1: Are you working at substantial gainful activity? If yes, not disabled.
  • Step 2: Do you have a severe impairment? If no, not disabled.
  • Step 3: Does your impairment meet or equal a Listing? If yes, disabled.
  • Step 4: What is your RFC, and can you do past work? If yes, not disabled.
  • Step 5: Given RFC, age, education, and experience, can you do other work? If yes, not disabled; if no, disabled.
• RFC (Residual Functional Capacity): The most you can do on a sustained basis despite your impairments. It is formulated from all relevant evidence.
• Medical Opinion vs. Other Medical Evidence (20 C.F.R. § 416.913):
  • Medical Opinion: A provider’s statement about what you can still do in a work setting despite impairments, addressing specific functional demands (e.g., lifting limits, ability to maintain attention for two‑hour periods).
  • Other Medical Evidence: Clinical notes, diagnoses, treatment plans, and observations that do not directly state vocational capacity.
• Supportability (20 C.F.R. § 416.920c(c)(1)): How well the medical source’s own objective findings and explanations back up the opinion.
• Consistency (20 C.F.R. § 416.920c(c)(2)): How consistent the opinion is with the rest of the evidence in the record.
• Substantial Evidence: More than a scintilla—enough relevant evidence that a reasonable person would accept to support a conclusion.
• Light Work (20 C.F.R. § 416.967(b)): Generally involves lifting up to 20 pounds occasionally and 10 pounds frequently, and standing/walking off and on during the workday, with some sitting.

Observations and Nuances

• Acceptable medical sources. Under post‑2017 rules, nurse practitioners are acceptable medical sources for many issues; however, not every statement by an acceptable medical source is a “medical opinion.” The content and framing of the statement govern its classification.
• Why context matters. A directive like “avoid lifting over 10 pounds” can be viewed differently depending on whether it is part of a treatment plan (general activity restriction) or a vocational assessment (explicit translation into workplace functional limits over an 8‑hour day).
• Scope of the court’s holding. The panel limited its analysis to the errors Ball alleged: it determined that (i) there was no duty to analyze the persuasiveness of NP Keahey’s treatment plan as a medical opinion; and (ii) the ALJ adequately addressed supportability for Dr. Nichols’s opinion. The decision does not alter the ALJ’s broader duty to consider all relevant evidence in determining RFC.

Conclusion

Ball v. SSA (unpublished) offers two clarifications under the post‑2017 medical‑evidence framework. First, not all provider statements—even from acceptable medical sources—qualify as “medical opinions.” Treatment‑plan activity restrictions are “other medical evidence” unless they are expressly framed as vocational capacity assessments addressing what the claimant can still do despite impairments. Second, ALJs meet the “supportability” articulation requirement by substantively explaining why a source’s own findings do or do not back the opined limitations; no talismanic use of the word “supportability” is required.

For practitioners, the decision underscores the importance of obtaining opinions that translate clinical observations into clear, work‑related functional terms, and of building the record so that supportability is evident on the face of the provider’s report. For adjudicators, it confirms that faithful application of § 416.913 and § 416.920c rests on substance over form and that substantial‑evidence review will defer to reasoned RFC determinations that engage with the record in this way.

Disposition: Affirmed.