Pufahl v. Commissioner of Social Security (7th Cir. 2025)
Clarifying the Limits of Treating-Physician Deference and the Sufficiency of “Two-Hour-Segment” Concentration Restrictions

1. Introduction

Alicia Rae Pufahl applied for Social Security disability insurance benefits, alleging that a constellation of physical and mental impairments rendered her unable to work between August 8, 2011 and December 31, 2016. After several administrative hearings and remands, an Administrative Law Judge (ALJ) again found that Ms Pufahl was not disabled. The District Court for the Eastern District of Wisconsin affirmed, and the Seventh Circuit has now upheld that judgment.

Although the panel issued a short, unpublished per curiam opinion, it addresses recurring issues that frequently dominate Social Security appeals: (1) how much weight an ALJ must give pre-2017 treating-source medical opinions; (2) how an ALJ should evaluate a claimant’s subjective symptom reports when treatment is conservative yet moderately effective; and (3) what language in a vocational hypothetical adequately captures moderate limitations in concentration, persistence, or pace (CPP).

2. Summary of the Judgment

• Holding – The Court of Appeals affirmed the District Court, concluding that substantial evidence supported the ALJ’s denial of benefits and that the ALJ followed applicable legal standards.
• Key Determinations
  • The ALJ permissibly gave little or some weight, rather than controlling weight, to treating physicians’ opinions where those opinions were unsupported, internally inconsistent, or speculative.
  • The ALJ’s treatment of the claimant’s subjective complaints was not patently wrong; citation to effective medication-management, conservative care, and daily activities sufficed.
  • A vocational hypothetical limiting a claimant to simple, routine tasks plus the ability to maintain attention and concentration for two-hour segments adequately incorporates moderate CPP deficits.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

The panel relied heavily on a line of Seventh Circuit precedent delineating the scope of review in Social Security cases and the treatment-source rule:

• Baptist v. Kijakazi, 74 F.4th 437 (7th Cir. 2023) – Reiterated that for claims filed before March 27 2017 a treating physician’s opinion is entitled to controlling weight only if well-supported and consistent with the record. Pufahl applies this rubric in discounting three treating doctors.
• Grotts v. Kijakazi, 27 F.4th 1273 (7th Cir. 2022) – Set the de novo standard of review of district-court decisions and clarified that an ALJ’s decision must stand if supported by substantial evidence.
• Winsted v. Berryhill, 923 F.3d 472 (7th Cir. 2019); Pavlicek v. Saul, 994 F.3d 777 (7th Cir. 2021) – Authorized ALJs to discount treating opinions that conflict with either their own treatment notes or other evidence.
• O’Connor-Spinner v. Astrue, 627 F.3d 614 (7th Cir. 2010) and progeny (Varga, Crump) – Warned that generic phrases like simple, routine, repetitive often fail to cover CPP deficiencies. The panel distinguishes those cases by noting the additional two-hour segment focus here.

3.2 The Court’s Legal Reasoning

1. Treating-Source Deference (pre-2017 rule)
   The panel methodically affirmed the ALJ’s three-step handling of treating opinions:
   1. Identify each opinion and decide whether it is controlling.
   2. If not controlling, articulate reasons—lack of objective support, internal inconsistency, conflict with other evidence—for discounting.
   3. Weigh remaining opinions under the §404.1527(c) factors (length of treatment, specialization, supportability, consistency).
   The Seventh Circuit pronounced this procedure well-within the ALJ’s discretion, thereby reinforcing administrative flexibility in future cases.
2. Subjective Symptom Evaluation
   Relying on Gedatus, Grotts, and SSR 16-3p, the panel endorsed the ALJ’s use of:
   • Objective clinical findings (normal gait, intact strength),
   • Documented improvement with medication, and
   • Daily activities (driving, household errands) as one factor rather than dispositive proof of work capacity.
   The decision clarifies that an ALJ may characterize pharmacologic adjustments and non-surgical care (e.g., dosage increases, physical therapy) as conservative when judging credibility, so long as the ALJ grapples with the nature of the underlying condition (e.g., fibromyalgia or migraines).
3. Vocational Hypothetical & CPP
   Unlike prior reversals where limitation phrases were too generic, the Court held that coupling simple, routine tasks with a concrete endurance restriction—maintain attention and concentration for two-hour segments—sufficiently mirrors moderate CPP deficits. This effectively announces that the two-hour-segment qualifier distinguishes acceptable hypotheticals from the defective ones criticized in Varga and Crump.

3.3 Anticipated Impact

• SSA Litigation – Claimants in the Seventh Circuit will face a steeper climb when arguing that ALJs failed to give controlling weight to treating doctors. The Court signals that pointing to internal inconsistencies, speculation, or sparse explanations is ordinarily enough to sustain a discount.
• Conservative Treatment Doctrine – By upholding the ALJ’s labeling of migraine and back-pain regimens as conservative, the opinion gives ALJs discretion to treat dosage tweaks or delayed escalation of therapy as evidence against disabling severity—provided they acknowledge the chronic nature of the disorder.
• Vocational Hypotheticals – Practitioners should note that adding an explicit two-hour concentration segment benchmark may immunize ALJ hypotheticals from CPP challenges, streamlining hearings and appellate review.

4. Complex Concepts Simplified

Treating-Source Rule (pre-2017)

Under the former 20 C.F.R. §404.1527, an ALJ must give a treating physician’s opinion “controlling weight” if it is both medically well-supported and not inconsistent with the overall record. Otherwise, the ALJ explains why and assigns lesser weight.

Residual Functional Capacity (RFC)

RFC is an administrative assessment of the most a claimant can still do despite limitations, expressed in work-related terms (e.g., light work, sit/stand, interactions).

Conservative Treatment

Non-invasive or routine care (medication changes, injections, therapy) as opposed to major surgery or aggressive interventions. Courts often view effective conservative treatment as evidence that a condition is not totally disabling.

Concentration, Persistence, or Pace (CPP)

Mental capacity to stay on task, sustain effort, and maintain productivity. When limitations are moderate, ALJs must craft corresponding restrictions in RFC and vocational questions.

Two-Hour Segment Limitation

A practical workplace proxy: the employee can remain on task for typical breaks (morning, lunch, afternoon). The Seventh Circuit now treats this as an adequate reflection of moderate CPP deficits when paired with other simplicity constraints.

5. Conclusion

Pufahl v. Commissioner is an affirmance, yet it carries doctrinal weight. First, it underscores that treating-physician opinions—especially when internally inconsistent or lightly reasoned—need not control an RFC finding. Second, it approves the use of conservative treatment analysis in credibility determinations when tethered to the medical record. Third, it blesses a specific vocational-hypothetical formula—simple tasks plus two-hour attention segments—as sufficient for moderate CPP limitations. Taken together, these points tighten the evidentiary demands on claimants and give ALJs clearer guidance, likely influencing hundreds of future Social Security disability determinations within the Seventh Circuit and potentially beyond.