Supportability and Consistency as Cornerstones of Medical Opinion Evaluation under 20 C.F.R. § 416.920c

Introduction

In Blanford v. Dudek (2d Cir. 2025), the Second Circuit affirmed the denial of Supplemental Security Income (SSI) benefits to plaintiff‐appellant Robert N. Blanford. Blanford had applied for SSI under Title XVI of the Social Security Act, claiming schizophrenia and related impairments that he argued rendered him unable to work. The Acting Commissioner of Social Security, Leland Dudek, denied his claim at the administrative level, and the District Court for the District of Connecticut (Judge Oliver) upheld that denial. Blanford then appealed to the Second Circuit, challenging (1) the Administrative Law Judge’s (ALJ’s) evaluation of medical opinion evidence under the agency’s new 2017 regulations (20 C.F.R. § 416.920c), (2) the ALJ’s residual functional capacity (RFC) finding, (3) the ALJ’s credibility assessment of his symptom testimony, and (4) the Appeals Council’s refusal to consider new evidence submitted post‐decision.

Summary of the Judgment

The Second Circuit, in a summary order, held unanimously that:

• The ALJ correctly applied the post‐March 27, 2017 regulatory framework by evaluating each medical opinion for “supportability” and “consistency” rather than under the old treating‐physician hierarchy.
• The ALJ’s RFC finding—limiting Blanford to medium work with simple, routine, repetitive tasks, few workplace changes, and minimal social contact—was supported by substantial evidence in the record.
• The ALJ’s credibility determination, which discounted the severity of Blanford’s subjective symptom reports in light of treatment records and inconsistencies in daily activities, was permissible and adequately explained.
• The Appeals Council properly refused to consider supplemental evidence from Dr. Ryser because it did not create a reasonable probability of changing the outcome and was largely duplicative of evidence already evaluated.

As a result, the District Court’s judgment affirming the Commissioner’s denial of benefits was itself affirmed.

Analysis

Precedents Cited

The court’s analysis heavily relied on controlling Second Circuit authority interpreting the Social Security Act’s standard of review and the substantial evidence requirement:

• Rubin v. O’Malley, 116 F.4th 145 (2d Cir. 2024) – reaffirming that on benefits appeals the reviewing court focuses on the administrative record and applies the substantial‐evidence standard de novo.
• Zabala v. Astrue, 595 F.3d 402 (2d Cir. 2010) – defining the substantial evidence test as “more than a mere scintilla” and requiring up‐or‐down deference to rational ALJ findings.
• Selian v. Astrue, 708 F.3d 409 (2d Cir. 2013) – clarifying that if evidence supports multiple rational interpretations, the Commissioner’s choice prevails.
• Brault v. Social Security Administration, Commissioner, 683 F.3d 443 (2d Cir. 2012) – explaining that an ALJ need not discuss every piece of evidence, so long as the record shows consideration.
• Genier v. Astrue, 606 F.3d 46 (2d Cir. 2010) – confirming the ALJ’s discretion to assess the credibility of subjective symptom testimony.
• Schillo v. Kijakazi, 31 F.4th 64 (2d Cir. 2022) – holding that the ALJ may weigh all evidence to craft an RFC consistent with the record “as a whole.”
• Perez v. Chater, 77 F.3d 41 (2d Cir. 1996) – outlining when the Appeals Council must consider new evidence.

These precedents shaped the court’s reaffirmation of the substantial‐evidence standard, deference to ALJ determinations, and the specific approach required under the 2017 medical‐opinion regulations.

Legal Reasoning

1. Evaluation of Medical Opinions under 20 C.F.R. § 416.920c: The 2017 regulations eliminated the old “treating physician rule” and instead instruct ALJs to assess every medical opinion according to five factors, with supportability and consistency being the most important. Supportability measures how well a provider’s opinion is backed by objective findings and explanations; consistency measures how that opinion aligns with other evidence in the record. Here, the ALJ discussed each relevant opinion—those of NP Charles, Drs. Mendlinger and Sprung (consultative examiners), and the treating social worker Bracero—explaining why some opinions were “unpersuasive” (e.g., NP Charles’s marked limitations) while others were “partially persuasive” in formulating an RFC that accommodated moderate limitations.

2. Substantial Evidence Standard and RFC Formation: The ALJ’s RFC allowed Blanford to perform “medium work” with non‐exertional limits—simple, routine tasks; few changes; and minimal social contact. This finding tracked the moderate functional restrictions identified by consulting sources (Dr. Sprung and agency psychologist Dr. Bruni) and was reinforced by longitudinal treatment notes showing stable mental status and good response to medication. Even where treating sources showed only mild limitations, the ALJ reasonably accommodated occasional paranoia and concentration lapses through non‐public, routine work settings.

3. Credibility Assessment: The ALJ applied the two‐step regulatory framework: first confirming that Blanford’s impairments could cause his alleged symptoms, then assessing the intensity and persistence of those symptoms against the record. The ALJ pointed to inconsistencies in daily activities (shopping, travel, socializing), absence of hospitalizations for mental decompensation, and objective signs of symptom control with treatment. This analysis satisfied Genier’s requirement that an ALJ may discount subjective testimony when reasonably explained.

4. Appeals Council and New Evidence: Blanford submitted a post‐ALJ report by Dr. Ryser. Under 20 C.F.R. § 416.1470(a)(5), the Appeals Council considers new, material evidence related to the period at issue that could change the outcome. The Council found Dr. Ryser’s report duplicative of NP Charles’s previously rejected opinion and insufficient to alter the decision. Because excluded evidence was substantially similar to what the ALJ had already considered, the denial of review was proper.

Impact

Blanford v. Dudek offers important guidance to ALJs, claimants, and practitioners:

• It underscores that supportability and consistency are the determinative factors in weighing medical opinions under the 2017 Social Security regulations.
• It affirms that an ALJ’s RFC must reflect a holistic weighing of the record, including consulting examiners and treating sources, even when some opinions conflict.
• It reinforces the principle that credibility questions—especially regarding daily activities and symptom control—are committed to the ALJ’s reasoned discretion.
• It clarifies that the Appeals Council will reject post‐decision evidence that does not materially alter the established medical picture.

Future SSI and SSDI applicants and their advocates should heed these standards when preparing medical evidence and framing credibility arguments.

Complex Concepts Simplified

• Substantial Evidence: More than a “scintilla” of proof; enough evidence that a reasonable person would accept the Commissioner’s conclusion.
• Supportability: How well a medical opinion is backed by objective tests and provider explanations.
• Consistency: How closely a medical opinion aligns with other medical records and testimony.
• Residual Functional Capacity (RFC): A claimant’s greatest level of work capability despite impairments, combining both physical and mental limitations.
• Treating Physician Rule (Eliminated): The former rule requiring special deference to long‐term treating physicians, now replaced by uniform factors for all medical opinions.
• De Novo Administrative Review: The appellate court’s fresh review of the administrative record to ensure substantial evidence supports the ALJ’s decision.
• Appeals Council New Evidence Standard: The requirement that new evidence be both material to the claim period and likely to change the outcome.

Conclusion

Blanford v. Dudek crystallizes the procedural and substantive framework for evaluating medical opinions in SSI disability determinations under 20 C.F.R. § 416.920c. By affirming the ALJ’s methodical focus on supportability and consistency, the court has fortified the Agency’s shift away from the outdated treating‐physician hierarchy. The decision also demonstrates the rigors of the substantial evidence standard, the ALJ’s latitude in credibility assessments, and the narrow scope for Appeals Council intervention. This ruling will serve as a practical roadmap for adjudicators and practitioners navigating the complex interplay of medical evidence, claimant testimony, and regulatory mandates in disability adjudications.