Supportability and Consistency: Evaluating Medical Opinion Evidence Under 20 C.F.R. § 404.1520c in Social Security Disability Claims

Introduction

In Susan Chung v. Commissioner of Social Security, the United States Court of Appeals for the Third Circuit addressed the proper application of the post-2017 Social Security Administration regulation governing the evaluation of medical opinions. Appellant Susan Chung, a 26-year financial aid counselor, claimed disabling musculoskeletal and mental impairments. An Administrative Law Judge (ALJ) denied benefits, the District Court upheld that decision, and Chung appealed. The key issues on appeal were whether the ALJ properly weighed the various medical opinions under 20 C.F.R. § 404.1520c—specifically the factors of supportability and consistency—and whether the decision is supported by substantial evidence.

Summary of the Judgment

The Third Circuit affirmed. It held that:

The ALJ permissibly applied the two “most important factors”—supportability and consistency—in weighing opinions of treating and examining sources.
The ALJ was entitled to consider objective medical findings (e.g., electromyogram results), conservative treatment history, and the claimant’s daily activities in evaluating claimed limitations.
The residual functional capacity (RFC) determination, based on all credible limitations, was supported by substantial evidence even though the ALJ gave “reduced persuasiveness” to certain treating opinions.

Accordingly, the court concluded that the ALJ’s evaluation complied with 20 C.F.R. § 404.1520c and affirmed the denial of disability insurance benefits.

Analysis

Precedents Cited

20 C.F.R. § 404.1520c (2017): Eliminated controlling-weight rule; mandates consideration of supportability and consistency of medical opinions.
Biеstеk v. Bеrryhill, 587 U.S. 97 (2019): Defines “substantial evidence” standard.
Plummеr v. Apfеl, 186 F.3d 422 (3d Cir. 1999): ALJ’s obligation to weigh conflicting medical accounts; caution against speculative inferences.
Zaborowski v. Comm’r of Social Security, 115 F.4th 637 (3d Cir. 2024): ALJ need not recite magic words so long as supportability and consistency are woven through the analysis.
Chandlеr v. Comm’r of Social Security, 667 F.3d 356 (3d Cir. 2011): ALJ, not treating physicians, makes ultimate RFC determination.
Mason v. Shalala, 994 F.2d 1058 (3d Cir. 1993): Reduced persuasiveness of checkbox forms.
Morrаlеs v. Apfеl, 225 F.3d 310 (3d Cir. 2000): Limits on ALJ forming lay medical opinions; reliance on objective evidence.
Ruthеrfоrd v. Barnhart, 399 F.3d 546 (3d Cir. 2005): Use of daily activities in assessing limitations.
Other circuit decisions (e.g., Colgan, Miller, Pierce): Address weigh-in-context approach to GAF scores, form reports, and conservative treatment.

Legal Reasoning

Under 20 C.F.R. § 404.1520c, an ALJ must evaluate the persuasiveness of medical opinions using five factors: supportability, consistency, relationship with the claimant, specialization, and any other factor supporting or contradicting the opinion. The regulation designates supportability and consistency as “most important.” Supportability measures how well an opinion is grounded in objective medical data and explanations. Consistency examines agreement with other evidence in the record.

In this case, the ALJ discounted treating occupational medicine specialist Dr. Richman’s “marked” manual limitations and physiatrist Dr. Yang’s similar restrictions because their opinions were not corroborated by objective findings—such as a 2018 electromyogram indicating only mild carpal tunnel syndrome—and contrasted with other exam records (e.g., Dr. Lee’s normal musculoskeletal findings). The ALJ similarly gave reduced weight to the check-box mental health opinions from treating and examining psychologists, finding them inconsistent with largely normal mental status exams, GAF scores, and the claimant’s daily cognitive activities.

The court held these determinations were permissible. The ALJ properly identified objective medical tests and treatment notes, noted conservative treatment approaches, and pointed to the claimant’s ability to perform personal care, household chores, driving, and leisure activities. Because “reasonable minds” could accept the ALJ’s explanation as adequate, the decision rested on substantial evidence.

Impact

This decision reinforces key principles for Social Security disability adjudications:

Post-2017 regulations eliminate deference to treating sources; ALJs are free to weigh all medical opinions equally, guided by supportability and consistency.
Objective diagnostic tests (e.g., EMGs, imaging, range-of-motion measurements) remain central to evaluating claimed impairments.
Conservative treatment and the claimant’s reported activities can be probative in assessing symptom severity.
Check-box forms, GAF scores, and other shorthand notations carry less persuasive weight if unsupported by narrative explanations or objective findings.

Future claimants and decision-makers should expect courts to uphold ALJs’ reasoned evaluations under § 404.1520c where the record contains substantial objective and non-medical evidence supporting the RFC.

Complex Concepts Simplified

Supportability: Does the medical opinion cite objective data (labs, imaging, exam findings) and reasoning to back up limitations?
Consistency: Does the opinion align with other record evidence—other doctors’ notes, diagnostic tests, treatment history, and daily activities?
Residual Functional Capacity (RFC): An assessment of the most a claimant can do despite physical and mental limitations, used to determine work capability.
Electromyogram (EMG): A clinical test measuring electrical activity in muscles; used here to gauge carpal tunnel severity.
Global Assessment of Functioning (GAF): A numerical scale (0–100) reflecting overall psychological functioning; no longer endorsed as determinative but considered as part of the record.
Check-box Forms: Standardized questionnaires that list limitations without detailed narrative; often viewed as less persuasive if unaccompanied by explanatory notes.

Conclusion

Susan Chung v. Commissioner of Social Security clarifies the post-2017 framework for weighing medical opinions in disability cases. It underscores that ALJs must give reasoned consideration to supportability and consistency, may properly rely on objective medical evidence and claimant activities, and need not assign special weight to treating physician opinions. This decision will guide practitioners and adjudicators in applying a uniform, transparent standard to medical evidence, ensuring that RFC determinations rest on substantial evidence rather than rigid deference rules.