GAF Scores must be properly considered by the ALJ

A recent case from the Eastern District of Tennessee resulted in a remand on a number of important issues. The first issue discussed in this post concerns GAF scores:

The ALJ rejected the Global Assessment of Functioning (“GAF”) scores. The ALJ reasoned that GAF scores “are not based on standardized norms and admittedly provide only a snapshot impression of an individual’s psychological status. . . .” (Tr. 16). The ALJ further stated that “detailed observations and descriptions in a provider’s notes are a vastly superior reflection of an individual’s true functional abilities than a shorthand GAF score. . . .” (Id.). As Plaintiff notes however, the ALJ does not cite to any observations and descriptions from treating providers to contradict the assigned GAF scores. Plaintiff argues the ALJ rejected the numerous GAF scores in the record that would support a finding of severe social and occupational impairment (Tr. 16). A review of the record shows that from the time of Plaintiff’s alleged onset date through the date of the hearing in this matter, treating psychologists and psychiatrists at the VA, almost without exception, rated Plaintiff’s GAF at 50 and on one occasion 45. (See, e.g., Tr. 763, 780, 783, 790, 1044 and 1068). In light of the multiple GAF scores in this range, I conclude a fuller explanation of the reason for their rejection is required. I note that the GAF scale shows 41 to 50 as serious symptoms but the range of 51 to 60 reflects moderate symptoms. There may be reasons why the ALJ concluded the scores  did not reflect serious symptoms but the articulation of those reasons is for the ALJ and not this court.

Reynolds v. Colvin, 2014 U.S. Dist. Lexis 8450 (E.D.Tenn. Jan. 3, 2014)

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Disability Lawyer in Tennessee and Georgia.

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