On February 10, 2011, the Social Security Administration (“SSA”) Office of Disability Adjudication and Review determined that Lakenisha Dowling (“Appellant”) had been disabled since April 15, 2009. However, on November 3, 2016, an administrative law judge (“ALJ”) found that Appellants disability had ceased as of March 31, 2013. Appellant challenged the ALJs decision in the United States District Court for the District of South Carolina pursuant to 42 U.S.C. § 405(g).
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The district court affirmed the decision of the ALJ, and this appeal followed.
The ALJ committed two legal errors. First, the ALJ erred by failing to consider each of the factors listed in 20 C.F.R. § 404.1527(c) before affording only negligible weight to the medical opinion of one of Appellants treating physicians. Second, the ALJ erred by assessing Appellants residual functional capacity (“RFC”) pursuant to an incorrect framework and without explaining his RFC-related findings in the manner required by Social Security regulations. Accordingly, we reverse the district courts order affirming the decision of the ALJ, and remand for further administrative proceedings consistent with this opinion.
I.
A.
Appellant is 42 years old and resides in South Carolina with her mother and 18 year old daughter. She suffers from a multitude of health problems, the most serious of which relate to her gastrointestinal system. She has lived with inflammatory bowel disease (“IBD”) since 1998 and has been diagnosed with both ulcerative colitis and Crohns disease.
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Appellants IBD causes her to experience diarrhea, abdominal pain, fatigue, body aches, and cramping. In addition, Appellant has a small hole in the skin near her anus, which has been diagnosed as an anal fissure, a perianal fistula, and a pilonidal sinus.
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The fissure routinely leaks and bleeds, and it causes Appellant discomfort when sitting. Appellant also suffers from numerous non-gastrointestinal health problems, including thyroid cancer, obesity, anxiety, anemia, arthritis of the right ankle, and migraine headaches.
Appellant graduated from high school and attended a technical college in Orangeburg, South Carolina, where she became a certified nursing assistant. After receiving this education, Appellant began working full-time in the healthcare sector. She spent six months as a nursing assistant in 2003, followed by nearly seven years as a dialysis technician. Then, in 2009, Appellant began work as a monitor technician at the Regional Medical Center in Orangeburg. Her primary duty as a monitor technician was to enter the doctors’ orders and comments into the hospitals computer system. However, Appellant left that job after only “a couple of months” because she “kept getting sick.” A.R. 140.
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After leaving this job, Appellant did not work again until the spring of 2015, when she began working one day a week as a home health aide for an elderly woman who lives near her.
B.
On May 6, 2009, shortly after leaving her job as a monitor technician, Appellant filed an application for disability insurance benefits pursuant to Title II of the Social Security Act, 42 U.S.C. §§ 401–433. In her application, Appellant claimed she had been “unable to work because of [her] disabling condition” since April 15, 2009. A.R. 274. On February 10, 2011, the SSA Office of Disability Adjudication and Review issued a fully favorable decision to Appellant, in which it found that Appellant suffered from “irritable bowel syndrome, aplastic anemia, arthritis of the right ankle, general anxiety disorder and affective disorder,” and concluded that she had been disabled since April 15, 2009. Id. at 175. However, the SSA decision also noted that Appellants medical condition was expected to improve “with appropriate treatment” and recommended that her case be reviewed again in 12 months. Id. at 178. When the SSA next reviewed Appellants case on March 8, 2013, it found that that her condition had indeed improved and stabilized with medication, and concluded that Appellant was “no longer disabled.” Id. at 184. As a result, Appellants disability benefits terminated in May 2013.
Appellant challenged the SSAs decision to discontinue her disability benefits and requested a hearing before an ALJ. At that hearing, which took place on February 2, 2016, Appellant testified about the activities and tasks she was physically capable of completing, which included driving and riding in a car, cleaning her house, going to the grocery store, putting on clothes, using the bathroom, preparing meals, and doing dishes. She also testified about her job as a home health aide, her medical problems and how they impacted her life, and the medications she took and how they affected her. A vocational expert also appeared at the hearing and testified about the nature of Appellants past jobs and the amount of physical exertion required to adequately perform them.
On November 3, 2016, the ALJ agreed with the initial SSA decision that Appellants disability had ended on March 31, 2013. The ALJ first noted that while Appellant continued to suffer from severe medical impairments, her overall medical condition had significantly improved between February 10, 2011, the day that she was originally determined to be disabled, and March 31, 2013. The ALJ found that, because of her medical improvement, Appellant possessed the RFC to perform sedentary work,
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but not work that required: (1) “lifting or carrying of more than 10 pounds ․ or lifting or carrying of less than 10 pounds more than frequently”; (2) “walking in combination for more than a total of 2 hours in an 8 hour workday”; or (3) “more than occasional stooping, balancing, crouching, kneeling, or climbing stairs or ramps.” J.A. 11.
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In the ALJs view, Appellants past work did not require her to engage in any of those activities. Therefore, the ALJ concluded that Appellants disability had ended. In reaching this conclusion, the ALJ afforded only “negligible weight” to the medical opinion of Dr. Rachael Gross, one of Appellants treating physicians. J.A. 16.
Per Appellants request, the SSA Office of Disability Adjudication and Review reviewed the ALJs decision on December 7, 2017, but found no basis for changing it. At that point, the ALJs decision became “the final decision of the Commissioner of Social Security in [this] case.” A.R. 1. Appellant then challenged the ALJs decision in the United States District Court for the District of South Carolina, which affirmed, finding the ALJs decision to be supported by substantial evidence. The ALJs decision is now before this court. We hold that it must be reversed.
II.
We review the ALJs Social Security disability determination pursuant to the standard set out in 42 U.S.C. § 405(g). We must uphold the ALJs decision if the ALJ “applied correct legal standards” and if the “factual findings are supported by substantial evidence.” Bird v. Commr of SSA, 699 F.3d 337, 340 (4th Cir. 2012) (citing 42 U.S.C. § 405(g)). “Substantial evidence is that which a reasonable mind might accept as adequate to support a conclusion.” Pearson v. Colvin, 810 F.3d 204, 207 (4th Cir. 2015) (internal quotation marks omitted). Though the “threshold for such evidentiary sufficiency is not high,” it requires that “more than a mere scintilla” of evidence support the ALJs findings. Shinaberry v. Saul, 952 F.3d 113, 120 (4th Cir. 2020). In undertaking this review, it is not our place to “re-weigh conflicting evidence, make credibility determinations, or substitute our judgment for that of the [ALJ].” Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996). However, “we do not reflexively rubber-stamp an ALJs findings.” Lewis v. Berryhill, 858 F.3d 858, 870 (4th Cir. 2017).
III.
A.
Regulatory Procedure
SSA regulations establish an eight-step procedure for determining whether a recipient of disability insurance benefits continues to be disabled. See 20 C.F.R. § 404.1594(f)(1)–(8). Those steps are as follows: (1) Is the claimant engaging in substantial gainful activity? If yes, the disability has ended. If no, proceed to step two. (2) Does the claimant have an impairment or combination of impairments which meets or equals an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1? If yes, the disability continues. If no, proceed to step three. (3) Has there been medical improvement as shown by a decrease in the medical severity of the impairment(s) that existed at the time of the most recent favorable disability decision? If yes, proceed to step four. If no, proceed to step five. (4) Is the medical improvement related to the ability to work, i.e., has there been an increase in the claimants RFC? If yes, proceed to step six. If no, proceed to step five. (5) Do any of the exceptions set out in 20 C.F.R. § 404.1594(d) or (e) apply? If none of them apply, the claimants disability continues. If one of the first group of exceptions to medical improvement applies, proceed to step six. If one of the second group of exceptions to medical improvement applies, the claimants disability has ended. (6) Is the claimants current impairment or combination of impairments severe? If yes, proceed to step seven. If no, the disability has ended. (7) Does the claimant possess the RFC to perform her past relevant work? If yes, the disability has ended. If no, proceed to step eight. (8) Does the claimants RFC, when considered with the claimants age, education, and work experience, allow the claimant to do other work? If yes, the disability has ended. If no, the disability continues. See id.
In this case, Appellants continuing eligibility for disability benefits boiled down to steps seven and eight: the assessment of whether, despite her severe impairments, she possessed the RFC to perform work she had done in the past. The ALJ found that, as of March 31, 2013, Appellant possessed an RFC “to perform sedentary work,” J.A. 11, which rendered her “capable of performing past relevant work,” id. at 18. Accordingly, the ALJ determined that Appellant ceased to be disabled as of that date.
B.
Medical Opinion Evidence
On May 4, 2015, Dr. Gross, Appellants treating physician from 2011 through 2016,
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submitted a treating source statement (the “Statement”) concerning Appellants medical impairments and ability to perform certain physical functions. In the Statement, Dr. Gross diagnosed Appellant with, inter alia, IBD, migraines, anxiety, depression, and thyroid cancer. She also explained that these conditions caused Appellant to experience fatigue, joint pain, abdominal pain, dizziness, and headaches. Dr. Gross then expressed her medical opinion as to Appellants ability to engage in certain activities. The prognosis was bleak. According to Dr. Gross, Appellant had the ability to sit for only 15 to 30 minutes at one time, and could not sit for even two hours “total in an 8-hour working day (with normal breaks).” A.R. 774. Dr. Gross opined that Appellant “frequently” experienced “pain severe enough to interfere with attention and concentration.” Id.
In his November 3, 2016 decision, although the ALJ acknowledged Dr. Grosss Statement, the ALJ stated that he gave the medical opinion contained therein only “negligible weight.” J.A. 16. We conclude that the ALJ erred in his treatment of Dr. Grosss medical opinion. The ALJ was required to do more than simply acknowledge the existence of Dr. Grosss opinion.
1.
When determining Appellants Social Security disability status, the ALJ was required to consider the medical opinions of Appellants treating physicians. See 20 C.F.R. § 404.1527(b) (“[W]e will always consider the medical opinions in [a claimants] case record.”).
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Furthermore, the ALJ was obligated to weigh those medical opinions in compliance with 20 C.F.R. § 404.1527(c)(2).
Section 404.1527(c)(2) sets out two rules an ALJ must follow when evaluating a medical opinion from a treating physician. First, it establishes the “treating physician rule,” under which the medical opinion of a treating physician is entitled to “controlling weight” if it is “well-supported by medically acceptable clinical and laboratory diagnostic techniques and is not inconsistent with the other substantial evidence in [the] case record.” 20 C.F.R. § 404.1527(c)(2); see also, e.g., Arakas v. Commr of SSA, 983 F.3d 83, 106–07 (4th Cir. 2020) (citing Section 404.1527(c)(2) and applying the treating physician rule); Brown v. Commr of SSA, 873 F.3d 251, 255–56 (4th Cir. 2017) (same). Second, if a medical opinion is not entitled to controlling weight under the treating physician rule, an ALJ must consider each of the following factors to determine the weight the opinion should be afforded: (1) the “[l]ength of the treatment relationship and the frequency of examination”; (2) the “[n]ature and extent of the treatment relationship”; (3) “[s]upportability,” i.e., the extent to which the treating physician “presents relevant evidence to support [the] medical opinion”; (4) “[c]onsistency,” i.e., the extent to which the opinion is consistent with the evidence in the record; (5) the extent to which the treating physician is a specialist opining as to “issues related to his or her area of specialty”; and (6) any other factors raised by the parties “which tend to support or contradict the medical opinion.” 20 C.F.R. § 404.1527(c)(2)(i)–(6).
2.
Here, substantial evidence supports the ALJs decision to not give controlling weight to the medical opinion contained in Dr. Grosss Statement. This is because while there is no indication that Dr. Grosss opinion was not “well-supported by medically acceptable clinical and laboratory diagnostic techniques,” 20 C.F.R. § 404.1527(c)(2), a reasonable mind could conclude that the opinion conflicts with other evidence in the record. For instance, treatment notes from some of Appellants other treating physicians demonstrate that, in the time leading up to the hearing before the ALJ, Appellant had experienced significant improvement with respect to her IBD. See, e.g., A.R. 720 (Dr. Narayanachar Murali, a gastroenterology specialist, noting that Appellants “abdominal pain is less intense and less frequent”), 890 (Dr. Murali noting that Appellants IBD “symptoms have regressed dramatically”).
Although we accept the ALJs conclusion that Dr. Grosss medical opinion was not entitled to controlling weight, it does not follow that the ALJ had free reign to attach whatever weight to that opinion that he deemed fit. The ALJ was required to consider each of the six 20 C.F.R. § 404.1527(c) factors before casting Dr. Grosss opinion aside. The ALJ plainly failed to do so.
3.
The ALJ explained that he afforded only negligible weight to Dr. Grosss medical opinion because he found the opinion to be inconsistent with other evidence in the record, and the basis for the opinion was “not adequately explained” by Dr. Gross. J.A. 16. This explanation by the ALJ touches on two of the Section 404.1527(c) factors -- consistency and supportability. However, there is no indication that the ALJ actually undertook the required analysis of Dr. Grosss opinion. Indeed, the ALJ never so much as acknowledged the existence of the Section 404.1527(c) factors. Moreover, the ALJ was completely silent as to the remaining four Section 404.1527(c) factors; for instance, the ALJ considered neither the “[l]ength of the treatment relationship and the frequency of examination,” nor the “[n]ature and extent of the treatment relationship.” 20 C.F.R. § 404.1527(c)(2)(i)–(ii).
The ALJs failure to consider each of the Section 404.1527(c) factors was error. While an ALJ is not required to set forth a detailed factor-by-factor analysis in order to discount a medical opinion from a treating physician, it must nonetheless be apparent from the ALJs decision that he meaningfully considered each of the factors before deciding how much weight to give the opinion. See Arakas, 983 F.3d at 107 n.16 (“20 C.F.R. § 404.1527(c) requires ALJs to consider all of the enumerated factors in deciding what weight to give a medical opinion.” (emphasis in original)); Newton v. Apfel, 209 F.3d 448, 456 (5th Cir. 2000) (agreeing with the “[s]everal federal courts [that] have concluded that an ALJ is required to consider each of the § 404.1527[c] factors” when weighing the medical opinion of a treating physician). In this case, it is far from apparent that the ALJ considered -- or was even aware of -- each of the Section 404.1527(c) factors. In addition to ignoring a majority of the specific factors, the ALJs decision was bereft of any reference to the factors as a whole. The ALJ simply declared that he possessed “the discretion to give less [than controlling] weight” to the opinion of the treating physician. J.A. 15. The ALJ never so much as hinted that his discretion was checked by the factors enumerated in Section 404.1527(c), which it is. In failing to acknowledge and apply each of these six factors, the ALJ erred.
4.
This error necessitates a remand in this case. Two of the factors ignored by the ALJ -- those which relate to the length, frequency, nature, and extent of Appellants treatment relationship with Dr. Gross -- appear to cut in Appellants favor. Dr. Gross was Appellants family physician. The record demonstrates that from as early as 2011 through at least 2016, Dr. Gross treated her regularly, with appointments occurring at least every three months. Through these frequent appointments, Dr. Gross surely “obtained a longitudinal picture of [Appellants] impairment[s].” 20 C.F.R. § 404.1527(c)(2)(i). Had the ALJ properly considered the treatment relationship between Dr. Gross and Appellant, he may not have been so quick to reject Dr. Grosss medical opinion. This is significant, because if the ALJ had accorded greater weight to Dr. Grosss opinion that Appellant was incapable of sitting for even two hours total in an eight-hour working day and that she frequently experienced pain so severe that it interfered with her attention and concentration, this reasonably could have altered the ALJs conclusion that Appellant was capable of performing sedentary work.
Further, it is an elemental principle of administrative law that agency determinations must “be made in accordance with certain procedures which facilitate judicial review.” Patterson v. Commr of SSA, 846 F.3d 656, 662 (4th Cir. 2017). One such procedure is Section 404.1527(c)’s requirement that ALJs consider each of the enumerated factors before assigning less than controlling weight to a medical opinion from a treating physician. Here, the ALJ neglected to even acknowledge the existence of those factors, much less engage in a meaningful discussion of them, so as to facilitate judicial review. Therefore, remand is necessary to allow the ALJ to consider Dr. Grosss medical opinion in light of each of the Section 404.1527(c) factors. See id. at 662–63 (remanding and noting that “because we cannot gauge the propriety of the ALJs [ ] assessment, we cannot say that substantial evidence supports the ALJs denial of benefits”); Cook v. Heckler, 783 F.2d 1168, 1173 (4th Cir. 1986) (remanding where the ALJs failure to comply with certain Social Security procedures made it “simply impossible to tell whether there was substantial evidence to support [his] determination”).
C.
Residual Functional Capacity Assessment
The failure to consider each of the 20 C.F.R. § 404.1527(c) factors was not the only error committed by the ALJ. The ALJ was also required to assess Appellants RFC when determining her disability status. See 20 C.F.R. § 404.1594(f)(7). When the ALJ did so, he concluded that, as of March 31, 2013, Appellant “had the residual functional capacity to perform sedentary work,” but could not perform work requiring lifting, carrying, walking, stooping, balancing, crouching, kneeling, or climbing stairs or ramps. J.A. 11. The ALJ did not find that Appellant faced any limitations concerning her ability to sit. The ALJ explained that he based his RFC assessment on Appellants alleged “symptoms and the extent to which these symptoms can reasonably be accepted as consistent with the objective medical evidence and other evidence,” including the medical opinions of Appellants treating physicians. Id. But we conclude that the framework through which the ALJ evaluated Appellants RFC and the manner in which he explained his RFC findings were both in error.
1.
A Social Security claimants RFC represents “the most [she] can still do despite [her] limitations.” 20 C.F.R. § 416.945(a)(1). Evaluating an RFC requires an ALJ to “consider all of the claimants ‘physical and mental impairments, severe and otherwise, and determine, on a function-by-function basis, how they affect [her] ability to work.’ ” Thomas v. Berryhill, 916 F.3d 307, 311 (4th Cir. 2019) (quoting Monroe v. Colvin, 826 F.3d 176, 188 (4th Cir. 2016)). Pursuant to Social Security Ruling
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96-8p, 1996 WL 374184, at *1 (July 2, 1996), an ALJs RFC assessment must include an evaluation of the claimants ability to perform the physical functions listed in 20 C.F.R. § 416.945(b). These functions are: “sitting, standing, walking, lifting, carrying, pushing, pulling, or other physical functions [that] may reduce [a claimants] ability to do past work and other work.” 20 C.F.R. § 416.945(b). “Only after such a function-by-function analysis may an ALJ express RFC in terms of the exertional levels of work” of which he believes the claimant to be capable. Monroe, 826 F.3d at 179 (internal quotation marks omitted). Finally, every conclusion reached by an ALJ when evaluating a claimants RFC must be accompanied by “a narrative discussion describing [ ] the evidence” that supports it. Thomas, 916 F.3d at 311. In this case, the ALJs evaluation of Appellants RFC fell short of these requirements.
2.
Here, the ALJ relied on an incorrect regulatory framework when he assessed Appellants RFC. He did not cite to 20 C.F.R. § 416.945, the section of the Code of Federal Regulations that is titled “Your residual functional capacity” and explains how ALJs should assess a claimants RFC. Nor did he cite to SSR 96-8p, the 1996 Social Security Ruling that provides guidance on how to properly evaluate an RFC. Finally, the ALJ did not indicate that his RFC assessment was rooted in a function-by-function analysis of how Appellants impairments impacted her ability to work. Instead, the ALJs RFC determination was based entirely on SSRs 96-7p and 16-3p, which set out the process ALJs use to “evaluate the intensity and persistence of [a claimants] symptoms” and determine “the extent to which the symptoms can reasonably be accepted as consistent with the objective medical and other evidence in the [ ] record.” SSR 16-3p, 2017 WL 5180304, at *2 (Oct. 25, 2017).
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Of course, a claimants symptoms, and the extent to which the alleged severity of those symptoms is supported by the record, is relevant to the RFC evaluation. See 20 C.F.R. § 416.945(a)(3) (stating that when evaluating an RFC, an ALJ should consider “limitations that result from [the claimants] symptoms, such as pain”). But an RFC assessment is a separate and distinct inquiry from a symptom evaluation, and the ALJ erred by treating them as one and the same.
The ALJs reliance on an incorrect regulatory framework led to an erroneous RFC assessment that, like the ALJs failure to consider each of the 20 C.F.R. § 404.1527(c) factors, requires us to remand this case. We find three aspects of the ALJs RFC analysis particularly troubling.
a.
First, the ALJ expressed Appellants RFC “in terms of [ ] exertional levels of work” without first engaging in “a function-by-function analysis.” Monroe, 826 F.3d at 179. “[A] proper RFC analysis” proceeds in the following order: “(1) evidence, (2) logical explanation, and (3) conclusion.” Thomas, 916 F.3d at 311. But here, the ALJ began with step three, noting at the outset of his RFC evaluation that Appellant only “had the residual functional capacity to perform sedentary work.” J.A. 11. Only then did the ALJ identify evidence and attempt to explain how that evidence logically supported his predetermined conclusion. In this way, the ALJ assessed Appellants RFC in a manner that this court rejected as erroneous in Thomas. There, like here, the ALJ stated the claimants “RFC first and only then conclud[ed] that the limitations caused by [her] impairments were consistent with that RFC.” Thomas, 916 F.3d at 312 (emphasis and alteration in original).
b.
Second, the ALJ did not properly assess the extent to which Appellants sitting problems impacted her ability to work. Appellant has argued throughout her administrative and judicial proceedings that her IBD and anal fissure cause her to experience discomfort when she sits for a prolonged period of time. But the ALJ apparently concluded that Appellant was not restricted in her ability to sit, as he did not indicate that her RFC was limited because of those problems. This conclusion should have been the result of an analysis that was separate from the ALJs appraisal of Appellants ability to perform other functions, and should have been accompanied by “a narrative discussion describing” the evidence supporting it. Thomas, 916 F.3d at 311. The ALJs evaluation of Appellants ability to sit was lacking in both respects. The ALJ never specifically discussed the extent to which Appellants alleged sitting problems impacted her ability to perform sedentary work. The ALJ could not have supported a conclusion in this regard through a narrative discussion concerning the relevant evidence because he reached no such express conclusion in the first instance. In fact, the ALJ barely mentioned Appellants sitting problems in his decision, and discussed them only when rattling off a laundry list of her many impairments and functional restrictions. This grouping of Appellants sitting limitations with her other impairments and restrictions is a far cry from the “function-by-function analysis” the ALJ was required to conduct.
In arguing that the ALJs RFC assessment does not require remand, Appellee, the Commissioner of the Social Security Administration, makes much of the fact that in Mascio v. Colvin, 780 F.3d 632, 636 (4th Cir. 2015), we declined to adopt “a per se rule requiring remand when the ALJ does not perform an explicit function-by-function analysis.” But the lack of a rule requiring remand does not mean that remand is never the appropriate outcome when an ALJ fails to engage in a function-by-function analysis. Moreover, the reasoning in Mascio actually bolsters our conclusion that remand is required here. In that case, we were concerned that a per se rule would require ALJs to “discuss functions that [were] irrelevant or uncontested.” Id. (internal quotation marks omitted). This case does not raise such concerns. The parties disagree over the extent that Appellants medical conditions restricted her ability to sit, which makes that function “contested.” Moreover, assessing Appellants ability to sit is critically relevant to determining her disability status, as she likely would have been deemed incapable of performing sedentary work if the ALJ had found that, in addition to not being able to lift, carry, stand, stoop, balance, and climb stairs or ramps, she was not able to sit for a prolonged period of time.
c.
Third, the ALJ failed to analyze whether Appellants RFC was impacted by her need to work near a restroom and take frequent bathroom breaks. There is considerable evidence in the record demonstrating that Appellant regularly experienced diarrhea and incontinence, as well as drainage from her anal fissure. Appellant argues that these problems caused her to require bathroom breaks at a frequent, and often unpredictable, rate. Obviously, the need to visit the bathroom many times throughout the day impacts ones ability to work. And yet, the ALJ did not analyze Appellants need for regular bathroom breaks. Instead, the ALJ simply noted that Appellant “accommodate[d] her drainage and accidents by using pads.” J.A. 16. That finding misses the point. Pads may keep Appellants clothes clean and help reduce the potential for embarrassing accidents. However, they do not save Appellant any trips to the bathroom, since the pads need to be changed once they are soiled. On remand, the ALJ should evaluate the frequency at which Appellant needed to use the bathroom and analyze how that restriction impacted her ability to work.
IV.
For the reasons set forth herein, we reverse the district courts order affirming the decision of the ALJ. The case is remanded to the district court with instructions to remand to the Commissioner for further administrative proceedings consistent with this opinion.
REVERSED AND REMANDED
FOOTNOTES
1
. 42 U.S.C. § 405(g) provides, “Any individual, after any final decision of the Commissioner of Social Security ․ may obtain a review of such decision by a civil action commenced ․ in the district court of the United States for the judicial district in which the plaintiff resides ․”
2
. Although we recognize that ulcerative colitis and Crohns disease are distinct forms of inflammatory bowel disease, we will refer to these ailments collectively as “IBD.”
3
. Again recognizing these are different afflictions, for simplicitys sake, we will refer to the hole in Appellants skin as an “anal fissure.”
4
. Citations to the “A.R.” refer to the Administrative Record filed in this appeal, which has been certified as accurate by the Office of Appellate Operations of the SSA.
5
. 20 C.F.R. § 404.1567(a) defines sedentary work as that which “involves lifting no more than 10 pounds at a time and occasionally lifting or carrying articles like docket files, ledgers, and small tools.” Additionally, that section provides, “Although a sedentary job is defined as one which involves sitting, a certain amount of walking and standing is often necessary in carrying out job duties. Jobs are sedentary if walking and standing are required occasionally and other sedentary criteria are met.” Id.
6
. Citations to the “J.A.” refer to the Joint Appendix filed by the parties in this appeal.
7
. The record demonstrates that Dr. Gross regularly treated Appellant during the SSA review period. However, it is not clear from the record precisely when that treating relationship began and whether it has concluded. Thus, it is possible that Dr. Grosss treatment of Appellant began earlier than 2011 and has continued past 2016.
8
. 20 C.F.R. § 404.1527 has been replaced by 20 C.F.R. § 404.1520c as the regulation that governs the evaluation of medical opinion evidence in Social Security cases. However, Section 404.1527 still applies to all Social Security claims filed before March 27, 2017, and, thus, remains the applicable regulation in this case.
9
. Social Security Rulings, or “SSRs,” are “interpretations by the Social Security Administration of the Social Security Act.” Pass v. Chater, 65 F.3d 1200, 1204 n.3 (4th Cir. 1995). They do not carry the force of law but are “binding on all components of the Social Security Administration,” 20 C.F.R. § 402.35(b)(1), as well as on ALJs when they are adjudicating Social Security cases, see Bray v. Commr of SSA, 554 F.3d 1219, 1224 (9th Cir. 2009).
10
. SSR 16-3p rescinded and superseded SSR 96-7p on March 28, 2016. Nonetheless, the ALJ cited to both rulings in his November 3, 2016 decision.
THACKER, Circuit Judge:
Reversed and remanded by published opinion. Judge Thacker wrote the opinion, in which Judge King and Judge Floyd concurred.