Tom Krause, NOSSCR Lifetime Member

What the ALJ Must Explain: A Practitioner’s Guide to the Articulation Requirements in Social Security Rulings

Every disability practitioner learns early that a favorable record is only half the battle. The other half is the written decision, and specifically what the adjudicator is obligated to “say” about the evidence. That duty to articulate reasons in a determination or decision so that the claimant and any reviewing body can follow the reasoning is where a surprising number of remands are won and lost. What follows is a working map of the articulation requirements in the Social Security Rulings, with attention to the rescinded predecessors that still govern claims moving through the pipeline and on court review.

A caution before the map: “articulation requirement” is a term of art in our practice, not an official category SSA maintains as a checklist. Reasonable practitioners may draw the boundary in slightly different places. The rulings discussed below are the well-established core.

The RFC narrative: SSR 96-8p and SSR 96-9p

SSR 96-8p remains the workhorse. Issued 30 years ago this month,[1] it requires that a residual functional capacity assessment include a narrative discussion describing how the evidence supports each conclusion, citing specific medical facts and nonmedical evidence. It demands a function-by-function analysis before the adjudicator collapses the findings into an exertional category, an explanation of how any material inconsistencies or ambiguities in the record were resolved, and a discussion of why reported symptom-related limitations were or were not accepted as consistent with the evidence. A boilerplate exertional conclusion untethered from the seven strength demands is the classic 96-8p defect, and courts across the circuits have remanded on precisely that ground.

One issue deserves emphasis for newer claims. SSR 96-8p instructs that the RFC assessment must address medical source opinions that conflict with the RFC, and explain why an opinion was not adopted, with treating-source opinions entitled to special significance. For claims filed on or after March 27, 2017, the controlling-weight framework was superseded by the revised medical-evidence regulations. The ruling’s core narrative-discussion requirement endures; its treating-source overlay has been overtaken for post-2017 claims. Read SSR 96-8p together with the applicable version of the opinion-evidence rules rather than in isolation.

SSR 96-9p, another Process Unification Ruling, applies to RFC assessments that permit less than a full range of sedentary work. SSR 96-9p carries a parallel command: the assessment must include a narrative that shows the presence and degree of specific limitations and restrictions, along with an explanation of how the evidence was considered. It, too, remains in force and is worth citing whenever a marginal sedentary case turns on an unexplained limitation, such as a sit/stand option specified without a frequency.

Symptom evaluation: SSR 16-3p, drawing on rescinded SSR 96-7p

SSR 16-3p replaced SSR 96-7p[2] in 2016, eliminating the term “credibility” and reframing the inquiry as one of consistency between the claimant’s statements and the record. For articulation purposes, the operative language survived the transition almost verbatim: it is not sufficient for an adjudicator to make a single conclusory statement that the symptoms have been considered or are (or are not) supported, and it is not enough merely to recite the regulatory factors. The determination or decision must contain specific reasons for the weight given to the symptoms, must be consistent with and supported by the evidence, and must be clearly articulated so that the individual and any subsequent reviewer can assess how the adjudicator evaluated the symptoms.

Because that standard is continuous with the old ruling, the substantial body of 96-7p case law on inadequate symptom articulation remains persuasive, so long as briefs are careful to cite 16-3p, not its predecessor. The practical target is unchanged: dismissive language, unexplained rejection of consistent symptom testimony, and findings that fail to bridge the claimant’s statements to the record.

Vocational evidence: SSR 24-3p, replacing rescinded SSR 00-4p (the biggest change)

This is the development most likely to trip up a brief written from memory. Effective January 6, 2025, SSR 24-3p rescinded and replaced SSR 00-4p. Under 00-4p, the adjudicator bore an affirmative duty to ask a vocational expert whether the testimony conflicted with the Dictionary of Occupational Titles, to elicit a reasonable explanation for any apparent conflict and to explain in the decision how the conflict was resolved. That requirement generated a large volume of remands and was a reliable line of attack.

SSR 24-3p purportedly abandons the obligation to resolve conflicts. SSA no longer requires adjudicators to identify and resolve conflicts between vocational testimony and the DOT. In its place is a lighter set of expectations: the expert is expected to identify the data source relied upon, and must acknowledge and explain any instance in which a chosen source defines exertion, education, or skill level differently than SSA’s controlling definitions; the adjudicator then evaluates whether the vocational evidence is adequate to support the finding. Vocational evidence from a qualified, impartial expert is normally deemed to be adequate, and a detailed inquiry is not usually required unless contrary evidence is presented.

Arguably, the burden has shifted toward the hearing itself: with the DOT-conflict articulation duty “gone”, the represented claimant is expected to raise vocational challenges through cross-examination when the expert testifies, rather than banking an unraised conflict for appeal. Generally, an objection not developed on the record will be far harder to preserve. The better practice is to press the VE on data sources and job-number methodology in real time.

To be clear, all is not lost. There is a strong argument that the duty to resolve conflicts still exists. See SSA Rescinds SSR 00-4p—But Does the Duty to Resolve VE Conflicts Survive?, NOSSCR Forum (Dec. 2025). The duty is based on the Social Security Act, the Administrative Procedure Act, and decades of caselaw. It is not clear why SSA believes that rescinding SSR 00-4p relieves the agency of its statutory duty.

Where the medical-opinion articulation requirements went

A recurring theme is that several classic articulation rulings were rescinded not because the duty disappeared but because it migrated into the regulations. Effective for claims filed on or after March 27, 2017, SSA rescinded SSR 96-2p (the treating-source controlling-weight ruling and the origin of the familiar “good reasons” articulation duty), SSR 96-5p (opinions on issues reserved to the Commissioner), and SSR 06-03p (opinions from sources who are not acceptable medical sources, and decisions by other agencies). SSR 17-2p replaced SSR 96-6p.[3]

For those newer claims, the articulation requirement for medical opinions now lives in 20 C.F.R. §§ 404.1520c and 416.920c, which direct the adjudicator to explain how the supportability and consistency of each medical source’s opinion were considered. Supportability and consistency are the two factors SSA deems most important. SSA generally treats the remaining factors as optional to discuss. A complete articulation analysis for a current claim therefore reaches beyond the rulings into the regulations themselves, and a brief that cites only the rescinded rulings for a post-2017 claim invites an easy rebuttal.

Medical equivalence: SSR 17-2p, replacing rescinded SSR 96-6p

SSR 17-2p, effective March 27, 2017, replaced SSR 96-6p and supplies a targeted articulation requirement at step three. To find that an impairment medically equals a listing, the adjudicator must articulate how the record establishes equivalence and must provide a rationale sufficient for a subsequent reviewer or court to understand the decision, generally by identifying the listing at issue and explaining how the record establishes equivalent severity.

The ruling is equally important for what it does *not* require, and this cuts against claimants. When the adjudicator finds that an impairment does *not* equal a listing, SSR 17-2p provides that a general statement to that effect ordinarily suffices, on the theory that the articulation supporting the ultimate disability finding at later steps will explain the step-three conclusion. Counsel expecting a detailed non-equivalence discussion will not find a hook in SSR 17-2p; the leverage lies in developing affirmative equivalence evidence, often through a medical expert, that the adjudicator must then confront.

Past relevant work: SSR 24-2p, replacing rescinded SSR 82-62 and SSR 82-61

For claims pending or filed on or after June 22, 2024, SSR 24-2p governs the step-four past-relevant-work analysis. It rescinded and replaced SSR 82-61 and SSR 82-62 and rescinded SSR 86-8. The new ruling reflects the regulatory change shortening the relevant work period to five years and excluding work that started and stopped in fewer than thirty calendar days, but for our purposes the continuity that matters is the articulation duty: SSR 24-2p expressly addresses what findings and rationale a determination or decision must include when SSA concludes that a claimant can perform past relevant work.

This is the current home of the requirement long associated with SSR 82-62: that a past-work denial rest on specific findings about the claimant’s RFC, the physical and mental demands of the past work, and the conclusion that the RFC permits a return to that work.

The bottom line for practice

The current articulation landscape in the rulings comes down to a manageable set: SSRs 96-8p and 96-9p for the RFC narrative, SSR 16-3p for symptom evaluation, SSR 17-2p for medical equivalence, SSR 24-2p for past relevant work, and the obligations of SSR 24-3p for vocational evidence. These Rulings are supplemented, for medical opinions, by 20 C.F.R. §§ 404.1520c, 416.920c.

---

   [1] SSR 96-8p is one of a series of Rulings issued July 2, 1996. The Process Unification Rulings emerged from class-action lawsuits filed across various states, where plaintiffs alleged significant discrepancies between standards used by State Disability Determination Services (DDSs) and Administrative Law Judges (ALJs). These Rulings continue to have a profound impact on disability claims. See 1996 Process Unification Rulings, NOSSCR Forum (Dec. 2024).

   [2]  SSR 96-7p is also a Process Unification Ruling. See fn. 1, supra.

   [3] SSR 96-2p, 96-5p, and 96-6p are also Process Unification Rulings. See fn. 1, supra.

---

The views and opinions expressed in this article are the author’s own and do not necessarily reflect the views of NOSSCR, its leadership, or staff.

---