PUBLISH UNITED STATES CO URT OF APPEALS FOR THE TENTH CIRCUIT

REBECCA L. MAYS, Plaintiff - Appellant,

v. CAROLYN W. COLVIN, Acting Commissioner, Social Security Administration, Defendant - Appellee. No. 13-5068

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE NORTHEN DIST RICT OF OKLAHOMA. (D.C. No. 4:10-CV-00506-FHM)

Submitted on the briefs: * Richmond J. Brownson, Timothy M. White, Tulsa, Oklahoma, for Plaintiff-Appellant. Danny C. Williams, Sr., United States Atto rney, Cathryn D. McClanahan, Assistant United States Attorney, Michael McGaughra n, Regional Chief Counsel, Region VI, Dianne Mullins Pryor, Special Assistant Un ited States Attorney, Social Security Administration, Office of General C ounsel, Region VI, Da llas, Texas, for Defendant-Appellee.

* After examining the briefs and appellate record, this pane l has determined unanimously to grant the parties’ request for a decision on the briefs without oral argument. See Fed. R. App. P. 34(f); 10th Cir. R. 34.1(G). The case is therefore ordered submitted without oral argument. FILED United States Court of Appeals Tenth Circuit 

### January 8, 2014
Elisabeth A. Shumaker Clerk of Court- 2 - Before LUCERO , Circuit Judge, BRORBY , Senior Circuit Judge, and BACHARACH , Circuit Judge.

BACHARACH , Circuit Judge.
Ms. Rebecca L. Mays appeals from a di strict court order affirming the Social Security Administration’s denial of her applic ation for disability be nefits. We affirm. I. Background Ms. Mays applied for bene fits, alleging a disability beginning in May 2004. The assessment began at step one, w ith the administrative law judge finding that Ms. Mays had not engage d in substantial gainful ac tivity from the alleged onset date to the date that her insurance coverage ended. At step two of the sequential evaluation process, the administrative law judge found a severe impairment of low back pain. At step three, the ALJ found that the impairments did not meet or medically equal the regulatory “listings,” wh ether alone or in combination. In assessing the residual functional cap acity at step four, the ALJ found a residual functional capacity that allowe d Ms. Mays to perform a full range of sedentary work. In making this finding, th e ALJ found that the opinion of Ms. Mays’ treating physician, Dr. Chorley, was not consistent with the objective medical evidence. The ALJ also found at step four that Ms. Mays could not perform her past relevant work.- 3 - But the judge determined at step five th at jobs existed in the national economy that Ms. Mays could perform. Thus, the AL J found that Ms. Mays was not disabled. The Appeals Council denied her request for review, and the district court affirmed the Social Security Administration’s decision. II. The Claims Ms. Mays raises two issues on appeal. First, she claims that the Social Security Administration failed to provide a complete administrati ve record. Second, she contends that the ALJ failed to properly analyze the medical source evidence. III. The Standard of Review “We review the Commissioner’s decision to determine whether the factual findings are supported by s ubstantial evidence and wh ether the correct legal standards were applied.” Robinson v. Barnhart , 366 F.3d 1078, 1080 (10th Cir. 2004) (internal quotation marks omitted). IV. Claims Regarding the Incomplete Administrative Record Ms. Mays’ first claim relates to Dr . Chorley’s assessment of residual functional capacity. Dr. Chorley changed th is assessment, but the new version was mistakenly omitted in the ev entual administrative record. Ms. Mays contends that the omission entailed a denial of due proce ss and left the eventual findings without substantial evidence. We reject these contentions.- 4 - A. The Error in the Administrative Record During the hearing, Ms. Ma ys asked if she could s ubmit a new version of the doctor’s written report. Ms. Mays represen ted that the two reports were identical with one exception. In the amended re port, Dr. Chorley dow ngraded Ms. Mays’ ability to sit, st and, and walk. On page 1 of his original report, Dr. Chorley had opin ed that Ms. Mays could:

● sit for 3 hours, stand for 2 hours, and walk for 1 hour at a time,

● sit or stand for a to tal of 3 hours, and

● walk for a total of 2 hours during an 8-hour work day. In the amended report, Dr. Chorley stated that Ms. Mays could stand and walk for 10 to 30 minutes at a time; sit and stand for a total of 2 hour s in an 8-hour work day; and walk for a total of 1 hour. The ALJ stated that page 1 of Dr. Chor ley’s original repor t was withdrawn and the amended page 1 was subs tituted in its place. The amended report was handed to the vocational expert, who was asked to assume the limita tions stated there. The vocational expert testified that accordi ng to the amended repor t, Ms. Mays could stand and walk for 10 to 30 minutes at a time; sit and stand for a tota l of 2 hours in an 8-hour work day; and walk for a total of 1 hour. The expert added that there would be no competitive work available to a pers on with the physical abilities stated in Dr. Chorley’s amended report.- 5 - The amended page 1 of the report was not ultimately incorporated into the administrative record. Thus, the record contains only the original version of Dr. Chorley’s report. B. The Due-Process Claim Ms. Mays contends that the error in the administrative r ecord resulted in a deprivation of due process because the ALJ and the Appeals Council could not review an exhibit missing from the reco rd. Without the new page, the ALJ and Appeals Council could review only the versi on of Dr. Chorley’s re port that had been withdrawn. Because the error was not pr ejudicial, we reject Ms. Mays’ due-process claim.
1. The District Court’s Reasoning The district court rejected Ms. Mays’ due-process claim, reasoning that the information from the amended page 1 of Dr. Chorley’s report was in the record through the vocational expert’s testimony. As we have noted, the vocational expert recited the limitations from that page when he answer ed the ALJ’s questions. Based on this exchange, the district court conc luded that the ALJ had considered the amended report. We agree with the district court that: (1) Dr. C horley’s amended report was presented at the hearing a nd its contents appeared in the administ rative record through the vocational expert ’s testimony, and (2) the AL J considered the amended report during the hearing. But these c onclusions do not fully address Ms. Mays’- 6 - current claims. She argues that in the eventual written d ecision, the ALJ relied on the wrong evidence (the original ve rsion of Dr. C horley’s report).
2. The Social Security Admi nistration’s Argument The Social Security Administration does not dispute Ms. Mays ’ assertion that the ALJ based his decision on Dr. Chorley’s or iginal report. From that conclusion, the agency argues that the original report was properly included in the administrative record and that the doctor’s amended report was properly excluded . The agency therefore contends that: (1) Ms. Mays is seeking a remand to submit new evidence, and (2) we need not remand because Dr. C horley’s amended repor t is immaterial.
See 42 U.S.C. § 405(g) (providing that new evidence must be material to justify a remand); Cagle v. Califano , 638 F.2d 219, 22 1 (10th Cir. 1981) (holding that a remand is proper when the reviewing c ourt concludes that the “decision might reasonably have been di fferent” had the new evid ence been considered). This reasoning, like the di strict court’s, does not fully address Ms. Mays’ current argument. Ms. Mays acknowledges that the record matches the ALJ’s decision. But Ms. Mays contends that both are wrong because Dr. Chorley amended his report and the ALJ purporte d to accept the amendment.
3. The Prejudice Inquiry Though we reject the reasoning of the di strict court and th e Social Security Administration, we must decide whether the error in the record deprived Ms. Mays of due process. We conclude that no du e-process violation took place because- 7 - Ms. Mays has not shown a lik elihood of a different resu lt if the ALJ had addressed Dr. Chorley’s amended repor t. Consequently, the due -process claim must fail. 1 “Social security hearings are s ubject to procedural due process considerations.” Yount v. Barnhart , 416 F.3d 1233, 1235 (10th Cir. 2005). A due process claim will not succeed, however, if th e claimant fails to show prejudice. See Energy W. Mining Co. v. Oliver , 555 F.3d 1211, 1219 (10th Cir. 2009). Thus, when “a party complains about the course of administrative pr oceedings, that party must demonstrate that the adjudicati on was infected by some prejudicial, fundamentally unfair element.” Id. (internal quotation marks omitted); see Glass v. Shalala , 43 F.3d 1392, 1396-97 (10th Cir. 19 94) (requiring a showing of prejudice for a due-process claim involving social-security proceedings). Ms. Mays contends that Dr. Chorley’s amended repo rt would be crucial on remand because it corrected an internal inconsistency be tween pages 1 and 3 of the doctor’s original report. On page 1 of th e original report, Dr. Chorley opined that Ms. Mays could sit for 3 ho urs, stand for 2 hours, an d walk for 1 hour. But Dr. Chorley added on page 3 that Ms. Ma ys was unable to maintain a position of comfort for more than 10 minutes. See Aplt. App., Vol. 3, at 280, 282. Ms. Mays asserts that Dr. Chorley’s amended report eliminated this inconsistency by reducing

1 We note that it is not clear how the amended version of Dr. Chorley’s report came to be omitted from the administrative record. It a ppears that Ms. Mays was the party responsible for ensuring that it wa s included. According to the hearing transcript, she agreed to subm it the replacement page electr onically after the hearing. The record does not disclo se whether she did so.- 8 - her abilities to stand and walk on page 1 to only 10 to 30 minutes at a time. Therefore, she claims, th e difference in the two ve rsions is significant. We disagree because the ALJ did not reje ct Dr. Chorley’s original report based on an internal inconsistency. Rather, the ALJ concluded that the doctor’s opinion was not supported by the obj ective medical evidence. The ALJ cited Dr. Chorley’s narrative, which involved his opinion th at Ms. Mays was 100% disabled until surgical intervention. Dr. Chorley did not alter that assessment in his amended report when he upgraded Ms. Mays’ limitations on page 1. Therefore, Ms. Mays fails to show a likelihood of a different result if the ALJ had considered the doctor’s greater restrictions in his amended report. Without such a showing, we do not regard the error in the record as pr ejudicial. And without prejudice, we must reject the due-process claim. C. The Claim Involving a La ck of Substantial Evidence Ms. Mays also argues that the mistake in the record left the decision without substantial evidence. We disagree. “We have defined ‘substantial evidence’ as more than a scinti lla. It is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Glass v. Shalala , 43 F.3d 1392, 1395 (10th Cir. 1994) (internal quotation marks omitted). Ms. Mays asserts that th e ALJ’s decision is not supported by substantial evidence because th e record is incomplete. We reje ct this argument for the reasons- 9 - discussed above with the due -process claim. The ALJ ha d substantial evidence to reasonably reject Dr. Chorley’ s conclusions, and the existe nce of that evidence is not undermined by the technical failure to repl ace one of the pages in the administrative record. V. Claims Regarding the ALJ’s Evalua tion of the Medica l Source Evidence Ms. Mays contends that the ALJ al so failed to pr operly analyze the medical-source evidence. These contentions focus primarily on the ALJ’s rejection of Dr. Chorley’s opinion. We re ject each of the contentions. A. The Required Process for Evalua ting a Treating Physician’s Opinion The ALJ must follow a specific pro cess when weighing a treating physician’s opinion: An ALJ must first co nsider whether the opi nion is well-supported by medically acceptable clinical and labor atory diagnostic techniques. . . . If the ALJ finds that the opinion is well-supported, he must then confirm that the opinion is consistent with other substantial evidence in the record. Robinson v. Barnhart , 366 F.3d 1078, 1082 (10th Ci r. 2004) (internal quotation marks omitted). “[I]f the opinion is deficient in either of these respects, then it is not entitled to controlling weight.” Id. And if the ALJ does not assign controlling weight to a treating physician’ s opinion, it is still entitled to deference and subject to weighing under the relevant factors. See id. ; see also 20 C.F.R. § 40 4.1527 (listing the factors).- 10 - B. The ALJ Properly Explained His Rejection of Dr. Chorley’s Opinion and Had Substantial Evidence for the Findings Dr. Chorley opined that Ms. Mays was 100% disabled until surgical intervention. The ALJ rejected this opini on, concluding that this opinion was not consistent with the objective medical evidence. Ms. Mays argues that the ALJ erred by:

 failing to specify the weight as signed to Dr. Chorley’s opinion,

 relying on a 2006 MRI and a 2008 CT,

 disregarding evidence of retrolisthesis,

 referring to Ms. Mays’ comment about pain control through medication,

 failing to consider the regulatory factors,

 selectively referri ng to the evidence,

 using boilerplate language,

 relying on a consultative examiner’s opinion, and

 misconstruing the consultative examiner’s statements. The ALJ pointed to two me dical tests: (1) a 2006 MRI that “revealed only central disc protrusion at L5-S1” that “i ndented the thecal sac but did not clearly result in neural encroachment ,” and (2) a 2008 CT of the lumbar spine th at “revealed minimal disk bulge without spinal or neur al foraminal impingement.” Aplt. App., Vol. 2, at 16. The ALJ also cited the re port of a consultative examiner, Dr. Nodine, who concluded that Ms. Mays “should be able to functi on in a work environment which would limit physical hardship.” Id. The ALJ noted that Ms. Mays had told- 11 - Dr. Nodine that “her pain [d id] not become severe if she stay[ed] on her medication.”
Id. The ALJ ultimately held that the medical evidence and Dr. Nodine’s opinion were consistent with Ms. Ma ys’ ability to perform a fu ll range of sedentary work.
1. Specification of the Weight Assigned to the Opinion Ms. Mays argues that the ALJ did not expressly state whet her he had given Dr. Chorley’s opinion “controlling weight.” But the ALJ implicitly declined to give the opinion controlling weight. Because we can tell from the d ecision that the ALJ declined to give controlling weight to Dr . Chorley’s opinion, we will not reverse on this ground. See Causey v. Barnhart , 109 F. App’x 375, 378 (10th Cir. 2004). 2
2. Reliance on the 2006 MRI and 2008 CT In rejecting Dr. Chorley’s opinions, th e ALJ could reasonably rely on the 2006 MRI and the 2008 CT. Ms. Mays questions this reliance, arguing that “foraminal narrowing and central canal st enosis are factors for cons ideration only in cases of meeting or equaling Listing § 1.04.” Aplt. Opening Br. at 24. But she does not explain the ALJ’s inability to draw inferences about p hysical capability from the MRI and CT.
3. Evidence of Retrolisthesis Ms. Mays also argues that th e ALJ ignored the detection of retrolisthesis in the 2008 CT and in a 2004 MRI. For Ms. Ma ys, this evidence is significant because Dr. Chorley referred to retrolisthesis in his opinion. But th e ALJ did discuss the

2 Though Causey is unpublished, it is persuasive.- 12 - 2004 MRI, noting that it revealed “mild” re trolisthesis. Aplt. App., Vol. 2 at 12;
see also id. , Vol. 3 at 161. And Ms. Mays does not point to anything in the 2008 CT report that would indicate a wo rsening of this condition.
4. Reference to Pain Cont rol Through Medication Along with the 2006 MRI and 2008 CT, th e ALJ cited Ms. Mays’ statement to a doctor that medication kept her pain fro m becoming severe. Ms. Mays complains about this reference, arguing that she also said that sh e was taking strong medications four or more times per day. She does not explain why this omission is significant and we will not construct an argument for her. See Murrell v. Shalala , 43 F.3d 1388, 1389 n.2 (10th Cir. 1994) (noting that “per functory complaints” failing “to frame and develop an issue” are not “suffici ent to invoke appellate review”); see also Keyes-Zachary v. Astrue , 695 F.3d 1156, 1161 (10th Cir. 2012) (declining to consider issues not adequately briefed for review).
5. Consideration of the Regulatory Factors Ms. Mays argues that the ALJ failed to weigh Dr. Chorley’s opinion based on the relevant factors in 20 C.F.R. § 404.15 27. But the ALJ liste d those factors, and the record shows that the ALJ adequately considered them. He recognized that Dr. Chorley is Ms. Mays’ treating physicia n and discussed the doctor’s treatment records going back several years. See Robinson v. Barnhart , 366 F.3d 1078, 1082 (10th Cir. 2004) (noting that the relevant factors included th e nature and extent of the treatment relationship, the le ngth of treatment, and the frequency of examination).- 13 - The ALJ also considered whether Dr. C horley’s opinion was c onsistent with the medical evidence. See id. (listing consistency with the record as another factor). A doctor’s relevant area of specia lization is also pertinent. See id. In her opening appeal brief, Ms. Mays contends that specia lization is only important because a neurosurge on had recommended surgery. She does not point to any opinion evidence from a neuros urgeon or explain why another physician’s area of specialization is relevant to the ALJ’s analysis of Dr. Chorley’s opinion. 3
See Oldham v. Astrue , 509 F.3d 1254, 1258 (10th Ci r. 2007) (holding that the ALJ need not expressly apply each fact or in weighing a medical opinion). Finally, the ALJ considered other factor s, including Ms. Mays ’ report that her pain does not become severe if she takes her medication. See Robinson v. Barnhart , 366 F.3d 1078, 1082 (10th Cir. 2004) (listing “other fact ors brought to the ALJ’s attention”). Ms. Mays has not shown that the ALJ fail ed to consider the relevant regulatory factors.
6. Selective Review of the Evidence She also contends that the ALJ impr operly picked from the record when assessing Dr. Chorley’s opinion.

3 In her reply brief, Ms. Mays conte nds that the ALJ should have recognized that Dr. Chorley was board certified in fam ily medicine. But we do not address this argument because it was raised for th e first time in the reply brief. See Stump v. Gates , 211 F.3d 527, 53 3 (10th Cir. 2000).- 14 - We have stated: The record must demonstrate that the ALJ considered all of the evidence, but an ALJ is not required to discuss every piece of evidence. Rather, in addition to discussing the evidence supporting his decision, the ALJ also must discuss the uncont roverted evidence he chooses not to rely upon, as well as significan tly probative evid ence he rejects. Clifton v. Chater , 79 F.3d 1007, 1009- 10 (10th Cir. 1996) (citation omitted). Ms. Mays points to evidence that she claims th e ALJ failed to discuss, but for the most part she does not say why it was significantly probative regarding Dr. Chorley’s opinion. Again, we will not develop an argument for Ms. Mays. See Murrell v. Shalala , 43 F.3d 1388, 1389 n.2 (10th Cir. 1994). 4 She does argue that the ALJ had to discuss evidence showing muscular weakness in heel walking, foot drop, weak or absent toe muscle strength, positive straight-leg raising tests, and asymmetric al deep tendon reflexes because these test results were “of listing level importance. ” Aplt. Opening Br. at 32. For this proposition, she cites § 1.00E1 of the listings, which states that “[i]nability to walk on the heels or toes, . . . when appropriate, may be considered evidence of significant motor loss.” 20 C.F.R. Part 404, Subpart P, App. 1, § 1.00E1. That section further advises that spinal ex aminations should include detailed descriptions of certain tests

4 In a perfunctory manner, Ms. Mays contends that the ALJ’s determination regarding Dr. Chorley’s opinion is not supported by substa ntial evidence. She asserts that the evidence supporting the opinion overwhelms the evid ence that the ALJ actually discussed. But her contentions c onsist mostly of reco rd citations without further development.- 15 - and observations, including straight-leg ra ising from the sitting and supine positions and deep tendon reflexes. 5 Ms. Mays does not challenge the ALJ’ s determination th at she lacks an impairment meeting or equaling the lis tings. Instead, Ms. Mays suggests that evidence regarding a listing test is always significantly pr obative. She does not cite authority for this suggestion, an d none exists in our court. It is true that the listing tests reflect ed evidence of back pain. But, the ALJ acknowledged at step two that Ms. Mays had low back pain. The ALJ simply rejected Dr. Chorley’s conclusion that the pain was sufficiently severe to render Ms. Mays disabled. In reaching this conclusi on, the ALJ could draw fro m the same te st results relied upon by Ms. Mays. For example, Dr. Chorley’s examination showed that Ms. Mays’ heel walking was nor mal, her sitting straight-leg raising was negative, and her deep tendon reflexes were symmetrical. 6 See Aplt. App., Vol. 3, at 283.

5 Ms. Mays also notes th at § 1.04A of the listings identifies a positive straight-leg raising test as a factor weighing in favor of a disability finding. See 20 C.F.R. Part 404, Subpart P, App. 1, § 1.04A (addressing spinal disorders). Nonetheless, we have concl uded in an unpublished decisi on that in itself, a positive straight-leg raising test does not render a cl aimant unable to perform sedentary work. Rhodes v. Barnhart , 117 F. App’x 622, 630 (10th Ci r. 2004). This conclusion is persuasive.
6 Dr. Chorley did report a positive supine straight-leg raising on one side. But Ms. Mays acknowledges that the ALJ di scussed other evidence of a positive straight-leg raising test. With this acknowledgment, Ms . Mays does not explain why the omitted evidence would have been significantly probative.- 16 - The ALJ did not selectivel y pick from the record.
7. Use of Boilerplate Language Ms. Mays argues that the ALJ relied on im proper boilerplate when he rejected Dr. Chorley’s opinion. The ALJ mentione d the possibility “that a doctor [could] express an opinion in an effo rt to assist a patient with whom he or she sympathize[d] for one reason or another” and that “patie nts [could] be quite insistent and demanding in seeking supportive notes or reports from their physicians.” Aplt. App., Vol. 2, at 15. Ms. Mays contends that an ALJ cannot reject a me dical opinion based solely on an assumption that the treat ing physician is biased. See Frey v. Bowen , 816 F.2d 508, 515 (10th Cir. 1987) ( holding that the ALJ’s statement th at a family doctor “naturally advocates his patient’s caus e” was insufficient to suppor t rejection of a doctor’s opinion (internal quotation marks omitted )). But the ALJ’s comments did not constitute the sole basis for rejecting Dr . Chorley’s opinion and did not detract from the ALJ’s further explanation.
8. Reliance on Dr. Nodine’s Opinion The Plaintiff also challe nges the ALJ’s reliance on Dr. Nodine’s opinion. The ALJ stated: Dr. Nodine’s physical assessment on December 28, 2005, found no inciting injury or distinctive pat hology on exam. The claimant told Dr. Nodine her pain does not beco me severe if she stays on her medication. Dr. Nodine opined that claimant should be able to function in a work environment which wo uld limit physical hardship.- 17 - Aplt. App., Vol. 2, at 16. Ms. Mays c ontends that the ALJ improperly relied on Dr. Nodine’s opinion that there was not an “inciting injury” and that Dr. Nodine’s opinion was internally inconsistent . These contentio ns are rejected. Ms. Mays contends in part that Dr. Nodine’s finding of “no inciting injury” is not supported by the record. For this c ontention, Ms. Mays insists that she has regularly reported that she awoke in May 200 4 with back pain one day after she had been “brush-hogging” on a tr actor. But Dr. Nodine’s co mment must be read in context. Dr. Nodine said that Ms. Mays ha d “denie[d] any injury,” and this statement immediately followed her account of the cause of her back pain. Id. , Vol. 3, at 176. Thus, Dr. Nodine appeared to distinguish “injury” from the pain that Ms. Mays experienced after engaging in physical activity. In any event, the ALJ twice noted Ms. Mays’ assertion that her back pain was traceable to her brush-hogging activity, and there is no indication that the AL J disbelieved this explanation. See id. , Vol. 2,
at 13. The Plaintiff also argues that Dr. Nodine ’s opinion is intern ally inconsistent because the doctor stated that he did not see “distinctive pathology,” yet he reported that Ms. Mays demonstrated a positive seated straight-leg raising test on one side, painful range of motion of her spine, mu scle spasms, and tende rness upon palpation, all of which she claims are distinctive pa thologies. But agai n, Ms. Mays does not explain why Dr. Nodine’s exam ination findings are inconsis tent with an ability to- 18 - function in a work environment. See Brown v. Bowen , 801 F.2d 361, 362-63 (10th Cir. 1986). According to the Plainti ff, the ALJ ignored Dr. Nodine’s statement that Ms. Mays “would benefit fro m a radiographic workup to rule out anatomical pathology and should avoid ma nual labor until this time.” Aplt. App., Vol. 3, at 178

. Ms. Mays interprets this statement as Dr . Nodine’s opinion that she “could not work at all without further evaluation.” Aplt. Op ening Br. at 29. It is Ms. Mays, however, who misreads Dr. Nodine’s c onclusion: Dr. Nodine stated only that Ms. Mays should avoid manual labor until she underwent further tests. C. The ALJ’s Alleged Failure to Di scuss and Weigh the State Agency Medical Consultants’ Opinions Would Constitute Harmless Error Ms. Mays also argues that the ALJ failed to discu ss agency medical consultants’ opinions about her physical limitations. This argument is rejected. “It is the ALJ’s duty to give considera tion to all the medical opinions in the record. He must also discu ss the weight he assigns to such opinions,” including the opinions of state agency medical consultants. Keyes-Zachary v. Astrue , 695 F.3d 1156, 1161 (10th Cir. 2012) (citations omitted). But th e need for express analysis is weakened “[w]hen the ALJ does not need to reject or weigh evidence unfavorably in order to determine a claimant’s RFC.” Id. at 1162. And an ALJ’ s failure to weigh a medical opinion involves harmless error if there is no inconsistency between the opinion and the ALJ’s assessment of residual functional capacity. See id. at 1162-63.- 19 - In that case, the claimant is not prejudi ced “because giving greater weight to [the opinion] would not have helped her.” Id. at 1163. For the sake of argument, we may assu me that the ALJ fa iled to weigh the state agency medical consu ltants’ opinions. Still, Ms . Mays does not identify any resulting prejudice. She cites one consu ltant’s conclusions that she could only occasionally climb, balance, stoop, kneel, crouc h, and crawl. But she fails to explain why these limitations would conflict with se dentary jobs, for “[p] ostural limitations or restrictions related to such activities as climbing la dders, ropes, or scaffolds, balancing, kneeling, crouching, or crawlin g would not usually erode the occupational base for a full range of unskilled sedentary work significantly becau se those activities are not usually required in sedentary work .” SSR 96-9p, 1996 WL 374185, at *7. Social Security Ruling 83-10 states that “[b]y its very natu re, work performed primarily in a seated position entails no si gnificant stooping.” SSR 83-10, 1983 WL 31251, at *5; see SSR 85-15, 1985 WL 56857, at *7 (“If a person can stoop occasionally . . . in order to lift objects, the sedentary and light occupational base is virtually intact.”). Similarly, crouching is rarely needed for sedentary work. See SSR 83-14, 1983 WL 31254, at *2 (noting that to pe rform substantially a ll of the exertional requirements of most sede ntary jobs, a person woul d not need to crouch); see also Robinson v. Sullivan , 956 F.2d 836, 841 (8th Cir. 199 2) (stating that the ability to crouch is not needed for substantia lly all sedentary and light jobs).- 20 - Like limitations on crouching, limitations on crawling, kneeling, or balancing would generally prove incons equential on the ability to perform sedentary jobs. See SSR 85-15, 1985 WL 56857, at *7 (stating that an inability to kneel or crawl is “of little significance in the broad world of work”); SSR 96-9p, 1996 WL 374185, at *7 (postural limitations on bala ncing would not erode the o ccupational base for a full range of sedentary work). As a result, the agency c onsultants’ opinions proved inconsequential when the ALJ limited Ms. Mays to sedentary work. In these circumstances, the alleged failure to discuss the consultants’ opinions would constitute harmless error. VI. Disposition The judgment of the distri ct court is affirmed.