PUBLISH UNITED STATES CO URT OF APPEALS FOR THE TENTH CIRCUIT

JOE ELLA WELLS, Plaintiff-Appellant,

v.
CAROLYN W. COLVIN, Acting Commissioner of Social Security Administration, * Defendant-Appellee. No. 12-6234

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA (D.C. No. 5:11-CV-0631-M)

Submitted on the briefs: ** Kyle J. Saunders, Saunders & Saunders, Ada, Oklahoma, for Plaintiff-Appellant. Sanford C. Coats, United States Atto rney, Michael McGaughran, Regional Chief Counsel, Virginia Watson Keyes, Special A ssistant United States Attorney, Office of

* In accordance with Rule 43( c)(2) of the Federal Rules of Appellate Procedure, Carolyn W. Colvin is substituted for Michae l J. Astrue as the defendant-appellee in this action.
** 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 

### August 19, 2013
Elisabeth A. Shumaker Clerk of Court- 2 - the General Counsel, Region VI, Social Secu rity Administration, Dallas, Texas, for Defendant-Appellee.

Before LUCERO , ANDERSON , and BALDOCK , Circuit Judges.

BALDOCK , Circuit Judge.
In a social security disa bility or Supplemental Secu rity Income (SSI) case, an administrative law judge (ALJ ) must evaluate the effect of a claimant’s mental impairments on her ability to work using a “special technique” prescribed by the Commissioner’s regulations. 20 C.F.R. §§ 404.1520a(b)-(d), 416.920a(b)-(d). At step two of the Commissi oner’s five-step analysis, 1 this special technique requires the ALJ to determine whether the mental impa irment is “severe” or “not severe.” Id. §§ 404.1520a(d), 416.920a(d). But the regulati ons also instruct th at even if the ALJ determines that a claimant’s medically determinable me ntal impairments are “not severe,” he must further consider and disc uss them as part of his residual functional capacity (RFC) analysis at step four. See id. §§ 404.1545(a)(2), 416.945(a)(2). The

1 The Commissioner follows a five -step sequential evaluation process to determine whether a claimant is disabled. See Williams v. Bowen , 844 F.2d 748, 750-52 (10th Cir. 1988) (describing pro cess). The claimant bears the burden of establishing a prima faci e case of disability at steps one through four. See id. at 751 n.2. If the claimant su ccessfully meets this burden, the burden of proof shifts to the Commissioner at step fi ve to show that the claimant retains a sufficient RFC to perform work in the national economy, given her age, education, and work experience. See id. at 751.- 3 - question is, how much further discussion of a non-severe impairment is required at step four? This issue, frequently enc ountered in social security disability appeals, has resulted in a number of recent unpublished dispositions in this court reaching divergent results. 2 Notwithstanding the diverg ence in these decisions, the Commissioner’s regulations, together with the rulings interpreting those regulations,

2 Compare Farrill v. Astrue , 486 F. App’x 711, 712-13 (10th Cir. 2012) (reversing because the ALJ neglected to discuss “non-severe” but medically determinable mental im pairments as part of his RFC determination); McFerran v. Astrue , 437 F. App’x 634, 638 ( 10th Cir. 2011) (same); Mushero v. Astrue , 384 F. App’x 693, 695-96 (10th Cir. 2010) (reversing because although ALJ found “no ‘significant’” work-related limitations due to claimant’s depression, which was equivalent to finding that depression was non-severe, ev en non-severe impairments must be considered as part of RFC); Grotendorst v. Astrue , 370 F. App’x 879, 883-84 (10th Cir. 2010) (reve rsing because although ALJ’s fi nding that mental impairments were non-severe at step two was harmle ss error, ALJ failed to give further consideration to mental impairments in RF C assessment, despite medical evidence of such limitations); Dorman v. Astrue , 368 F. App’x 864, 865-66 (10th Cir. 2010) (reversing because although ALJ found claima nt had only “mild me ntal impairments” and concluded claimant could perform his past relevant wo rk, ALJ failed to properly evaluate the mental demands of that past relevant work), with Miller v. Astrue , 496 F. App’x 853, 859-60 (10th Cir. 2012) (affirming notwithstanding ALJ’s failure to discuss severe mental impairment as part of hi s RFC determination, where “claimant was not markedly impaired in any functional area s” for purposes of Paragraph B criteria, and clai mant failed to provide any additional record evidence of mental functional limitations resulting from personality disorder (e mphasis omitted)); Grede v. Astrue , 443 F. App’x 323, 325-26 (10th Cir. 2011) (affirming where ALJ found mental impairment non- severe, made no further findi ngs concerning a mental impairment at step four, but stated he had considered all of claimant’s symptoms and the medical evidence); Barrett v. Astrue , 340 F. App’x 481, 4 85 (10th Cir. 2009) (finding no reversible error where ALJ concluded mental impairments were non-severe and therefore included no mental limitation in RFC, but also “indicated that he had . . . considered the entire record and all of [t he] claimant’s symptoms to the extent . . . they were reasonably c onsistent with the evidence, including the objective medical evidence”).- 4 - provide us with the appropriate path to follow here. These re gulations inform us, first, that in assessing th e claimant’s RFC, the ALJ mu st consider the combined effect of all of the cl aimant’s medically dete rminable impairments, whether severe or

not severe

. See 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2). Second, the Commissioner’s procedures do not permit the ALJ to simply rely on his finding of non-severity as a substitute for a proper RFC analysis. See Social Security Ruling (SSR) 96-8p, 1996 WL 374184, at *4 (July 2, 1996) (noting th at criteria used at steps two and three of the analys is to evaluate mental im pairments are “not an RFC assessment,” and that “[t]he mental RFC assessment used at steps 4 and 5 of the sequential evaluation process requires a more detailed assessment by itemizing various functions contained in the broad cat egories found in para graphs B and C of the adult mental disorders listings in 12.00 of the Li sting of Impairments, and summarized on the [Psychiatr ic Review Technique Form].”). Finally, and most importantly, the ALJ’s “RFC assessment must include a narrative discussion describing how the evidence supports each c onclusion, citing specific medical facts . . . and nonmedical evidence.” Id. at *7. Here, the ALJ found that Ms. Wells’ alleged ment al impairments were medically determinable but non-severe. He then used language suggesting he had excluded them from consideration as part of his RFC assessment, based on his determination of non-severity. The Commi ssioner urges us to “uphold the ALJ’s determination that . . . [Ms.] Wells did not have a severe mental impairment” and that- 5 - he therefore had no obligation “to include additional work restrictions in his RFC finding.” Aplee. Br. at 23. Under the regul ations, however, a findi ng of non-severity alone would not support a decision to pr epare an RFC assessment omitting any mental restriction. 3 The ALJ did go on to discuss Ms. Wells’ mental functioning, to some extent, in the credibility portion of his RFC analys is. His discussion, though far from systematic, may have been adeq uate to fulfill his duty at step four to determine her mental RFC. In this partic ular case, however, the specifi c conclusions he reached in this portion of his analysis were unsupported by substantia l evidence. Accordingly, we must reverse the district court’s affirmance of the ALJ’s decision and remand to the district court with instructions to remand to the Commi ssioner for further proceedings at step four. In addition to our reversal and rema nd on the mental impairment issue, we conclude that the ALJ should re-evaluate Ms. Wells’ alle ged physical limitations on reaching and handling. We find no reversib le error in other aspects of the ALJ’s decision. These include his rejection of a physician’s assi stant’s report, his

3 An ALJ could, of course, find at st ep two that a medically determinable impairment posed no restriction on the claima nt’s work activities. See 20 C.F.R. §§ 404.1520a(c)(4), 416.920a(c)(4) (permitti ng ALJ to find that degree of limitation in each of the four relevant functional areas is “none”). Such a finding would obviate the need for further analysis at step four. That is not the case here, however; the ALJ did find “mild” restrictions in three of th e relevant functional areas, requiring further analysis.- 6 - evaluation of her past relevant work (PRW), and his evaluation of the effect of her symptoms, including pain, on her ability to work. BACKGROUND 1. Prior History of this Case This case has a complex procedural hi story. Ms. Wells filed her first application for disability and SSI benefi ts in 1994. The Commissioner denied benefits and she did not s eek judicial review. On April 7, 2000, Ms. Wells filed a second application for disability benefits. After her application was denied, she obt ained a hearing before an ALJ. He determined that she was engaged in substa ntial gainful activity (SGA) during all time periods relevant to the application and issued an unfavorable step-one ruling in 2001. Ms. Wells requested review from the Appeals Council. While her request for review was pending, Ms. Wells filed a third application for disability and SSI benefits with a pr otective filing date of October 8, 2002, alleging a disability onset date of December 1, 2001. An ALJ issued an unfavorable decision on this third application in Decemb er 2004. Ms. Wells requested review of the ALJ’s decision from the Appeals Council. On December 19, 2005, the Appeals Coun cil granted her requests for review from both the second and third applications . It vacated both hearing decisions, consolidated the cases, and remande d them for further proceedings. On August 24, 2006, an ALJ held a s upplemental hearing on the consolidated cases. At the hearing, Ms. Wells amended her alleged onset date to April 25, 1997,- 7 - based on the res judicata effect of the denial of her first a pplication. The ALJ issued an unfavorable decision on th e consolidated cases. Ms. We lls sought review from the Appeals Council. On May 19, 2008, the Appeals Counc il again vacated the ALJ’s decision and remanded for further proceedings. 2. Decision Currently on Review In August 2009, Ms. Wells received a se cond supplemental hearing before yet another ALJ. At this heari ng, Ms. Wells again amended her disability onset date, this time to October 31, 1999. On November 16, 2009, the ALJ issued th e decision that is now before us. At step one of the five-step sequential evalua tion process, he determined that during calendar year 2005, Ms. Wells ha d engaged in SGA. She wa s therefore ineligible for benefits for calendar year 2005. 4 For the time period October 31, 1999, to December 31, 2004, however, and for th e time period beginning December 31, 2005 through the date of his decisi on, the record was insufficie nt to show that Ms. Wells had engaged in SGA. The ALJ therefore f ound that she had sati sfied her step-one burden as to those time peri ods, and he proceeded to step two of the process. For steps two through five, he divided his d ecision into two parts, each containing a separate analysis.

4 Ms. Wells has not challe nged this determination.- 8 - A. October 31, 1999 to December 31, 2004 For the time period October 31, 1999, through December 31, 2004, the ALJ determined at step two that Ms. Wells suffered from the following, severe impairments: degenerative di sc disease, status post carp al tunnel surgery times two of the right upper extremity, status post re moval of kidney, status post arthroscopic surgery of the right knee, obesity, hype rtension, hyperlipidemia, and diabetes mellitus. He decided that her alleged me ntal impairments, a nxiety and affective disorder, caused her no more than mild rest riction of activities of daily living, mild limitations in social functioni ng, mild limitations in con centration, persistence, or pace, and no episodes of decompensation. They were ther efore not “severe” impairments. See 20 C.F.R. §§ 404.1520a(d )(1), 416.920a(d)(1). At step three, the ALJ determined that Ms. Well s did not have a listed impairment. See id. , Part 404, Subpt. P, App. 1. At step four, he opined that she retained the RFC to perform the full range of light work. Specifically, he found that she could occasionally lift and/or carry tw enty pounds, and frequently lift and/or carry ten pounds. She could stand and/or walk six hours in an eight-hour workday and could sit for six hours in an eight-hour workday. The ALJ found that during this time pe riod, Ms. Wells could return to her PRW as a chemical dependency assistant/a ide (as actually performed), bookkeeper, clerk, customer complaint cler k, order clerk, and home health aide. Alternatively, at step five, there were a signifi cant number of other jobs th at she could perform in the- 9 - national or regional economy. Applyi ng the Medical-Vocational Guidelines, id. , Part 404, Subpt. P, App. 2, rules 202.21 and 202.14 (the grids) , the ALJ concluded that Ms. Wells was not disabl ed within the meaning of th e Social Security Act. B. After December 31, 2005 For the period after December 31, 2005, the ALJ found that Ms. Wells had two additional severe impairments: status post heart attack with stent placement in 2007 and a hospitalization in April 2009 for low blood sugar. He again reviewed the evidence concerning her mental impairments and again determ ined that they were not “severe.” He again determined that she did not meet a li sting at step three of the
process. For this latter period, rather than the full range of light work, the ALJ found at step four that Ms. Wells could perform se dentary work. She could occasionally lift or carry no more than ten pounds. She coul d stand and/or walk about four hours of an eight-hour workday and sit six hours of an eight- hour workday. She could perform her PRW at the sedentary level as a bookkeeper, customer complaint clerk, order clerk, and home health aide coordinato r. The ALJ did not make an alternative step-five finding for this time period. ANALYSIS Because the Appeals Counc il denied Ms. Wells’ reques t for review, the ALJ’s decision is the Commissioner’s final deci sion. “We review the Commissioner’s decision to determine whether the factua l findings are suppor ted by substantial- 10 - evidence in the record and whether the correct legal standards were applied.” Wilson
v. Astrue , 602 F.3d 1136, 1140 (10t h Cir. 2010). “Substan tial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Id. (quotation omitted). On appeal, Ms. Wells raises two is sues: (1) whether the ALJ properly evaluated the medical evidence concerning he r mental and physical impairments, and (2) whether the ALJ properly determined her RFC and reached a permissible conclusion that she could return to her PR W. We consider each issue in turn. 1. ALJ’s Evaluation of the Medical Evidence A. Mental Impairments 1. Findings at Steps Two and Four The Commissioner follows a special tec hnique to evaluate the severity of mental impairments and their effect on th e claimant’s ability to work. 20 C.F.R. §§ 404.1520a(a), 416.920a(a). In applying the special t echnique, the ALJ must first decide whether the claimant has a medica lly determinable mental impairment. Id. §§ 404.1520a(b)(1), 416.920a(b)(1). The ALJ determined that Ms. Wells had two medically determinable mental impairments: an anxiety disorder and an affective disorder. The ALJ must next rate the degree of the functional limitation resulting from the claimant’s medically dete rminable mental impairment s in four broad functional areas: “[a]ctivities of daily living; social functioning; c oncentration, persistence, or- 11 - pace; and episodes of decompensation.” Id. §§ 404.1520a(c)(3), 41 6.920a(c)(3). To complete this step, the ALJ uses a five-poi nt scale, rating the degree of limitation in the first three areas as eith er none, mild, moderate, ma rked, or extreme; and the limitation in the fourth area using a numerical scale of either none, one or two, three, or four or more. Id. §§ 404.1520a(c)(4), 416.920a(c )(4). The ALJ’s degree-oflimitation ratings then inform his conclusions at steps two and th ree of the five-step analysis. Id. §§ 404.1520a(d); 416.920a(d). Here, for both time periods in question, the ALJ determined that Ms. Wells’ mental impairments would cause her no more than “mild” limitati ons in each of the first three functional areas, and “no” limitation in the fourth area. Aplt. App., Vol. I at 30, 40 (internal quotation marks omitted). Under the regulations , this means that her mental impairments were “not se vere.” 20 C.F.R. §§ 404.1520a(d)(1), 416.920a(d)(1). 5 Ms. Wells challenges the ALJ’s finding of non- severity, contending it is unsupported by substantial evidence. She also challenges the ALJ’s further conclusion at step four that her ment al impairments would impose no limitation on her ability to work, and the ALJ’s consequent failure to include any mental limitation in his RFC assessment or in his hypothetical questions to the vo cational expert (VE).

5 Although the regulations do not expr essly require the ALJ to determine whether a non-severe mental impairment “meets or is e quivalent in severity to a listed mental disorder,” see 20 C.F.R. §§ 404.1520a(d)( 2), 416.920a(d)(2), the ALJ also determined that Ms. Wells’ non-seve re impairments did not meet or equal a listing at step thr ee of the analysis, see Aplt. App., Vol. I at 29, 39.- 12 - Although we cannot endorse all of Ms. Wells’ chal lenges to the ALJ’s evaluation of her mental impairments—we agree with the Commissioner that any harmful errors would have o ccurred at step four rather than at step two of the analysis 6 —we do conclude that the ALJ failed to properly evaluate her mental impairments. First, a conclusion that th e claimant’s mental impa irments are non-severe at step two does not permit the ALJ simply to disregard those impairments when assessing a claimant’s RFC a nd making conclusions at step s four and five. In his RFC assessment, the ALJ must cons ider the combined effect of all medically determinable impairments, whether severe or not. 20 C.F.R. §§ 404.1545(a)(2), 416.945(a)(2). Here, after stating his conclusion that Ms . Wells’ mental impairments were non-severe, the ALJ stat ed that “[t]hese findings do not result in further limitations in work-related functions in th e [RFC] assessment below.” Aplt. App., Vol. I at 30, 40. He then reiterated his conclusion that the mental impairments were

non-severe. See id. The language used suggests that the ALJ may have relied on his step-two findings to conclude that Ms. Wells had no limitation based on her mental impairments. If so, this was inad equate under the regulations and the Commissioner’s procedures.

6 See Carpenter v. Astrue , 537 F.3d 1264, 1265-66 ( 10th Cir. 2008) (holding that any error in consideration of impairme nts at step two was harmless, given that ALJ found step-two test sati sfied by other severe impairme nts and continued with his analysis).- 13 - In assessing a claimant’s RFC, “[t]he adjudicator must remember that the limitations identified in the ‘p aragraph B’ . . . criteria [fo r severity] are not an RFC assessment but are used to rate the severity of mental impairment (s) at steps 2 and 3 of the sequential evaluation process.” SSR 96-8p, 1996 WL 374184, at *4. “The mental RFC assessment used at steps 4 and 5 of the sequential evaluation process requires a more detailed assessment by item izing various functions contained in the broad categories found in paragr aphs B and C of the adult mental disorders listings in 12.00 of the Listing of Impairments, a nd summarized on the [P sychiatric Review Technique Form].” Id. Although the PRT form merely provides a summary of these functions, the Ruling provides additional guidance concerni ng the focus of the ALJ’s assessment of the claimant’s mental RFC. “Work-related mental act ivities generally required by competitive, remunerative work include th e abilities to: unders tand, carry out, and remember instructions; use judgment in making work-related decisions; respond appropriately to supervision, co-workers a nd work situations; an d deal with changes in a routine work setting.” Id. at *6. Moreover, the “RFC assessment must include a narrative discussion describing how the evidence supports each conclusion , citing specific medical facts (e.g., laboratory findings) and no nmedical evidence (e.g., daily activities, observations).” Id. at *7 (emphasis added). Notwithstanding his previous statem ent about step-two findings, the ALJ did—as previously mentioned— separately discuss Ms. Well s’ mental impairments to- 14 - some degree, when assessing her credibility as part of hi s RFC determination. This discussion, though far from comprehensive, might have satisfied the ALJ’s obligation at step four to provide a mo re detailed assessment of Ms . Wells’ ability to complete various job functions as part of determining her RFC. But we need not determine whether the discussion was procedurally adequate, because the ALJ’s conclusions on this point were not supporte d by substantial evidence. This can clearly be seen by analyzing the statements he made about Ms. Wells’ me ntal impairments during the course of his RFC determination. First, the ALJ relied on Ms. Wells’ own prior alleged statement to a consultative examiner to gauge her ability to do activities of daily living: “The claimant admitted during the January of 19 97 consultative psychological examination that she helped with household chores (i ncluding vacuuming and dishwashing), she continued to drive, she drove to Shrevepor t, LA. to gamble, and she enjoyed hobbies such as sewing and fishing.” Aplt. App., Vol. I at 33. This statement, however, refers to an examination co nducted nearly three years before Ms. Wells’ currently alleged onset date of Octobe r 31, 1999. Ms. Wells testif ied at four different ALJ hearings subsequent to the 1997 statement. At none of them did she indicate she could do all of the activitie s she allegedly mentioned during the 1997 consultative examination. See id. at 93-94, 95, 97, 106-07, 10 9, 143, 151-52, 154-55, 187, 189-90, 220, 222, 224. Moreover, the January 1997 c onsultative examination the- 15 - ALJ cited does not appear to be part of the administrative reco rd in this case presented for judicial review. The ALJ next stated: “The claimant reported on May 23, 2000 that her activities of daily living included watching television, preparing meals, shopping, reading the newspaper, visiting friends and relatives, drivi ng, and going to church.” Id. at 33. The record cited is insufficien t to provide substan tial evidence for the ALJ’s conclusion that Ms. Wells’ mental impairments would have no significant effect on her RFC. See id. , Vol. III at 788-93 (“Disab ility Supplemental Interview Outline”). The statements reported on the fo rm were much more nuanced than the ALJ’s summary suggests. Fo r example, Ms. Wells stated that she fixes meals only “when [I] feel like cooking,” whic h is “once or twice a week.” Id. at 789. She also stated that eating can make her “get real sick [to] the stomach.” Id. She stated she watches television because she cannot sleep. Id. at 788. Although she does socialize, she stated she “like[ s] to be alone most of the time.” Id. Finally, relative to Ms. We lls’ alleged difficulties w ith persistence and pace and in dealing with the public, the ALJ noted “that the claimant was employed for at least a portion of the period October 31, 1999 through December 31, 2004 .” Id. , Vol. I at 34 (emphasis added). But most of the examples he cited dated from the time- 16 - period before October 31, 1999, see id. at 34-35, not during th e period he identified, and therefore provided no su pport for his statement. 7 The ALJ did cite a few examples of j obs Ms. Wells held after October 31, 1999, to support his claim that she demons trated an ability to maintain adequate persistence and pace and to deal with the public. First, she wo rked in customer service for Williams-So noma doing catalog sales in 1999 and 2000. 8 The ALJ listed the strength demands of this job, and al so noted that it requi red “using technical knowledge or skills to write reports/complete forms.” Id. at 35. But as Ms. Wells points out, this job was of short duration, over the Christmas season, lasting only a month or two. Id. at 134, 177. She did not work ag ain until four years later, in June 2004, when she began work for PIA, a detox center. This job, however, was part-time, see id. at 103, and does not necessarily demonstrate Ms. We lls’ ability to sustain the mental demands of full-time work. The ALJ continued his anal ysis by stating that “[i] n October of 2005, the claimant returned to work at levels above substa ntial gainful activity.” Id. at 35. This appears incorrect; the AL J may have meant to say Oc tober 2004. In fact, the

7 As part of this analysis, the ALJ st ated that “[b]eginning in 1995 until August of 2006, [Ms. Wells] worked full time in payroll and accounts receivable at a nursing home.” Aplt. App., Vol. I at 34. This appears to be a typographical error. According to her testimony, she actually worked at that job from November 1995 through August 1996. See id. at 137.
8 The ALJ misstated the name of this employer as “Sonoma-Williams.” Aplt. App., Vol. I at 35.- 17 - evidence shows that Ms. Well s was last gainfully empl oyed in September 2005. Id. , Vol. II at 389, 453. She was laid off in October 2005 from R ecovery Tech, another detox center, where she had been workin g forty hours per week since about the beginning of 2005. Id. , Vol. I at 104. 9 In sum, although there is some appeal to the ALJ’s conclusion that Ms. Wells’ work experience in 2004 and 2 005 is “evidence [that she] retains . . . th e ability to perform semi-skilled to skilled work, the ability to interact socially , and the ability to respond to usual work changes,” id. at 35, the ALJ’s mistaken chronology and use of pre-onset date work cast doubt on the valid ity of his analysis, and we cannot credit his conclusion with substantial evidence. To sum up, to the extent the ALJ relied on his fi nding of non-severity as a substitute for adequate RFC analysis, the Commissioner’s regulations demand a more thorough analysis. See 20 C.F.R. §§ 404.1545(a)(2), 416. 945(a)(2). To the extent the ALJ intended his further statements about credibility to constitute a step-four mental RFC analysis, the conclusions he reached from these statements are not supported by substantial ev idence. We must ther efore remand for further proceedings concerning the effect of Ms . Wells’ medically determinable mental impairments on her RFC, and for further anal ysis at steps four and five, including any further hearing the ALJ deems necessary, in his discretion.

9 Elsewhere in his decision, the ALJ correctly stated th at Ms. Wells was laid off in 2005. See Aplt. App., Vol. I at 42.- 18 - 2. Evaluation of Medical Opinions Ms. Wells also complains about the AL J’s treatment of the medical opinions concerning her mental impairments. Becau se the issue involving this evidence may recur on remand in connection with the ALJ’ s need to adequately explain his RFC finding, we will briefly address this i ssue. The record includes three medical opinions concerning Ms. Wells’ mental im pairments, two of which assigned her “moderate” and even “marked” limitations in certain areas. 10 The ALJ rejected all three of them on the issue of severity because he c oncluded that they were inconsistent with the othe r evidence in the file show ing that Ms. Wells’ mental impairments had only a “mild” effe ct on her ability to work. Ms. Wells contends that substantial ev idence is necessarily lacking because, having rejected all of the medical opinions concerni ng the severity of her mental impairments, the ALJ must have improperl y substituted his own judgment concerning their severity. We have already determined that any step-two error was harmless. But to the extent th is issue might affect the ALJ’s proper determination of her RFC on remand, we note that exact corresponde nce between a medical opinion and the mental RFC is not required. See Chapo v. Astrue, 682 F.3d 1285, 1288 (10th Cir. 2012) (“[T]here is no requirement in th e regulations for a direct correspondence

10 In his decision, the ALJ also di scussed a fourth opinion, prepared by Dr. Richard Swink, Ph.D., in January 1997. Aplt. App., Vol. I at 28-29. This opinion was prepared prior to the allege d onset date and is not part of the administrative record on app eal. Accordingly, we will not discuss it further.- 19 - between an RFC finding and a specific medi cal opinion on the functional capacity in question” because “the ALJ, not a physic ian, is charged with determining a claimant’s RFC from the me dical record” (alteration and internal quotation marks omitted)). In reaching his RFC determination, an AL J is permitted, a nd indeed required, to rely on all of the record evidence, including but not limited to medical opinions in the file. See SSR 96-8p, 1996 WL 374184, at *5. Inconsistency with the record as a whole, the basis on which the ALJ relied here, is in general a legitimate basis on which to discount or reje ct a medical opinion. Cf. 20 C.F.R. §§ 404.1527(c)(4), 416.927(c)(4); Pisciotta v. Astrue , 500 F.3d 1074, 1077 (10th Cir. 2007). That said, in cases like this one, where the medical opinions appear to conflict with the ALJ’s decision regarding the extent of a claimant’s mental impairment to the point of posing a “serious[] challenge [to] the ALJ’s [RFC] assessment,” Andrade v. Sec’y of Health & Human Servs. , 985 F.2d 1045, 1050 (10t h Cir. 1993), it may be inappropriate for the ALJ to reach an RFC determinati on without expert medical assistance, see id. ; Chapo , 682 F.3d at 1289 & n.1; cf. 42 U.S.C. § 421(h) (stating Commissioner must “ma[k]e ev ery reasonable effort to ensure that a qualified psychiatrist or psychologist has completed the medical porti on of the case review and any applicable residual functional capaci ty assessment.”). On remand, the ALJ should therefore carefully reconsider whethe r to adopt the restrictions on Ms. Wells’- 20 - mental RFC detailed in the medical opinions contained in the file, or whether further medical evidence is need ed on this issue. B. Dr. Saidi’s Opinion We turn from consideration of Ms. Wells’ mental impa irments to evidence concerning her physical impa irments. She argues that the ALJ failed to properly consider the opinion of John A. Saidi, M.D., who performed a consultative examination in August 2008. As a result of the examination, Dr. Saidi completed a “Medical Source Statement of Ability to Do Work-Related Activ ities (Physical),” in which he limited Ms. Wells to sitting only five to ten minut es at a time; standing and walking five minutes at a ti me; sitting for a total of on e hour in an eight-hour day; and standing or walking only one or two hours in an eight-hour day. Aplt. App., Vol. II at 663, 664. He further opined that she would need to lie down for four hours of an eight-hour workday, would be limited by postural and environmental limitations, and could only occasionally reac h, handle, and push/pull with either hand. See id. at 664-67. The ALJ gave Dr. Saidi’s findings lit tle weight, based on inconsistencies between the boxes Dr. Saidi checked on the fo rm compared to his written narrative, and based on the lack of objective medical fi ndings. He also noted that Dr. Saidi’s opinion conflicted with the opinion of Dr . Don Clark, a medi cal consultant who testified at the second supplem ental hearing. The ALJ stat ed that he “assigned more- 21 - weight to the opinion of . . . Dr. Clark, who had the opport unity to review the entire record at the hearing.” Id. , Vol. I at 43. Ms. Wells complains th at the ALJ’s stated re asons are unsupported by substantial evidence. In pa rticular, she argues that Dr. Clark’s opinions did not in fact significantly differ from Dr . Saidi’s. We disagree. Admittedly, Dr. Clark’s narrative at th e hearing was not a model of clarity. He began by saying that he “tend[ed] to agr ee pretty much with what [Dr. Saidi’s] examination said.” Id. at 77. But immediately afte r saying this, he went on to outline some significant points of disagree ment he had with Dr. Saidi’s opinions. First, he found no explanation for the postura l limitations Dr. Said i assigned. Nor did he think Dr. Saidi’s limitation on Ms. Wells’ sitting and standing to only five minutes was supported by his examination or by her hist ory. In fact, Dr. Clark stated that “the physical examination is not substantiating difficulty walking or standing.” Id. at 80. By the end of his initial discussion of Dr. Saidi’s report, Dr. Clark had mostly expressed his agreement with those portions of the report that outlined Ms. Wells’ affirmative capabilities. See id. at 78 (Dr. Clark’s tes timony noting that Dr. Saidi “felt she could do all those things”). Dr. Clark then c oncluded his initial discussion of the report by noting that “I don’t think she could do anything heavier than light work.” Id. The language we have cited in Dr. Clar k’s analysis genera lly supports the ALJ’s rejection of Dr. Saidi’s opinion. Bu t Ms. Wells zeroes in on two particular- 22 - areas of agreement between Dr . Clark and Dr. Saidi that sh e claims the ALJ failed to explain. She contends the ALJ should have detailed “w hy he did not accept Dr. Clark’s agreement with Dr. Saidi’s li mits on [Ms.] Wells[’] ability to reach and handle, and the inability to work an eight -hour workday.” Aplt. Br. at 23. Ms. Wells fails to show that Dr. Clark adopted Dr. Saidi’s conclusion that she could not work an eight-hour day; such a conclusion would have been inconsistent with Dr. Clark’s general observations con cerning her ability to wo rk. The limits on reaching and handling present a different problem. The VE testified that if accepted, they would preclude Ms. Wells’ pe rformance of her sedentary PRW. See Aplt. App., Vol. I at 119. While Dr. Clark did not speci fically adopt these lim itations, nor did he reject them, even though he was clearly familiar with Dr . Saidi’s report and expressly detailed his reservations con cerning other portions of it. Of course, in addition to relying on Dr . Clark’s testimony, the ALJ rejected Dr. Saidi’s opinions because they lacked objective findings and were inconsistent with the supporting narrative. Indeed, Dr. Saidi expr essly based some of the restrictions in his medical s ource statement on a simple dete rmination that there were “no . . . other significant findings.” Id. , Vol. II at 665-66. But neither of these objections seems to apply to the limitations Dr. Saidi imposed on reaching and handling. Dr. Saidi stated he imposed the limitations because Ms . Wells’ “range of motion in shoulder and neck ar e within normal limit[s] but associated with stiffness,”- 23 - a conclusion neither unsupported by his obj ective medical testing nor inconsistent with his narrative. Id. at 665. 11
Given the VE’s statement about the effect of these limitations on Ms. Wells’ ability to perform her PRW, and given ou r remand on other grounds, the ALJ should re-evaluate on remand Ms. Wells’ alleged limi tations on reaching and handling. He should provide proper reasons if he again ch ooses to reject them, or else properly factor them into his an alysis of her RFC. C. Physician Assist ant Boatner’s Assessment McKinley Boatner, a physician’s assistant, provided a medical source statement that contained seve re limitations on Ms. Wells’ ab ility to lift, stand, walk, sit, and perform such activities as cl imbing, balancing, stooping, kneeling or crouching. Aplt. App., Vol. II at 537-38. In considering this statement, the ALJ noted that Mr. Boatner was not an “accepta ble medical source[]” within the meaning of the regulations. See 20 C.F.R. §§ 404.1513(a), 416. 913(a) (defining acceptable medical sources). This meant that Mr . Boatner’s statemen t was not entitled to consideration as a “medical opinion” under the regulations, but could be considered to show the severity of Ms. Wells’ impairments and how th ey affected her ability to work. See id. §§ 404.1513(d) , 416.913(d).

11 The Commissioner discounts this reasoning because Dr. Saidi’s range-of-motion testing revealed stiffness but no pain. Aplee. Br. at 30. But there is no inconsistency here: Dr. Said i stated it was stiffness, not pain, that would preclude Ms. Wells from more than occasional reaching, hand ling, or pushing/pulling.- 24 - The ALJ assigned Mr. Boatner’s statement less weight than the opinions of the non-examining state agency doctors and the medical expert at the hearing. He found that Mr. Boatner’s conclusions were inconsistent with th e medical expert’s testimony and with other evidence in the file. Notwithstanding Ms . Wells’ argument to the contrary, the ALJ’s explanation of the wei ght assigned to Mr. Boatner’s statement is sufficient for us to follow his reasoning. See Bowman v. Astrue , 511 F.3d 1270, 1275 (10th Cir. 2008) (requiring th at ALJ’s discussion of “o ther source” evidence be sufficiently clear that cour t can “follow the adjudicat or’s reasoning” (internal quotation marks omitted)). We discern no reversible error in the ALJ’s discussion of this report, and his conclusions concerni ng the report were s upported by substantial evidence. 2. ALJ’s Conclusions Concerning Past Relevant Work Ms. Wells makes additional arguments concerning the ALJ’s decision at step four. “Step four of the sequential analys is . . . is comprise d of three phases.” Winfrey v. Chater , 92 F.3d 1017, 1023 (10t h Cir. 1996). “In the first phase, the ALJ must evaluate a claimant’s physical and mental [RFC], a nd in the second phase, he must determine the physical and mental de mands of the claimant ’s past relevant work.” Id. (citation omitted). “In the final phase, the ALJ determines whether the claimant has the ability to meet the job demands found in phase two despite the mental and/or physical limita tions found in phase one.” Id. “At each of these phases, the ALJ must make specific findings.” Id.- 25 - Ms. Wells first disagrees with the AL J concerning which jobs constituted her PRW. The ALJ found that she was capable of performing her PRW as a bookkeeper, a customer complaint clerk, an order clerk, and a home h ealth aide coordinator. Ms. Wells argues that three of these four jobs—custome r complaint clerk, order clerk, and home health coor dinator—did not constitute PR W because she did the jobs on a part-time basis or only for a short time. She also argues that she performed them after October 31, 1999, and the Appeals Coun cil previously determined that her work activity after that date di d not constitute SGA. The Commissioner does not contest her repr esentation that thes e three jobs did not constitute PRW. But even if she coul d only perform the job of bookkeeper, that job is sufficient to suppor t the ALJ’s step-four determin ation concerning her PRW. The Commissioner need not esta blish that a prior job exists in significant numbers in the national economy to find th at job constitutes PRW. See Barnhart v. Thomas , 540 U.S. 20, 25, 29-30 (2003). Second, Ms. Wells argues that the AL J erred by failing to make the required phase-two findings regarding the physical and mental de mands of her PRW. To make the findings required by phase two of step four, an ALJ must obtain adequate “factual information about those work demands which have a bearing on the medically established limitati ons.” SSR 82-62, 1982 WL 31 386, at *3 (1982). Such information regarding work demands may be obtained from the clai mant herself, her employer, or another informed source. See id. Ms. Wells contends that the ALJ- 26 - “failed to obtain testimony re garding the specific duties of Wells’ PRW from either [Ms.] Wells or the VE.” Aplt. Br. at 31. We disagree. The ALJ’s phase-two task is case-dependent. See SSR 82-62, 1982 WL 31386, at *3 (“Detailed information abou t . . . mental demands [of past relevant work] . . . must be obtained as appropriate .” (emphasis added )). Here, the only medically established limi tations at issue in our Winfrey analysis are the ALJ’s findings that Ms. Wells could only perform the full range of light work between October 31, 1999, and December 31, 2004, and only a full range of sedentary work after December 31, 2005. Thus, the ALJ n eeded only to obtain enough information regarding these limitations to determine whether Ms. Wells could perform her PRW as a bookkeeper despite them. Winfrey , 92 F.3d at 1025. This, he did. The ALJ questioned the VE concerning th e bookkeeper job, and was told that it was “a sedentary skilled occupa tion” at level six. Aplt. A pp., Vol. I at 112. Thus, the ALJ had sufficient information re garding the demands of Ms. Wells’ bookkeeping job relevant to his RFC asse ssment, which included the full range of either light or sedentary work and feat ured no other specific mental or postural limitations. Furthermore, the ALJ made a sufficient finding concerning this issue when he stated that “[t]he cl aimant’s past work of bookk eeper . . . [was] sedentary in exertional level.” Id. at 44. 12 In the event that this RFC assessment changes as a

12 The ALJ imposed further restricti ons on the bookkeepi ng job beyond those inherent in sedentary work, stating that it “require[d] lifting, carrying, pushing, and (continued)- 27 - result of the remand we have ordered, howev er, we note that the ALJ may be required to obtain additional information concerni ng the physical or me ntal demands of Ms. Wells’ PRW in order to properly complete the Winfrey analysis. Ms. Wells also complains that the AL J failed to determin e whether she could perform the requisite physi cal and mental activities a ssociated with her PRW on a full-time, sustained basis. 13 The issue is whether th e ALJ improperly failed to “discuss [Ms. Wells’] ability to perform sustained work act ivities in an ordinary work setting on a regular and continuing basis (i.e., 8 hours a day, for 5 days a week, or an equivalent work schedule).” SSR 96-8p, 1996 WL 374184, at *7. We conclude (subject to additional development of the issu es on remand that we have ordered) that he did provide an adequate discussion. The ALJ did not simply make general findings that Ms. Wells could perform the full range of light work between October 31, 1999, and December 31, 2004, and only a full range of sedentary work after

pulling 10 pounds occasiona lly; and required mostly si tting, but may involve standing or walking for brief periods of time .” Aplt. App., Vol. I at 44. We cannot discern the basis in the reco rd for these findings. But a ny error or inconsistency is harmless, because according to the ALJ’s RFC, such restrictions would pose no problem for Ms. Wells, who can do the full range of either light or sedentary work.
13 Confusingly, she then argues that the ALJ did make such findings, but that they were not supported by substantial evidence. See Aplt. Br. at 32. Her argument about substantial evidence, how ever, is inadequate for j udicial review; she merely states in a single sentence th at “[t]he record contains evidence from Dr. Swink, Dr. Saidi, Dr. Clark, and McKinley Boat ner that clearly show s [Ms.] Wells cannot perform her PRW or SGA on a sustained basis.” Id. at 33. Accordingly, we will confine our discussion to her i ssue concerning adequate findings.- 28 - December 31, 2005. He also made subsidiary findings, pertaining to the former period, that she could “occasionally lift a nd/or carry 20 pounds,” could “frequently lift and/or carry 10 pounds,” c ould “stand and/or walk 6 ho urs in an 8 hour workday (with normal breaks),” and could “sit for 6 hours in an 8 hour workday (with normal breaks).” Aplt. App., Vol. I at 31. With regard to the latt er period, he found that she could “occasionally lift and/or carry no more than 10 pounds,” that she could “stand and/or walk (with normal breaks) about 4 h ours of an 8-hour workday and sit (with normal breaks) 6 hours of an 8-hour workday.” Id. at 41. Moreover, his findings concerning these exertional ab ilities were supported by a discussion of such factors as the “medical history,” “medical signs and laborat ory findings,” “effects of treatment,” “[r]eports of daily activities,” “[l]ay ev idence,” “[m]edical source statements,” “[e]ffects of symptoms,” and “[e]vidence from attempts to work.” SSR 96-8p, 1996 WL 374184, at *5. Ms. We lls fails to show that this discussion was inadequate. Finally, Ms. Wells contends that the AL J failed to discuss the effect of her symptoms, including pain, on her ability to work. Additional development and/or discussion is needed on the issu e of her mental impairments, as discussed herein. But otherwise, in his decision, the ALJ pr ovided the required narrative explanation concerning why he did not find her subject ive complaints to be fully credible. See Aplt. App., Vol. I at 31-36, 41-43. We therefore reject this argument.- 29 - CONCLUSION The judgment of the district court is reversed and remanded with instructions to remand to the Commissioner for further proceedings cons istent with this opinion.