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If medical evidence is thought of as the technical consideration of a disability claim, nonmedical factors can be thought of as the human consideration. This is where a disability 

claim begins - what is the ailment and how does it affect the applicant? A report of nonmedical factors enables DPS to evaluate the applicant's residual capacity for work. It is 

the consideration of non-medical factors which makes a disability decision not just a 

medical decision. Therefore, good development of non-medical factors is just as 

important in many cases as development of medical evidence. Since the disability 

claims examiner who makes the determination of disability under the Railroad 

Retirement Act and the Social Security Act does not see the applicant, the non-medical 

factors report is a "picture" of the applicant that the examiner must weigh along with the 

medical evidence submitted. Correct disability determinations depend upon good 

representation of both.

Non-medical factors may also serve as the basis for developing medical evidence at 

Railroad Retirement Board expense when no other medical evidence exists.

1315.5 Non-Medical Factors Defined

In general terms, non-medical factors include:

• A description from the applicant of his medical condition.

• The applicant's statement of how and when his condition affected his ability to work.

• A description from the applicant of his current daily activities and how they have 

been changed due to his medical condition.

• A summary of the applicant's education and training.

A description of the duties of the job(s) the applicant performed in the 5 years and in the 

15 years prior to filing a disability claim. (Vocational factors are considered when 

determining if an employee or a widow(er) is disabled. They are not considered when 

determining if a remarried widow(er) or a surviving divorced spouse is disabled.)

In cases when the application is taken in person and the contact representative 

observes something pertinent to the disability claim, the observations are noted on 

Form G-626A, Field Office Personal Observation Record. It is not necessary for a 

contact representative to travel or meet with an applicant in order to obtain a personal 

observation, unless requested. If activities of daily living (ADLs) are needed, these can 

be secured either by phone or in person. 

The following are examples of observations that may be considered pertinent: a 

description of any unusual aspects regarding the applicant's appearance, abnormal skin 

conditions, swelling or abnormality of any joints, peculiarity of speech or manner, 

shortness of breath, nervousness; supporting devices such as a cane, crutches, corset, 
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or leg brace; if eye glasses and hearing aid are owned, whether worn or not; stance; 

walk, such as a limp or foot drag.

1315.10 Reporting Non-Medical Factors

Vocational (Non-medical) factors for employee, surviving spouse, surviving remarried 

spouse or surviving divorced spouse applicants are reported on Form G-251. Form G251A is completed in occupational disability claims only.

Form G-251 should ordinarily be completed by the applicant. Form G-251A request job 

information from railroad employers. Specific instructions for completing Forms G-251 

and G-251A are contained in FOM-I-1720. 

When it is established that a person intends to file an application for disability, they 

should be furnished with Form G-251. Field offices are encouraged to furnish this form 

before an application is filed, if possible. However, do not refuse or delay an application 

for disability until the applicant furnishes a vocational report. 

When an employee, surviving spouse, surviving remarried spouse or surviving divorced 

spouse is filing an application for a period of disability (Disability Freeze) and/or early 

Medicare and has previously submitted a Form G-251, it is not necessary to secure a 

new G-251 if they not worked since they last filed for disability. A note should be put in 

the Remarks section of the application transmittal form that a G-251 will not be 

submitted because the claimant has not worked since the last G-251 was submitted. In 

addition, EDMA should be checked to verify that no earnings have been posted since 

the last G-251 was submitted.

Do not make diagnoses or judgments in the report as to whether the applicant is 

disabled under the Railroad Retirement Act. While regard should be given to the fact 

that the applicant claims to be disabled, do not say anything that might cause a claimant 

to believe they will be found disabled. The assurance you can give them is that their

claim will be developed properly, that it will receive just consideration and that there is 

an appeals procedure if they disagrees with the determination.

Other pertinent non-medical factors are noted in the Remarks section of the disability 

application. In some cases, DBD may request the field representative to provide their 

personal observations. In these cases, the observation can be provided via e-mail or 

memorandum.

1315.15 Documenting Daily Activities For Development Of Mental 

Impairment Cases

Mental impairments cause disability when the individual’s ability to function is 

significantly restricted by the mental condition. In evaluating mental impairments, 

severity is measured in part by an objective description of findings of the claimant’s 

activities of daily living (ADL). These ADL findings are documented in the Daily 

Activities sections of the disability applications and the G-254 (for cases requiring a 
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continuing disability review), and the form G-31 Activities of Daily Living Worksheet. 

The field service is primarily responsible for securing ADL findings in the RRB forms. 

They are essential to mental impairment claims adjudication and are used at 

headquarters to determine the severity of impairment, ascertain an appropriate mental 

residual functional capacity or determine a claimant’s ability to perform their past 

railroad work or any other work. 

NOTE: ADL findings may also be needed when determining the effect of symptoms 

such as neurological disorders, chronic fatigue, and chronic pain. The need for ADL 

findings in pain cases is a technical determination that can be made by a disability 

examiner but is usually made by a medical consultant. 

1315.15.1 Why We Develop for ADL 

An objective description of signs, symptoms and findings from existing records from 

hospitals, treating physicians, therapists and consultative examinations are used to 

determine the existence of a mental impairment. However, since there are no 

laboratory tests or any other diagnostic methods that can reliably measure functional 

limitations caused by mental impairments, we must rely on other evidence such as daily 

activities. The applicant is the primary source for this information unless the Disability 

Benefits Division (DBD) advises otherwise, or the contact representative believes the 

applicant to be unreliable or incapable of accounting for their daily activities. 

NOTE: In cases where a third-party source is used to obtain ADL findings, the name 

and relationship of that person is to be noted under “additional information” in the RRB 

form being completed by the field service. 

1315.15.2 Activities of Daily Living Documentation

For mental disorders, severity is assessed in terms of the functional limitations imposed 

by the impairment. Documentation of functional limitations is essential to accurate 

adjudication. A marked limitation may arise when activities or functions are impaired 

and the degree of limitations is such as to severely interfere with the ability to function 

independently, appropriately and efficiently. 

The ADL findings are documented in Daily Activities sections of the disability 

applications and the G-254 (for continuing disability reviews), and the form G-31 

worksheet. A detailed documentation of the applicant's activities of daily living and 

social functioning is an important tool in determining the severity of most mental 

impairments. Documentation should include a complete description of each activity 

discussed in the interview. The frequency, appropriateness, and quality of activities 

should be described along with the description of independence with which the 

applicant can perform them (that is, does the applicant need help to do them?). For 

instance, applicants who claim that they can cook should explain how the food is 

prepared, the variety of food and how often they cook. The more complete the 

information, the better a reviewer can evaluate a claim and avoid follow-up 

assignments. 
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1315.15.3 Field Office Development of the G-31

The form G-31 worksheet should be developed at the time the disability application is 

taken if any of the following criteria applies:

• The applicant is claiming a mental impairment, neurological impairment, chronic 

pain, or chronic fatigue as one of the primary conditions contributing to their claim 

of disability.

• Examples of mental impairments include but are not limited to:

o Bi-polar disorder, anxiety, schizophrenia, obsessive compulsive 

disorder, post-traumatic stress disorder

• Examples of neurological impairments include but are not limited to:

o Epilepsy, Alzheimer disease, Parkinson’s disease, brain tumor, 

cerebrovascular accident (stroke)

• Examples of chronic pain and chronic fatigue allegations when due to a 

diagnosis include but are not limited to:

o Multiple sclerosis, cancer related fatigue, or depression due to 

chronic pain 

• As part of the review of the medical evidence it is discovered that the applicant 

has been treated for a mental impairment, a neurological impairment, chronic 

pain, or chronic fatigue. 

• As part of the interview process the claims representative notices bizarre 

behavior from the applicant.

• As part of the interview process the claims representative infers that a mental 

impairment, neurological impairment, chronic pain, or chronic fatigue may exist. 

For example, the applicant alleges impairments which the medical evidence does 

not support.

1315.15.4 When it is not Necessary to Develop a G-31

It is not necessary to develop a G-31when the applicant’s condition is obviously severe 

and enough other medical evidence is being submitted to substantiate a claim of 

disability. This includes a condition such as a disabled child with an IQ of 59 or less.

There are at least three instances where it is not necessary to develop for a G-31 with 

the initial application. However, upon review of all information in the file, the disability 

examiner may still determine additional ADL findings development needed. The 

conditions are: 

• An applicant is currently institutionalized due to a mental condition,
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• An applicant has filed and is receiving benefits at SSA based on a disability rating 

within the last year.

• An applicant’s physical condition will be severe enough for a finding of disability. 

See example in Section FOM-I-1315.15.5. 

1315.15.5 Requests for Completion of the G-31

Many disability applicants who file based on physical impairments also complain of 

anxiety or depression. It may be indicative of a significant psychiatric illness, or it may 

be a natural manifestation of a person who is no longer working because of a disability. 

We should not develop medical evidence for alleged psychiatric impairments, including 

a G-31, unless there is an indication that the applicant’s alleged psychiatric impairment 

is potentially severe.

For example, an applicant applies for a total and permanent disability annuity based on 

a herniated disk, diabetes mellitus, color blindness and depression. The AA-1d shows 

they are taking insulin but no anti-depressants. The timely records of the treating 

physician show mental functioning to be normal and mention no depression. The 

hospital records likewise do not show depression in either the pre- or post- operative 

diagnoses. Because there is no indication that the applicant’s depression is severe or 

potentially severe, no development is necessary in this area, unless the claimant 

alleges that the mental impairment is new.

Any request for a G-31received from DBD should include an explanation from the 

disability examiner making the request as to why G-31 is needed. The explanation 

should provide the claims representative with an understanding of why the G-31is 

needed. 

For example, if the Disability Post section needs a G-31 as part of the CDR process, 

the explanation would say something like, “This applicant was previously rated disabled 

based on depression. We are now conducting a CDR and need an updated G-31.”

Occasionally an RRB medical consultant will request G-31 development in situations 

that would appear to meet the criteria for not being needed, as explained in this 

procedure. The medical consultants request is based on medical findings by a medical 

professional, using knowledge and experience that is not covered in this procedure. In 

these cases, the explanation is a statement that the medical consultant requested G-31

development. 

1315.15.6 Conducting an ADL Interview and Compiling ADL Documentation

If the field service is interviewing for the purpose of obtaining ADL findings it is important 

to make applicants feel that they are part of the process rather than the subject of an 

interrogation. Explain that the purpose of the interview is to consider how daily activities 

have been affected by the condition they are claiming. Encourage applicants to freely 

describe their activities by using open ended questions such as "What, Why, When, Tell 
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Me," rather than questions that are conducive to a yes or no answer. The form G-31

worksheet, available on RRAILS, is recommended as a guideline for conducting the 

interview and provides a structured narrative reporting that gives the complete 

information needed for the disability determination process.

In some instances headquarters will send a copy of previous ADL documentation in file 

for the applicant/annuitant. This will happen when DBD is performing a CDR or if an 

applicant is filing for a disability freeze after having their initial disability freeze 

application denied. The field staff should be sure that the new ADL documentation

shows any changes in the various activities. (Note: It is possible that due to the 

applicant’s lifelong condition, no changes have occurred.) It is important to obtain the 

individual's current status on all daily living activities. Therefore, the "old" activities of 

daily living documents are to be used only as background and a reference to assist the 

C/R in developing more complete ADL findings when changes in the daily activities are 

noted. Annuitants must still be questioned about each activity. In questioning 

annuitants, do not refer directly to a behavior reported in previous ADL documents. 

For example, if an annuitant previously said they stopped attending their child’s sporting 

events due to depression, do not ask if they are still too depressed to attend their child’s 

sporting events. Instead, approach the issue indirectly by asking about what they enjoy 

doing? Do they participate in family activities? Are they involved with their children’s 

school and/or after school activities?

Once the communication flow is established, encourage the applicant to continue 

talking by using phrases such as "tell me more." Record only objective data with 

examples, including a comparison of current daily activities to activities prior to the 

onset of the mental impairment.

For example: When asked about recreation, hobbies or social activities, the applicant 

said that they used to enjoy going to the movie theater. They explained that for the past 

15 years they went to the theater at least twice a month with a friend or by themselves.

They went on to say that it has been over 6 months since they have gone to a theater 

because they believe that everyone in the theater is laughing at them. Further, they

avoid any public activities for the same reason. 

Rather than trying to determine how the person’s activities or behaviors compare to 

some norm, the objective of ADL documents is to determine how the impairment has 

affected their lives and ability to function. Therefore, documentation for the period 

before the onset date is very helpful in determining functional limitations caused by 

mental impairments. 

Exception: When the claimed impairment is Intellectual Disability the ADL documents

should illustrate the claimant’s lifelong limitations rather than changes in the ADL. 
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1315.15.7 Preparing and Submitting ADL Documents

Field staff is required to ensure that the Daily Activities sections of the disability 

applications or the G-254 (if a CDR is being conducted) contain responses. These 

sections can be completed without the need for the field service to conduct an interview

and should be imaged along with the rest of the disability application or G-254. 

When a mental impairment (psychological and neurological) is alleged or suspected 

then the field service will need to further elaborate on the responses given in the Daily 

Activities sections by performing an interview and completing the form G-31 worksheet. 

During the interview process for alleged or suspected mental impairment be sure to use 

G-31 as a guide to solicit clear and complete ADL findings. If you have questions that 

will elicit the necessary information and they are not on the G-31, then use your

questions and add them to the G-31. The questions on the G-31 may not fit all 

situations, but they are helpful as a guide. 

The G-31 worksheets should never be photocopied and handed to the applicant, nor 

should it ever be mailed to the applicant. The applicant will provide more complete and 

useful information in the interview process. Before concluding the interview and 

finalizing the documentation of the ADL findings refer to the worksheet to verify that all 

relevant questions have been discussed with the applicant for a complete description of 

daily activities and social functioning. It should also be noted that the interviewer needs 

to obtain information from the applicant that illustrates how the mental condition has 

changed the applicant’s ADL since the onset of the mental condition. Be sure to include 

examples and quotations to help support and clarify information given in the interview.

When the G-31 is finalized, it is to be imaged. After having it imaged a paper copy is to 

be made and included with the disability application package being forwarded to DBD. 

If the G-31 is being done after the disability application package is submitted, send the 

G-31 to DBD as an e-mail attachment. As an alternative, if you are also sending 

additional medical evidence, you may send a completed G-31 paper copy along with the 

other medical.