See Ranellucci v. Astrue, No. 3:11-cv-00640, 2012 WL 4484922, at *10 (M.D. Tenn. Sept. 27, 2012) (addressing SSR 18-3p's predecessor).

As highlighted by Defendant, medical records also describe Plaintiff as having been "very inconsistent with her attendance" at physical therapy (AR 1479, 1489, 1498), and that she refused to engage in continued treatment with rheumatologists despite referrals to do so (AR 786, 1327), which further supports the ALJ's adverse finding. See Ranellucci v. Astrue, No. 3:11-cv-0640, 2012 WL 4484922, at *11 (M.D. Tenn. Sept. 27, 2012) (noting that an ALJ "could properly use Plaintiff's non-compliance with treatment as a factor in analyzing Plaintiff's credibility"). Finally, although Plaintiff suggests that the ALJ disregarded her need to use a motorized wheelchair (DE 18-1 at 13), the record indicates that her treating providers actually advised against the use of a wheelchair and recommended regular exercise and weight loss, as noted by the ALJ. (AR 26, 677, 681, 1622.)

Accordingly, as illustrated above, the ALJ provided meaningful explanations, supported by substantial evidence, when crafting Plaintiff's RFC. Considering her use, or non-use, of a specific treatment in making that determination is not an error. Id.; see also Ranellucci v. Astrue, No. 3:11-cv-00640, 2012 WL 4484922, at *11 (M. D. Tenn. Sept.27, 2012). IV. CONCLUSION

See Peacock v. Astrue, No. 2:05-cv-0076, 2009 WL 3615011, at *14 (M.D. Tenn. Nov. 2, 2009) ("The reason giving requirement also exists so plaintiffs understand the disposition of their cases and to ensure[] that the ALJ applies the treating physician rule and permits meaningful review of the ALJ's application of the rule.") (citing Wilson, 378 F.3d at 544-45) (internal quotations omitted). Additionally, while noncompliance with treatment may be relevant in evaluating the credibility of a claimant's allegations of disabling pain, Ranellucci v. Astrue, No. 3:11-cv-0640, 2012 WL 4484922, at *11 (M.D. Tenn. Sept. 27, 2012), it is unclear how Plaintiff's use of substances detracts from either of the MSS findings given that Dr. Dhamodharan was not only aware of Plaintiff's alcohol and marijuana use, but identified "alcohol dependence" and "cannabis use disorder" as diagnoses and bases for her suggested mental restrictions. (AR 743, 1261, 2098).

See Quinlan v. Comm'r of Soc. Sec., No. 1:14-cv-427, 2015 WL 3447844, at *11 (S.D. Ohio May 28, 2015), report and recommendation adopted, 2015 WL 3822624 (S.D. Ohio June 19, 2015) (ALJ's finding that a claimant's mental impairment was non-disabling supported by records documenting an absence of abnormalities of thought content and mild to moderate symptoms that improved with medication). The ALJ further noted Plaintiff's lack of strict compliance with her medication regimen, which similarly bolsters her analysis. Ranellucci v. Astrue, No. 3:11-cv-0640, 2012 WL 4484922, at *11 (M.D. Tenn. Sept. 27, 2012) (noting that the ALJ "could properly use Plaintiff's non-compliance with treatment as a factor in analyzing Plaintiff's credibility"). With respect to the latter, Plaintiff argues that the ALJ overemphasizes her non-compliance since the only medication that she "rarely" took was mirtazapine, which she dismisses as a mere "bedtime medication."

She did not engage in the recommended aerobic exercise (Tr. 421). An ALJ may use a claimant's non-compliance with treatment as a credibility factor. See Ranellucci v. Astrue, No. 3:11-cv-00640, 2012 WL 4484922, *10 (M.D. Tenn., September 27, 2012) (finding noncompliance with prescribed treatment is appropriate factor with which to assess claimant's credibility) (citing Holley v. Massanari, 253 F.3d 1088, 1092 (8th Cir. 2001)); see also SSR 96-7p (claimant's claims of disabling impairment "... may be less credible if ... not following treatment as prescribed ..."). In sum, the ALJ carefully considered numerous factors bearing on Plaintiff's credibility and concluded that her statements regarding the degree of her limitations was not credible. He then made an assessment of her limitations based on the numerous factors cited above in addition to the opinion evidence provided in this case.

In fact, Plaintiff's doctor recommended conservative treatment, not surgery. Inconsistencies detract from Plaintiff's credibility. See Ranellucci v. Astrue, 2012 WL 4484922, *10 (M.D. Tenn., September 27, 2012) (citation omitted). R. 46.