Opinion
CV-23-00197-TUC-RM (LCK)
05-06-2024
Sheryl Ann Weber, Plaintiff, v. Commissioner of Social Security Administration, Defendant.
REPORT AND RECOMMENDATION
HONORABLE LYNNETTE C. KIMMINS, UNITED STATES MAGISTRATE JUDGE.
Plaintiff Sheryl Weber filed this action pursuant to 42 U.S.C. § 405(g) seeking judicial review of a final decision by the Commissioner of Social Security. (Doc. 1.) Befor the Court are Plaintiff's Opening Brief, Defendant's Responsive Brief, and Plaintiff's Reply (Docs. 15, 17, 18.) Pursuant to the Rules of Practice of the Court, this matter was referred to Magistrate Judge Kimmins for Report and Recommendation. Based on the pleading and administrative record, the Magistrate Judge recommends the District Court, after it independent review, affirm the Commissioner's decision.
FACTUAL AND PROCEDURAL HISTORY
Plaintiff filed an application for Disability Insurance Benefits (DIB) in July 2020 alleging disability from February 1, 2019. (Administrative Record (AR) 195.) She wa born in August 1963, making her 55 years of age at the alleged onset date of her disability (AR 227.) She had past relevant work as a cashier, sales associate, inventory clerk, an stocker for Walmart. (AR 46-47, 207, 234-38.) Plaintiff's application was denied upoi initial review (AR 53-69) and on reconsideration (AR 70-77).
A hearing was held on April 25, 2022 (AR 33-50), after which the ALJ found that Plaintiff was not disabled (AR 13-27). The ALJ determined Plaintiff had one severe impairment of degenerative disc disease. (AR 16.) The ALJ concluded Plaintiff had the Residual Functional Capacity (RFC) to perform light work with no exposure to unprotected heights or hazardous machinery. (AR 20.) The ALJ concluded at Step Four, based on the testimony of a vocational expert (VE), that Plaintiff could perform her past work as a cashier. (AR 26-27.) The Appeals Council denied review of the ALJ's decision. (AR 1.) STANDARD OF REVIEW
The Commissioner employs a five-step sequential process to evaluate DIB claims. 20 C.F.R. § 404.1520; see also Heckler v. Campbell, 461 U.S. 458, 460-462 (1983). To establish disability the claimant bears the burden of showing she (1) is not working; (2) has a severe physical or mental impairment; (3) the impairment meets or equals the requirements of a listed impairment; and (4) claimant's RFC precludes her from performing her past work. 20 C.F.R. § 404.1520(a)(4). At Step Five, the burden shifts to the Commissioner to show that the claimant has the RFC to perform other work that exists in substantial numbers in the national economy. Hoopai v. Astrue, 499 F.3d 1071, 1074 (9th Cir. 2007). If the Commissioner conclusively finds the claimant "disabled" or "not disabled" at any point in the five-step process, he does not proceed to the next step. 20 C.F.R. § 404.1520(a)(4).
"The ALJ is responsible for determining credibility, resolving conflicts in medical testimony, and for resolving ambiguities." Andrews v. Shalala, 53 F.3d 1035, 1039 (9th Cir. 1995) (citing Magallanes v. Bowen, 881 F.2d 747, 750 (9th Cir. 1989)). The findings of the Commissioner are meant to be conclusive if supported by substantial evidence. 42 U.S.C. § 405(g). Substantial evidence is "more than a mere scintilla but less than a preponderance." Tackett v. Apfel, 180 F.3d 1094, 1098 (9th Cir. 1999) (quoting Matney v. Sullivan, 981 F.2d 1016, 1018 (9th Cir. 1992)). The court may overturn the decision to deny benefits only "when the ALJ's findings are based on legal error or are not supported by substantial evidence in the record as a whole." Aukland v. Massanari, 257 F.3d 1033, 1035 (9th Cir. 2001). This is so because the ALJ "and not the reviewing court must resolve conflicts in the evidence, and if the evidence can support either outcome, the court may not substitute its judgment for that of the ALJ." Matney, 981 F.2d at 1019 (quoting Richardson v. Perales, 402 U.S. 389, 400 (1971)); Batson v. Comm'r of Soc. Sec. Admin., 359 F.3d 1190, 1198 (9th Cir. 2004). The Commissioner's decision, however, "cannot be affirmed simply by isolating a specific quantum of supporting evidence." Sousa v. Callahan, 143 F.3d 1240, 1243 (9th Cir. 1998) (citing Hammock v. Bowen, 879 F.2d 498, 501 (9th Cir. 1989)). Reviewing courts must consider the evidence that supports as well as detracts from the Commissioner's conclusion. Day v. Weinberger, 522 F.2d 1154, 1156 (9th Cir. 1975).
DISCUSSION
Plaintiff alleges the ALJ committed two errors: (1) he failed to properly analyze opinion evidence from Dr. Katie Grund; and (2) he failed to find Plaintiff's mental impairments severe at Step Two and did not include any mental limitations in the RFC.
Opinion Evidence by Dr. Katie Grund
Plaintiff contends that the ALJ erred in her evaluation of the opinion of Dr. Grund and his rejection of her opinion was not supported by substantial evidence. The regulations governing cases filed after March 27, 2017, such as this one, state that an ALJ will consider all medical opinions and, at a minimum, articulate how he evaluated the opinion's supportability and consistency. 20 C.F.R. § 404.1520c(a) & (b). The governing regulations provide the following additional guidance regarding the factors of supportability and consistency:
(1) Supportability. The more relevant the objective medical evidence and supporting explanations presented by a medical source are to support his or her medical opinion(s) or prior administrative medical finding(s), the more persuasive the medical opinions or prior administrative medical finding(s) will be.
(2) Consistency. The more consistent a medical opinion(s) or prior administrative medical finding(s) is with the evidence from other medical sources and nonmedical sources in the claim, the more persuasive the medical opinion(s) or prior administrative medical finding(s) will be.20 C.F.R. § 404.1520c(c). "Even under the new regulations, an ALJ cannot reject an examining or treating doctor's opinion as unsupported or inconsistent without providing an explanation supported by substantial evidence." Woods v. Kijakazi, 32 F.4th 785, 792 (9th Cir. 2022).
On March 29, 2022, Dr. Grund completed a physical assessment. (AR 444-45.) She diagnosed Plaintiff with lumbar canal stenosis and major depression, chronic recurrent. (AR 444.) She opined that Plaintiff's symptoms were of a severity level at which they frequently interfered with concentration and attention for simple work tasks, and that Plaintiff's medications caused sedation, dizziness, and impaired concentration. (Id.) Dr. Grund found Plaintiff could sit for 5-6 hours and stand for 1 hour in an 8-hour workday. (Id.) The doctor determined that Plaintiff could walk one half-block without a break or experiencing significant pain. (Id.) She opined that Plaintiff could never lift or carry even 10 pounds. (Id.) She indicated that Plaintiff could reach with her arms only 10% of a workday. (Id.) Dr. Grund stated that Plaintiff would need to take a 5-minute break every hour and would need to lie down outside of the 3 breaks allowed in a standard workday. (Id.) And she concluded that Plaintiff would miss more than 4 days of work per month due to her impairments. (AR 445.)
Dr. Grund also completed a Mental Capacity Assessment on the same date. (AR 440-42.) Plaintiff did not challenge the ALJ's rejection of this opinion.
The ALJ found that Dr. Grund did not provide support for her opinions and that her opinions were inconsistent with the diagnostic and objective findings. (AR 25.) The ALJ cited unremarkable physical exams with frequent normal findings. (Id.) The ALJ concluded that these exam findings did not reflect the level of limitation found by Dr. Grund. (Id.)
First, Defendant argues that the ALJ properly rejected Dr. Grund's opinion because the doctor provided little support for her opinion. Defendant is correct that Dr. Grund provided little explanation for her opinion on the form she completed. However, as this Court has explained, "the supportability of a physician's opinion necessarily still includes a review of that doctor's treatment notes, not just the narrative explanation on the form." Curtin v. Comm'r of Soc. Sec. Admin., No. CV-21-00790-PHX-GMS, 2023 WL 387202, at *6 (D. Ariz. Jan. 25, 2023); Moreno v. Comm'r of Soc. Sec. Admin., No. CV-22-00319-PHX-DLR, 2023 WL 4926258, at *3-4 (D. Ariz. Aug. 2, 2023). It is error to reject a doctor's opinion as lacking explanation without examining whether the opinion reflects that practitioner's treatment notes. See Garrison v. Colvin, 759 F.3d 995, 1013, 1014 n.17 (9th Cir. 2014); cf. Trevizo v. Berryhill, 871 F.3d 664, 677 n.4 (9th Cir. 2017) (finding that "check-the-box" forms are not inherently unreliable). Thus, the Court looks to Dr. Grund's treatment notes to evaluate supportability.
The ALJ highlighted numerous records from Dr. Grund with primarily normal examination including "no acute distress, with normal range of motion of all major joints, normal motor strength throughout, grossly normal sensation throughout, normal reflexes, intact coordination, normal bilateral grip strength, and a normal gait." (AR 21-25.) The ALJ's summary is supported by substantial evidence. The first two substantive records from Dr. Grund, in January 2019, revealed the most abnormal examinations. At that time, Plaintiff reported an exacerbation of her low back pain and Dr. Grund noted an antalgic and slow gait, tenderness to palpation in right lumbar musculature, and limited lumbar spinal flexion, but no acute distress. (AR 344, 339.) In May 2019, Dr. Grund documented that Plaintiff was in no acute distress, her gait was normal, and her neurological motor and sensory were intact. (AR 334.) The following month, Plaintiff reported that her back had "gone out" and her pain was not well-controlled. (AR 328.) However, Dr. Grund's objective examination was normal. (AR 329.) In November 2020, Plaintiff was in a car accident and Dr. Grund's contemporaneous examination reflected poor range of cervical motion and tenderness at the back of the head and ribcage. (AR 379.) At her next appointment, in April 2021, Plaintiff's examination was normal, and her pain had returned to pre-accident levels. (AR 373-75.) In July 2021, Plaintiff reported experiencing borderline back spasms, but stated they were brief, did not restrict her activity, and medication controlled her pain. (AR 367.) Upon exam, Plaintiff was in no acute distress. (AR 368.) In December 2021, Plaintiff reported an increase in hip pain; however, an examination and subsequent x-rays of her hips were normal. (AR 427-28, 438.) As Plaintiff contends, Dr. Grund's records document her complaints of pain (Doc. 15 at 8), which the ALJ acknowledged in his summary of the records (AR 21-23). However, the supportability factor is focused on objective medical findings. 20 C.F.R. § 404.1520c(c)(1). Looking at the entire record, there is substantial evidence to support the ALJ's conclusion that Dr. Grund's opinion was not supported by her examinations.
Plaintiff argues that Dr. Grund's opinion was supported by June 2021 imaging of her spine. That image was ordered by DES and there is no evidence it was transmitted to Dr. Grund. (AR 365.) Therefore, the Court considers it with respect to consistency but not as to whether Dr. Grund's own records support her opinion.
Second, the Court examines the ALJ's finding that Dr. Grund's opinion was not consistent with other evidence of record. There are very limited records from sources other than Dr. Grund, but the Court summarizes it below. On January 9, 2021, Dr. Robert Barlow examined Plaintiff and documented that she: was in no acute distress; had a normal gait, tandem walk, reflexes, and range of motion; exhibited strength 5/5; had a normal sensory exam, with the exception of a decreased sensation to pinprick and light touch on her right foot; had a negative straight leg raise test; could lift and carry light objects, half-squat, get on and off the exam table without difficulty, and do a one-foot hop; and could use her hands without difficulty. (AR 354-58.) Dr. Barlow's opinion was that Plaintiff did not have a severe impairment. (AR 362.) As mentioned above, an x-ray of Plaintiff's hips was normal. (AR 438.) The only record from a source other than Dr. Grund that Plaintiff cites as consistent with the doctor's opinion is a June 2021 image of Plaintiff's spine, which reflected minimal grade 1 anterolisthesis L4 over L5 and degenerative disc and facet joint arthropathy L4-5 and L5-S1. (AR 365.) Although the imaging reflects objective evidence of an impairment, the state agency medical consultants that reviewed it, along with other record evidence, determined Plaintiff did not have a severe impairment. (AR 63, 73-74.) Again, looking at the records as a whole, there is substantial evidence to support the ALJ's conclusion that Dr. Grund's opinion was inconsistent with other record evidence.
Dr. Grund did not diagnose Plaintiff with anterolisthesis or degenerative disc and facet joint arthropathy. She diagnosed Plaintiff with lumbar canal stenosis, which the ALJ noted was not supported by the June 2021 imaging. (AR 19.)
As Plaintiff contends, there is some evidence to support Dr. Grund's opinion. But "the key question is not whether there is substantial evidence that could support a finding of disability, but whether there is substantial evidence to support the Commissioner's actual finding that claimant is not disabled." Jamerson v. Chater, 112 F.3d 1064, 1067 (9th Cir. 1997); see also Burch v. Barnhart, 400 F.3d 676, 680-81 (9th Cir. 2005) (“[w]e must uphold the ALJ's decision where the evidence is susceptible to more than one rational interpretation.”). With respect to Dr. Grund's physical assessment, the Court finds that there is substantial evidence to support the ALJ's rejection of it.
Mental Impairment
Plaintiff argues that the ALJ erred in finding that her mental impairment of major depressive disorder was not severe at Step Two. Plaintiff also contends the ALJ erred in not including any limitations from her mental impairment in her RFC.
Step Two
Step Two is a “de minimis screening device” used to identify all impairments (singly or in combination) with more than a minimal impact on a person's functioning. See Smolen v. Chater, 80 F.3d 1273, 1290 (9th Cir. 1996). An impairment is not severe if it does not "significantly limit[] your physical or mental ability to do basic work activities." 20 C.F.R. § 404.1520(c). To qualify as severe, an impairment also must last or be expected to last for 12 or more months. 20 C.F.R. § 404.1509.
The ALJ acknowledged that Plaintiff had a medically determinable impairment of major depressive disorder, but concluded it was non-severe because it did not cause more than minimal limitation in her ability to perform basic mental work activities. (AR 16.) The ALJ evaluated the "Paragraph B" criteria and found Plaintiff had no limitation in understanding, remembering, or applying information; and, at most, a mild limitation in interacting with others, concentrating, persisting, or maintaining pace, and adapting or managing oneself. (AR 17-18.) Plaintiff argues that the ALJ's findings were contrary to the record evidence.
Plaintiff contends the opinions of Dr. Grund and consulting psychologist Rohen supported finding her depression severe at Step Two. The ALJ rejected the opinion of Dr. Grund as not persuasive with respect to Plaintiff's mental health limitations, because he determined it was minimally supported and not consistent with the longitudinal record, Plaintiff's activities of daily living, and her mental status examinations. (AR 25.) Plaintiff has not challenged this finding by the ALJ. The ALJ also rejected the opinion of psychologist Rohen as not persuasive, because he determined it was speculative and not based on objective observations, and it was inconsistent with the longitudinal record, mental status exams, and Plaintiff's activities of daily living. (AR 24.) Plaintiff has not challenged this finding by the ALJ. A Plaintiff cannot establish that an impairment is severe at Step Two by relying on medical opinions properly discounted by the ALJ. See Lupe Gracia v. Comm'r of Soc. Sec. Admin., No. CV-20-01132-PHX-JAT, 2021 WL 3046903, at *5 (D. Ariz. July 20, 2021).
Defendant made this argument in his Answering Brief. (Doc. 17 at 13-14.) In her Reply, Plaintiff did not contend that she had, or could, legally challenge the ALJ's rejection of the opinions by Drs. Grund and Rohen. (Doc. 18.)
Plaintiff also argues that her primary care records demonstrate her major depressive disorder was severe. In December 2018, Dr. Grund documented Plaintiff's depression as stable. (AR 413.) At the two appointments in the following month, her mood and affect were normal. (AR 339, 344.) In June 2020, Plaintiff was in no acute distress with a normal mood and affect. (AR 329.) In April and December 2021, Plaintiff exhibited no acute distress, and normal appearance, mood, behavior, and thought. (AR 374-75, 428.) At only two appointments during three years of records did Plaintiff exhibit signs of depression. In May 2019, Plaintiff presented as tearful, crying, with poor eye contact, and isolating socially; however, her grooming was appropriate, and the doctor noted her to be in no acute distress. (AR 333-34.) Two years later, in July 2021, Plaintiff was stressed and exhibited a dysphoric mood and avoided eye contact; however, again, the doctor noted her to be in no acute distress. (AR 367-68.) Additionally, Plaintiff repeatedly declined Dr. Grund's offer to refer her for therapy. (AR 332, 367, 413.)
Plaintiff's mental status exams by consulting medical sources were essentially normal. Upon examination by psychologist Rohen, Plaintiff was appropriately groomed, she exhibited a full affect with a stoic manner, her thoughts were linear, her memory adequate, her speech and motor activity normal, her understanding and memory were grossly intact, her concentration and persistence were adequate, and she scored 26/30 on the MMSE. (AR 347-48.) When examined by Dr. Barlow, Plaintiff was in no acute distress, her eye contact, speech, and mood were appropriate, and her memory and concentration were normal. (AR 353-54.) Although limited medical records document signs of depression, Plaintiff's mental status exams were mostly normal. Additionally, state agency medical consultant psychologists Kaz and Penner concluded Plaintiff did not have a severe mental impairment at Step Two. (AR 64-66, 74-75.) In other words, there is substantial evidence to support the ALJ's finding that Plaintiff's major depressive disorder was not severe. Additionally, the ALJ's Step Two determination is in-line with the regulations, which provide that when an ALJ finds no limitation or only mild limitations when evaluating the Paragraph B criteria, typically, he will conclude an impairment is not severe. 20 C.F.R. § 404.1520a(d)(1) (noting an exception if "the evidence otherwise indicates that there is more than a minimal limitation in [the claimant's] ability to do basic work activities").
Residual Functional Capacity
Plaintiff argues that, even if the ALJ's finding of non-severity at Step Two was correct, he erred in not including any limitations from her mental impairment in the RFC. Specifically, that the ALJ found, at Step Two, that she had mild limitations in interacting with others, concentrating, persisting, or maintaining pace, and adapting or managing oneself (AR 17-18); however, he did not include those limitations in his RFC.
When formulating a claimant's RFC, an ALJ must consider all medically determinable impairments, including those he finds not severe at Step Two. 20 C.F.R. § 404.1545(a)(2), (e). Here, the ALJ did that. In determining Plaintiff's RFC, the ALJ considered her mental health symptoms and related testimony, medical records, and medical opinions. (AR 21-26.) The ALJ noted that Plaintiff's mental status exams "generally reflect a lack of significant and consistent deficits in any area." (AR 26.) The ALJ also examined Plaintiff's activities of daily living and found "[t]he physical and mental capabilities requisite to performing many of the tasks described above are similar to those necessary for obtaining and maintaining employment" and Plaintiff's "activities of daily living are indicative of an individual whose day-to-day functional abilities remain generally intact." (AR 24, 26.) In rejecting the opinion of Dr. Rohen, the ALJ summarized the mental health records as follows:
although mental status exam findings occasionally document a dysphoric mood and tearfulness, exam findings also reflect that the claimant frequently presented to examiners appropriately dressed and groomed, with a cooperative demeanor, the ability to communicate effectively, normal thought content, normal thought processes, intact attention and concentration, an appropriate fund of general knowledge, and intact judgment and insight.... These findings, when considered with the claimant's activities of daily living, do not support finding . . . any mental functioning limitations.(AR 24.) He later concluded that "the record does not support restrictions greater than those reflected in the assigned residual function capacity." (AR 26.) The Court finds the ALJ did not err in his consideration of Plaintiff's mental limitations in crafting the RFC.
In support of her argument that the ALJ erred by not including mental limitations in her RFC, Plaintiff relies on an unpublished Ninth Circuit case, Hutton. In that case, the ALJ found a mild limitation in concentration, persistence, and pace at Step Two, based on a non-severe impairment of PTSD. Hutton v. Astrue, 491 Fed.Appx. 850, 850 (9th Cir. 2012). However, in the subsequent steps, the ALJ excluded PTSD from consideration based on his finding that Hutton lacked credibility. Id. at 850-51. The court found it was error for the ALJ to reject his own finding of a mild limitation based on his credibility analysis. Id. at 851. Here, the ALJ did not reject Plaintiff's diagnosis of depressive disorder. Although boilerplate, the ALJ stated that the RFC "reflects the degree of limitation I have found in the 'paragraph B' mental function analysis." (AR 18.) The ALJ included no subsequent language contrary to that statement, so the Court assumes he followed it. Further, when assessing her RFC, the ALJ discussed Plaintiff's mental health limitations by analyzing her symptom testimony, mental health medical opinions, and medical records relevant to her depression.
The Court finds the case of Frary v. Comm'r of Soc. Sec., No. 1:20-CV-00260-SAB, 2021 WL 5401495 (E.D. Cal. Nov. 18, 2021) analogous and persuasive. In Frary, the court reviewed groups of cases that found error and groups of cases that found no error based on Hutton. Id. at *10-16. The court distinguished Hutton and found the ALJ did not err when he chose not to include in the RFC the three mild mental limitations that he found at Step Two. The court relied upon the fact that the ALJ discussed in detail relevant record evidence at Step Two when he evaluated each of the paragraph B criteria, including the claimant's testimony, her reports to medical providers, and subjective and objective evidence from medical appointments. Id. at *17. Here, the ALJ similarly conducted a detailed analysis of evidence at Step Two, including Plaintiff's activities of daily living, her testimony, mental status exams, treatment notes, and her behavior during the hearing. (AR 17-18.) In Frary, the court noted that, at Step Two, the ALJ also discussed the medical opinion evidence and a third-party report. 2021 WL 5401495, at *17. And, in the section on RFC, the ALJ discussed the plaintiff's mental status exams, presentation for the hearing, and activities of daily living as relevant to her mental impairment. Id. at *18. Here, in evaluating Plaintiff's RFC, the ALJ summarized the entire medical record including mental status exams and treatment notes, discussed Plaintiff's activities of daily living, examined the medical opinion evidence, and considered a third-party report. (AR 21-26.) This entire evaluation included discussion of Plaintiff's physical and mental impairments. (Id.) In particular, the ALJ concluded that Dr. Rohen's opinion did not support "any mental functioning limitations." (AR 24.)
Frary distinguished Hutton because the ALJ "did not expressly decline to consider Plaintiff's mental impairments and the ALJ's own finding of a mild limitation stemming from such"; instead, the ALJ considered "evidence relating to Plaintiff's mental impairments after step two in a reasoned manner within the RFC determination," and concluded that the RFC was supported by evidence that the plaintiff's psychological functioning was stable. 2021 WL 5401495, at *18 (collecting similar cases); see also Ruiz v. Comm'r of Soc. Sec. Admin., No. CV-22-01252-PHX-DJH, 2023 WL 6306457, at *7 (D. Ariz. Sept. 28, 2023) (distinguishing Hutton because the ALJ considered the plaintiff's mental impairments when formulating the RFC even though she did not include the mild social limitations found at Step Two). Here, the ALJ expressly discussed Plaintiff's mental impairments after Step Two and determined the RFC was supported by the record as a whole. Therefore, he did not err. See Ward v. Comm'r of Soc. Sec. Admin., No. CV-20-08239-PCT-GMS, 2022 WL 4008024, at *4 (D. Ariz. Sept. 2, 2022) (finding that if the ALJ considers a claimant's mental limitations in evaluating her RFC, he is not required to adopt mild mental limitations found at Step Two); see also Janet Margaret G. v. Saul, No. CV 19-5095-KS, 2020 WL 2039944, at *7 (C.D. Cal. Apr. 27, 2020) (collecting cases).
As a final matter, Plaintiff did not identify a single mental limitation that impacted her work abilities. She suggested only that the ALJ erred by not including "even a limitation to simple or unskilled work." (Doc. 15 at 12.) No medical records or medical opinion indicates that Plaintiff was limited to performing unskilled work. Further, she argued that any error in the RFC was not harmless because "other work in the national economy . . . would have been precluded with a proper RFC." (Id.) She provided absolutely no support for that conclusion. Regardless, the Court found the ALJ did not err in his evaluation of her mental limitations for purposes of determining her RFC.
RECOMMENDATION
A federal court may affirm, modify, reverse, or remand a social security case. 42 U.S.C. § 405(g). The Court concludes the ALJ did not err as to the claims raised by Plaintiff. Therefore, the Magistrate Judge recommends that the District Court deny Plaintiff's appeal.
Pursuant to Federal Rule of Civil Procedure 72(b)(2), any party may serve and file written objections within fourteen days of being served with a copy of the Report and Recommendation. A party may respond to the other party's objections within fourteen days. No reply brief shall be filed on objections unless leave is granted by the district court. If objections are not timely filed, they may be deemed waived. If objections are filed, the parties should use the following case number: CV-23-0197-TUC-RM.