John E. Horn of Horn & Kelley, PC, Attorneys at Law won the accompanying Appeals Council remand of Dec. 31, 2012. After a hearing, the Administrative Law Judge found that claimant’s only mental limitations were moderate in the abilities to understand, remember, and carry out detailed instructions; maintain concentration and attention for extended periods; and interact properly with the general public. The Appeals Council found that the term “moderate” is not specific enough to provide a function by function analysis in accordance with Social Security Ruling 96-8p. It was determined that nonspecific qualifying terms (e.g. moderate, moderately severe, and marked) should not be utilized since they do not describe function, nor do they usefully convey the extent of the claimant’s limitations.