DI 22515: Vocational Evidence
TN 2 (08-17)
A. Definition
Work evaluation is a comprehensive process that systematically uses work, real or simulated, as a focal point for assessment. The full program includes a detailed interview. It incorporates medical, psychological, social and vocational data to determine an individual's current level of functioning.
B. Description of work evaluations
1. Usage
In the unusual circumstance when despite a complete and comprehensive clinical examination and description of activities of daily living, you are unable to assess whether a claimant has the ability to function in a competitive work environment on a sustained basis, consider ordering a work evaluation. Generally, we use a work evaluation in connection with the last two steps of the sequential evaluation process, to help us determine the nature and extent of the physical and mental abilities that the individual retains in a work setting.
2. Level of severity
In limited circumstances, we may also use work evaluations to help determine or resolve the level of severity of a mental impairment, where, after comprehensive development, findings are still inconclusive about the claimant's ability to perform activities of daily living, maintain social functioning, etc.
3. Level of adjudication
These guidelines apply to disability cases at all levels of adjudication.
C. Work evaluation policies
1. Acceptable sources
A qualified work evaluation source is one recognized (e.g., licensed) by a:
State government agency, or
Federal government agency, or
nationally recognized accrediting organization.
NOTE: A work evaluation source may also be qualified by training, experience or recognized specialization.
2. Unacceptable sources
You may not use in the disability program any work evaluation source that:
is excluded, suspended, or otherwise barred from participation in any Federal or federally-assisted program.
has been convicted, under Federal or State law, in connection with the delivery of services, of fraud, theft, embezzlement, breach of fiduciary responsibility or financial abuse.
has had its license to provide services revoked or suspended by any State licensing authority for reasons bearing on professional competence, professional conduct, or financial integrity.
has surrendered such a license while formal disciplinary proceedings involving professional conduct are pending.
has had a civil monetary assessment or penalty imposed for any activity described herein or as a result of formal disciplinary proceedings.
3. Payments
Make payments to sources in accordance with CFR §§ 404.1624 and 416.1024 (Medical and other purchased services).
See Also:
DI 39545001 Purchased Medical Services – Introduction
DI 39545.600 Fee Schedules
4. Conflict of interest
All implications of conflict of interest between SSA adjudicators (or reviewers) and work evaluation sources must be avoided.
See Also:
DI 39569.100 Conflict of Interest
D. Disability Determination Services (DDS) responsibilities
1. Establishing and maintaining qualified sources
DDS is responsible for establishing and maintaining the following:
Recruit qualified sources.
Review the qualifications of sources, including determining what agencies, organizations and geographic areas a source normally serves.
Decide which sources are best able to provide the services needed to conduct proper work evaluation.
Maintain a good working relationship with sources of work evaluations.
2. Selecting an appropriate source
Obtain a complete picture of the facility's scope and operation to determine the appropriateness of referral in the case. For example, do not refer a claimant whose impairments are primarily physical, to a source servicing principally those with intellectual disabilities or emotionally disturbed clients.
Sources may specialize in services for:
children,
hearing and speech problems,
the blind or visually impaired,
persons with neuropsychiatric problems, or
physical medicine and rehabilitation.
E. Description of methods of evaluation
A work evaluation source uses a number of techniques to obtain information about a claimant’s abilities, limitations, and behaviors in the context of a work environment. The work sample results can indicate which situational tasks and job tryouts would be most appropriate and meaningful for a more specific evaluation.
Examples of techniques include:
psychometric testing;
work samples;
situational assessments;
job tryouts; and
combinations of these techniques.
F. Referring the claimant to a work evaluation
1. Possible medical contraindication
Discuss the referral with a DDS medical consultant (MC) in any case where there may be a medical question as to the claimant's ability to undergo the testing or work evaluation.
Consult with the claimant’s physician to obtain his or her opinion regarding potential medical contraindication. Document the MC’s resolution of the issue(s).
IMPORTANT: If the MC directly consults with the claimant’s physician to obtain his or her opinion regarding potential medical contraindication, the MC must document resolution of the issue(s).
2. Arranging for the evaluation
Explain to the claimant:
the reason for the evaluation.
what he or she can expect from the work evaluation.
about any travel involved.
estimated length of stay.
what he or she should bring.
that we will pay for travel, food and lodging while he or she is being evaluated.
3. Companion or attendant required
If the claimant alleges inability to travel without a companion or attendant services, pay such expenses if it the:
expenditures are necessary, and
anticipated cost is reasonable.
4. Travel
Schedule the work evaluation as close to the claimant's home as possible.
If there is no source available in the desired locality, make reasonable arrangements for the claimant to travel to the closest suitable source.
Use a work evaluation source in a neighboring State where necessary.
5. Food and lodging
Arrange for payment for food and lodging when the claimant must stay away from home. Use work evaluation facilities that have a boarding arrangement, if possible, as this is less expensive than motel accommodations and the boarding facility may have experience dealing with impaired persons.
6. Communicating with the source
Furnish the work evaluation source with:
all available medical and vocational information.
a detailed explanation of the questions the evaluation is expected to resolve.
the specific information that the DDS needs to more accurately determine the claimant's RFC.
the claimant's prescriptions for medication (if any).
7. Guidelines for the source
Inform the source at the outset of the provisions of the Privacy Act concerning the necessity for maintaining confidentiality of information about claimants for disability insurance benefits.
NOTE: The report should avoid rendering conclusions on the ultimate issue of disability, which necessarily entails legal and administrative considerations reserved to the agency responsible for administering the program.
a. Evidence
Provide guidance to the source regarding SSA's evidentiary requirements. The report must include:
A narrative description that helps to answer the questions submitted by the DDS and describes the claimant's performance on each sample or task that he or she performs.
Discussion of the claimant's ability to perform rather than to secure jobs, and the specific fields of work and examples of jobs the claimant can do now without vocational rehabilitation or extended training. If the claimant is unable to function in a competitive work setting, the specific functional and vocational reasons for his or her inability.
Discussion of the quality and quantity of work performed in each job task or job sample, the claimant's level of understanding, motivation, effort expended in accomplishing assigned tasks, and his or her personal integration within the work or testing environment.
Observational details to corroborate conclusions.
Clinical judgments and findings based on workshop performance.
These require correlation with the claimant's medical and vocational history.
An explanation of all performance deficiencies
-
Descriptions of behavior, which explain how the deficiencies are attributable to functional limitations and whether they are recurrent.
NOTE: Isolated or independent deficiencies in performance such as a high rate of error or below-standard production alone do not establish a significant functional limitation.
Facts and demonstrable findings reported in concrete (not highly generalized) terms that support the conclusions arrived at.
A description of each test given and an explanation of each.
An explanation of any inconsistencies.
b. Quantitative findings
The work evaluation source should not simply state quantitative findings from work samples and psychometric tests in the report. For example, the percentiles and ratings for work samples are meaningless unless the report identifies the norm group and clearly defines the normative population. If the report omits this information, it should be available upon request. However, even when the report identifies norm groups, the interpreter should not base a disability decision solely on percentiles and ratings. For additional guidelines, see DI 22505.035F.7.