DI 25005: Capacity to Do Past Relevant Work
TN 6 (05-17)
Citations:
SSR 82-62 A Disability Claimant’s Capacity to Do Past Relevant Work, In General
A. Policy for making PRW determination
The claimant is the primary source for vocational documentation, and statements by the claimant regarding past work are generally sufficient for determining the skill level, exertional demands, and non-exertional demands of such work. For development and follow-up requirements, see General Development of Vocational Evidence DI 22515.001.
If the claimant refuses or is unable to provide the necessary work history, the evidence is not available from a third party, and this evidence is material to the disability determination, deny his or her claim for insufficient evidence. See Refusal to Cooperate With Requests to the Claimant for Evidence, or Action, DI 23007.004 and Failure to Cooperate with Requests to the Claimant for Evidence or Action, DI 23007.005.
Explain your determination in the personalized disability notice.
NOTE: See DI 25005.005 for situations adjudicators may apply expedited step 4 processing.
B. Procedure for making PRW determination
Compare the claimant’s RFC on a function-by-function basis with the physical and mental demands of his or her PRW.
-
Consider whether the claimant’s RFC permits PRW:
as he or she performed it; or
as generally performed in the national economy.
Perform the steps for comparison in the order you determine most expeditious based on the facts of the case. Stop once you identify PRW that the claimant can do.
Do not proceed to step 5 of sequential evaluation until you determine that the claimant cannot do any PRW as performed or as generally performed in the national economy.
NOTE: See DI 25005.005 for situations adjudicators may apply expedited step 4 processing.
C. Special case--process for evaluating a non-severe impairment that prevents PRW
In the rare case where a claimant has no “severe” impairment or combination of impairments, but the non-severe impairment prevents the ability to do PRW because of the unique features of the work, do not deny the claimant at step 2. Proceed through the sequential evaluation process.
Assess the claimant’s non-severe limitations or restrictions and make a function-by-function comparison of your assessment with the requirements of the claimant’s PRW.
At step 4, find that the claimant cannot do PRW unless he or she is capable of doing the work as generally performed in the national economy.
If the claimant cannot do PRW as he or she performed it or as generally performed in the national economy, proceed to step 5.
Do not consider the special medical vocational profiles when a non-severe impairment prevents PRW because of the unique feature(s) of the work. These profiles require a severe impairment. See DI 25010.001A, Special Medical Vocational Profiles.
Consider ability to adjust to other work using a framework of medical-vocational rule 204.00. See DI 25025.010 Using rule 204.00 as a Framework for a Determination.
EXAMPLE: The claimant is 60 years of age, has a 9th grade education and 34 years of work at a printing factory. He has recently become severely allergic to the chemicals required to do this work. He is no longer able to do this work as he performed it or as generally performed in the national economy because of his allergy. Because the claimant has a not severe impairment that prevents his PRW, he is not a denial at step 2. At step 5, he will be able to adjust to other work using a framework of medical-vocational rule 204.00.