A recent Emergency Message issued by the Social Security Administration (SSA) provides a major update to its use of the Dictionary of Occupational Titles (DOT) when determining a disability ruling.
The SSA announced it will no longer use 114 occupations found in the Dictionary of Occupational Titles for supporting a “not disabled” finding, as these jobs are no longer found in significant numbers in the national economy and therefore cannot be considered as options when determining an individual’s disability status. In addition, 13 occupational titles will also require further supporting evidence if proposed in a “not disabled” finding.
Going forward, outdated jobs such as “nut sorter”, “reptile farmer”, and “microfilm processor” can no longer be considered viable employment options for those seeking disability benefits. Many applicants seeking benefits were frustrated by denials that pointed to potential work alternatives that did not exist in today’s economy.
The big picture for SSA disability determinations
The SSA has been evaluating its disability determination process as prompted by President Biden’s Executive Order on Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government. As a result of the order’s directives for improving its processes and access to services, the SSA has been focusing on ways to “reduce administrative burdens for applicants and help more people with disabilities receive government benefits and services if they are eligible.”
Recently, the SSA also passed a final rule that reduced the past-work window from fifteen to five years for disability evaluations. As part of this rule, SSA will no longer consider any past work that began and stopped within 30 calendar days.
Why is this update significant?
Developed by the Department of Labor (DOL) in 1938, the DOT list has long been the SSA’s reliable source of work found in the national market. The companion publication, The Selected Characteristics of Occupations Defined in the Revised Dictionary of Occupational Titles, is also regularly referenced in the disability determination process.
These sources have remained largely untouched since 1991 when the last update was made to the DOT list.
Considering the remarkable evolution of the modern workplace in the past thirty years, the DOT list and its companion publication are woefully behind the current vocational climate. In an effort to modernize the disability determination process, the SSA has committed to creating an updated system for referencing occupational information called the Occupational Information System (OIS), which began in 2008 and continues to be developed with enhanced data that includes mental and cognitive work requirements.
What this change means to SSDI and SSI applicants
For SSA claim adjudicators looking to determine whether to issue a disability benefit, they must assess what alternative occupations can be found for an individual unable to perform their past duties. Based on the nine US Census divisions used to determine occupational numbers, none of the 114 titles being eliminated by the SSA are found in significant numbers in those areas.
For those occupations that will now require additional evidence, a “not disabled” finding “must include or summarize the Vocational Specialist or Vocational Expert’s evidence that supports such a conclusion.”
| DOT Code | DOT Occupational Title | DOT Industry Designation |
| 209.587-010 | Addresser | clerical |
| 249.587-018 | Document Preparer, Microfilming | business services |
| 249.587-014 | Cutter-and-Paster, Press Clippings | business services |
| 239.687-014 | Tube Operator | clerical |
| 318.687-018 | Silver Wrapper | hotel and restaurant |
| 349.667-010 | Host/Hostess, Dance Hall | amusement and recreation |
| 349.667-014 | Host/Hostess, Head | amusement and recreation |
| 379.367-010 | Surveillance-System Monitor | government services |
| 521.687-010 | Almond Blancher, Hand | canning and preserving |
| 521-687-086 | Nut Sorter | canning and preserving |
| 726.685-010 | Magnetic-Tape Winder | recording |
| 782.687-030 | Puller-Through | glove and mitten |
| 976.385-010 | Microfilm Processor | business services |
NOTE: Alternatively, adjudicators may support the determination or decision with other occupation(s) appropriate to the facts of the claim. This approach may be the most efficient way to ensure our burden at step five of the sequential evaluation process is met and that the record contains the necessary evidence to support the “not disabled” finding.
This important change to the SSA’s use of the DOT list means the potential for increased access to disability benefits since only the most relevant occupations will be considered when determining if an applicant could perform other types of work. With the assurance that disability determinations will be assessed using a modern view of the workplace, applicants can also expect a fairer, more trustworthy process.
As always, Brown & Brown Absence Services Group will monitor this change closely and will report any updates related to this and other Social Security matters. We encourage you to contact us directly should you have any questions about this exciting update.
