Effective Dates: 11/17/2023 - Present Previous | Next

TN 22 (11-23)

DI 25015.017 Transferability of Skills Assessment Policy

CITATIONS:

Social Security Act §§ 223(d)(2)(A) and 1614(a)(3)(B);

20 CFR §§ 404.1565, 404.1568, 416.965, and 416.968

A. When transferability of skills assessment (TSA) is required

If transferable skills are material to the determination of disability, the adjudicator must complete and document a TSA.

1. When TSA is required

Complete a TSA when ALL the following conditions apply:

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The individual cannot do past relevant work (PRW), see DI 25005.015.
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Work experience is skilled or semi-skilled.
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Residual functional capacity (RFC) reflects the ability to sustain a 40-hour workweek, see DI 24510.057B.1.
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Mental RFC indicates capacity for skilled or semi-skilled work.
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The Medical-Vocational guidelines indicate a decision of " disabled" if the skills are not transferable, and a decision of " not disabled" if the skills are transferable.

2. When TSA is not required

If work experience is skilled or semiskilled, and any of the conditions specified above does not apply, do not complete a TSA.

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Document the “TSA not material” finding in the Disability Case Processing System (DCPS).
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Use the applicable “not transferable” rule as a framework for the decision as explained in DI 25025.022

B. TSA policy concepts

1. What is a skill

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A skill is practical and familiar knowledge of the principles and processes of an art, science, or trade, combined with the ability to apply them in practice in a proper and approved manner. This includes activities like making precise measurements, reading blueprints, and setting up and operating complex machinery.
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A skill is knowledge of a work activity which requires the exercise of significant judgment that goes beyond the carrying out simple job duties.
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A skill corresponds directly with a work-related task that generally requires more than 30 days to learn.

NOTE: The 30-day guideline considers time needed to acquire the information, learn the techniques, and develop the facility needed for average performance. The length of time this would take depends on the nature and complexity of the work.

2. Source of skills

Individuals acquire skills from experience and performance of work activities in skilled or semiskilled PRW.

3. Not sources of skills

We do not consider any of the following to be a source of transferable skills:

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Unskilled work,
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Past work that is not PRW,
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Inherent aptitudes, abilities, or traits,
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Hobbies,
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Volunteer work, or
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Completion of formal education or training without experience and demonstrated proficiency in skilled or semiskilled PRW.

NOTE:For information about how we consider the vocational advantage provided by direct entry education, see DI 25015.010

4. Skills may or may not provide a vocational advantage

a. Claimant with transferable skills

Skills are transferable when the skilled or semiskilled job functions performed in PRW can be used to meet the requirements of other work within an individual’s RFC. Having a skill may give the claimant a vocational advantage over unskilled workers in the labor market if it is usable in other semiskilled or skilled work that exists in significant numbers in the national economy.

b. Claimant with skilled or semiskilled work history and skills that do not transfer

If a claimant with skilled or semiskilled work experience cannot transfer skills acquired to other skilled or semiskilled work, the skills do not provide a vocational advantage. When skills gained from PRW do not provide a vocational advantage to adjusting to other work within the claimant’s RFC, we treat the claimant’s work experience the same as an unskilled worker.

NOTE: The regulatory Medical-Vocational Guidelines (See Part 404, Subpart P, Appendix 2) are consistent with 20 CFR 404.1565(a) and 416.965(a) because they direct the same conclusion for individuals with an unskilled work background as they do for those with a skilled or semiskilled work background whose skills are not transferable.

5. Residual functional capacity (RFC) and transferability

Skills do not transfer to work with physical or mental requirements that exceed the claimant’s RFC.

6. Work experience skill level, complexity, and transferability

a. Skills may transfer

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From skilled PRW to other skilled work or semiskilled work, or
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From semiskilled PRW to other semiskilled work.

b. Skills never transfer

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From unskilled PRW,
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To unskilled work,
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From semiskilled PRW to other skilled work, or
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From less complex to more complex work (i.e., lower specific vocational preparation SVP to higher SVP).

7. Similarity of occupations and transferability

A person’s skills are most likely to transfer between jobs in occupations which use the same or similar:

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Tools and machines, or
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Raw materials, products, processes, or services.

NOTE: Similarity of all these factors is not required unless the claimant meets certain vocational criteria as explained in DI 25015.017D in this section.

C. TSA policy definitions

1. Vocational adjustment

Vocational adjustment means learning about tools, work processes, work setting, and industry, that a specific individual would need to do, to perform work in another specific occupation

2. Tools

Tools are instruments used in performing or completing a specific job or task. They can include physical tools, software platforms or other items needed to complete work tasks.

3. Work processes

Work processes are methods used to ensure tasks are completed in a way that is systematic and organized, i.e., standard procedure.

4. Work settings

A work setting includes the physical conditions or environment in which a job is performed.

5. Industry

An industry is a group of establishments performing the same or similar economic activities.

CAUTION: When considering the industry of the claimant’s PRW, keep in mind that the “Clerical and Kindred,” “Professional and Kindred,” and “Any Industry” DOT industry codes do not actually specify a single industry.

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CLERICAL AND KINDRED.This designation includes occupations common to a number of industries, including: (1) those occupations whose clerical duties take up a majority of the worker's time; (2) those occupations whose clerical duties take up a minority of the worker's time, but for which the major requirement is the ability to perform the clerical duties; (3) those occupations whose duties, although nonclerical, are dependent on and intimately connected with definite clerical jobs, and for which the promotional sequence usually is to positions of a strictly clerical character; and (4) white collar occupations that are not strictly clerical in character but that are more closely associated with truly clerical workers than with occupations in other occupational groups.
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PROFESSIONAL AND KINDRED. This designation includes occupations requiring extensive study or experience in professions, technical services, sciences, art, and related types of work. The preparation for these occupations (with certain exceptions, such as occur in art and literature) is typically acquired through university, college, and technical institute training; experience providing institute training; experience providing equivalent backgrounds; or some combination of these. The functions of these occupations are predominantly mental rather than manual. This designation includes only occupations which cross industrial designation lines or which by the nature of the jobs cannot be identified as belonging to any one industry. Occupations which are found in only one DOT industry, however, are classified in that industry.
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ANY INDUSTRY. This designation includes occupations that are not allocated to other classifications. The principal groups of jobs included under this designation are: (1) occupations that characteristically occur in practically all industries; (2) occupations that occur in a number of industries (which number is not exactly determinable) but that do not characteristically occur in most industries; and (3) occupations that are not considered to have any particular industrial attachment. The occupations included under this designation are considered to be essentially the same wherever they occur, in that they involve the same fundamental functions, and are performed for the same general purpose wherever they exist. Familiarity with a given job in one industry, however, may not permit a worker to transfer to the same job in another industry without some training period to acquaint the worker with the processes, terminology, hazards, or other factors in the industry to which he or she is being transferred that would affect the occupation in question in that industry.

D. Very little if any vocational adjustment

Very little, if any, vocational adjustment means other work is so similar to PRW in terms of

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Tools,
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Work processes,
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Work setting, and
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Industry,

that the amount of additional learning needed to make a vocational adjustment to the other work would be minimal.

1. When we apply the very little, if any, vocational adjustment standard

Apply the very little, if any, vocational adjustment standard when evaluating whether skills transfer for a claimant who is:

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closely approaching retirement age (age 60 or older) and has a light RFC, or
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advanced age (age 55 or older) and has a sedentary RFC.

2. Medical-Vocational Rules requiring application of the very little, if any, vocational adjustment standard

a. The very little, if any, vocational adjustment standard applies when considering transferability of skills under the following medical-vocational guidelines rules for individuals with sedentary residual functional capacity.

Rule	Age	Education	Previous Work Experience	Decision
201.02	Advanced	Limited or less	Skilled or semiskilled—skills not transferable	Disabled
201.03	Advanced	Limited or less	Skilled or semiskilled—skills transferable	Not disabled
201.06	Advanced	High school graduate or more—does not provide for direct entry into skilled work	Skilled or semiskilled—skills not transferable	Disabled
201.07	Advanced	High school graduate or more—does not provide for direct entry into skilled work	Skilled or semiskilled—skills transferable	Not disabled

b. The very little, if any, vocational adjustment standard applies when considering transferability of skills under the following medical-vocational guidelines rules for individuals with light residual functional capacity ONLY IF the claimant is closely approaching retirement age (i.e., 60 or older). The standard does not apply when considering individuals aged 55-59 under these rules.

Rule	Age where the very little if any vocational adjustment standard applies	Education	Previous Work Experience	Decision
202.02	60 or older	Limited or less	Skilled or semiskilled—skills not transferable	Disabled
202.03	60 or older	Limited or less	Skilled or semiskilled—skills transferable	Not disabled
202.06	60 or older	High school graduate or more—does not provide for direct entry into skilled work	Skilled or semiskilled—skills not transferable	Disabled
202.07	60 or older	High school graduate or more—does not provide for direct entry into skilled work	Skilled or semiskilled—skills transferable	Not disabled

3. Examples illustrating application of the very little, if any, vocational adjustment standard

a. EXAMPLE 1: carpentry skills

Consider a 61-year-old claimant, with an RFC for light work and no more than occasional reaching with both upper extremities, and PRW as a carpenter in the construction industry. The individual cannot do any PRW. The claimant provides a detailed description of the work on form SSA-3369 (Work History Report). The description includes the following skills:

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Ability to study blueprints and plans to determine requirements to construct structures and fixtures of wood, plywood, and wallboard.
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Ability to measure materials precisely and use saws to cut materials to specific dimensions.
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Ability to select appropriate materials and tools to construct structures and install fixtures.
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Erecting framework and subflooring for structures.
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Erecting scaffolding for work above ground level.

This job is identified in the DOT as 860.381-022 Carpenter (medium strength, SVP 7, Construction Industry). Materials, Products, Subject Matter, and Services (MPSMS) codes are 360 and 450. Work Field (WF) code is 102.

A worker trait search using the WF code, light work or less, occasional reaching or less, semiskilled and skilled work, but no SVP greater than 7, yields the following occupations:

DOT CODE	Occupation	Industry	SVP	Strength
731.684-014	Doll Repairer	Any Industry	3	L
732.684-122	Sports Equipment Repairer	Any Industry	4	L
851.137-014	Supervisor, Sewer Maintenance	Government Services	6	L
851.137-010	Bank Boss	Construction	7	L
730.131-010	Supervisor	Musical Instruments and Parts	7	L
669.130-014	Supervisor Cutting Department	Pen, Pencil, Marking Service	7	L
529.132-106	Supervisor Wash House	Beverage	7	L
184.167-286	General Car Supervisor Yard	Railroad Transportation	7	L
184.167-234	Supervisor of Way	Railroad Transportation	7	S

The only occupation in the same industry as the claimant’s PRW is Bank Boss, though we also consider the occupations designated as in “Any Industry.” The tasks required by Bank Boss are not similar to the claimant’s PRW. The tasks are supervising and coordinating activities of workers engaging in placing shore sections of discharge pipe from suction dredge and in grading material discharged from dredge at the shore. Doll Repairer and Sports Equipment Repairers are not done in construction settings even though they are listed as “any industry.” Because more than very little, if any, vocational adjustment is required for skill transfer in this case, the claimant has no transferable skills.

A worker trait search using MPSMS codes 360 and 450 for Light work or less, occasional reaching or less, semiskilled and skilled work but no SVP greater than 7 yields only one occupation:

DOT Code	Occupation	Industry	SVP	Strength
561.587-010	Pole Inspector	Wood Products	3	L

This occupation is in a manufacturing rather than a construction work setting (a different industry). None of the occupations identified would permit transfer of the claimant’s skills with very little, if any, vocational adjustment. We conclude the individual does not have transferable skills.

b. EXAMPLE 2: supervisory skills

Consider a 58-year-old claimant with an RFC for sedentary work and PRW as a supervisor in the retail trade industry. The individual cannot do any PRW. The claimant provides a detailed description of the work on form SSA-3369 (Work History Report). The description includes the following management skills:

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Planning and organizing work of others,
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Making decisions based on data,
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Writing shift reports,
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Preparing budgets,
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Keeping records, and
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Inventorying stock.

This job is identified in the DOT 185.137-010 Manager, fast food services, in the retail trade industry, light strength, SVP 5. WF is 146 and MPSMS codes are 881 and 882.

The worker trait search using WF returned no occupations, however the worker trait search using MSPMS codes identified three occupations within the claimant’s RFC, at or below an SVP of 5 but at least an SVP of 3.

DOT	Title	Industry	SVP	Strength
294.567-010	Auction Clerk	Retail Trade	3	S
249.362-026	Order Clerk	Clerical and Kindred	4	S
299.387-010	Drapery and Upholstery Estimator	Retail Trade	5	S

The claimant did not use the same tools and materials as the drapery and upholstery estimator which required computing the cost of fabric and hardware for draperies. The claimant is not experienced with the work processes of an auction clerk which requires listening to bids and record winning bid, item, and cost. Both occupations are also done in different work settings, i.e., a drapery or décor shop or at an auction house. Based on a review of the occupational description, we determine there are order clerks in the retail trade industry, however, these jobs involve different work processes, e.g., different kinds of paperwork, such as purchase requisitions.

Because the claimant is of advanced age and has a sedentary RFC, the very little, if any, vocational adjustment standard applies. We conclude the individual does not have transferable skills.

c. EXAMPLE 3: clerical skills

Consider a 55-year-old claimant with an RFC for sedentary work and PRW as an Airport Clerk. The individual cannot do any PRW. The claimant provides a detailed description of the work on form SSA-3369 (Work History Report). The description includes the following skills:

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Checking available flight data and arranging flights using computers,
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Issuing boarding passes and checking in customers,
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Giving announcements about flights,
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Talking to travelers (customers),
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Using a multi-line phone system, and
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Typing.

This job is identified in the DOT as 219.362-010 Administrative Clerk, Clerical and Kindred industry, light strength, SVP 4. WFs are 231, 232, 282 and MPSMS is 890.

Understanding that the Clerical and Kindred industry designation is not industry-specific, the adjudicator determines that the job was in the air transportation industry. Because clerical skills are very transferable across industry lines, and there are so many types of clerical occupations, skills are likely to transfer even when we apply the very little, if any, vocational adjustment standard.

The worker trait search using WF codes, sedentary exertion, and SVP 3-4, identified 236 occupations, including 4 in the Air Transportation Industry and 47 Clerical and Kindred occupations. While there may be other occupations to which the skills transfer, the adjudicator in this example identified these three:

DOT	Title	Industry	SVP	Strength
238.367-018	Reservations Agent	Air Transportation	4	S
237.367-022	Information Clerk	Clerical and Kindred	4	S
237.367-038	Receptionist	Clerical and Kindred	4	S

The claimant has done tasks very similar to those required of a reservations agent, an information clerk, and a receptionist. Although it might be possible to make a reasonable argument based on a difference in work setting since this claimant did clerical work in an airport, it is also reasonable to find that she was in a similar work setting interacting with the public and provided information and providing similar services and work products using similar tools. The conclusion in this case is reached without querying the MPSMS code. Skills are transferable due to very little, if any, vocational adjustment in the industry, tools, work processes and products and work settings.

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DI 25015.017 - Transferability of Skills Assessment Policy - 11/17/2023
Batch run: 04/04/2024
Rev:11/17/2023

Program Operations Manual System (POMS)