If a claimant is not performing SGA, we assume that the claimant cannot do any work,
including work that requires skills and abilities comparable to those of any SGA that
the claimant had done with some regularity and over a substantial period.
However, if, before stopping work, the claimant performed any SGA after the onset
of blindness or age 55 (whichever is later), compare the work done before and after
the onset of blindness or age 55.
Since the ability to see is usually such an essential requirement of work performed
in the competitive labor market, blindness itself constitutes a major loss of job
skills and abilities.
Even though a claimant who is age 55 or older and statutorily blind manages to work
despite this severe impairment, we will frequently find that the skills and abilities
required by the claimant's current work are not actually comparable to those required
by the work he or she did previously. See Examples 1, 2, and 4 at the end of this
There are instances when we may find a claimant successfully performing comparable
work. This may occur when:
there has been a progressive reduction in sight to which the claimant has been making
a gradual work adjustment so that he or she is able essentially to continue to perform
usual work even after reaching the level of blindness; or
the nature of the skills and abilities required in work previously performed with
sight are such that he or she can transfer at least some of them to the successful
performance of similar or different types of work, even after onset of blindness.
See Example 3 at the end of this section.
A difference in types of duties in different jobs is by itself not sufficient for
a determination of noncomparability. Also, the fact that later work does not require
all of the skills and abilities used in the previous work means that the work is noncomparable.
The crucial issue is whether the major basic skills and abilities required in work performed after blindness and age 55 are comparable to those required
in work performed prior to that time.
If a claimant uses any new and significant skills in performing later work, find that
the work is noncomparable.
In making comparisons, give consideration to such physical requirements as:
vision, eye-hand, eye-foot, or other coordination; and
In addition, consider mental requirements such as:
professional and technical knowledge and experience,
communication skills, and
similar skills and abilities that may remain useful even without sight.
Example 1 – Noncomparable SGA
David became statutorily blind in June 2011 at age 57. His previous regular work,
which lasted for 15 years, had been as an auto mechanic, ending in May 2011.
After a brief period of training, he started SGA in August 2011 as a vending stand
operator in a public building.
Since the skills or abilities required in this current work are not comparable to
those required in his previous work, we found David entitled to DIB under the work
comparability provisions, as explained in DI 26005.001E in this section.
His 5-month waiting period was from June through October 2011 even though in some
of those months he performed SGA, because that work did not require skills or abilities
comparable to those of his previous regular work.
We withheld DIB payments because David was performing SGA. However, in June 2012 he
notified the FO that he had stopped working at the end of May 2012. We paid benefits
beginning with June 2012.
We will continue to pay David benefits unless he again performs SGA, at which time
we will need to determine whether we should suspend benefits immediately or after
a trial work period.
Example 2 – Noncomparable SGA
Before she became blind at age 52, Ann had been a mathematics teacher in junior and
senior high schools.
After losing her sight, she stopped working as a teacher. She subsequently learned
to read and write fluently in Braille. At age 56, she started a new job as an editorial
assistant for a Braille book publisher for the blind. She does her work with the help
of a Braille keyboard and other special aids.
Ann’s current work differs materially from her previous regular work (before age 55)
in the skills and abilities it requires from her previous regular work. She has had
to become skilled not only in Braille but also in special writing, editorial review,
and publication techniques to be able to perform the duties of her new job adequately.
Because she had to acquire new skills and abilities to be able to work, it is reasonable
to find that Ann can no longer perform SGA requiring skills or abilities comparable
to those of her previous regular work.
Accordingly, we would find Ann under a disability for cash benefit purposes with payments
withheld for any months in which she performs SGA.
Example 3 – Comparable SGA
John had been a clergyman for many years, concerned with visiting the sick and bereaved,
officiating at religious ceremonies, studying and preparing sermons, and preaching.
After becoming statutorily blind at age 47, John started a new job as an instructor
in ethics and religion at a local college where he worked from age 47 to age 57. He
also performed duties as a counselor to students.
While John needed some assistance at times in moving about, particularly between his
residence and the college, and occasionally needed someone to read to him, the major
skills, knowledge, and abilities required to perform his new work were essentially
comparable to those he used in his former activities (before age 55).
Accordingly, we could reasonably determine that John does not meet the comparability
provisions. We would deny his DIB claim, although he would be entitled to a disability
Example 4 – Noncomparable SGA
Before becoming blind at age 56, Bob had been a heat treater for a tool manufacturer.
He placed cold metal objects on a special type of hanger and moved the hanger into
various heated situations to harden the steel.
Since this job required good eyesight to avoid accidents while moving heavy steel
parts above the heads of other workers, Bob could no longer do it after the onset
of blindness. However, he did work in another job created especially for him, screwing
together small plastic parts, which were brought to him and taken away when finished.
Although we found this latter job was SGA, we determined that Bob was entitled to
DIB under the work comparability provisions, as explained in DI 26005.001E in this section, because he could no longer perform SGA requiring skills or abilities
comparable to those of his previous regular work as a heat treater. However, we withheld
benefit payments while he was performing SGA in his current job.