Effective Dates: 1/08/2025 - Present

Identification Number:
DI 25003 TN 16
Intended Audience:See Transmittal Sheet
Originating Office:ORDP ODP
Title:Vocational Specialists
Type:POMS Full Transmittals
Program:All Programs
Link To Reference:
 

PROGRAM OPERATIONS MANUAL SYSTEM

Part DI – Disability Insurance

Chapter 250 – Medical-Vocational Evaluation

Subchapter 03 – Vocational Specialists

Transmittal No. 16, 01/08/2025

Audience

PSC: DE, DEC;
OCO-OEIO: CR, ERE, FDE, RECONE;
OCO-ODO: DE, DEC, DS, RECONE;
ODD-DDS: ADJ, DHU;

Originating Component

ODP

Effective Date

Upon Receipt

Background

ODP is revising DI 25003.001 to reflect the vocational evidence policy promulgated via SSR 24-3p: Titles II and XVI: Use of Occupational Information and Vocational Specialist and Vocational Expert Evidence in Disability Determinations and Decisions. We are also adding a new example of a situation that may require VS consultation. 

Summary of Changes

DI 25003.001 Vocational Specialists

We:

  • •

    Added a fifth bullet point to C.2.4 (Examples of situations that may require VS consultation to consider the remaining occupational base) reading:

    • –

      RFC with solely nonexertional limitations (SSR 85-15).

 

  • •

    Added subsection C.3: VS Evidence and Required Vocational Evidence.  This subsection includes requirements for VS evidence, promulgated in SSR 24-3p.

  • •

    Made non-substantive grammatical edits.

DI 25003.001 Vocational Specialists

CITATIONS:

Social Security Act, as amended §§ 216(i), 223(d)(2)(A), and 1614(a)(3)(B)
20 CFR Part 404 Subpart P, Appendix 2
20 CFR §§ 404.1566 thru 404.1569, and 416.966 thru 416.969
SSR 24-3p

A. Definition of Vocational Specialist (VS)

A vocational specialist is an individual with specialized knowledge and experience who serves as a vocational resource for a state Disability Determination Service (DDS) or federal adjudicating unit.

The adjudicating unit may have a dedicated VS, or designate another individual or individuals, such as a:

  • •

    quality reviewer,

  • •

    senior disability examiner, or

  • •

    other appropriately qualified personnel to perform the VS role.

The VS:

  • •

    ensures consideration of the residual functional capacity (RFC) assessment with vocational factors such as age, education, training, and work experience; and

  • •

    trains and mentors staff on vocational issues.

For information on designating vocational specialists, see DI 25003.005.

B. Vocational review issues

Vocational review issues include, but are not limited to:

  • •

    ability to perform work within assessed Residual Functional Capacity (RFC)/Mental Residual Functional Capacity (MRFC) limitations;

  • •

    relevancy of past work;

  • •

    identification of job skills and duties;

  • •

    identification of the claimant’s past occupation in the national economy;

  • •

    transferability of skills;

  • •

    application of borderline age;

  • •

    onset and ending dates as it relates to the vocational assessment;

  • •

    sufficiency of the vocational evidence in file;

  • •

    special medical-vocational profiles;

  • •

    illiteracy; and

  • •

    estimation of the remaining occupational base.

C. When to use a VS

Consult a VS when:

  • •

    a vocational issue is beyond your level of expertise; and

  • •

    you do not have a clear understanding of the effects of limitations on the claimant’s remaining occupational base.

1. Disability examiner (DE) development prior to VS consultation

DEs have sufficient expertise to assess the vast majority of vocational issues and must complete the initial vocational development prior to consulting the VS. This includes obtaining a complete 5-year work history and attempting to resolve Steps 4 and 5 of sequential evaluation.

2. VS consultation

Examples of complex vocational issues that may require VS consultation include:

  1. 1. 

    Determinations made in the 8th Circuit under the Brock acquiescence ruling (AR) (See details on Brock AR per, DI 25003.001D, in this section.)

  2. 2. 

    Determining skills acquired from a job and whether those skills are transferable. (SSR 82-41).

  3. 3. 

    Determining the functional demands and job duties of the occupation as ordinarily required by employers throughout the national economy.

  4. 4. 

    Considering the remaining occupational base for a case where the claimant has an:

    • •

      RFC that represents a compromised range of sedentary work. (SSR 83-12, SSR 83-14, SSR 96-9p).

    • •

      RFC between two levels of exertion. (SSR 83-14).

    • •

      RFC limitation of ability to sit or stand that falls between exertional levels. (SSR 83-12).

    • •

      “unusual” non-exertional RFC limitations. (SSR 83-14).

    • •

      RFC with solely nonexertional limitations. (SSR 85-15).

NOTE : State agencies may purchase the services of vocational evaluation workshops to assist with resolution of complex case-specific vocational issues. See details on Use of Work Evaluations per DI 22515.035.

3.  VS Evidence and Required Vocational Evidence

When providing evidence, VSs may consider any reliable source of occupational information that is commonly used by vocational professionals and is relevant under our rules, along with their professional knowledge, training, and experience (SSR 24-3p).

VSs are responsible for providing evidence about work that is tailored to the specific facts of the case based on their professional knowledge, training, and experience, and the vocational data available to them.

VS evidence must include an explanation and identify the sources of data used to support the VS conclusion.

D. Brock Acquiescence Ruling (AR)

IMPORTANT: This ruling applies to determinations or decisions made in the Eighth Circuit (Arkansas, Iowa, Minnesota, Missouri, Nebraska, North Dakota, and South Dakota) at all levels of administrative review.

AR 14-1(8) Requiring Vocational Specialist (VS) or Vocational Expert (VE) Evidence When an Individual has a Severe Mental Impairment(s)


DI 25003 TN 16 - Vocational Specialists - 1/08/2025