Generally, to be relevant, the past work the claimant performed must have been within
15 years prior to the date of adjudication (the date of the determination or decision
at any level of review). However, for some title II claims, the relevant period may
end prior to the date of adjudication. See DI
25001.001A.64
for instructions on how to determine the relevant period for different types of claims.
NOTE: When determining the relevant period for a concurrent title II or title II and title
XVI claim, the relevant periods and the step 4 determinations for each claim may differ
if the title II relevant period ended prior to adjudication.
When determining if work is within the relevant period, consider the relevant period
to begin 15 years prior to its ending date (e.g., if the relevant period ended 12/20/14,
it began on 12/21/99).
IMPORTANT: Do not consider the date that work was no longer relevant when establishing onset
of disability.
EXAMPLE: A 60-year old, high school educated claimant filed a DIB claim alleging onset on 01/01/10.
The claimant performed an SGA-level, unskilled job from 12/01/93 to 10/30/98. The
physical and mental requirements of this work are within his RFC. All of his other
work required greater lifting and carrying than his RFC allowed. The date of adjudication
is 01/05/14 and the claimant has a future DLI of 12/31/15. The claimant has a prior
denial dated 07/07/11 for ability to perform the past relevant work (PRW) he performed
12/01/93 to 10/30/98.
Summary of case facts:
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Alleged onset date (AOD): 01/01/10
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Date Last Insured (DLI): 12/31/15
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Prior finding of PRW on work performed from 12/01/93 to 10/30/98
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Current claim adjudication date: 01/05/2014
Based on an adjudication date of 01/05/14 and future DLI 12/31/15, the relevant period
in the current claim is 01/05/99 to 01/04/14, the fifteen years prior to the date
of adjudication. The job that is within the claimant's RFC would not be within the
relevant period because the work ended 10/30/98, more than 15 years prior to the 01/05/14
date of adjudication. Therefore, the claimant had no PRW within his RFC at the time
of adjudication
The adjudicator proceeded to step 5 of sequential evaluation. An allowance was appropriate
based on the medical-vocational rules. The claimant met the disability requirements
as of his AOD; however, it was not possible to reopen the prior denial determination
of 07/07/11 because the DDS appropriately denied the claim based on an ability to
perform PRW. The adjudicator awarded an established onset date as of 07/08/11, the
day after the prior denial. We do not consider the date past work was no longer relevant
when we establish onset. Therefore, the day after the prior denial date was the correct
onset date even though the fifteen year period following the claimant’s past work
ended on 10/29/13 (after his EOD).
IMPORTANT: Consider work performed prior to the relevant period to be PRW when there is a continuity
of skills, knowledge, and work processes between the work outside the relevant period
and PRW.
EXAMPLE: The claimant worked on an assembly line making appliance parts from 01/01/92 to 10/31/99.
On 11/01/99, he became a line supervisor, and continued to supervise the assembly
of appliance parts on the line until 11/20/06. Based on an adjudication date of 12/30/14
and the claimant having a future DLI, the assembly line job is no longer in the relevant
period (the 15 years prior to the 12/30/14 adjudication date). However, the supervisor
job is within the relevant period and is PRW. The claimant is no longer able to tolerate
the level of interpersonal interaction required by his supervisor job due to his mental
impairment. He is able to tolerate the level of interpersonal interaction required
by his previous job working on the assembly line. Even though the assembly line job
was prior to the relevant period, because there was continuity of skills, knowledge,
and work processes between the supervisor job and the assembly line job, the adjudicator
may find the assembly line job is PRW and determine that the claimant is capable of
performing that PRW.
IMPORTANT: If any portion of the period the claimant performed past work extends into the relevant
15-year period, the work is in the relevant period. If it meets the other criteria
for PRW, consider it at step 4 of the sequential evaluation.
EXAMPLE: The claimant worked as a cashier from 01/20/96 to 12/10/2000. If the DDS adjudicates
the case on 01/20/15 and the claimant has a future DLI, the claimant’s cashier work
is within the relevant period because a portion of the period of performance is within
the 15-year period prior to the 01/20/15 adjudication date.