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I recently read a good practice tip from Mobile Alabama Social Security lawyer Gilbert Laden in the April Social Security Forum, which is a newsletter published by NOSSCR for its members. Mr. Laden’s article is entitled Preparing a Detailed Work Background for the ALJ. Here is an excerpt:

I order a “Detailed Earnings Query” (DEQY) in every case and use it to prepare a work background, which I submit in advance to the ALJ. It can be used to trigger a client’s memory about forgotten jobs. Also, sometimes, there are mistakes on the DEQY. On the work background, I note the amount of the earnings [from the DEQY] for a particular job and if they are below SGA. I can readily call it to the ALJ’s attention when the VE is giving an assessment of purportedly past relevant work, but which was not done at the SGA level.

This is excellent advice. Ordering a DEQY well in advance of the hearing is a good practice. The DEQY is usually not in the claim file until just before the hearing. Getting a copy early avoids surprises at the last minute.

Since past relevant work extends back 15 years, the claimant may not remember each job that was held. The DEQY can refresh the client’s memory. Also, since the DEQY contains earnings information, it can tell you when a job was performed below the level of SGA, and therefore does not constitute past relevant work.

Unless a listed impairment is met or equaled, you must be unable to perform your past relevant work to have a chance at obtaining Social Security disability benefits. A DEQY can help to define your past relevant work.