At the hearing level, the SSA adds to the disability claim file a document called the “Detailed Earnings Query,” or DEQY. The DEQY lists all the employers that have paid wages (and the amount of annual wages paid), during the past 15 years. Fifteen years is the time frame for past relevant work for Step 4 of the sequential evaluation of a Social Security disability claim.
When past relevant work is critical to a claim (Social Security disability claimants over the age of 55 suffering from physical impairments, in particular), a Representative needs to look very carefully at the DEQY, so that all past relevant work can be properly classified and evaluated.
Let me give an example, one that turned out fine but could have been a disaster.
I had a recent disability hearing for a 60-year old client with significant physical impairments. Throughout several conversations with him, he was emphatic that his past relevant work had been solely as a carpenter, for several different employers. He had always been in construction, he said, and it had taken a toll on his body.
It was pretty clear from the medical record, and an opinion I obtained from his primary care physician, that given his physical limitations he could no longer work as a carpenter, which is a Medium to Heavy exertional occupation.
A 55+ year old person who can no longer perform his or her past relevant work, and lacks job skills that transfer to a range of skilled work within his RFC (and has no recent education allowing direct entry to skilled work), would be found “disabled” at the Light exertional level according to the Medical-Vocational Guidelines. So I was feeling good about the prospect of an award of disability benefits for this client.
The DEQY lists the name of each employer, but often the name is something generic, like “ABC Inc.” It is not always apparent what type of business such an entity is conducting. So you have to ask the client about each employer on the DEQY. In my recent case, it turns out that the client worked at a gas station for a while between construction jobs. That is Light work. So all of a sudden, a Light exertional RFC was not enough to win the case. A Light RFC would allow the claimant to perform one of his past relevant jobs (as a gas station attendant), and the claim would then be denied at Step 4 of the sequential evaluation.
As it turns out, the judge at the hearing assessed a Sedentary RFC, which ruled out the gas station job as well as all the carpenter work. So the claimant was awarded benefits. But a different judge could have assessed a Light RFC, and that 8-month stint as a gas station attendant would have lost the case.
When I challenged the claimant after the hearing about this job, he said “It was only for 8 months, and that was 10 years ago.” People forget about past jobs. So you as their Representative have to be thorough, and account for each job on the DEQY.
See also: Prepare a Detailed Work Background