Transferable skills are getting attention across the board in Social Security disability claims. I am particularly seeing transferable skills analyzed more frequently in DDS determinations.
At the DDS level, transferable skills are assessed with reference to POMS DI 25015.017
The POMS treatment of transferable skills is a great starting point for your review. If the concept of transferable skills is new to you, or you need a refresher, read the POMS section on transferable skills first. At the hearing level, see Social Security Ruling 82-41.
POMS DI 25015.017 section B. states:
Transferability of skills is an issue when all four of the following are true:
1. Transferability is material to the determination;
2. The individual’s residual functional capacity (RFC) or mental residual functional capacity (MRFC) prevent the performance of past relevant work (PRW);
3. PRW has been determined to be skilled or semiskilled; and
4. The claimant does not have a mental impairment that prevents him or her from doing skilled and semiskilled work.
Having transferable skills can cause you to lose a disability case that you otherwise would win. That’s what “material to the determination” means in part 1 above.
For example, consider a 56-year old claimant who is unable to perform past relevant work at step 4 of the sequential evaluation. In the absence of transferable skills (or recent education that allows direct entry to skilled work), that claimant will be found disabled under Medical-Vocational Rule 201.06 (sedentary RFC) or Rule 202.06 (light RFC).
However, if that same claimant has acquired job skills that would transfer to a range of skilled work with their RFC, the claimant will be found not disabled under Medical-Vocational Rule 201.07 (sedentary RFC) or Rule 202.07 (light RFC). The acquired skills must be “readily transferable to a significant range of skilled work within an individual’s residual functional capacity” to deny the claim at step 5. See Medical-Vocational Rules 201.00(e) and 202.00(e).
So please beware. Do not take transferable skills for granted.