Social security has published a proposed rule which would reduce the period for past relevant work (PRW) from 15 to 5 years. The proposal is the result of a great deal of research by Social Security, and it presents a practical improvement to the disability adjudication process.

The proposed rule is currently in the comment period. Below is the comment I submitted to the Social Security Administration.

As a claimant’s representative, I support the proposed rule.

Limiting PRW to 5 years would help to streamline the disability adjudication process. A great deal of time and effort is spent cataloguing and evaluating jobs going back 15 years. It would save significant time and effort by claimants, representatives, disability examiners, judges and staff.

The proposed rule recognizes that a job held 10-15 years ago has limited relevance to a claimant’s ability currently to perform that past work, because the workplace has changed significantly. This is particularly true of technology jobs (as some commenters have noted), which constantly require new knowledge and skills as software and systems evolve. But it is also true of general office work, which now relies heavily on technology (computers, software, scanners) in a way that office work did not even 10 years ago.

Likewise, job skills acquired 10-15 years ago are unlikely to be readily transferable to a significant range of semi-skilled or skilled jobs in the current workplace.

The proposed rule could be implemented quickly, so that the rule is effective as soon as possible. While a great deal of thought and preparation have gone into the proposed rule, it would only require a simple change to the regulations. Please finalize and implement the rule with all deliberate speed.

The comment period for the proposed rule is open until November 28, 2023. Let’s hope that SSA adopts the proposed rule early in 2024.