Current course:  SSI/SSDI Outreach, Access, and Recovery (SOAR) Online Course: Adult Curriculum

Disability Determination: The SSA Sequential Evaluation

SSA conducts the non-medical review of the application while the state DDS handles the medical or disability determination.

SSA has a five-step process to determine disability called the sequential evaluation. 
  • This process illustrates SSA’s standard 
  • It serves to ensure accurate disability determinations
  • An application does not necessarily make it through all 5 steps before being denied or approved 
 
This article looks at the Sequential Evaluation steps and describes the questions that SSA and DDS need to answer at each step.  

The SSA Sequential Evaluation - content available in following text.

Step 1 – Is the Applicant Working at a "Substantial Gainful" Level?
What is Substantial Gainful Activity (SGA)?
SSA uses the term SGA to describe a level of work activity and earnings that involves performance of significant mental or physical activities, or a combination of both.
  • Gainful work activity is work performed for pay or profit, or work intended for profit, even if profit is not realized.
  • Each year, SSA sets an amount of gross monthly earnings that are considered to be SGA ($1,220/month in 2019).
  • The type and amount of supports an individual receives while at work is taken into consideration when determining SGA.

SSA will evaluate the applicant's work activity
  • If the applicant is working and earning gross monthly wages equivalent to or exceeding SGA, the claim will be denied.
  • The applicant is potentially eligible if they are:
    • Not working or
    • Working, but not at SGA
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SOAR Tip: If the applicant is currently working, SSA uses the SSA-821 Work Activity Report to document any work incentives that may apply before making a determination about Substantial Gainful Activity (SGA) for initial decisions, appeals, and continuing disability reviews.
Step 2 – Does Applicant Have a Severe Impairment?
At Step 2, SSA considers the medical severity of the applicant's medically determinable impairment and its duration. An impairment is considered severe if it significantly limits the applicant’s physical or mental ability to do basic work activities.
  • Case managers can help by clearly and accurately presenting information about the person’s functioning.
  • DDS considers physical activities involved in work, such as standing, walking, lifting, carrying, seeing, hearing, and speaking.
  • They consider mental activities such as understanding, remembering, and carrying out simple instructions, judgment, responding to supervision, dealing with changes.
  • If the impairment is considered severe the application moves to Step 3
  • If the impairment is not severe the application is denied
 
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NOTE: Serious illness is NOT equivalent to severe impairment. For example, a person diagnosed with bipolar disorder may be able to manage his or her illness, complete activities of daily living, have healthy ongoing relationships, and complete cognitive tasks. Clearly bipolar disorder is a serious illness, and there may be times when it is difficult to manage. However, many people with this disorder function very well and are capable of work. If a person does not have a severe impairment the application will be denied.
Step 3 – Does the Impairment Meet or Equal the Listing?
This step is critical as it is the first point at which a person can be found disabled. Ideally, there is enough information for the DDS adjudicator to make a disability determination at this step.
  • The Listing of Impairments, (also known as the "listings"), is SSA’s categorized lists of illnesses/conditions and the severity criteria that must be met for a person to be considered disabled. (You will learn more about the listings in Class 4).
  • A diagnosis alone is not sufficient simply because it is a listed impairment.
  • Medical evidence must be provided that documents how the illness "meets" or "medically equals" a listing.
    • To "meet" a listing, an impairment must meet the severity of a set of criteria for the impairment in the listing.
    • To "medically equal" a listing, the impairment(s) must be at least equal in severity and duration to the criteria of any listed impairment.
  • Significant functional limitations must be demonstrated.
  • A person may be found disabled at Step 3 and begin receiving benefits.
  • If the evidence is not sufficient to meet a listing, the examiner moves to Step 4.
Step 4 – Does the Impairment Allow for Past Relevant Work?
DDS looks at work the applicant has done in the past (generally the last 15 years). They also assess the applicant’s residual functional capacity (RFC) based on their current functional abilities.
  • Considering their RFC, DDS determines if the person can do work they have done before.
  • They do not consider whether the applicant can get a particular job.
  • If the applicant is determined to be able to do their past work the application is denied.
  • If the applicant is unable to perform their past work, the application moves to Step 5.
Step 5 – Can the Person Do Any Other Work?
DDS must assess whether a person can adjust to any other work despite their impairments.
  • DDS takes into consideration the applicant’s RFC and other vocational factors, including age, education, and experience.
  • They determine if the applicant can do other work that exists in the regional or national economy.
  • There are no requirements that this work be available locally or generate the same level of income as past work.
  • To deny, DDS must articulate three jobs that meet the person’s abilities.
  • DDS consults the Dictionary of Occupational Titles (a listing of jobs and descriptions of tasks, skills, and level of exertion required to perform  these jobs).
  • Vocational factors are important. Example: Two 55 year old women with depression and arthritis apply for disability. One has a college degree and history of working of a receptionist. The second did not finish high school and has never worked outside of the home. The first woman is more likely to be denied due to her education and work history.
Step 3 is Key!
This is where you can make a big difference! A person can be approved at Step 3 with sufficient medical evidence and clearly demonstrated functional impairment. 
  • Time to process the claim is often shorter when a person is found disabled at Step 3.
  • With fewer steps, the time before the applicant begins to receive benefits is reduced.
  • Steps 4 and 5 are more subjective and more difficult to assess but allow for the possibility of approval even though impairment does not meet the severity criteria of a listing.
  • Approval at Step 3 is preferred!