Quick Summary:
- The SSA identified 114 DOT occupations it considers “isolated/obsolete” and limited their use to support a “not disabled” finding.
- The agency changed the relevant period for Past Relevant Work (PRW) from 15 years to 5 years in most cases (effective June 2024 for many changes).
- SSR 24-3p (effective January 6, 2025) rescinds SSR 00-4p. VEs/VSs may now rely on any reliable occupational data sources — but they must explain their methodology, including how they estimate job numbers.
Background: why these changes now?
A combination of factors pushed SSA to modernize: the DOT (Dictionary of Occupational Titles) has not been updated for decades and contains job descriptions and enormous job-number estimates that no longer reflect today’s labor market. Courts, advocates, and labor-market analysts have repeatedly criticized reliance on the DOT for denying claims by pointing to rare or outdated jobs. SSA’s recent changes aim to reduce use of clearly obsolete occupations, shorten the backward look for PRW to better reflect current employability, and update how adjudicators treat occupational evidence and VE testimony.
1) “Obsolete” DOT jobs — what SSA did and why it matters
What SSA announced
- In June 2024 SSA issued guidance identifying 114 DOT occupations it found to exist “in very limited numbers, if at all,” within each of the nine U.S. Census divisions. SSA’s announcement said it would not use these occupations to support a “not disabled” finding at step five of the sequential evaluation process.
Examples & numbers
- The public materials and SSA Emergency Messages list specific DOT titles (examples widely reported in advocacy coverage include jobs like nut sorter, pneumatic tube operator, and various specialty breeder/scaler roles*). SSA reached its determinations by comparing DOT job listings to modern employment data sources (such as BLS/OEWS).
Operational effect
- Adjudicators should not rely solely on those isolated DOT occupations to find that suitable jobs “exist in significant numbers in the national economy” for a claimant. Instead, adjudicators must look to contemporary occupational data and may need additional corroborating evidence when a VE cites a rare DOT job.
Why it matters for claimants
- Denials that previously depended on obsolete DOT entries may be harder to sustain. Claimants (and advocates) should make sure the record contains modern occupational evidence and challenge reliance on outdated DOT titles when they appear.
2) Past Relevant Work (PRW): the 5-year look-back
What changed
- SSA revised its guidance so that, in most cases, PRW is limited to work performed within the 5 years prior to the date of the determination or decision (instead of the prior 15-year period). The agency implemented this change in summer 2024 and issued related DI/SSR guidance and policy updates explaining how to measure the relevant period in different procedural situations.
Key operational details
- PRW still requires the work to meet the threshold for substantial gainful activity (SGA) and for the claimant to have had enough time in the job to learn it (generally more than short stints). Work that lasted fewer than 30 calendar days is not PRW. The “relevant period” is generally measured from the date of adjudication, with some special rules for Title II claims and other procedural scenarios.
Practical implications
- For claimants who stopped working more than 5 years ago, prior jobs that used to count as PRW (and thereby supported denial) may now be outside the relevant period — which can improve the claimant’s odds at step four/five.
- For claimants who have had intermittent work in the 5-year window, careful documentation of dates, hours, earnings, and learning time becomes even more crucial.
- Advocates should re-evaluate older cases (and reopened claims) where denials relied on very old PRW determinations.
Where this fits in the timeline
- These PRW changes were implemented via SSA policy and rulemaking in mid-2024 as part of a package of “intermediate improvements” to the disability adjudication process; the new 5-year rule also aligns CDR (continuing-disability review) rules to the same time frame in many situations.
3) SSR 24-3p replaces SSR 00-4p — what changed about VE testimony and occupational evidence
What SSR 00-4p required (the old rule)
- SSR 00-4p (issued in 2000) required that adjudicators identify and resolve conflicts between VE (or VS) testimony and the DOT. In practice, ALJs had to ask whether the VE’s testimony conflicted with the DOT and obtain reasonable explanations for any apparent conflicts. That rule effectively elevated the DOT as the benchmark and constrained VE use of other data sources.
What SSR 24-3p does (the new rule)
- Rescinds SSR 00-4p. SSR 24-3p (published December 2024; effective January 6, 2025) explains SSA’s updated standard for evaluating whether vocational evidence is sufficient to support a determination or decision.
- VEs/VSs may use any reliable occupational data commonly used by vocational professionals.
- VEs must explain their general approach to estimating job numbers and the data sources/methods they used. SSA published an accompanying VE handbook and resource list to guide acceptable data sources and methodologies.
What VE testimony now must include (in practice)
- Identify the data sources they used (e.g., BLS/OEWS, O*NET, proprietary labor-market tools).
- Describe how they mapped job tasks and exertional/cognitive demands to the claimant’s residual functional capacity (RFC).
- Explain the methodology for estimating the number of jobs available (geographic assumptions, code crosswalks, aggregation methods).
Potential downstream consequences
- More variability in VE testimony — VEs may rely on different data sources and produce differing job-number estimates. That makes cross-examination and methodological testing more important.
- Greater emphasis on methodology — judges and advocates will assess the reasonableness of a VE’s methods rather than rely on an outdated benchmark.
- Opportunities for claimants — where a VE’s methodology is weak, claimants may be better able to challenge VE testimony than when the DOT held center stage.
Bottom line
These reforms collectively move SSA away from mechanical reliance on an outdated DOT, shorten the window for what counts as past relevant work, and require greater methodological transparency from vocational experts. That combination can benefit claimants — especially those whose only “matching” DOT jobs are obsolete or whose work history falls outside the new 5-year PRW window — but it also raises the stakes for rigorous vocational methodology and effective cross-examination.
