If your long-term disability claim was denied based on a vocational report saying your past work gave you “transferable skills,” you are not alone. In many LTD cases, that phrase becomes the bridge insurers use to move from “you cannot do your old job” to “you can still do some other job.” The problem is that transferable-skills analyses are often only as reliable as the assumptions behind them.
In general terms, a transferable-skills analysis tries to identify whether experience from prior work can realistically carry over to other occupations. In a disability case, that analysis may turn on the physical demands of your past work, your current medical restrictions, cognitive limitations, pace and attendance issues, the way your job was actually performed, and whether the alternate jobs cited are truly a fit. When any of those inputs are wrong, the conclusion may be wrong too.
In this post you’ll learn how transferable-skills analyses work, where they often break down, what evidence people often use to challenge them, and how an attorney may help build a cleaner vocational record for an LTD appeal or lawsuit. If you want a broader primer before diving in, our guide to how vocational proof shapes disability work-capacity disputes gives useful background.
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Many employer-sponsored long-term disability plans are governed by ERISA. During the claim and appeal process, insurers often rely on medical reviews and vocational reviews together. The medical file may describe restrictions. The vocational file then tries to convert those restrictions into employability conclusions.
That matters because the U.S. Department of Labor’s disability-claims rules require a full and fair review, including meaningful disclosure of relevant material and an opportunity to respond to new evidence or new rationales developed during appeal. The DOL has explained that these protections are intended to increase transparency and allow claimants to respond to the reasoning behind a denial, and the regulation requires disclosure of new or additional evidence before a final appeal denial is issued. The rules also require plans to identify medical or vocational experts whose advice was obtained in connection with an adverse determination when requested. DOL fact sheet; 29 C.F.R. § 2560.503-1; DOL FAQ
So when a transferable-skills analysis appears late in the process, or rests on unsupported assumptions, it can become one of the most important documents in the record.
A transferable-skills analysis, often shortened to TSA, is a vocational method used to decide whether skills learned in past work can carry over to other work. Social Security’s guidance is not binding in every LTD case, but it is still helpful because it lays out core vocational concepts clearly: skills transfer only when prior skilled or semiskilled job functions can be used in other work within the claimant’s residual functional capacity, and unskilled work does not create transferable skills. SSA also states that skills do not transfer to work with physical or mental requirements that exceed the claimant’s functional capacity. SSA POMS DI 25015.017
SSA’s policy also explains that transferability is generally tied to similarity in tools, machines, materials, products, processes, or services. And it notes that skills never transfer from unskilled work, to unskilled work, from semiskilled work to skilled work, or from less complex work to more complex work. SSA POMS DI 25015.017
Even though LTD policies and ERISA litigation are not identical to Social Security disability claims, those basic principles often highlight the same weak spots in an insurer’s vocational reasoning: Was the past job correctly classified? Were the claimed skills actually skills? Do they transfer to real jobs that fit the claimant’s documented limitations?
A typical vocational denial looks something like this: