Clients sometimes begin their outreach by expressing concern that their application for Social Security Disability benefits will be rejected because they have heard from some source that the majority of applications are rejected. I do not have statistics to support or refute this concern; however, it is valuable to understand the exact process that the Social Security Administration (SSA) follows, in order to determine whether an applicant meets their requirements for “having a disability”. For the purposes of this blog, I will be speaking about applicants who are at least 18 years of age. The considerations are different for children. Here are the steps for adults.
The SSA first asks: Is the person engaging in Substantial Gainful Activity? The Social Security Administration considers “Substantial Gainful Activity” to be employment that generates at least a certain amount of monthly gross earnings. That figure for 2025 is $1,620 for people with disabilities that do not include blindness and $2,700 for people whose disability is blindness. It is worth noting that “SGA” means that the worker achieves that level of earned income without special circumstances or support. Impairment Related Work Expenses (IRWE) or Employer Subsidies, both of which we have discussed in other blogs, may reduce how much of a worker’s earned income is counted when determining whether the worker is performing SGA. Although the SSA does apply the SGA earned income threshold to self-employed individuals, they may also employ other criteria, such as looking at how many hours a self-employed person puts into her or his business monthly. If a worker meets or exceeds any of the applicable SGA criteria, then s/he is denied disability benefits.
If an applicant is not working at a level that meets the SGA criteria, then the SSA asks whether the impairments that the applicant claims are medically determinable to be both severe and enduring. “Severe” is defined as “of a nature and degree of severity sufficient to justify its consideration as the cause of failure to obtain any substantial gainful work.” Conversely, “not severe” is defined as “only a slight abnormality or a combination of slight abnormalities which would have no more than a minimum effect on an individual's ability to work.” The SSA also clarifies that impairments cannot be considered severe if an individual is able to engage in the basic physical and or mental activities that are required by most jobs. In addition, the impairments claimed to be severe must either have lasted or be expected to last at least 12 months. If the impairments are either not severe or not expected to last 12 months or more, the applicant is denied.
If an applicant meets the severity criteria, the SSA then asks whether the applicant’s claimed impairments meet one of a long list of identified and defined disorders, which are grouped according to the bodily systems that they affect. You can find the complete listing here. If an applicant’s condition(s) is/are not listed specifically, it is possible to use medical records to demonstrate that they are “medically equal” to one of the conditions named and described on the list. Note that each listing has multiple criteria that the condition(s) must meet to be considered disabling. The applicant’s conditions must meet all required criteria. If the claimed impairments do not meet all the necessary criteria, the applicant is denied.
If the applicant’s claimed impairments meet or medically equal one of the so-called “Bluebook” listings, the SSA then asks whether, despite the impairments, the applicant can engage in their past relevant work. Past relevant work is work in which the applicant has engaged within the last 5 years and engaged in long enough to have learned the job. The five-year time-frame is used because the nature and requirements of many jobs often change over time. A worker, who last held a specific job 15 years ago, may not have the up-to-date knowledge and skills to perform that same job now. In addition, a worker, who only held a particular job for a short amount of time, may not have mastered the knowledge and skills required to return to that job.
If the applicant cannot engage in past relevant work, the SSA asks a final question: Is the applicant able to adjust to doing work other than what they had done in the past, given their residual functioning capacity, age and education level, and previous work experience? This is actually a complex calculation, involving both an objective table and subjective reasoning. “Residual functioning capacity”, is the type of mental and/or physical activities that the applicant can perform despite her/his impairments. Age is relevant because the SSA considers that people who are younger have more time to learn what is required by a new occupation. An applicant’s education level is important because, generally speaking, the higher the level of education a person has completed, the wider the range of jobs they can perform. Finally, previous work experience is considered because some jobs have more or less skills which are “transferable” to other jobs. If the applicant can either engage in past relevant work or adjust to other work, the applicant is denied. If s/he can do neither, s/he may be approved.
These are the steps the SSA takes to determine if a person meets their definition of “having a disability”, which hinges on the capacity (or not) to perform Substantial Gainful Activity. Note that an applicant must further meet certain income and asset criteria to be eligible for Supplemental Security Insurance (SSI) and that an applicant must further meet the criteria of overall and recent work credits to be eligible for Social Security Disability Insurance. Note also that applications that are denied initially may be appealed.
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