In the long-term disability arena, benefit eligibility is typically evaluated through three lenses: financial earnings, medical restrictions and limitations, and occupational duties. Financial information helps determine whether the claimant meets the policy’s earnings threshold. Medical evidence identifies the claimant’s restrictions and limitations.
Vocational evidence identifies the material and substantial duties of the occupation performed at the time of disability and, when the policy transitions to an Any Occupation standard, supports decisions by identifying other work the claimant may be qualified to perform based on medically supported restrictions and identified transferable skills.
Of these three areas, identifying the material and substantial occupational duties performed at the time of disability often presents the greatest challenge, particularly when a condition develops gradually, job duties have evolved over time, or employer records do not capture the full scope of the work performed.
The Value of Vocational Expertise
Vocational expertise helps translate a claim file from a collection of records into a practical work-capacity analysis. A vocational professional can evaluate a claimant’s education, training, work history, transferable skills, exertional demands, cognitive demands, environmental exposures, and delineate the material and substantial duties of the occupation as it is generally performed in the national economy.
This analysis is especially important because medical restrictions alone do not determine disability. The key issue is whether those restrictions prevent the claimant from performing the material and substantial duties required based on the policy definition.
A strong vocational analysis also improves consistency and fairness. It reduces overreliance on job titles that may not reflect actual duties, generic occupational descriptions that do not match the claimant’s actual duties performed, or assumptions about skills and abilities that are transferable to occupations in the labor market.
By clarifying the duties the claimant performed, the occupational requirements, and whether alternative occupations are realistic under the policy language, vocational expertise supports a more complete and defensible adjudication.
Own Occupation and Any Occupation Analysis
Many LTD policies begin with an “Own Occupation” definition and later transition to an “Any Occupation” definition. The vocational question and analysis therefore, changes over the life of the claim. During the Own Occupation period, the analysis asks whether the claimant’s medically supported restrictions and limitations prevent performance of the material and substantial duties of the relevant occupation. During the Any Occupation period, the analysis broadens to determine whether the claimant can perform another occupation for which they are reasonably qualified by education, training, or experience and, when the policy requires it, whether that work is expected to satisfy a stated earnings threshold.
A sound evaluation applies the precise policy language, applicable dates, geographic or labor-market data, and any special rules for part-time work, gainful employment, or indexed earnings before applying vocational conclusions.
Own Occupation Evaluation
An Own Occupation evaluation begins by defining the occupation that was performed when the disability occurred. Depending on the policy, that may be the claimant’s actual job for a specific employer, the occupation as performed in the national economy, or a hybrid of the two.
A vocational review will distinguish employer-specific tasks from duties that are material and substantial to the occupation itself using employer job descriptions, claimant questionnaires, performance reviews, interviews, and occupational reference materials. Job title alone is not sufficient because identical titles can involve materially different tasks and physical, cognitive, interpersonal, or environmental demands.
Once the substantial and material duties of the Own Occupation are determined, a vocational assessment of work capacity is performed where the occupational duties are compared to the residual functional capacity. Physical factors may include lifting, carrying, sitting, standing, walking, reaching, gross and fine motor activity, keyboarding, and postural activity. Non-exertional factors may include sustained concentration, memory, pace, attendance, stress tolerance, judgment, communication, supervision, decision-making, and interaction with customers or the public.
The vocational evaluator will identify which duties are material and substantial, how frequently they occur, whether they can be performed safely and reliably throughout a normal work schedule, and whether proposed accommodations are a viable option that can be supported.
This analysis supports the disability determination by making the rationale transparent. It will identify the material and substantial duties, the functional ability to perform or not perform each duty, any conflicts in the record, and why the claimant can or cannot perform the occupation on a sustained basis. A conclusion that expressly connects the policy definition, occupational evidence, and medical restrictions is more persuasive than a conclusory statement that the claimant can or cannot perform their job.
Any Occupation Evaluation
An Any Occupation evaluation will provide occupations that the claimant can perform based on education, training and experience that are available in the labor market, exclusive of the claimant’s Own Occupation. The evaluation will utilize the claimant’s residual functional capacity, vocationally relevant education, licenses, certifications, work history, demonstrated skills, and learning capacity to conduct a transferable-skills analysis. The transferable skills analysis provides a foundation for the vocational consultant to also apply clinical judgment to determine if there are alternative occupations the claimant can perform.
Each proposed alternative occupation should be screened against the residual functional capacity profile, including physical requirements, cognitive and behavioral demands, expected attendance, work pace, environmental restrictions, schedule requirements, and the need for retraining. The vocational evaluator will provide supporting evidence as to why the claimant is or is not reasonably suited for an occupation.
When the policy contains a gainful earnings requirement, the analysis will identify the average wage based on local and national geographic data and whether the expected earnings reasonably meet the threshold stipulated in the policy. If labor-market availability is identified in the policy, the report will distinguish the existence of an occupation in the labor market and provide suitable evidence of such.
The Any Occupation conclusion should identify the occupations that are feasible after all screening criteria are applied. It should also explain why excluded occupations were rejected. If no occupation satisfies the functional, vocational, and earnings requirements, the analysis supports continued disability under the applicable policy definition. If one or more occupations meet the criteria outlined in the policy, the report should show the relationship between the claimant’s residual functional capacity and qualifications to each occupation and earnings result.
How ERISA Supports Defensible Claim Decisions
ERISA can support LTD claim decisions by requiring a disciplined administrative process. For employer-sponsored disability plans governed by ERISA, the claim decision is generally judged based on the administrative record created during the claim and appeal process. That makes the quality of the record essential. A vocational report that explains the claimant’s occupation, the source of the occupational data, the connection between residual functional capacity and substantial and material duties, and the rationale for any transferable-skills findings can help demonstrate that the decision was reasoned, evidence-based, and consistent with the plan terms.
ERISA also places emphasis on fiduciary decision-making and a full and fair review. Recent appellate decisions illustrate this balance. A claim determination may withstand judicial scrutiny when it follows a principled reasoning process, applies the plan’s occupational definition, and is supported by substantial evidence. 1 At the same time, ERISA permits courts to correct benefit denials that are not supported under the plan’s terms 2 and allows claimants to seek judicial review when an administrator fails to issue a timely appeal determination. 3
When a plan administrator considers relevant vocational evidence, addresses contrary evidence, explains why certain duties or occupations are considered material and substantial, and ties the conclusion to the policy definition of disability, the decision is more likely to withstand scrutiny. If the plan grants discretionary authority to the administrator, courts may apply a deferential arbitrary-and-capricious, or abuse-of-discretion, standard of review. In that setting, a well-documented vocational analysis can help show that the decision had a reasonable basis, even where the medical and occupational evidence is complex.
Practical Benefits for Claim Administration
The strongest LTD decisions are not based on medical conclusions alone. They are based on a complete analysis of what the policy requires, what the medical evidence supports, and what the occupation demands. Vocational expertise provides the bridge between those points. When incorporated into an ERISA-governed claim process, it strengthens the administrative record, supports reasoned decision-making, and helps produce decisions that are clearer, objective, and more defensible.
For claim professionals and attorneys, vocational evidence should be viewed as an essential part of deciding long-term disability claims, not as optional. It often helps explain, in practical terms, how the facts and legal standards support the decision. Claim professionals can use vocational analysis to develop a complete administrative record, explain how policy language applies to the claimant’s actual residual functional capacity, and communicate decisions with greater clarity.
Attorneys can use the same analysis to evaluate whether the claim file supports the benefit determination, whether contrary evidence was meaningfully addressed, and whether the decision reflects the type of fair and reasoned process ERISA requires. When vocational expertise is integrated early and clearly documented, it strengthens both the quality of the decision and the ability to defend it upon review.
1 See Geiger v. Zurich American Insurance Co. of New York, 90 F.4th 637 (4th Cir. 2023) (affirming an LTD denial reached through a principled reasoning process and supported by substantial evidence, including consideration of the plan’s occupational definition and a job-demand analysis).
2 See Tekmen v. Reliance Standard Life Insurance Co., 55 F.4th 951 (4th Cir. 2022) (affirming an award of LTD benefits where the record supported disability under the plan’s terms).
3 See McQuillin v. Hartford Life & Accident Insurance Co., 36 F.4th 419 (2d Cir. 2022) (holding that a claimant was deemed to have exhausted administrative remedies when the administrator failed to issue or properly extend a final appeal determination within the regulatory period).
