By Rovaryn Digital · October 27, 2026 · 8 min read
When a Labor Market Survey Answers the Wrong Question
A claims examiner at a group LTD carrier sends back a labor market survey with a single line: "This survey addresses the claimant's prior occupation. The file is in any-occupation review." The vocational counselor who prepared it built the survey the way she always has — pull the pre-disability job title, crosswalk it to O*NET, run three comparable postings, attach wage data. That survey would hold up fine in a workers' comp file. In an any-occupation LTD review, it's the wrong document.
The policy language has shifted the question from "can this claimant do the job they used to have" to "is there any occupation, anywhere in the labor market the claimant can reasonably access, that fits their restrictions, education, and work history — regardless of whether they've ever done it." That's a fundamentally different survey: a different starting occupational base, a different wage-earning-capacity comparison, and different documentation that carriers, and eventually appeal reviewers, expect to see. By the end of this article you'll know what a labor market survey built for an LTD any-occupation review needs to contain, and where it diverges from the workers' comp version.
What an LTD Any-Occupation Review Expects From a Labor Market Survey
Group and individual LTD policies almost universally define "any occupation" with reference to the claimant's education, training, and experience, and to work existing in the national economy in reasonable numbers — not the claimant's prior job title. A labor market survey for an LTD any-occupation review has to document a transferable skills analysis first, because the survey's job universe is the output of that analysis, not a given. If the TSA step is thin or missing, the survey that follows it has no defensible foundation no matter how well the wage data is sourced.
This is the single most common documentation gap carriers flag: a survey that lists occupations without showing how they were derived from the claimant's actual restrictions, residual functional capacity, and work history. The survey record needs to show its work — restrictions in, TSA methodology applied, occupational base out — before a single wage figure appears. For background on how the any-occupation standard differs from the own-occupation period that typically precedes it, see our own-occupation vs. any-occupation comparison, and for the review cadence carriers follow across the claim lifecycle, see our overview of the LTD vocational review process.
Building the Occupational Base: From Restrictions to a Defensible Job List
The occupational base is where most any-occupation surveys succeed or fail on review. The counselor starts from the claimant's documented physical and cognitive restrictions — not the diagnosis, the functional limitations — and crosswalks prior work experience and transferable skills against the occupational classification systems that give the survey its structure. The ONET database, maintained by the U.S. Department of Labor's Employment and Training Administration, covers 900 occupation profiles across more than 55,000 jobs, which is the breadth that makes a genuine "any occupation" search possible rather than a search confined to a handful of familiar titles. (ONET content used under CC BY 4.0; ONET is a trademark of USDOL/ETA.)*
Documentation at this stage should show, in order: the restrictions as stated in the medical and vocational record, the transferable skills identified from the claimant's work history, the SVP and physical demand levels the restrictions permit, and the resulting candidate occupation list — with a stated rationale for inclusion, not just a list of titles. A survey that skips straight to "here are three jobs" without showing this derivation invites the exact rejection described in the opening scenario. Our walkthrough of how to conduct a labor market survey covers the mechanics of this derivation step in more detail, and our defensible methodology piece covers how to write up the rationale so it reads as reasoned judgment rather than a bare assertion.
Wage Data and Earning Capacity Under the Any-Occupation Test
Once the occupational base is set, the survey turns to whether those occupations exist "in reasonable numbers" at wages the policy language recognizes as substantial gainful activity or a comparable earnings threshold — policy-specific language the counselor should confirm against the actual plan document rather than assume. Wage figures in this section should be sourced from the Bureau of Labor Statistics Occupational Employment and Wage Statistics program, which draws its estimates from a probability sample of roughly 1.1 million establishments surveyed in semiannual panels of about 186,000–189,000 each — a sampling base broad enough that OEWS figures are the default standard carriers and reviewing physicians expect to see cited, rather than a single job posting or a handful of classified ads.
The documentation should show the wage band for each surviving occupation, not just a single point estimate, and should state plainly whether the claimant's restrictions place them at the entry, median, or upper end of that band given their experience level. This is a worked judgment call, not a formula the software completes on its own — the counselor's stated rationale for where in the band the claimant lands is part of what a reviewer is evaluating. Because the any-occupation standard looks at earning capacity across an entire occupational field rather than a single employer's posted rate, a survey that cites only one local job order is thinner evidence than one that shows the wage range an occupation commands across the relevant labor market area.
Structuring the Survey Record for Carrier and Appeal Review
LTD claim files have a longer downstream life than most workers' comp files: an adverse any-occupation determination routinely proceeds to an internal appeal, and for ERISA-governed plans, the administrative record closes at a defined point and generally cannot be supplemented later. That makes the labor market survey's internal organization matter more, not less. A survey built for an LTD any-occupation review should be structured so a reviewer who has never spoken to the counselor can follow the logic start to finish: restrictions, TSA, occupational base with rationale, wage data with source citations, and a dated, versioned conclusion.
Version control deserves particular attention here. If the survey is updated after a records request or an independent medical exam changes the restriction picture, the record should preserve the prior version rather than silently overwrite it — a reviewer or opposing counsel asking "what did this survey say before the IME" is a common appeal-stage question, and an undated overwrite reads badly regardless of what it actually said. This is a documentation-hygiene point, not a legal one; confirm with the specific carrier or plan administrator what their appeal record expects, since ERISA appeal procedures and plan-specific submission rules vary by policy and are not uniform across insurers.
Where This Differs from a Workers' Comp Labor Market Survey
The biggest practical difference is scope. A workers' comp labor market survey, built around state-specific vocational rehabilitation rules, is typically anchored to the claimant's date of injury and the jurisdiction's statutory definition of suitable gainful employment — often still tethered loosely to prior occupation, wage replacement percentages, or a specific voucher structure. California's workers' compensation system, for example, provides a $6,000 Supplemental Job Displacement Benefit voucher for education and retraining when an injured worker cannot return to long-term employment due to permanent disability — a program structure specific to California and not a model that generalizes to other states or to LTD claims at all.
An LTD any-occupation survey has no equivalent statutory anchor. It's a private contract standard, and the "reasonable labor market" the survey searches is typically broader geographically and occupationally than a workers' comp survey tied to a local labor market area. The counselor should expect to document a wider occupational net, a more explicit SGA or earnings-threshold comparison, and — because there is no state board setting the rules — a closer read of the specific plan document's definitions before deciding how broad "any occupation" actually is for that claim. For a fuller comparison of how the any-occupation review itself is triggered and conducted relative to other LTD review stages, see our any-occupation LTD review overview and our labor market survey for vocational rehabilitation piece, which covers the workers' comp-style survey this one is contrasted against.
It's worth noting the scale of the population these reviews touch, even though SSDI and LTD are separate systems with separate standards: as of December 2024, 7,231,147 disabled workers were receiving SSDI benefits, with 8,614,659 total disability beneficiaries across the program. LTD any-occupation reviews frequently run alongside an SSDI claim for the same claimant, and the labor market survey's occupational base and the SSA's own vocational grid rarely line up perfectly — another reason the survey needs to show its independent reasoning rather than borrow a conclusion from a different standard.
Keeping the Documentation Consistent Across a Caseload
A counselor handling a mixed caseload of workers' comp and LTD files is the most common place this documentation discipline breaks down — not from carelessness, but because the two survey types share enough surface structure (occupations, wages, a written conclusion) that it's easy to default to one template for both. Keeping the any-occupation survey's distinct sections — TSA derivation, occupational base rationale, wage band with source, and a versioned conclusion — as a separate, repeatable structure from the workers' comp template is what keeps carrier submissions and appeal records consistent across a growing caseload, rather than reinvented file by file.
A practice built around a template that enforces this structure, rather than relying on each counselor to remember it, is the more scalable answer as caseload volume grows. If you want a starting structure rather than building one from scratch, our LTD vocational review kit and labor market survey documentation kit are built around the section order described above — download the templates and adapt them to the specific plan language and carrier submission requirements your file requires.