By Rovaryn Digital · October 23, 2026 · 10 min read
When one counselor runs three TSAs in the same week
A caseload rarely sorts itself by claim type. On Monday, a counselor runs a transferable skills analysis for a warehouse supervisor with a lumbar injury, filed under a state workers' compensation statute with a hearing date already on the calendar. On Wednesday, the same counselor is asked to evaluate a claimant's residual capacity for a Social Security Disability Insurance hearing, where the question isn't whether this worker can return to a specific job but whether any job exists in the national economy that fits their limitations. By Friday, it's a long-term disability file for an insurer deciding whether a claimant who can no longer perform her "own occupation" can perform any occupation reasonably suited to her background.
Same counselor. Same underlying skill set — crosswalking past work, functional capacity, and labor market data into a defensible opinion. Three completely different reports, because three different legal frameworks are asking three different questions. Treat them as interchangeable and the analysis gets challenged — sometimes by a hearing officer, sometimes by opposing counsel, sometimes by the claims examiner who simply sends it back.
By the end of this piece, you'll be able to explain to a new hire, a referral source, or your own documentation why a workers' comp TSA, an SSA TSA, and an LTD TSA all start from the same methodology but end up answering different legal questions.
The one constant: the transferable skills analysis methodology itself
Before the differences, the shared foundation. A transferable skills analysis identifies the skills a worker developed in past relevant work, translates those skills using an occupational classification system, and matches them against jobs the worker's current functional capacity can still perform. The Dictionary of Occupational Titles (DOT) remains the historical backbone of this crosswalk in many contexts, with the Occupational Information Network (O*NET) now serving as the modern, continuously updated occupational database — it currently profiles roughly 900 occupations covering more than 55,000 jobs in the economy. Wage data for those matched occupations typically comes from the Bureau of Labor Statistics Occupational Employment and Wage Statistics (OEWS) program.
That three-step backbone — skills extraction, occupational crosswalk, wage/labor-market matching — doesn't change across claim types. What changes is which functional limitations get fed in, which legal standard the output has to satisfy, and what the report is ultimately used to decide. For a plain-language walkthrough of the base methodology before you compare contexts, see what a transferable skills analysis is and how it's built.
Workers' compensation TSA: wage-earning capacity, jurisdiction, and the clock
In a workers' compensation claim, the TSA usually exists to answer one practical question: given this worker's permanent restrictions, what can they still earn, and does that create a wage loss compared to their pre-injury job? That comparison — pre-injury wage versus post-injury wage-earning capacity in suitable, available occupations — is often the number that drives a settlement, a permanent disability rating, or eligibility for vocational rehabilitation benefits.
Three things make the workers' comp context distinct:
It's governed by state statute, and only that state's statute. Vocational rehabilitation eligibility rules, which occupations count as "suitable gainful employment," and how a labor market survey must be documented all vary by jurisdiction. A rule that applies in one state does not transfer to another, and a competent TSA practitioner verifies the current requirement with the relevant state workers' compensation board rather than assuming consistency across state lines.
Deadlines carry financial consequences. Workers' comp reporting and vocational-eligibility deadlines are typically set by statute or regulation, and missing one can affect fee-schedule reimbursement or benefit eligibility outright — again, jurisdiction-specific, and worth confirming directly with the relevant board rather than assuming a uniform national clock.
Some jurisdictions attach a concrete retraining benefit to the finding. California is the clearest example: its Supplemental Job Displacement Benefit provides a $6,000 voucher for education and retraining to injured workers who cannot return to long-term work because of permanent disability. That figure is California-specific — it does not apply in other states, and no other state's retraining benefit should be assumed to match it.
Billing in workers' comp cases is also typically tied to a published fee schedule with defined codes for evaluation, report writing, and testimony — which is part of why documentation discipline (what was analyzed, when, and under which version of the report) matters as much as the analysis itself.
SSA transferable skills analysis: the Grids, "any occupation," and national numbers
Social Security disability determinations ask a fundamentally different question than workers' comp does. SSA isn't asking whether a claimant can return to their job, or even a job reasonably similar to it. At the later steps of its sequential evaluation process, SSA asks whether the claimant can perform any occupation that exists in significant numbers in the national economy, given their age, education, residual functional capacity, and past relevant work. That's a materially stricter, and differently structured, standard than a wage-loss comparison.
This is also where SSA's Medical-Vocational Guidelines — commonly called "the Grids" — come into play, combining a claimant's age category, education level, and exertional capacity to point toward a finding of disabled or not disabled in many cases without even requiring an individualized TSA. When a case falls outside a clean Grid rule, a vocational expert's transferable skills testimony becomes the deciding input at a hearing — which is why SSA-context TSAs are built to withstand direct examination by an administrative law judge, not just desk review by a claims adjuster.
Scale matters here too: as of December 2024, 7,231,147 disabled workers were receiving SSDI, with 8,614,659 people receiving disability benefits in total across all beneficiary categories. That's a national program making an "any occupation, national economy" determination at enormous volume — a different posture than a single state's wage-loss calculation. For the full breakdown of how SSA's sequential evaluation and vocational expert testimony shape the TSA, see transferable skills analysis for Social Security disability.
A note on precision: the current Substantial Gainful Activity (SGA) dollar threshold SSA uses, and the exact Grid rule outcomes for specific age/education/RFC combinations, change periodically and should always be confirmed against SSA's current published guidance rather than carried forward from memory or a prior case file.
LTD transferable skills analysis: policy language is the law
Long-term disability claims flip the source of authority entirely. There's no statute and no federal regulation defining the standard — the insurance policy itself does. Most LTD policies define disability differently depending on how long the claimant has been out of work: an initial period evaluated against their own occupation (can they do the specific job they held), followed by a later period evaluated against any occupation reasonably suited to their training, education, and experience. Many policies make that transition at a defined elimination period, but the exact length and definition vary by carrier and by policy — never assume one LTD policy's transition terms match another's, and confirm the specific language with the policy document before building an opinion around it.
That own-occupation-to-any-occupation shift is the single biggest driver of how an LTD TSA is scoped. Early in a claim, the analysis may need to go no further than the claimant's own job duties. Later, it has to do the same breadth-of-market-occupation sweep that an SSA case requires — except measured against the insurer's definition of "reasonably suited," not SSA's "exists in significant numbers nationally" test. Two different "any occupation" standards, from two different authorities, producing two different reports even when the claimant's functional profile is identical. The mechanics of that shift — and what a counselor needs to document to support an insurer's or a claimant's position at either stage — are covered in transferable skills analysis for long-term disability.
LTD billing also runs differently than workers' comp: there's typically no public fee schedule, and the relationship is often a direct contract between the counselor and the insurer or the claimant's attorney rather than a state-coded reimbursement structure.
Where courtroom exposure changes the report, regardless of claim type
Across all three contexts, there's a fork in how much scrutiny the TSA is built to survive. A desk-review TSA supporting an insurer's internal claims decision is a different document than one prepared for cross-examination at an SSA hearing or a workers' comp deposition — not because the methodology changes, but because the documentation trail has to. When a vocational expert is going to be deposed or put on a witness stand, every input — which DOT or O*NET codes were selected and why, which wage sources were pulled and when, which version of the report reflects the final opinion — has to be reconstructable months or years later. That documentation discipline matters in every context, but it's non-negotiable the moment a report becomes expert testimony. The specific demands that shift places on a TSA — version control, source citations, defensible wage data — are covered in transferable skills analysis for vocational experts.
It's also worth remembering the stakes behind all three contexts aren't abstract. More than 1 in 4 U.S. adults — over 70 million people — reported having a disability in 2022, and the employment gap is stark: a 2024 employment-population ratio of 22.7% among people with a disability compared to 65.5% among people without one. Transferable skills analysis, in any of its three legal forms, is one of the few tools that puts a rigorous, occupation-by-occupation answer behind the question of what work is actually still possible — which is a meaningful part of why the Commission on Rehabilitation Counselor Certification reports more than 15,000 Certified Rehabilitation Counselors practicing in the United States, Canada, and several other countries today.
Building one system that respects three different standards
The practical challenge isn't understanding that these three contexts differ — most practitioners learn that early. It's running a practice where the same week brings all three, each with its own documentation requirements, its own deadline structure, and its own billing logic, without the analysis for one case quietly borrowing an assumption that only belongs in another. A workers' comp wage-earning-capacity figure doesn't answer an SSA "any occupation nationally" question. An LTD own-occupation finding doesn't satisfy a state's vocational rehabilitation eligibility rule. Treating the three as one generic "TSA template" is how reports get challenged.
That's also why the underlying occupational data — the DOT-to-O*NET-to-SOC crosswalk and the wage figures behind it — benefits from being handled consistently even when the legal wrapper around it changes case to case. If you're building or refreshing your own reference materials, the TSA worksheet pack and the O*NET-DOT occupation crosswalk reference workbook are built around that same three-step methodology, structured so the same crosswalk logic holds up whether the report in front of you is headed to a workers' comp hearing, an SSA judge, or an LTD claims file.
For a broader map of how all of these TSA contexts connect — including the pieces not covered here — the transferable skills analysis resource hub is the place to start.
Keep the distinctions straight as the rules shift
Workers' comp statutes get amended. SSA updates its guidance periodically. LTD carriers write and revise their own policy language. None of that is static, and none of it generalizes cleanly from one jurisdiction, program, or carrier to the next. If you want the practical, non-sales version of how these rules evolve — case-type comparisons, jurisdiction notes, and methodology breakdowns like this one — subscribe to our newsletter below and we'll send new installments as they publish.