Question 1: What is the correct way to evaluate composite jobs?

Answer: It is no longer necessary to document if job duties are done in terms of percentages or fractions of a work day or to evaluate the work at the higher exertional level. DDS will only determine that an individual cannot do past work as generally performed in the national economy if it is able to find a reasonable occupational counterpart. DDS will not find an individual capable of doing past relevant work if he or she can only do parts of a past job or parts of several past jobs. The adjudicator should provide a rationale why he/she is unable to complete Step 4 of sequential evaluation.

Consider the work activity as actually performed as the claimant describes, including all elements (both exertional and non-exertional) and function-by-function. Compare this work to the RFC assessment to determine if the claimant can perform each activity described. If the answer is yes, find them capable of past work as performed. If not, consider if there is a DOT description that closely corresponds to the job description provided. If there is a comparable DOT description and the claimant can perform the functions as the DOT describes it with the given RFC, find them capable of past work as generally performed. Composite jobs are rare.

The following examples illustrate composite jobs:

Example 1: In one particular state, teacher aides also drive buses as part of their duties. If only one paycheck with no separation in pay for each particular job, this constitutes a composite job with no DOT counterpart. However, if there are two different checks or distinct pay rates for each separate job, further evaluation may be needed to determine if either of the job duties was performed at SGA level.

Example 2: The claimant has an RFC for sedentary work. The past work description is a receptionist at a mobile homes sales lot. For five hours a day, visitors are greeted, phones answered, appointments scheduled and mail opened. For the other 3 hours each day, cleaning of model homes is performed including vacuuming, mopping and dusting. The claimant cannot return to past work as performed with her RFC. A past work denial cannot be done saying she can perform just the receptionist job without the cleaner duties because that was only part of the past job. Since a DOT description that requires both functions cannot be located, DDS will proceed to step 5 of the sequential evaluation.

Question 2: Many small business owners have functioned essentially as owner/operators. Does DDS consider this a composite job?

Answer: Such work does not normally represent a composite job. A valid assessment requires a complete description of the work. How does the individual spend his or her time? Which duties and responsibilities are basic and which are incidental? The reality of the situation will dictate the assessment, but generally speaking, the smaller the business, the more likely it is that the individual functioned as a worker rather than as a manager.

Reference: VG 01-02 Working Supervisors (dated March 7, 2001 )