Start with the position description, not the diagnosis

THE FEDERAL DISABILITY REVIEW, LLC

Educational information only. TFDR is not a law firm; it does not provide legal or medical advice, represent applicants before OPM, or predict individual outcomes.

Start With the Position Description, Not the Diagnosis

How your federal job duties give a FERS disability retirement file its structure

When federal employees begin looking into FERS disability retirement, most start in the same place: the diagnosis. They gather appointment notes, imaging results, and letters from specialists, and they build the file outward from the medical condition. It feels like the natural center of gravity. Yet the applicants who end up with the most organized, readable packages usually start somewhere less obvious — the position description.

This is not a stylistic preference. It reflects how the FERS disability standard is written and how the Office of Personnel Management (OPM) reads an application. Understanding that order can save weeks of rework.

What OPM is actually measuring

FERS disability retirement is not awarded for having a serious diagnosis. It is awarded when a medical condition prevents “useful and efficient service” in the position you occupy. The governing regulation, 5 CFR 844.103, lists the core conditions: at least 18 months of creditable civilian service; a disabling condition that arose while employed and causes a deficiency in performance, conduct, or attendance (or is incompatible with useful and efficient service or retention); a condition expected to continue for at least one year; the absence of a reasonable accommodation in the position held; and no declined offer of reassignment to a vacant position at the same grade or pay level. The definitions that give those phrases meaning sit in 5 CFR 844.102.

Read that list closely and a pattern emerges. Almost every element is tied to a specific job — your position, your duties, your grade. The medical condition is essential, but it is evaluated through the lens of what your position requires. That is why the diagnosis alone, however serious, does not answer OPM’s question.

Why the position description is the anchor

If the standard is about your position, then the document that describes your position is the natural starting point. Your official position description lists the essential duties of the job — the tasks that define “useful and efficient service” for you. Those duties become the framework everything else hangs on: the demands each duty places on you, the limitations that interfere with those demands, and the records that document those limitations.

The SF 3112 package is designed around this logic. The applicant is instructed to give a copy of the position description to the treating physician. The Supervisor’s Statement (SF 3112B) asks the agency to attach the position description and current performance standards. And the Physician’s Statement (SF 3112C) is written so the position description sits alongside the medical opinion, allowing functional limitations to be matched to job requirements. The forms keep pointing back to the same document because the standard does.

The three statements all point to the same duties

SF 3112 is built from several parts, and the first three tell a single connected story. Part A, the Applicant’s Statement of Disability (SF 3112A), is where you describe how your condition affects your ability to perform your duties. Part B, the Supervisor’s Statement (SF 3112B), is where the person who observed your work speaks to performance, attendance, and conduct against those same duties and standards. Part C, the Physician’s Statement (SF 3112C), is where your treating provider connects the medical findings to functional limitations. Parts D and E — the agency’s certification of accommodation and reassignment efforts (SF 3112D) and the checklist (SF 3112E) — round out the package.

When Parts A, B, and C are each written from the same position description, they reinforce one another. When they are written in isolation — a physician who never saw the duties, a personal statement organized by diagnosis rather than by task — they can read as three unrelated documents describing three different situations. Consistency across the file is easier to build when everyone starts from the same page, literally.

A duty-to-limitation self-audit

Here is a simple, neutral way to reorganize your own materials before anyone writes a statement. It is a self-audit — a way to see your file more clearly — not a test of whether you qualify. Only OPM makes that determination.

First, pull your official position description and highlight the essential duties. Second, for each essential duty, write down the demand it places on you — physical, cognitive, environmental, or scheduling. Third, next to each demand, note the functional limitation that interferes with it. Fourth, identify which document in your records shows that limitation: a treatment note, a test result, or a supervisor’s observation. Fifth, flag the duties for which you have no supporting document yet — those are your gaps, and they tell you where to focus.

Worked from the top down, this turns a stack of appointments into information that answers specific duties. It also mirrors what the SF 3112A and SF 3112C are asking you to show: not simply that a condition exists, but how it affects the work.

Where this approach stops

Organizing your file around your duties is educational, administrative work you can do yourself. But some questions fall outside that lane. If your application has been denied, if you are heading into reconsideration or a Merit Systems Protection Board (MSPB) appeal, or if you are facing a live dispute over an accommodation, a reassignment offer, a removal, or a filing deadline, those are legal matters. TFDR does not represent applicants before OPM or handle appeals, and the responsible step in those situations is to consult a qualified attorney who practices federal disability law.

For the preparation stage — understanding the standard, organizing your own records, and reviewing the documents you have drafted — starting with the position description is one of the highest-leverage moves available to you.

A five-point checklist to keep on your desk

1. Position description in hand, essential duties highlighted.
2. Each duty translated into its physical, cognitive, environmental, or scheduling demand.
3. Each demand matched to a functional limitation you experience.
4. Each limitation linked to a specific record that documents it.
5. Every duty without supporting documentation flagged as a gap to address.

Talk it through

If you would like a second set of eyes on how your own prepared materials line up with your position’s duties, TFDR’s Document Review examines the physician statement, SF 3112A, and OPM forms you have already drafted. If you want to map your duties and plan your next steps in a focused session, a Strategy Consult is the place to start. Visit thefederaldisabilityreview.com to schedule.

Sources

• 5 CFR 844.102–844.103 (eligibility and definitions), current on eCFR.
• SF 3112, Documentation in Support of Disability Retirement Application, Parts A–E (SF 3112A applicant, 3112B supervisor, 3112C physician, 3112D agency accommodation/reassignment certification, 3112E checklist), OMB No. 3206-0228.