Using Job Data to Win Cases with Mental Limitations – 2026 Spring National Conference – Track II (Presented by National Organization of Social Security Claimants’ Representatives)

Michelle Spadafore
Michelle Spadafore
New York Legal Assistance Group (NYLAG)

Michelle Spadafore is the Senior Supervising Attorney of the Disability Advocacy Project at the New York Legal Assistance Group (NYLAG). Prior to joining NYLAG, she worked at the AIDS Center of Queens County, a community-based nonprofit providing comprehensive services to individuals living with HIV/AIDS.

Kevin Liebkemann
Kevin Liebkemann
Rutgers Law School

Kevin Liebkemann is a Tulane Law graduate who has represented clients in Social Security disability cases for over 25 years. He works at Legal Services of New Jersey, a nonprofit legal aid organization providing free legal assistance to low-income individuals and also serves as Acting Director of the Economic Justice and Public Benefits Clinic at Rutgers Law School

Live Video-Broadcast: April 21, 2026

1.25 hour CLE

Tuition: $395.00
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Program Summary

JBP job numbers only account for SVP and GED mental demands, not the full scope of a claimant's RFC. This session shows attorneys how to use ORS, OEWS, and ONET to reduce JBP figures to accurately reflect mental limitations, identify the right data sources for common restrictions like occasional contact with others, and hold Vocational Experts accountable for unreduced testimony at Step 5 hearings.

Eligible for up to 1 CLE Credit Hour

This session was originally submitted for CLE as a live, in-person presentation and a live webcast for the 2026 Spring National Conference and may be eligible for self-study credit.

Each state handles self-study credit differently; for questions, please consult your State Bar Association.

Recorded Tuesday, April 21, 2026.

  • Why JBP numbers alone fall short
    • JobBrowserPro figures only capture SVP and GED mental demands, leaving critical RFC limitations unaccounted for in VE testimony.
  • How to reduce job numbers using supplemental data
    • Apply ORS, OEWS, and ONET to adjust JBP figures so they accurately reflect the full scope of a claimant's mental RFC.
  • Key data sources for common mental limitations
    • Identify which vocational datasets apply to restrictions like occasional contact with others and how to extract the relevant figures.
  • Strategies for holding VEs accountable
    • Use targeted cross-examination grounded in vocational data to challenge unreduced job numbers and strengthen the evidentiary record at Step 5.

This course is co-sponsored with myLawCLE.

Date / Time: April 21, 2026

  • 3:15 pm – 4:30 pm Eastern
  • 2:15 pm – 3:30 pm Central
  • 1:15 pm – 2:30 pm Mountain
  • 12:15 pm – 1:30 pm Pacific

Closed-captioning available

Speakers

Michelle Spadafore, Esq., Senior Supervising Attorney, Disability Advocacy Project | New York Legal Assistance Group (NYLAG)

Michelle Spadafore is the Senior Supervising Attorney of the Disability Advocacy Project at the New York Legal Assistance Group (NYLAG). Prior to joining NYLAG, she worked at the AIDS Center of Queens County, a community-based nonprofit providing comprehensive services to individuals living with HIV/AIDS. Her practice encompasses Social Security law, access to public benefits, and consumer credit issues. Michelle has played a significant role in impact litigation aimed at improving the SSA’s handling of non-disability appeals, including her involvement in the landmark cases Amin v. Kijakazi, Ershteyn v. Berryhill, and Campos v. Kijakazi.

  • Education & Credentials
    • Michelle is a licensed attorney with deep expertise in Social Security law, public benefits access, and consumer credit issues a combination of practice areas that reflects both the legal complexity and the economic vulnerability facing many of NYLAG’s clients. Her involvement in multiple impact litigation cases addressing SSA non-disability appeals procedures demonstrates appellate and systemic litigation credentials that extend well beyond routine administrative representation.
  • Recognition & Leadership
    • As Senior Supervising Attorney of NYLAG’s Disability Advocacy Project, Michelle holds one of the most senior leadership roles in one of New York City’s most prominent legal aid disability programs. Her participation in Amin v. Kijakazi, Ershteyn v. Berryhill, and Campos v. Kijakazi, a trio of impact cases focused on reforming SSA’s non-disability appeals processes, reflects recognition of her as a litigator capable of advancing systemic change. Her earlier work at the AIDS Center of Queens County demonstrates a career grounded in service to some of New York’s most vulnerable communities, a commitment she has continued and expanded through her leadership at NYLAG.
  • Professional Involvement
    • Michelle’s professional involvement spans direct client representation, organizational leadership, and impact litigation. In addition to supervising the Disability Advocacy Project at NYLAG, she has been a key participant in multiple impact cases challenging the SSA’s handling of non-disability appeals, Amin v. Kijakazi, Ershteyn v. Berryhill, and Campos v. Kijakazi, that represent some of the most significant recent efforts to improve systemic fairness in the SSA’s administrative process. Her prior work at the AIDS Center of Queens County adds a community health and benefits advocacy dimension to a career defined by service to low-income New Yorkers navigating complex government systems.
  • Experience
    • Michelle’s legal career has been built at the intersection of Social Security law, public benefits, and community-based advocacy. Before joining NYLAG, she developed her public interest foundation at the AIDS Center of Queens County, where she served individuals living with HIV/AIDS. At NYLAG’s Disability Advocacy Project, she has risen to Senior Supervising Attorney and expanded her work into impact litigation, taking on SSA non-disability appeals in Amin v. Kijakazi, Ershteyn v. Berryhill, and Campos v. Kijakazi in an effort to improve the systemic fairness of SSA’s administrative procedures. Her career reflects a practitioner who has consistently used both direct representation and strategic litigation to advance the rights of low-income and underserved New Yorkers.

 

Kevin Liebkemann, Esq., Staff Attorney, Legal Services of New Jersey, Acting Director, Economic Justice and Public Benefits Clinic | Rutgers Law School

Kevin Liebkemann is a Tulane Law graduate who has represented clients in Social Security disability cases for over 25 years. He works at Legal Services of New Jersey, a nonprofit legal aid organization providing free legal assistance to low-income individuals and also serves as Acting Director of the Economic Justice and Public Benefits Clinic at Rutgers Law School. He is the 2018 recipient of NOSSCR’s Eileen P. Sweeney Distinguished Service Award. In addition to his direct representation work, Kevin writes articles on disability-related topics, trains attorneys and advocates, and engages in disability policy work. Outside the office, he is an avid songwriter and musician.

  • Education & Credentials
    • Kevin earned his Juris Doctor from Tulane University Law School. He is a licensed attorney with over 25 years of concentrated experience in Social Security disability law, complemented by his role as Acting Director of the Economic Justice and Public Benefits Clinic at Rutgers Law School, a position that requires both substantive expertise and clinical teaching skills. His combination of direct legal aid practice, law school clinical leadership, scholarly writing on disability topics, and practitioner training reflects a multidimensional legal career grounded in deep subject matter expertise.
  • Recognition & Leadership
    • Kevin received NOSSCR’s Eileen P. Sweeney Distinguished Service Award in 2018, one of the field’s most prestigious honors, recognizing distinguished service on behalf of people with disabilities in America. His appointment as Acting Director of the Economic Justice and Public Benefits Clinic at Rutgers Law School reflects his standing as both a skilled practitioner and an educator trusted to lead one of the state’s most prominent law school clinical programs. His decades of service at Legal Services of New Jersey, combined with his national profile as a writer, trainer, and policy advocate, cement his reputation as one of the most well-rounded and respected figures in the Social Security disability bar.
  • Professional Involvement
    • Kevin’s professional involvement extends well beyond his caseload. As Acting Director of the Economic Justice and Public Benefits Clinic at Rutgers Law School, he helps train the next generation of public interest lawyers. He
      regularly writes articles on disability-related topics and trains attorneys and advocates, activities that multiply his impact far beyond individual representation. His policy work adds a systemic dimension to a career that already spans direct advocacy, clinical education, and scholarship. Kevin has been a featured speaker at NOSSCR national meetings, and his breadth of engagement across the disability law community reflects a practitioner who is as invested in the health of the field as in the outcomes of his own cases.
  • Experience
    • With over 25 years of Social Security disability representation, Kevin Liebkemann has built one of the most comprehensive and multifaceted careers in the field. At Legal Services of New Jersey, he has devoted his practice to providing free legal assistance to low-income individuals navigating the Social Security disability system. Simultaneously, his role as Acting Director of the Rutgers Law School Economic Justice and Public Benefits Clinic has allowed him to shape clinical legal education while maintaining an active practice. His writing on disability law topics, his practitioner training, and his disability policy work reflect a career that integrates advocacy, education, and systemic change, all recognized by NOSSCR’s 2018 Eileen P. Sweeney Distinguished Service Award. When not practicing law, Kevin channels his creativity into songwriting and musical performance.

Agenda

I. Using Job Data to Win Cases with Mental Limitations | 3:15pm – 4:30pm

Using JobBrowserPro (JBP) for job numbers is not the end of the line for a RFC with mental limitations. VEs using unreduced JBP job numbers in their testimony are only taking into account the mental limitations provided by SVP and GED. For job numbers that accurately reflect the RFC, VEs should reduce the job numbers provided by JBP using other vocational data sources (ORS, OEWS, ONET) to account for the mental limitations in a hypothetical. Learn about key data sources for common mental limitations (e.g. occasional contact with others) and learn how to use this data to hold VEs accountable.

Credits

Alaska

Approved for CLE Credits
1.25 General

Our programs are CLE-eligible through Alaska’s recognition of multi-jurisdictional reciprocity.
Alabama

Approved for CLE Credits
1.3 General

Arkansas

Approved for CLE Credits
1.25 General

Arizona

Approved for CLE Credits
1.25 General

California

Approved for CLE Credits
1.25 General

Colorado

Pending CLE Approval
1.25 General

Connecticut

Approved for CLE Credits
1.25 General

District of Columbia

No MCLE Required
1.25 CLE Hour(s)

Delaware

Pending CLE Approval
1.25 General

Florida

Approved via Attorney Submission
1.25 General Hours

Receive CLE credit in Florida via attorney submission.
Georgia

Approved for CLE Credits
1.5 General

Hawaii

Approved for CLE Credits
1.25 General

Iowa

Pending CLE Approval
1.25 General

Idaho

Pending CLE Approval
1.25 General

Illinois

Approved for CLE Credits
1.25 General

Indiana

Approved for CLE Credits
1.3 General

Kansas

Pending CLE Approval
1.25 Substantive

Kentucky

Pending CLE Approval
1.25 General

Louisiana

Pending CLE Approval
1.25 General

Massachusetts

No MCLE Required
1.25 CLE Hour(s)

Maryland

No MCLE Required
1.25 CLE Hour(s)

Maine

Pending CLE Approval
1.25 General

Michigan

No MCLE Required
1.25 CLE Hour(s)

Minnesota

Pending CLE Approval
1.25 General

Missouri

Approved for CLE Credits
1.5 General

Mississippi

Pending CLE Approval
1.25 General

Montana

Pending CLE Approval
1.25 General

North Carolina

Pending CLE Approval
1.25 General

North Dakota

Approved for CLE Credits
1.25 General

Our programs are CLE-eligible through North Dakota’s recognition of multi-jurisdictional reciprocity. Section 1, Policy 1.14
Nebraska

Pending CLE Approval
1.25 General

myLawCLE reports attendance to Nebraska on each attorney’s behalf for all programs. Please do not self-report.
New Hampshire

Approved for CLE Credits
75 General minutes

As of July 1, 2014, the NHMCLE Board no longer provides pre- or post-approval of courses. Attendees must self-determine whether a program is eligible for credit, and self-report their attendance online at www.nhbar.org, based on qualification provisions of Rule 53.
New Jersey

Approved for CLE Credits
1.5 General

Our programs are CLE-eligible through New Jersey’s recognition of multi-jurisdictional reciprocity, except for the courses required under BCLE Reg. 201:2
New Mexico

Approved for CLE Credits
1.25 General

Nevada

Approved for CLE Credits
1.25 General

New York

Approved for CLE Credits
1.5 General

Our programs are CLE-eligible through New York’s Approved Jurisdiction Group “B”.
Ohio

Approved for CLE Credits
1.25 General

Oklahoma

Pending CLE Approval
1.5 General

Oregon

Pending CLE Approval
1.25 General

Pennsylvania

Approved for CLE Credits
1.25 General

Rhode Island

Pending CLE Approval
1.5 General

South Carolina

Pending CLE Approval
1.25 General

South Dakota

No MCLE Required
1.25 CLE Hour(s)

Tennessee

Approved for CLE Credits
1.25 General

Texas

Approved for CLE Credits
1.25 General

Utah

Pending CLE Approval
1.25 General

Virginia

Not Eligible
1.25 General Hours

Vermont

Approved for CLE Credits
1.25 General

Washington

Approved via Attorney Submission
1.25 Law & Legal Hours

Receive CLE credit in Washington via attorney submission.
Wisconsin

Approved for CLE Credits
1.5 General

West Virginia

Pending CLE Approval
1.5 General

Wyoming

Pending CLE Approval
1.25 General

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