In July 2012, we signed an interagency agreement with the Bureau of Labor Statistics (BLS) to test occupational data collection methods that could lead to the development of a new Occupational Information System (OIS). The new OIS will replace the outdated Dictionary of Occupational Titles (DOT) in our disability determination process. In fiscal year 2013, BLS will test the feasibility of using the National Compensation Survey (NCS) platform as a means to gather the occupational data we need for our OIS.
Background – The DOT and O*NET
Our disability program policy requires that we follow five steps of sequential evaluation to determine whether adult claimants qualify for disability benefits. Through step three, we make eligibility decisions essentially based on information about the severity of claimants’ medical impairments. At steps four and five, we require information about work that exists nationally in addition to information about the severity of claimants’ impairments to determine whether they qualify for benefits under our rules. At step four, we compare claimants’ functional abilities with the demands of their past work as they describe it or as workers generally perform it in the national economy. At step five, we determine whether there are other types of work in the national economy a claimant can perform.
Currently, we base these medical-vocational decisions at steps four and five on the occupational information found in the Department of Labor’s (DOL) DOT and its companion volume, the Selected Characteristics of Occupations (SCO). Although DOL did not design the DOT for our use, we adapted our disability program to it by incorporating many of its concepts and definitions into our regulations and policy. However, DOL stopped updating the DOT in 1991 and replaced it with the Occupational Information Network (O*NET), which was designed for training and career exploration. O*NET’s definitions of some occupational measures do not conform to requirements in our regulations, and we are not able to use O*NET in its current format in our disability adjudication process.
More than half of the decisions we make at the initial level and greater than 80 percent at the hearing level are medical-vocational decisions that require current occupational information about work that exists in the national economy. Thus, we face the critical challenge to develop or adapt an OIS that can replace the DOT.
Advisory Panel Established
In August of 2008, we assembled a project team to develop the OIS, and in December 2008, we established the Occupational Information Development Advisory Panel (the Panel), in accordance with the Federal Advisory Committee Act. The Panel made recommendations to us regarding OIS development and held regular public meetings. These meetings served the important purpose of allowing stakeholders external to SSA, such as disability advocates and vocational experts, to share their advice and concerns regarding our OIS development. During the first three years of OIS development, our project staff performed research to identify our specific disability program needs for an OIS. The charter for the Panel expired on July 6, 2012.
Interagency Agreement with BLS
Although the Panel recommended that we develop a new OIS tailored specifically for our disability program needs, Congress has expressed concern over the projected cost of the project, and suggested we work with DOL to develop the updated occupational information we need. In July 2012, we signed an interagency agreement with BLS to test the feasibility of using the NCS platform to collect updated occupational information. Specifically, BLS will collect:
- An indicator of "time to proficiency," defined as the amount of time required by the typical worker to learn the techniques, acquire the information, and develop the facility needed for average job performance, comparable to the Specific Vocational Preparation (SVP) used in the DOT.
- Physical Demand (PD) characteristics/factors of occupations measured in such a way to support SSA disability program needs, comparable to measures in Appendix C Physical Demands of the SCO.
- Environmental conditions that replicate as closely as possible those listed in Appendix D Environmental Conditions of the SCO, or specific revisions or additions to these factors as agreed upon by SSA and BLS.
BLS will conduct the testing in three phases. At the end of each phase, BLS will evaluate the test results and make refinements to the data collection protocols, testing design, and test processes. We expect to continue testing throughout 2013, and perhaps into 2014. Depending on issues we identify during the testing, BLS hopes to begin gathering production data in 2015.
Partnership with DOL Employment and Training Administration (ETA)
Our past research and work done by the Panel indicate that we cannot use O*NET in our disability program without significant modifications. The Panel offers a detailed discussion of our concerns with O*NET and Q&As with National Academy of Science staff on issues with O*NET, in particular discussions of the scales with incomplete anchors.
However, we think there are aspects of O*NET that we could effectively integrate in our OIS and avoid duplicating work already done by DOL. Initially BLS will test classifying occupations using O*NET’s framework. We will work with the ETA to incorporate O*NET task descriptions and lay titles, and identify other O*NET descriptors that might be useful for disability adjudication. The occupational data that BLS collects will supply the critical information we need regarding the exertional and nonexertional requirements of occupations, SVP, and environmental factors based on our current policy definitions. We hope our new OIS will incorporate the O*NET elements we determine we can use with the new occupational characteristics collected by BLS. In September, we held an introductory meeting with O*NET staff at ETA to begin a conversation about how we might use the existing O*NET data and platform. We will continue our correspondence with ETA during the coming year.
For more information regarding our work with DOL and the development of the OIS, please contact us at firstname.lastname@example.org.