Even though the estimates are that the proposal would save almost $6 billion over the next ten years, SSA has received few comments on its Notice of Proposed Rulemaking (NPRM) that would add of the age categories of the grid regulations. My own comment may be worth taking notice of, more for the 426 pages of material I attached to the comment than for the comment itself.
The grid regulations were originally based upon administrative notice taken of the numbers of unskilled sedentary, light and medium jobs found in the Third Edition of the Dictionary of Occupational Titles, which has long since been superceded by the Fourth Edition of the DOT and now by O*NET. The material which I attached shows SSA's own serious concerns that the evidence no longer shows the existence of such numbers of unskilled jobs, particularly at the sedentary level. This material has received almost no attention over the years. My point is that if the entire foundation for the grid regulations has crumbled, it makes little sense to keep adding to the ediface.
The comment period on the NPRM closes on January 3, 2006.
The grid regulations were originally based upon administrative notice taken of the numbers of unskilled sedentary, light and medium jobs found in the Third Edition of the Dictionary of Occupational Titles, which has long since been superceded by the Fourth Edition of the DOT and now by O*NET. The material which I attached shows SSA's own serious concerns that the evidence no longer shows the existence of such numbers of unskilled jobs, particularly at the sedentary level. This material has received almost no attention over the years. My point is that if the entire foundation for the grid regulations has crumbled, it makes little sense to keep adding to the ediface.
The comment period on the NPRM closes on January 3, 2006.
No comments:
Post a Comment