Replacing The DOT -- Delay Order From Martin Gerry

As boring as this may seem, it is a big honking deal.

Social Security relies heavily upon the Dictionary of Occupational Titles (DOT) in making disability determinations. The DOT lists something like 12,000 different occupations in the national economy. Social Security uses the DOT in classifying the work formerly performed by a claimant and, more importantly, in coming up with alternative job possibilities for a claimant who can no longer perform his or her past relevant work. Disability claims are approved and denied based upon the DOT.

The problem is that the DOT is seriously out of date -- like 30 years or more out of date. It largely predates personal computers. No one familiar with the situation denies the obvious, that the DOT is seriously unreliable. Social Security is skating on thin ice in making disability determinations based upon the DOT and has known it for years.

The Department of Labor has replaced the DOT with something called the O*NET, but Social Security cannot use the O*NET. The information in the O*NET does not come close to meshing with Social Security's regulations. It may be hard to believe if you are unfamiliar with the DOT, the O*NET and Social Security's regulations, but there is no way to bridge the gap. So what does Social Security do? They were looking at doing their own version of an update to the DOT, but read this from The Work Suite, by John Reeves:

Although no longer listed at the International Association of Rehabilitation Professionals’ web site, http://www.rehabpro.org, it was previously reported that:

"SSA [Social Security Administration] and DOL [Deparment of Labor] have been working, both independently and together, to prepare for the transition from DOT to an updated occupationally specific data. Both agencies are preparing a joint white paper that outlines recent and planned SSA and DOL efforts to support SSA’s development of the type of data required for disability programs and vocational rehabilitation services. This document will serve as a basis for executive-level agency discussions, leading to more formal collaborative arrangements, such as an interagency workgroup established under a Memorandum of Understanding. To address the changes anticipated by the eventual obsolescence of the DOT, SSA needs to work with DOL on strategies for SSA’s development of additional occupational data while simultaneously investigating options for updating its medical-vocational policies as well."

According to one participant in the Interorganizational O*NET Task Force [IOTF], IOTF has done nothing further for the past several years. Martin Gerry (Deputy Commissioner for Disability) apparently put a hold on the DOT update that the policy people wanted, and had an RFP [Request for Proposal, a prelude to signing a contract with a vendor] ready for. [emphasis added] There is now a new Commissioner, Michael Astrue. Not surprisingly, SSA apparently has no discretionary dollars because of war in Iraq, so the need for an occupational database might be a unaddressed until after the next presidential election.