One of the major bases for disability determination at Social Security is the Dictionary of Occupational Titles (DOT). There is just one little problem with the DOT. It is terribly out of date, meaning that there is a terrible flaw in disability determination at Social Security. I know, someone in an office in D.C. is reading this and thinking, "What are you talking about? Disability determination is medical. What does occupational data have to do with it?" Trust me. Occupational data is important in disability determination. To be disabled for Social Security purposes you have to be unable to do not only the work you have done in the past, but other work. How do we know whether there is other work that a person can do despite their physical or mental impairments? We look at occupational data. If that occupational data is out of date -- and not just by a little bit, but by about 20 years, the whole disability determination process is dubious.
What to do about the DOT problem? For a very long time, Social Security has looked the other way and just hoped no one would notice the problem, but people are noticing. The ground underfoot is starting to feel pretty shaky and Social Security is casting about for a solution.
I do not think this is going to come close to being a solution, but the Social Security Administration just posted this "presolicitation" notice on FedBizOpps.Gov:
What to do about the DOT problem? For a very long time, Social Security has looked the other way and just hoped no one would notice the problem, but people are noticing. The ground underfoot is starting to feel pretty shaky and Social Security is casting about for a solution.
I do not think this is going to come close to being a solution, but the Social Security Administration just posted this "presolicitation" notice on FedBizOpps.Gov:
The Social Security Administration (SSA) has a need to acquire occupational information based on the Department of Labor’s Dictionary of Occupational Titles (DOT), 4th edition. This DOT-based information will be evaluated in order to determine whether the data can be used in SSA’s disability evaluation process in terms of current SSA disability guidelines. ... SSA anticipates awarding one or more firm-fixed price type contract(s) for this effort. The period of performance is anticipated to be for nine months in duration. The solicitation will be issued as a small business set-aside. It is anticipated that the Request for Quote (RFQ) will be issued on or about June 23, 2008. The selection decision will be on a low-priced, technically acceptable basis. ...
4 comments:
what do do about vocational occupational info? this may not be as glib as it sounds. Get rid of the need for it. You will run into the exact same problem 20 years from now if all you do is update a data base that looks like dot
or not, people need to eat, someone should make some money off dot updates i guess
DDS's deny claims using the outdated dot info. There are job titles used that no longer exist "in substantial numbers in the national economy". Jobs are used that in the current day are part-time minimum wage, under SGA where they exist, but used to be valid occupations 30 years ago. This update is liable to create as many potential new approvals as not. There are job titles used that I have never encountered in 30 plus years at SSA. This is a reason that so many claims are reversed on appeal--the ALJ's basically ignore the dot info and rely either on their own judgment or on so-called vocational experts in viewing a person's capabilities in relation to their medical conditions.
Good catch! It will be interesting to see what Social Security does to fix the DOT problem, because the problem has become huge. As reliance of the listings has gone down (the listings are only used in about 50% of granted claims), reliance on the DOT has gone up. So the problem has been growing larger over recent years, and is apparently now too large to ignore.
Thank you for the update. I am seeing more and more claims decided at steps 4 and 5 of the sequential evaluation process. I am also seeing vocational testimony at more and more hearings. A change in the DOT underpinnings of this vocational evidence would be remarkable.
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