IARP Recommends Updating DOT

The International Association of Rehabilitation Professionals (IARP) publishes a professional journal called "The Rehabilitation Professional." A recent issue of this journal contains an article written by a committee established by IARP to study replacements for the Dictionary of Occupational Titles (DOT), a fundamental basis for disability determination at Social Security. The title gives away the findings of the committee: "A Call to Update the DOT: Findings of the IARP Occupational Database Committee."

The study details the unreliability of the DOT at the time it was originally published as well as the far more serious problems with using the terribly outdated DOT today. Products already on the market which purport to be replacements for the DOT are discussed, but in the end the committee recommends updating the DOT.

The idea of updating the DOT gives Social Security a bunch of headaches. Here are some of them:

• The DOT was far from perfect even at the time the last edition was published. It will take quite some time to figure out exactly how to update the DOT so it will be better.
  
• Gathering and compiling the data to update the DOT will take years.
• Gathering and compiling the data to update the DOT will cost a lot of money.
• Social Security does not have the money or expertise needed to update the DOT. It is far from clear that the Department of Labor (DOL), which should update the DOT, has any interest in doing so or that DOL can get the money to do so or will have any urgency about the task if it tries to do so.
  
• No one knows what a new DOT will show. The current grid regulations may have to be scrapped or dramatically changed based upon a new DOT.
  

Social Security really should have started taking this problem seriously a long time ago -- like ten years ago -- but the agency chose to put off difficult decisions. Delaying action for the next decade or so is unrealistic. It is amazing that there has not been litigation on this issue already. I might have litigated it myself if I were not in the 4th Circuit.

Other than staffing shortages, the DOT is, by far, the biggest problem facing the Social Security Administration. The staffing problems affecting Social Security are much simpler to solve, however. All that is required is money and time. Congress and the Office of Management and Budget are already well aware of the staffing problem and trying to help. The DOT problem is far more complex. It is probably already too late for a good solution to the DOT problem.