The "Content Model"

This morning's e-mail included a message from Nancy Shor, Executive Director of the National Organization of Social Security Claimants Representatives (NOSSCR), sent to all NOSSCR members. The e-mail concerned Nancy's other duties as a member of Social Security's Occupational Information Development Advisory Panel (OIDAP). Attached to Nancy's e-mail was a message to NOSSCR members from Dr. Mary Barros-Bailey, the Interim Chair of OIDAP, to which was attached a document titled "What is a Content Model?" I have e-mailed the panel asking that they post the entire lengthy document.

It is obvious from what I received that the Social Security Administration and OIDAP are interested in going ahead with essentially recreating the Dictionary of Occupational Titles (DOT), although in a format that would be more usable to Social Security than the DOT ever was. This would be a very expensive and time-consuming effort.

Let me make some very preliminary observations.

1. Even though the DOT was based upon many tens of thousands of job site observations, it is now widely accepted that the data in the DOT was far from authoritative even at the time it was published. Many jobs had only been viewed one time and data collection methods were inconsistent. Will Social Security be able to do better? People will be watching much more closely now than they were at the time the DOT was created.
   
2. Creating a DOT replacement will be an expensive endeavor. Does Social Security have Congressional and Office of Management and Budget (OMB) backing for this endeavor?
3. Will a DOT replacement created at the behest of Social Security have the credibility it will need? Nancy Shor's e-mail talked of possible Daubert challenges to whatever comes out of this. There is that problem, but a more direct problem is the Data Quality Act.
   
4. If this DOT replacment is to be done, would it not be better to have it done by the Deparment of Labor rather than Social Security?
5. The DOT replacment envisoned by the "Content Model" would include a good deal of information never previously gathered. How practical will it be to even gather this data? The "Content Model" may require collection of data about the mental demands of employment. Is it possible to define whether a job is "high stress" or "low stress" for instance?
   
6. OIDAP and Social Security are interested in gatering data on the extent to which jobs may be restructed to accommodate workers' impairments. Social Security's position to this point has been that Americans with Disabilities Act (ADA) accommodations to workers' impairments may not be considered in determining disability. There are many in the rehabilitation community who regard "disability" as essentially non-existent, that with sufficient accommodation anyone not in a coma can work and that it is the duty of society to provide whatever level of accommodation is required. I find this absurd and dangerous, not just for disabled Americans, but for the American economy. Basing disability determination on a theoretical level of accommodation that can never be achieved in the real world would have a devastating effect upon millions of Americans. In the real world the ADA is virtually a dead letter. The Courts have interpreted it almost out of existence. There have been recent legislative efforts to give the ADA more substance, but it is far from clear that these efforts will succeed. It will never achieve the goal of allowing any person to work regardless of the extent of their impairments. In my view any discussion at OIDAP about accommodation is cause for great alarm.