Dec 14, 2009

Why Doesn't SSA Want To Work With DOL?

In making disability determinations, the Social Security Administration (SSA) relies upon the Dictionary of Occupatonal Titles (DOT), both as a means of classifying a claimant's past work and as a means of determining whether alternative jobs may exist which the claimant can perform despite his or her impairments. The data upon which DOT is based dates back more than thirty years. There is universal agreement that the DOT is unreliable, but Social Security still uses it to deny disability claims. The DOT was produced by the Department of Labor (DOL). The DOL has produced a replacement for the DOT called the O*NET. Unfortunately, the O*NET as it currently exists does not mesh with Social Security's methods for determining disability.

Social Security appointed the Occupational Information Development Advisory Panel (OIDAP) to study what to do about this situation. OIDAP has recently issued its report. There is one glaring omission in the lengthy OIDAP report -- any discussion of the possibility of SSA working with DOL to create some version of O*NET that would satisfy Social Security's needs. Instead, OIDAP recommended that Social Security create its own occupational information system, that is its own equivalent of the DOT or O*NET, from scratch.

OIDAP may not feel like working with DOL, but that feeling is not mutual. The DOL recently set up a panel to review O*NET. That panel has issued its report which is available to download for free. The report devotes an entire chapter to the question of how O*NET might be made to work for disability determination. I have reproduced that entire chapter elsewhere. Here are some excerpts from that chapter (emphasis in original):
Given that occupational information is critical for use in disability determination, our panel invited Sylvia E. Karman, a representative of SSA, to make a presentation on this issue. SSA appears to think that O*NET is not able to fulfill the needs of vocational rehabilitation experts and others involved in the process of disability determination. ...

Having ruled out the use of O*NET for disability determination purposes, SSA has begun taking steps to develop its own occupational information system. In December 2008, the commissioner of social security established the Occupational Information Development Advisory Panel. ... The panel’s report, issued in September, 2009, recommends the creation of a new “Social Security Administration Occupational Information System” for use in disability determination ...

The panel understands that, pending SSA’s response to the advisory panel recommendations, the jury is still out on the topic of whether and to what extent O*NET should be changed or expanded to meet SSA’s needs. However, given public demand for budgetary restraint and efficient government, which acquire additional importance in times of economic recession and slow economic growth, duplication in government functions should be prevented. Therefore, the development of parallel, possibly redundant, occupational information systems, one for general purposes termed O*NET and the other tailored to the needs of SSA, is of concern to taxpayers. In addition, dual data collection processes would seem unnecessarily expensive.

The panel is not advocating the adoption of O*NET by SSA or the development of a hybrid O*NET-Disability system in the disability determination process. However, we conclude that a considerably modified and expanded O*NET may be capable of informing the disability determination process. There are also some potential economies of scale to be derived from the development of a single occupational information system to be used by both agencies, which may allow cost-sharing of resources in such functions as data collection and system maintenance. ...

Not all stakeholders share the opinion that O*NET cannot be amended to meet the needs of those involved in disability determination. In fact, the Committee to Review the Social Security Administration’s Disability Decision Process called for interagency collaboration (Institute of Medicine, 1998). Its 1998 report encouraged SSA to explore some interagency agreement “to initiate a version of O*NET that would collect information on minimum as well as average job requirements to better serve SSA’s needs to assess ability to engage in substantial gainful activity” (p. 24).

We found evidence suggesting that these calls for collaboration between DOL and SSA were heeded. In 2000, vocational rehabilitation professionals initiated discussions with DOL and SSA which led to the creation of the Inter-Organizational O*NET Taskforce with representatives of 16 associations of physicians, psychologists, therapists, counselors, insurers and educators (Cannelongo, 2009). The group met for 4 years and proposed development of a modified version of O*NET called O*NET –D (for Disability) that would incorporate occupational information gathered in the field by disability professionals trained in job analysis, using standardized questionnaires. A pilot study of the approach funded by DOL yielded promising results. Although SSA staff initially agreed with the plan and submitted it to the SSA administrator, the agency later withdrew its support.

At around the same time, SSA commissioned the American Institutes for Research (AIR) to examine the suitability of O*NET for the disability determination process (Gustafson and Rose, 2003). Based on an analysis of the initial O*NET database (the “occupational analyst” database), the AIR research team found that reliability, definitional, and anchoring issues could lead to problems if O*NET data were used for disability determination. At the same time, however, the authors identified specific steps for addressing these problems. For example, they suggested that a disability decision maker could use O*NET task lists and other descriptive information to help determine the activities of claimants’ current jobs and described an approach to using selected O*NET descriptors that would adjust for the positively skewed distributions of ratings of these descriptors. Gustafson and Rose (2003, p. 15) concluded that “SSA could implement into the [disability determination process] a version of O*NET that is legally defensible and acceptable to decision-makers and claimants alike.”

Another piece of evidence, suggesting the continued possibility of collaboration between DOL and SSA, is the testimony provided by former O*NET director, James Woods, to the SSA advisory panel on January 13, 2009 (Woods, 2009). In his address, he regretted that earlier efforts to accommodate the SSA needs into O*NET did not bear fruit; however, he remained hopeful that O*NET
may provide a basis to help SSA focus on a specific set of data needs and to organize data within the O*NET framework—for SSA’s specific needs. O*NET, or at least the lessons learned in developing the O*NET system, may provide a starting point rather than SSA starting from scratch.
In spite of such past interagency efforts, communication and collaboration between DOL and SSA regarding a common occupational database now appears quite limited. An inspection of their most recent communications suggests that both agencies have reached the implicit conclusion that DOL will not modify O*NET to accommodate disability determination users, and that SSA will build an entirely different occupational information system for its purposes. The fact that SSA’s newly formed advisory panel does not include a DOL liaison suggests that the development of an SSA-sponsored system may proceed relatively independent of O*NET.

[The report goes on to examine objections raised by SSA to using the O*NET and then comes to its conclusions and recommendations]
Recommendation: SSA and DOL should create an interagency task force to study the viability of potential modifications of O*NET to accommodate the needs of SSA with regard to disability determination. Before implementing these or similar modifications, however, we recommend that the task force conduct (1) an in-depth needs analysis of the occupational information required by the current disability determination process and (2) an interagency cost-benefit and
cost-sharing analysis of the additional resources that would be needed to make O*NET suitable to the disability determination process.

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