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Jan 25, 2024

What About Occupational Information? Does Scientific Integrity Apply To That?

     From today's Federal Register:

The SSA is soliciting comments and suggestions from the public on the DRAFT Scientific Integrity Policy of the Social Security Administration (DRAFT SSA Scientific Integrity Policy). The DRAFT SSA Scientific Integrity Policy codifies expectations to preserve scientific integrity throughout SSA scientific activities, establishes key roles and responsibilities for those who will lead the agency’s scientific integrity program, and, as appropriate, establishes relevant reporting and evaluation mechanisms.

    Social Security uses occupational information in determining which disability claims to approve. The source it's using now mostly dates back to 1979! Everyone concedes that it's hopelessly out of date but they're still using it. They've been working on a replacement now for well over a decade but almost nothing has been released and the agency is extremely vague on what's going on and when they'll be finished. I'm not the only one who's convinced that they keep delaying releasing anything because the data doesn't jibe with what the agency wants it to say. I think they want to keep massaging the data until it says that they don't have to change who they're approving and who they're denying even a little bit. Am I being unfair to Social Security? They can always make a full release of the data collected to date and give a good explanation for the delay. Does anyone still believe that this remains a good faith effort to collect data?

7 comments:

  1. I get that it’s tempting to feel this is conspiratorial and motivated by fear that moving to a new system will result in more payouts. Take it from an insider thought: the folks in charge of this effort are just inept, and far too disorganized and lazy to engage in the sort of goal oriented behavior you suspect.

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    1. Lazy is the biggest keyword here, followed real closely by inept. I can’t tell you how many ideas I’ve suggested to higher ups that have been shot down. I’ve had leadership above me comment how making a change would cause them to have to do more work, so they aren’t going to do that, or how it’s too much paperwork to hassle with. It’s insane how lazy a lot of SSA leadership is.

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  2. I guess conspiracy theorists come in all stripes.
    Maybe they are taking so long because they are inept.

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  3. @1:53 is correct. Good, common sense solutions often get shot down due to "regulations" or too hard. Guess who writes the regulations/policy...SSA. It's a frustrating place to work. Combine this with the fact that labor data is gathered/maintained by the Dept of Labor and you add another level of bureaucracy. It's easy to think there is a conspiracy, but the truth is sadder...inept management and inability to think outside the box. Govt mantra is often, if it's not broke, don't fix it. We all know it's broke, but SSA hasn't admitted that yet, so they don't have an urgency to fix it.

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  4. Hanlon's Razor is a reminder that not everyone is plotting against you so it's worth giving people who annoy you the benefit of the doubt. NOT MALICE, HUMANS. Hanlon's Razor states: never attribute to malice that which can be adequately explained by neglect, ignorance or incompetence.

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  5. https://www.bls.gov/ors/data.htm

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  6. SSA lost scientific integrity regarding vocational evidence when it failed to adequately address the Dept. of Labor's abandonment of the Dictionary of Occupational Titles and adoption of a new jobs classification system in the early 1990s. The biggest problem is the obsolescence of the DOT job requirements survey data that is decades old, exacerbated by the agency's reluctance to admit the problem and deal with it in current cases.

    The next biggest problem involves the various unscientific methods vocational experts are forced to employ to provide SSA adjudicators with job incidence numbers by DOT title. No government source has surveyed the economy for job numbers by DOT title in the past several decades. The private services that claim to give numbers by DOT title admit that they have not done so either, and that they don't consider job obsolescence issues. As a result, vocational experts who testify in these hearings apply a mish-mash of unscientific methods to convert job survey numbers from the modern U.S. Dept. of Labor job classification systems that the DOT did not employ, into a guesstimate of how many jobs exist for a particular DOT title. The closer you look at those methodologies and guesstimates (which vary greatly amongst different vocational experts) the more it becomes clear that the process currently lacks scientific integrity. I support greater efforts by SSA to deal with this problem. Stopgap measures are needed to stop the rot from the unreliable data that continues to taint disability claim decisions, while SSA considers a permanent solution.

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