Will We Ever See A New Occupational Information System?

     It may give no answers relevant to Social Security disability determination but this recent release from the Bureau of Labor Statistics is interesting. It looks like they could tell us whether there are sedentary unskilled jobs if they wanted to. Why not? Why can't we get a completely new Occupational Information System? No one is satisfied with what we have now.

     At what point is the continued use of the ancient Dictionary of Occupational Titles (DOT) litigated? The only thing restraining Social Security attorneys from litigating has been the fear of what might replace the DOT. 

A Busy Saturday For Social Security

      It was a busy Saturday for Social Security. Yes, a busy Saturday!

     First, Social Security has added significantly more data to the online reports available to attorneys representing claimants at the initial and reconsideration levels. I have not tried it yet but early reports I have heard indicate that it’s a work in progress. Still, this holds out the prospect of two advantages. It gives attorneys easier access to information on the status of their clients’ cases. It cuts down on the number of calls to Social Security asking about case status.

     Second, Social Security issued two Emergency Messages on which jobs can be considered as alternative work a claimant can perform if he or she is unable to perform their past relevant work. In the more important of the Emergency Messages there is a list of jobs that cannot be considered absent “additional evidence” from a Vocational Expert:

DOT Code	DOT Occupational Title	DOT Industry Designation
209.587-010	Addresser	clerical
249.587-018	Document Preparer, Microfilming	business services
249.587-014	Cutter-and-Paster, Press Clippings	business services
239.687-014	Tube Operator	clerical
318.687-018	Silver Wrapper	hotel and restaurant
349.667-010	Host/Hostess, Dance Hall	amusement and recreation
349.667-014	Host/Hostess, Head	amusement and recreation
379.367-010	Surveillance-System Monitor	government services
521.687-010	Almond Blancher, Hand	canning and preserving
521-687-086	Nut Sorter	canning and preserving
726.685-010	Magnetic-Tape Winder	recording
782.687-030	Puller-Through	glove and mitten
976.385-010	Microfilm Processor	business services

     In another Emergency Messages there’s this list of jobs that can no longer be considered at all:

DOT Code	DOT Occupational Title	DOT Industry Designation(s)
013.061-010	AGRICULTURAL ENGINEER	professional and kindred occupations
013.061-014	AGRICULTURAL-RESEARCH ENGINEER	professional and kindred occupations
013.061-018	DESIGN-ENGINEER, AGRICULTURAL EQUIPMENT	professional and kindred occupations
013.061-022	TEST ENGINEER, AGRICULTURAL EQUIPMENT	professional and kindred occupations
021.067-010	ASTRONOMER	professional and kindred occupations
029.067-010	GEOGRAPHER	professional and kindred occupations
029.067-014	GEOGRAPHER, PHYSICAL	professional and kindred occupations
045.061-014	PSYCHOLOGIST, ENGINEERING	professional and kindred occupations
045.107-030	PSYCHOLOGIST, INDUSTRIAL-ORGANIZATIONAL	professional and kindred occupations
052.067-014	DIRECTOR, STATE-HISTORICAL SOCIETY	professional and kindred occupations
052.067-018	GENEALOGIST	professional and kindred occupations
052.067-022	HISTORIAN	professional and kindred occupations
052.067-026	HISTORIAN, DRAMATIC ARTS	professional and kindred occupations
052.167-010	DIRECTOR, RESEARCH	motion picture; radio and television broadcasting
072.101-018	ORAL AND MAXILLOFACIAL SURGEON	medical services
072.101-034	PROSTHODONTIST	medical services
193.162-022	AIRLINE-RADIO OPERATOR, CHIEF	air transportation; business services
193.262-010	AIRLINE-RADIO OPERATOR	air transportation; business services
193.262-014	DISPATCHER	government services
193.262-022	RADIO OFFICER	water transportation
193.262-026	RADIO STATION OPERATOR	aircraft manufacturing
193.262-030	RADIOTELEGRAPH OPERATOR	telephone and telegraph
193.262-034	RADIOTELEPHONE OPERATOR	any industry
193.362-010	PHOTORADIO OPERATOR	printing and publishing; telephone and telegraph
193.362-014	RADIO-INTELLIGENCE OPERATOR	government services
193.382-010	ELECTRONIC INTELLIGENCE OPERATIONS SPECIALIST	military services
203.562-010	WIRE-TRANSFER CLERK	financial institutions
235.462-010	CENTRAL-OFFICE OPERATOR	telephone and telegraph
235.562-010	CLERK, ROUTE	telephone and telegraph
235.662-018	DIRECTORY-ASSISTANCE OPERATOR	telephone and telegraph
236.562-010	TELEGRAPHER	railroad transportation
236.562-014	TELEGRAPHER AGENT	railroad transportation
237.367-034	PAY-STATION ATTENDANT	telephone and telegraph
239.382-010	WIRE-PHOTO OPERATOR, NEWS	printing and publishing
297.667-014	MODEL	garment; retail trade; wholesale trade
299.647-010	IMPERSONATOR, CHARACTER	any industry
305.281-010	COOK	domestic service
338.371-010	EMBALMER APPRENTICE	personal service
338.371-014	EMBALMER	personal service
379.384-010	SCUBA DIVER	any industry
410.161-010	ANIMAL BREEDER	agriculture and agricultural service
410.161-014	FUR FARMER	agriculture and agricultural service
410.161-018	LIVESTOCK RANCHER	agriculture and agricultural service
410.161-022	HOG-CONFINEMENT-SYSTEM MANAGER	agriculture and agricultural service
411.161-010	CANARY BREEDER	agriculture and agricultural service
411.161-014	POULTRY BREEDER	agriculture and agricultural service
413.161-014	REPTILE FARMER	agriculture and agricultural service
452.167-010	FIRE WARDEN	forestry
452.367-010	FIRE LOOKOUT	forestry
452.367-014	FIRE RANGER	forestry
455.367-010	LOG GRADER	logging; sawmill and planing mill
455.487-010	LOG SCALER	logging; millwork, veneer, plywood, and structural wood members; paper and pulp; sawmill and planing mill
519.684-010	LADLE LINER	foundry; smelting and refining
519.684-022	STOPPER MAKER	blast furnace, steel work, and rolling and finishing mill
579.664-010	CLAY-STRUCTURE BUILDER AND SERVICER	glass manufacturing
661.281-010	LOFT WORKER	ship and boat manufacturing and repairing
661.281-018	PATTERNMAKER APPRENTICE, WOOD	foundry
661.281-022	PATTERNMAKER, WOOD	foundry
661.380-010	MODEL MAKER, WOOD	any industry
690.682-078	STITCHER, SPECIAL MACHINE	boot and shoe
690.682-082	STITCHER, STANDARD MACHINE	boot and shoe
690.685-494	STITCHER, TAPE-CONTROLLED MACHINE	boot and shoe
693.261-018	MODEL MAKER	aircraft-aerospace manufacturing
714.281-010	AIRCRAFT-PHOTOGRAPHIC-EQUIPMENT MECHANIC	photographic apparatus and materials
714.281-014	CAMERA REPAIRER	photographic apparatus and materials
714.281-018	MACHINIST, MOTION-PICTURE EQUIPMENT	motion picture; photographic apparatus and materials
714.281-022	PHOTOGRAPHIC EQUIPMENT TECHNICIAN	photographic apparatus and materials
714.281-026	PHOTOGRAPHIC-EQUIPMENT-MAINTENANCE TECHNICIAN	photographic apparatus and materials
714.281-030	SERVICE TECHNICIAN, COMPUTERIZED-PHOTOFINISHING EQUIPMENT	photofinishing
715.281-010	WATCH REPAIRER	clocks watches, and allied products
715.281-014	WATCH REPAIRER APPRENTICE	clocks, watches, and allied products
715.381-010	ASSEMBLER	clocks, watches, and allied products
715.381-014	ASSEMBLER, WATCH TRAIN	clocks, watches, and allied products
715.381-018	BANKING PIN ADJUSTER	clocks watches, and allied products
715.381-022	BARREL ASSEMBLER	clocks, watches, and allied products
715.381-026	BARREL-BRIDGE ASSEMBLER	clocks, watches, and allied products
715.381-030	BARREL-ENDSHAKE ADJUSTER	clocks, watches, and allied products
715.381-038	CHRONOMETER ASSEMBLER AND ADJUSTER	clocks, watches, and allied products
715.381-042	CHRONOMETER-BALANCE-AND-HAIRSPRING ASSEMBLER	clocks, watches, and allied products
715.381-054	HAIRSPRING ASSEMBLER	clocks, watches, and allied products
715.381-062	HAIRSPRING VIBRATOR	clocks, watches, and allied products
715.381-082	PALLET-STONE INSERTER	clocks, watches, and allied products
715.381-086	PALLET-STONE POSITIONER	clocks, watches, and allied products
715.381-094	WATCH ASSEMBLER	clocks, watches, and allied products
715.584-014	REPAIRER, AUTO CLOCKS	clocks, watches, and allied products
715.681-010	TIMING ADJUSTER	clocks, watches, and allied products
761.381-014	JIG BUILDER	wooden container
788.684-114	THREAD LASTER	boot and shoe
826.261-010	FIELD-SERVICE ENGINEER	photographic apparatus and materials
841.381-010	PAPERHANGER	construction
841.684-010	BILLPOSTER	business services
849.484-010	BOILER RELINER, PLASTIC BLOCK	foundry
850.663-010	DREDGE OPERATOR	construction; coal, metal, and nonmetal mining and quarrying
861.381-046	TERRAZZO WORKER	construction
861.381-050	TERRAZZO-WORKER APPRENTICE	construction
861.664-014	TERRAZZO FINISHER	construction
899.261-010	DIVER	any industry
899.684-010	BONDACTOR-MACHINE OPERATOR	foundry
910.362-010	TOWER OPERATOR	railroad transportation
910.363-018	YARD ENGINEER	railroad transportation
910.382-010	CAR-RETARDER OPERATOR	railroad transportation
910.583-010	LABORER, CAR BARN	railroad transportation
910.683-010	HOSTLER	railroad transportation
910.683-022	TRANSFER-TABLE OPERATOR	railroad equipment building and repairing; railroad transportation
911.663-010	MOTORBOAT OPERATOR	any industry
919.663-014	DINKEY OPERATOR	any industry
919.683-010	DOCK HAND	air transportation
919.683-026	TRACKMOBILE OPERATOR	any industry
930.683-026	ROOF BOLTER	coal, metal, and nonmetal mining and quarrying
952.362-022	POWER-REACTOR OPERATOR	utilities
960.362-010	MOTION-PICTURE PROJECTIONIST	amusement and recreation; motion picture
960.382-010	AUDIOVISUAL TECHNICIAN	any industry
961.367-010	MODEL, PHOTOGRAPHERS'	any industry
961.667-010	MODEL, ARTISTS'	any industry

     I’m not completely sure about this second list. There aren’t terrazzo finishers or artist’s models anymore? I don’t see being an artist model as a career, however. Aren’t there still embalmers these days?  None of this matters except in rare cases, however.

Why Is SSA Still Relying On Ancient Occupational Data?

     David Weaver asks why Social Security doesn't do something about its reliance upon the ancient Dictionary of Occupational Titles in making disability determinations. Everyone agrees it's unreliable. People are being approved and denied based upon data collected more than 40 years ago. Why? My guess is that all of us are afraid of what comes next if we drop the DOT.

Why Does Social Security Keep Relying Upon Ancient Occupational Data?

    Andrew Van Dam at the Washington Post has written a "Department of Data" piece on the Social Security Administration's continuing reliance upon incredibly old data in the adjudication of disability claims. He asks whether the Occupational Requirements Survey (ORS) from the Bureau of Labor Statistics could be the answer. Van Dam gives examples from the ORS but concentrates only upon the heaviest and lightest jobs in the economy and the ones that require the most and least training. That's fine but Social Security needs to concentrate upon those jobs that have both low physical AND mental demands. That's where the action is at Social Security.

Past Time For Social Security To Do Something About Its Occupational Data Problem

      David Weaver, a former Social Security official, has written a piece for The Hill urging that incoming Social Security Commissioner O’Malley do something about the agency’s reliance on occupational data that is more than 40 years old in making determinations on disability claims. 

     I can only guess at what has been going on behind the scenes. My guess is that the agency would love to rely upon contemporary occupational data, as long as it doesn’t change who gets approved and who gets denied. They’re particularly terrified of using data that leads to more claims being approved. My strong suspicion is that updated data would show that too many claims are being denied. Am I being unfair to those involved at Social Security? Maybe, but they always have the option of giving a coherent explanation for all the delay. Instead, they keep everything top secret. Who wouldn’t have dark suspicions about what’s been going on?

This Is Ridiculous

    Social Security's continued use of wildly outdated vocational information in determining disability continues to draw media attention. How much longer will the agency go on with the pretense that it's trying to develop a new source of vocational information? What's it been now, 12 years or more, that they've been working on this and they still can't get the answers they want?

Wonder Why Social Security Is Dragging Its Feet On The Occupational Information System They Say They Want?

    The table below is from the Department of Labor's Occupational Requirements Survey (ORS). This is what Social Security hopes to use as a replacement for the Dictionary of Occupational Titles (DOT). 

    

    Some things to notice here:

• Less than a third of the workforce has jobs at the sedentary level. Contrary to the instincts of many office workers, they're very much in the minority in the workforce. Count your blessings. Don't assume that the work style you enjoy is available to most people. It's not.
• What part of that 29.1% of jobs at the sedentary level is available to those with only a high school education? What about those with less than a high school education? What? You thought that everyone has a high school education? How naive. Those with lower cognitive abilities often fail to complete high school. Those with lower cognitive abilities also file a lot of Social Security disability claims. You see, if all you had to offer an employer was a strong back, you don't have much to fall back on if you lose the strength in your back. By the way, what do you think the odds are that Social Security already knows the percentage of jobs at the sedentary level performed by those with a high school level or less? Wouldn't giving Social Security an answer to that question have been a simple matter for DOL? They're already collected the data.
  
• Of that 30.2% of jobs that have no minimum educational requirement, what percent do you think would be at the sedentary or even light level? I'd guess not too many. Again, what do you think the odds are that Social Security already knows the answer to this question?
  
• Most workers are exposed to at least moderate noise. Who knew? Not many office workers would guess that.
  
• 78.7% of employees have to interact with the general public. That's one of many work demands that can be tough for those with psychiatric difficulties.

Washington Post On SSA’s Failure To Adopt New Occupational Information System

      The Washington Post has a new editorial out criticizing Social Security for failing to use the new occupational information system that has been under development for more than a decade. 

     The Post falls for the right wing argument that use of the new OIS will result in more people being denied Social Security disability benefits. The new OIS will show what sophisticated observers already know. The cognitive demands of employment have gone up significantly. This has significantly decreased the availability of unskilled work. Those unskilled sedentary jobs are gone as are many of the light ones. Without major, and quite hostile, revisions to disability determination regulations, this results in far more disability claims being approved.

Why Does SSA Keep Using The DOT?

      Lisa Rein at the Washington Post has a long piece out on Social Security’s use of the horribly outdated Dictionary of Occupational Titles (DOT) in making disability determinations. Everyone involved knows the DOT is completely unreliable. 

     Social Security has been working on a replacement for the DOT for decades. Supposedly it’s ready but they aren’t using it. Why? The only thing I can surmise is that a new occupational information system will end up affecting who gets approved and who gets denied and that’s unacceptable to Social Security. They want something “new” that’s exactly the same as the outdated data they’ve been using since 1979.

The ORS?

     I just saw that the National Association of Disability Representatives (NADR) has scheduled training on the Occupational Requirements Survey. They ask if it might be a replacement for the long outdated Dictionary of Occupational Titles (DOT) that Social Security uses. This is the first I've heard of the ORS. Anyone else have info on it?

Book Forthcoming On Labor Market And Socal Security Disability Determination

      From a notice of a book forthcoming in September:

... In Social Security Disability Law and the American Labor Market, Jon C. Dubin challenges the contemporary policies for determining disability benefits and work assessment. He posits the fundamental questions: where are the jobs for persons with significant medical and vocational challenges? And how does the administration misfire in its standards and processes for answering that question? Deploying his profound understanding of the Social Security Administration and Disability law and policy, he demystifies the system, showing us its complex inner mechanisms and flaws, its history and evolution, and how changes in the labor market have rendered some agency processes obsolete. Dubin lays out how those who advocate eviscerating program coverage and needed life support benefits in the guise of modernizing these procedures would reduce the capacity for the Social Security Administration to function properly and serve its intended beneficiaries, and argues that the disability system should instead be “mended, not ended.” 

Dubin argues that while it may seem counterintuitive, the transformation from an industrial economy to a twenty-first-century service economy in the information age, with increased automation, and resulting diminished demand for arduous physical labor, has not meaningfully reduced the relevance of, or need for, the disability benefits programs. Indeed, they have created new and different obstacles to work adjustments based on the need for other skills and capacities in the new economy—especially for the significant portion of persons with cognitive, psychiatric, neuro-psychological, or other mental impairments. Therefore, while the disability program is in dire need of empirically supported updating and measures to remedy identified deficiencies, obsolescence, inconsistencies in application, and racial, economic and other inequities, the program’s framework is sufficiently broad and enduring to remain relevant and faithful to the Act’s congressional beneficent purposes and aspirations.

Why Is Social Security Still Using The DOT?

     From WBTV in Charlotte:

A WBTV Investigation into social security shows thousands of people are denied disability claims every year because of jobs that are out-of-date.

The Social Security Administration uses a guide called the Dictionary of Occupational Titles that hasn’t been updated since 1991, even as technological advancements have made many of the jobs described in the book obsolete.

The impact that it’s had can be felt by people like Gray Hogan. ...

Hogan applied for disability. He’s been unable to work a forty-hour week for years because of the pain.

But Hogan was denied twice. When social security denies a claimant, the person can often file an appeal in court with an administrative law judge. That process has numerous steps and the last one is for social security to determine if there are any jobs a claimant could work. That’s when Hogan was told there were jobs that were suited for him. But none of them were from the 21st Century.

“Document preparer, addresser and (envelope) stuffer,” Hogan said.

“Common sense would tell you that job doesn’t exist as it’s described,” attorney George Piemonte told WBTV. ...

“Over the millions of claims that they’re reviewing, you’re still talking about hundreds of thousands of people being denied based on these nonexistent jobs,” Piemonte said. ...

My Top Eight List

     I've finally gotten around to the sort of list you've seen a lot of in the last couple of weeks -- the most important things that have happened in the Social Security world in the last decade. Below is my list but feel free to post your own list. I came up with eight and didn't want to pad it to make it ten.

1. Constant administrative under-funding of the Social Security Administration accompanied by frequent shutdown threats and occasional actual shutdowns. Agency performance suffered as a result. Service has deteriorated to levels that would have once been thought unimaginable;
2. After the number of Social Security disability claims soared in the 2000-2009 decade, the number of claims started declining in 2010. That decline is continuing. We think we know why claims soared from 2000-2009 -- primarily the aging of the baby boomer population -- but no one has a good handle on why the number of disability claims filed has gone down so much since then or why the decline continues;
3. The Eric Conn debacle which led to a general climate of hostility towards Social Security disability claimants;
4. Social Security went more than six years without a confirmed Social Security Commissioner because Republican Senators wouldn't confirm an Obama nominee and Trump was so slow in nominating anyone;
5. The ongoing story of Social Security's Disability Case Processing System (DCPS) which may or may not ever work;
6. The deal to extend the life of the Social Security Disability Insurance Trust Fund;
7. Social Security's ongoing refusal to deal with the obsolescence of the Dictionary of Occupational Titles;
8. The collapse of Binder and Binder. Yes, I know there's a stub of Binder and Binder left but it's nothing like what it was. A 60 Minutes hit piece hurt Binder and Binder but the bigger problem was that it was based upon a business model that could not succeed at a time when the number of disability claims was going down and it was becoming progressively more difficult to get a claim approved. The ironic thing was that the 60 Minutes hit piece damaged Social Security attorneys generally even though we were appalled by Binder and Binder long before the rest of the world was. At least the original owners sold out to a private equity company -- which I still find astounding -- before the bottom dropped out and have now bought back the stub.

DOT Replacement Coming Soon?

     The National Association of Disability Examiners (NADE) has posted its most recent newsletter. NADE members make determinations on disability claims for Social Security at the initial and reconsideration level. Here’s an excerpt from a write up on a talk by Gina Clemons, Social Security’s Associate Commissioner for Disability Policy:

... Gina also updated the NADE audience on work underway in the agency’s Vocational Regulations Modernization (VRM) and Occupational Information Systems (OIS) projects. These companion projects have been ongoing for several years. Key to the OIS project is an ongoing effort (since 2012) with the Bureau of Labor Statistics (BLS) to collect updated occupational information through the Occupational Requirements Survey (ORS) that we will use in adjudication. The good news here is that, after three years of testing and three years of data collection, BLS will publish a complete data set documenting requirements of work in the U.S. economy sometime this winter. BLS is committed to regularly updating occupational information moving forward on a 5-year refresh cycle and has already started collecting updated occupational data to refresh the ORS data set by 2024. BLS will document some of the basic mental demands of jobs in the 2024 ORS refreshed data.

The ORS data set will replace the Dictionary of Occupational Titles in adjudication. SSA has adopted an evidence-based, data-driven approach to modernizing the vocational regulations. The scope of the VRM project includes policy considerations in step 4 and 5 of the sequential evaluation process. Gina explained that several internal teams involving representatives from across SSA have been working on policy development for VRM.

 

A Flea On The Back Of A Buffalo

     The Supreme Court has agreed to hear Biestek v. Berryhill, a Sixth Circuit Social Security case presenting the issue:

Whether a vocational expert’s testimony can constitute substantial evidence of “other work,” 20 C.F.R. § 404.1520(a)(4)(v), available to an applicant for social security benefits on the basis of a disability, when the expert fails upon the applicant’s request to provide the underlying data on which that testimony is premised.

      What is it exactly that the Vocational Expert (VE) is supposed to reveal to me? As a general matter, VEs aren't researchers. They don't have research, either published or unpublished, that they have done that they can reveal to me. They're basing their testimony on the Dictionary of Occupational Titles (DOT) and generalized experience. One can ask questions like "Which factories did you visit to observe this job?" but I'm not sure where any answer to that question gets you.

     More important, concentrating on the issue presented in Biestek is like focusing one's attention on a flea on the back of a buffalo -- while one is being trampled by the buffalo. The enormous issue is the use of the DOT itself. The data in it is more than 40 years old! Everyone knows it's way out of date and quite unreliable yet the Social Security Administration keeps using it as a foundation for disability determination. The DOT isn't the issue presented in Biestek but it's hard to see how the Supreme Court can fail to notice it.

Some Tidbits From NADE

     The National Association of Disability Examiners (NADE), an organization of the personnel who make initial and reconsideration determinations on Social Security disability claims, has issued its most recent newsletter. Here's some tidbits from a summary of remarks made by Deborah Harkin, Senior Advisor in Social Security's Office of Disability Policy (ODP), at a NADE conference:

ODP explored many factors while updating the musculoskeletal listings to ensure the new listings adequately addressed the needs of the disability program and disability adjudicators. Among those factors were: Requirements for objective/diagnostic imaging criterion for a disorder of the spine resulting in nerve root compromise; How to assess adults who have had unsuccessful back surgeries; Adult and childhood listings for pathologic fractures; and New childhood listings for musculoskeletal developmental delays in infants from birth to age 3 ...

When complete, OIS [Occupational Information System, being developed by the Department of Labor for Social Security to replace the Dictionary of Occupational Titles] : 

• Will contain fewer than 1,000 occupations 
• Will utilize the O*NET - Standard Occupational Classification (SOC) 
• Will code occupations’ strength and skill requirements like the DOT but also include detailed information 
• For manipulative requirements, will specify whether one or two hands are needed; reaching will include above shoulder level vs. at or below; and will include alternating sit/stand 
• Will eventually include descriptors of the basic mental and cognitive work requirements. ...

     The problem with having fewer than 1,000 occupations in your OIS is that many, perhaps most, of the occupations described would actually be composites, covering disparate jobs performed in significantly different ways. Doing this makes makes the data presentation muddy. Many of the occupations will be done at the sedentary, light and medium exertional levels as well as at the skilled, semi-skilled and unskilled levels, depending upon how it's done at the exact employer. You can use such such muddy data to justify anything you want to justify. I fear that the ability to justify any desired result is exactly the point for Social Security. The agency can say that there are some jobs in a broad category that are performed at the sedentary level and that there are some jobs in that same broad category that are performed at the unskilled level without having to show that they are the same job. The "basic mental and cognitive work requirements" would be the least that is required by any employer rather than what is normally required by an employer. Instead of the horribly outdated DOT, we'd have a synthetic OIS that would give "answers" for which there would be no real world proof. Real people would be denied disability benefits based upon a "let them eat cake" OIS.

Some History To Explain Why I Don't Trust Social Security's Occupational Informational Project

Click on each page to view full size.

Just A Note To Social Security: We Haven't Forgotten

     Here's something I posted on October 26, 2015:

The National Association of Disability Examiners (NADE), an organization of personnel involved in making disability determinations for Social Security, has released its most recent newsletter, focusing on NADE's recent conference in Portland.

NADE members attending the conference heard a presentation on Social Security's effort to create a new occupational information system to replace the outdated Dictionary of Occupational Titles (DOT) used in disability determinations. There are a couple of items of interest from the write-up. The number of occupations listed will go down from the DOT's 12,000 to 1,000, which means that each job title will be even more of a composite. Composite jobs are broader and can only be described in more amorphous ways. Training on the new occupational information system is supposed to begin sometime in 2016.

     Here's a little something from the newsletter of the National Organization of Social Security Claimants Representatives (not available online) concerning the organization's conference in Washington in June 2017 where Bea Disman, Acting Chief of Staff of the Acting Commissioner of Social Security, spoke:

Disman also discussed SSA’s work with the Bureau of Labor Statistics to update the Dictionary of Occupational Titles. She indicated that they have ended the first year of a multi-year effort by the Bureau of Labor Statistics to complete an Occupational Requirements Survey SSA can use in a replacement for the DOT.

     Wait, what? In October 2015, the DOT replacement was so nearly done that it could be described, so nearly done that training was scheduled to begin shortly. However, in June 2017, the DOT replacement project had just begun with completion many years into the future. Anybody at Social Security want to explain that one?
     My assumption is that the data collected earlier didn't show what the agency wanted it to show. The unskilled sedentary jobs have disappeared and the unskilled light jobs are dramatically fewer. That's inconvenient for Social Security since that should result in many more disability claims being approved but Congressional Republicans don't want that. The result is that Social Security sits on the updated data and tries to find some way to twist the results into something that will please Congressional Republicans. I don't think I'm alone in this assumption. In fact, does anyone who understands this issue think otherwise?
     Democrats can do little about this now but if they control the House of Representatives after the 2018 election, the agency should expect pointed questions on this subject. Sitting on this for several years won't look good.

One Of The Many Changes Since The Dictionary Of Occupational Titles Was Published

     The abstract of Surveillance-system Monitors in the Work Force Kincaid Vocational and Rehabilitation Services in the Journal of Forensic Vocational Analysis:

A labor market survey was conducted to assess the responsibilities and skills of Surveillance-system Monitors as they exist in the current labor market. A tri-modal approach was taken. First, 58 job vacancy advertisements were reviewed to analyze the physical requirements of Surveillance-system Monitors as they exist in the labor market today, along with other factors that contribute to the skill-level of this position. Second, the position of Transportation Security Officer was reviewed via the job vacancy advertisement and job description video (accessed through the Transportation Security Administration website). Third, employers of Surveillance-system Monitors, and employees currently performing work as a Surveillance-system Monitor, were contacted at various establishments including colleges, hotels, and malls in the New Jersey and Texas State areas. The results indicate that the physical and cognitive requirements of Surveillance-system Monitors have changed significantly since the last major revision of the Dictionary of Occupational Titles in 1991. The essential functions of Surveillance-system Monitors now require use of others skills, longer training, higher aptitudes, and greater physical demands. The research conducted for this study returned a 0% prevalence of Surveillance - system Monitors as it is conventionally described in the Dictionary of Occupational Titles.

     So what's the status of the DOT replacement? Is this reason it keeps being delayed the fear that there won't be any unskilled, sedentary jobs left? By now could there even be any other reason? This delay may not look too good if Democrats get control of the House of Representatives after the 2018 election and start asking questions and demanding documents.

And Yet Disability Determination At Social Security Is Premised Upon Belief That Unskilled Manufacturing Jobs Are As Plentiful Today As They Were 40 Years Ago

From Brookings Instititute