Can You Spot A Theme?

     From the final report of Social Security's Occupational Information Development Advisory Panel (OIDAP) (bolding in the original):

Central to OIDAP’s role as a Federal Advisory Committee Act (FACA) Panel, is transparency in its process. ...

To date, transparency in the process of developing occupational data for SSA’s disability programs has been achieved primarily through the OIDAP. SSA’s decision to discontinue the OIDAP beyond its 6 July 2012 charter, presents the additional challenge of maintaining transparency with this project in the future. ...

The OIDAP held its last public teleconference on 4 June 2012 and strongly advised SSA to maintain all development of occupational data for disability programs in a transparent and public arena, and to adhere to scientific standards and scrutiny. ...

At the OIDAP meeting on 4 June 2012, the Panel unanimously developed General Recommendation #9 about the transparency and scientific activities for future efforts ...

The OIDAP has not been consulted or involved in efforts for the future direction of occupational data development beyond the public meeting on 4 June 2012. ...

The OIDAP brought transparency to SSA’s occupational information development process that impacts the lives of millions of Americans. We believe SSA must continue this transparency as it develops any occupational information that will affect decision-making in the disability programs. ...

Failure to fully ensure the scientific veracity of the occupational taxonomy, data collection instrument, sampling strategy, and sources of data or data collection methods, will make SSA vulnerable to legitimate litigation. ...

Further, SSA should consider external oversight, including establishing an oversight body involving technical experts and users, as part of future efforts and initiatives for occupational information development.

     And I didn't think that OIDAP itself was anywhere near transparent enough itself! Anyone still think I'm paranoid about what Social Security is up to with its occupational information system project?
     By the way, OIDAP sent this report out as an e-mail attachment to those on its mailing list. I've uploaded it to Scribd. Will Social Security post this final report online?

OIDAP To End

      From an e-mail sent out by Mary Barros-Bailey, Chair of Social Security's Occupational Information Development Advisory Panel (OIDAP), which has been working on creating a successor to the Dictionary of Occupational Titles (DOT):

After over three years serving as the Chair to the Occupational Information Development Advisory Panel (OIDAP), this will be my last Message from the Chair.  On 21 May 2012, the Social Security Administration (SSA) decided that because of fiscal issues associated with the current Federal financial crisis, they would not extend the OIDAP charter beyond its expiration in July.  We are the last Federal Advisory Committee Act (FACA) panel at SSA at this time.

     Occupational information is crucial in disability determination under the Social Security Act. Social Security's effort to create a new occupational information system is going forward full speed ahead. The only thing that is happening is that Social Security is dropping the pretense that there is anything independent about this. Abolishing OIDAP will make it even more difficult for the occupational information system it develops to be seen as credible by the courts, Congress and the public. It's hard for me to imagine Social Security submitting its occupational information system to independent review.

DOT Replacement Not Available In Full Until 2016

     One important question about Social Security's effort to develop a replacement for the Dictionary of Occupational Titles is when the work will be completed. Here is something of an answer. This is from the transcript of the July 27, 2011 teleconference meeting of Social Security's Occupational Information Development Advisory Panel (pages 29-30)

This is Andy Wakshul [Panel Member]. I have a question. As I look at the Plan I was impressed certainly with the breadth and the scope of it, and how detailed it was. But I notice that the timeline extends out pretty far, five years at the bottom of the chart, and that's only for data collection. Do you have an idea when this will be an instrument that adjudicators will be able to use in making disability determination? It's got to be after 2016.

MS. KARMAN [Director]: This is Sylvia. We anticipate that through a program evaluation and any information that we have collected through 2016 if, in fact, we are targeting, for example, occupations that are frequently presented to us in claimant's vocational work histories, there may be the possibility that the Agency would be in a position to begin using that  information for those areas of work.

Preaching It However You Want

     Social Security's effort to create an Occupational Information System (OIS) to replace the Dictionary of Occupational Titles (DOT) is the most important policy development at the agency in more than thirty years. Recent activities at the agency's Occupational Information Development Advisory Panel (OIDAP), which is tasked with creating the OIS, remind me of the story of a young preacher, badly in need of a job, who is sitting before a church board. A member of the board asks, "How do you feel about same sex marriage?" The young preacher immediately replies, "Just tell me how you feel. I can preach it either way." OIDAP wants to make sure they are creating the OIS in such a way that it will say whatever Social Security management at any given time wants it to say -- and remember that the term of Social Security Commissioner Michael Astrue expires in January 2013. OIDAP wants to please not just the current Commissioner but his successor as well. No one knows how that person will want it preached so OIDAP is building in the capacity to preach it any way the new Commissioner wants it preached.
     Recently I asked what I think are the key questions about Social Security's OIS plans:

• Let us suppose that you collect data on a job, such as office assistant, and this data shows it to have been performed at the sedentary level at 20% of employers, at the light level at 70% of employers and at the medium level at 10% of employers. How would this job be categorized in the occupational information system you are developing -- as sedentary, as light or as medium -- or would it be categorized as all three -- or would it be broken down into three new job titles of Office Assistant I, II and III? A similar question could also be asked about the length of time it takes to learn the job of office assistant or many other criteria.
• When will the decision be made on how to categorize jobs? Before or after the data is collected?

     OIDAP has released its Occupational Information System Fiscal Year 2011 Research And Development Plan which gives us a good idea of how these questions will be answered. I have uploaded this using Scribd, a helpful service that allows anyone to get documents on the public record for free. This is a roadmap for Social Security's OIS development. It definitely answers the last question I asked above and sets forth the process for how the rest of the questions will be answered, although everything is expressed in OIDAP's typically opaque prose.
     One early stage in the development of the OIS to is create a prototype data analysis plan. The plan identifies the following as a "key question": "What are SSA's analytic objectives (e.g., aggregation of position-level data to job-and occupation-level categories and calculation of occupational prevalence) How do they align with SSA OIS requirements." page 36. Exactly. They are not asking the abstract question of how this data should be classified but how does Social Security want the data classified so that it meets the agency's "requirements." They are going to be making the decision about whether the hypothetical job I was asking about will be aggregated simply as Office Assistant or broken down as three separate jobs of Office Assistant I, II and III or how the information about this job or jobs is presented based upon what the Social Security Administration wants. But you may object that the language I quoted above only shows that OIDAP is legitimately concerned with Social Security's needs and isn't really going to tailor the OIS to what Social Security management wants at any given time. Read on.

     The next stage is to conduct a pilot using the prototype. Here the report identifies a key question as being "What can SSA learn for OIS design from the occupational information collected as part of the data collection analysis pilot? (For example, does the information help SSA determine what level of within-title heterogeneity is acceptable given the agency's program needs.)" page 37. That term "within-title heterogeneity" tends to throw one, doesn't it? The titles they are talking about are job titles and by heterogeneity they mean how wide or narrow to make the job titles. Again, do we just have the job title of Office Assistant or do we divide it into Office Assistant I, II and III. They say explicitly that this decision will be made based upon "the agency's program needs" after data collection has started Again, the decision is not being made on the basis of any science or the basis of any independent judgment but on the basis of what Social Security wants. Are you starting to get the picture?

     Next we go to a national pilot and again there is the same key question about "within-title heterogeneity." pages 39 and 41.

   Beyond that, OIDAP must formalize an "occupational title taxonomy" and again the same key question of "heterogeneity" pops up. page 43.

    At the next step, OIDAP intends to evaluate what will happen when the OIS is implemented in the real world by comparing results using the OIS with results using the DOT "to assess relative utility of new OIS data and potential operational and programmatic gaps." page 44. They want to make sure that Social Security is achieving whatever goal it has in approving and denying claimants. Of course, as part of that they will again address that pesky issue of "within-title heterogeneity." page 48.

     If you read the whole thing, it is clear that this plan explicitly allows Social Security management to control the process each step of the way to achieve whatever goals that agency management has at any given point. OIDAP is ready to "preach" it however Social Security management wants it preached.

     Science is being employed here, to be sure, but science will not determine the results. The results will be determined by the agency's policy desires. That is the whole point. Social Security management doesn't want to spend hundreds of millions of dollars to produce an OIS that it cannot stand and the Social Security employees working on the OIS don't want to worry that they will be fired by a new Commissioner because they were unable to predict what that future Commissioner would want. What we have here, to quote Dilbert, is "the way of the weasel."

A Message From The Chair

 An e-mail I received recently:

A MESSAGE FROM THE CHAIR

On June 13, the Social Security Administration (SSA) posted a position for a lead scientist for the Office of Vocational Resources Development to provide technical guidance for the development of the occupational information system to replace the Dictionary of Occupational Titles in SSA's disability programs.  The OIDAP strongly supports SSA's effort in recruiting for this position.  Please disseminate the link below for the position to all parties who may be interested in applying.

http://jobview.usajobs.gov/GetJob.aspx?JobID=100109783&JobTitle=Senior+Research+Psychologist&q=Senior+Research+Psychologist&where=&brd=3876&vw=b&FedEmp=N&FedPub=Y&x=38&y=5&AVSDM=2011-06-13+00%3a03%3a00

Mary Barros-Bailey, Ph.D

Chair

Occupational Information Development Advisory Panel

OIDAP Documents Released -- What's The Plan?

The Occupational Information Development Advisory Panel (OIDAP), Social Security's effort to develop an alternative to the antiquated Dictionary of Occupational Titles (DOT), a key element in disability determination, has released some documents from its May 4, 2011 public meeting. 

Many of the speakers the Panel heard were from the Department of Labor, which had prepared the DOT and its successor, the O*NET, and from the Department of the Census, which has its own very limited occupational information system. Maybe these presentations helped the Panel. My possibly jaundiced view is that this was nothing more than window dressing to give an appearance that whatever the Panel produces reflects a scientific consensus.My view may also be influenced by the fact that many of the presentations were in Powerpoint. I agree with those who blame Powerpoint "for everything from corporate [and governmental] stupidification to burying Western civilization in a hailstorm of bullet points."

The more important presentations were from the Panel Chair, Mary Barros-Bailey, and Social Security's Director of Occupational Information System development, Sylvia Karman. What has been posted is not complete enough to give one a clear idea of the plans of Barros-Bailey and Karman but it is clear that Social Security is charging ahead with a major endeavor.

I wish I could get answers to two questions from Barros-Bailey and Karman:

• Let us suppose that you collect data on a job, such as office assistant, and this data shows that it to have been performed at the sedentary level at 20% of employers, at the light level at 70% of employers and at the medium level at 10% of employers. How would this job be categorized in the occupational information system you are developing -- as sedentary, as light or as medium -- or would it be categorized as all three -- or would it would be broken down into three new job titles of Office Assistant I, II and III? A similar question could also be asked about the length of time it takes to learn the job of office assistant or many other criteria.
• When will the decision be made on how to categorize jobs? Before or after the data is collected?

You might think that categorizing a job at all levels at which it is performed would be more accurate, and in a sense it is, but it also produces such muddy results that this approach has always been rejected in the past when occupational information systems were compiled. An occupational information system that does not try to categorize jobs by how they are typically performed could be used to justify denying virtually any disability claim. All you would have to do is to find a few people performing a job at the same limited level as the claimant and you have justification for denial. This is a big country. There are millions of employers. There are many ways that most job can be performed. Employers often regard employees as their friends. Employers make many concessions to the circumstances of individual valued employees, especially those they regard as their friends, concessions that are not available to the general public. Go down this route and vocational information becomes almost irrelevant since you would always be able to find work that a claimant could perform no matter what his or her limitations might be.

I think my concern with OIDAP's work is best summarized with a sports quote whose origins are probably apocryphal : "The problem with referees is that they just don't care which side wins." I would like OIDAP to be that referee who does not care which side wins but I am pretty sure that they do.

OIDAP Meeting

Social Security's Occupational Information Development Advisory Panel (OIDAP) is holding a meeting today and tomorrow. On the schedule today and tomorrow are several speakers from the Department of Labor and the U.S. Census who will be describing how they have gone about collecting occupational information. The first day will end with this presentation:

Occupational/Medical/Vocational—Initial Claims Review Final Results
Deborah Harkin, Social Insurance Specialist
Office of Vocational Resources Development

Mark Trapani, Social Science Research Analyst
Office of Vocational Resources Development

I wonder what that is.

You can read the entire "public" agenda below.

OIDAP Public Agenda--May 2011

Huh?

From a presolicitation notice posted by Social Security:

The Social Security Administration (SSA) has a need to acquire consulting services in the field of Industrial Organizational (I/O) psychology or an equivalent field in support of the design of an Occupational Information System (OIS).

Can anyone explain this one?

Will OIDAP Be Scientific?

The Chairman of Social Security's Occupational Information Development Advisory Committee (OIDAP) has posted an interesting statement on OIDAP's website suggesting that Social Security and OIDAP may be starting to get the message that not everyone trusts them. Here is a brief excerpt:

The OIS [Occupational Information System] project faces a variety of misconceptions that could inhibit its rapid development. Foremost, the OIS’s development is scientific. Because the elements of its development are not tangibly put into test tubes, this premise is often missed or minimized by stakeholders. The OIDAP’s advice and recommendations to SSA for the development of the OIS hinge upon the importance of good science, the scientific process, and scientific integrity as cornerstones.

So the response to the criticism of OIDAP is to claim to be scientists seeking neutral facts.

Give me a break.

No matter how wonderfully scientific the data collection is, there is every sign that OIDAP and Social Security are determined to make decisions before, during and after data collection to assure that the scientific data is presented in such as way as to conform to Social Security's desires to support current policies. Stuffing the data collected into categories such as "Sedentary", "Light" and "Medium" is an inherently imprecise business that requires many judgment calls. The agency seems to want to be certain that there is no one like the Department of Labor who can say "Stop" when it makes judgment call after judgment call in one direction. This has happened before even with the Department of Labor involved. See above. Nothing whatsoever that OIDAP has done would give the least bit of assurance that they have any other plan.

OIDAP's critics are convinced that the U.S. labor market has changed dramatically and that these changes seriously undercut current Social Security policies. The cognitive demands of work have gone up and there are far fewer manufacturing jobs. This should lead to changes in Social Security disability determination such that more claims would be approved but OIDAP's critics believe that Social Security and OIDAP are determined to prevent such changes and may even want to manipulate the data to support denying more claims.

There have been many signs that OIDAP members have been looking way outside their charter to find ways that Social Security can deny more claims.

OIDAP Charter Renewed

Not that it comes as any surprise but Social Security has renewed the charter for the Occupational Information Development Advisory Panel (OIDAP).

Commissioner On Phasing In DOT Replacement And Possible Automatic Approvals For 100% Disabled Vets

The National Association of Disability Examiners (NADE), an organization of personnel who make initial and reconsideration determinations on Social Security disability claims, has issued its Fall 2010 newsletter. Here is an excerpt from an article on Commissioner Michael Astrue's speech to a NADE conference in September:

Perhaps the one single issue facing the disability claims process that must be addressed is the need for SSA to replace the outdated Dictionary of Occupational Titles (DOT). Even at the mention of the DOT, the Commissioner was greeted with laughter from the audience. These NADE members were well acquainted with the DOT and its increasing prominence as an antique book. ... SSA has taken some major heat for accepting responsibility to update this volume of work that previously was the responsibility of the Department of Labor. ... Although it is a multi—year project to complete the new OIS [Occupational Information System], the Agency does not plan to wait until the end to roll out the new OIS but plans to phase in portions of the new OIS. ...

There has been some expression of thought among Members of Congress that there should be increased sharing of information between the Veterans Administration and the Social Security Administration, even to the point that veterans qualifying for disability benefits under the VA should automatically become entitled to SSA disability benefits. Although the two agencies have very different definitions of disability, the Commissioner reported there had been some initial communication between the two agencies as to how they could achieve such a goal. SSA is looking into the possibility of granting disability benefits to veterans qualifying for 100% disability from the VA and additional talks on this subject would continue.

OIDAP Asks For Comments

Social Security's Occupational Information Development Advisory Panel (OIDAP) has posted a notice in the Federal Register requesting comments on its plan for Social Security to develop its own new occupational information system.

Resignation From OIDAP

Professor Mark Wilson has resigned from the Occupational Information Development Advisory Panel (OIDAP). Click twice on the thumbnail to read his letter of resignation. Note that he says that "I no longer feel that the management of this project can bring about the occupational information system that the agency and the country needs and that the panel envisioned."

From The NOSSCR Conference -- III

Nancy Shor, the long time executive director of the National Organization of Social Security Claimants Representatives (NOSSCR) spoke at the organization's conference in Chicago yesterday. Here are a few points from what she had to say:

• She understands that the proposed regulations that would recognize law firms and other entities as representing Social Security claimants are now dead. She does not understand why.
• Ms. Shor has resigned from the Occupational Information Development Advisory Panels (OIDAP). She felt that she had to after NOSSCR adopted a position statement opposing Social Security going ahead with its own occupational information system, something that OIDAP wants to do.
• She expects a new report from OIDAP by the end of the year.
  

From The NOSSCR Conference -- II

It would be impractical for me to summarize everything said at the Wednesday general session of the National Organization of Social Security Claimants Representatives conference in Chicago. I will stick to that which regular readers of this blog might find newsworthy.

Catherine Olson, the staff director of the House Social Security Subcommittee spoke. Congressional staffers are not supposed to make news and Ms. Olson did as she was supposed to do in giving those present an update on Social Security and Congress. She expressed concern about Social Security's Occupational Information Development Advisory Panel (OIDAP). She thought, or perhaps hoped, that Social Security was reaching out to the Department of Labor (DOL). I hope she is correct. My guess is that any outreach to DOL will disappear if Republicans take control of the House of Representatives. As I have stated before, OIDAP's work is, by far, the most important policy issue that the Social Security Administration has dealt with in more than 30 years.

Judge David Hamilton of the U.S. Court of Appeals for the 7th Circuit also spoke. Federal judges are also supposed to avoid making newsworthy speeches. Judge Hamilton managed to give an interesting, engaging speech without making news. He did give an answer to a question that lawyers who do Social Security work in the federal courts -- but no one else -- will find interesting. He was asked whether it is a good idea in drafting a brief to keep the statement of the facts and the legal arguments completely separate or whether an attorney should have a somewhat brief statement of the facts and then supplement those facts in the argument section of the brief. Judge Hamilton prefers the latter course, of mixing in detailed facts with the legal argument. This must sound extremely unimportant to most people reading this blog but I assure readers that it is a crucial question for anyone drafting a Social Security appellate brief. It is an excellent example of the sort of decisions that attorneys have to make every day. This one is a particularly tough call for an attorney. As boring as it sounds, it can be the difference between winning and losing a client's case. One problem with what Judge Hamilton rlecommended is that he expressed his preference but that is not necessarily the preference of every other appellate judge. Another problem, as Judge Hamilton mentioned, is that what he suggests does not precisely comply with the Federal Rules of Appellate Procedure. Attorneys have to worry how far they can bend these rules before they offend an appellate judge. Aren't you glad that you're not a practicing attorney?

OIDAP Agenda

Social Security's Occupational Information Development Advisory Panel (OIDAP) is holding a meeting in Boston next week. Below is the "Public Agenda" for the meeting.

A couple of reports are mentioned in the agenda. I hope these reports will be released to the public in the near future but I fear they will not. Rapid dissemination of information that OIDAP receives or develops is essential for the panel's credibility but that is not the way OIDAP has operated. They seem to have a conspiratorial bent. I would be suspicious of OIDAP under any circumstances. The way they have operated has made me very suspicious.

WEDNESDAY—September 1, 2010

8:30 a.m. to 8:45 a.m. Call to Order

Overview of Today’s Agenda

v Terrace, Lower Level

Mary Barros-Bailey, Ph.D., Chair

Opening Statement

Richard Balkus, Associate Commissioner

Office of Program Development and Research

Social Security Administration

8:45 a.m. to 9:00 a.m. Occupational Information Development Project Report

Sylvia E. Karman, Director, OID Project & OIDAP Member

9:00 a.m. to 9:30 a.m. Evaluation of 2008 Occupations Held by SSDI and SSI Disability Claimants

Renee Ferguson, Statistician

Office of Program Research

Office of Program Development and Research

9:30 a.m. to 10:15 a.m. Briefing on the Occupational/Medical-Vocational Study

Deborah Harkin, Social Insurance Specialist

Social Security Administration

10:15 a.m. to 10:30 a.m. BREAK

10:30 a.m. to 11:45 a.m. Status on the Development of the OIS—Content Model

Shirleen Roth, Social Insurance Specialist

Social Security Administration

11:45 a.m. to 1:00 p.m. LUNCH ON YOU OWN

WEDNESDAY—September 1, 2010 (continued)

1:00 p.m. to 1:15 p.m. OIDAP Comment Process

Mary Barros-Bailey, Ph.D., Chair

v Terrace, Lower Level

1:15 p.m. to 2:00 p.m. Public Comment

2:00 p.m. to 3:00 p.m. Update on User Needs Report on Comments on the OIDAP Recommendations

Shanan Gwaltney Gibson, Ph.D., Member, User Needs & Relations Subcommittee

3:00 p.m. to 3:15 p.m. BREAK

3:15 p.m. to 3:45 p.m. Subcommittee Report—Research Subcommittee

Mark Wilson, Ph.D., Subcommittee Chair

3:45 p.m. to 5:00 p.m. Panel Discussion and Deliberation

Mary Barros-Bailey, Ph.D., Chair

5:00 p.m. ADJOURN

THURSDAY —September 2, 2010

8:30 a.m. to 8:45 a.m. Call to Order

Overview of Today’s Agenda

v Terrace, Lower Level

Mary Barros-Bailey, Ph.D., Chair

8:45 a.m. to 9:15 a.m. Subcommittee Report—User Needs

Robert Fraser, Ph.D., Member, User Needs & Relations Subcommittee

9:15 a.m. to 9:45 a.m. Status: Job Analysts Ad Hoc Group

Deborah Lechner, Ad Hoc Chair

9:45 a.m. to 10:00 a.m. BREAK

10:00 a.m. to 10:30 a.m. Public Comment

10:30 a.m. to 11:00 a.m. Administrative Meeting

Mary Barros-Bailey, Ph.D., Chair

11:00 a.m. ADJOURN

Movivg Ahead On Occupational Information System

From a notice posted on FedBizOpps.gov:

The Social Security Administration (SSA) has a need to acquire expert services in the field of Industrial Organizational (I/O) psychology or an equivalent field to develop a prototype work-side instrument for the purpose of conducting analyses of work that exists in the national economy. ... The size standard is $7M. This procurement is a 100% small business set aside. SSA anticipates awarding one (1) firm fixed price contract for this effort. The period of performance shall be for 6 months from date of award. It is anticipated that the Request for Quotation (RFQ) will be issued on or about July 7, 2010.

This is the sort of thing that makes it obvious that Social Security plans to go ahead with its own occupational information system. The advisory committee and the request for public comments are little more than window dressing.

Does OIDAP Regard Public Comments As A Meaningless Formality?

It must be a tense time for those who are heavily invested in Social Security developing its own occupational information system for disability determination.

Social Security has its own Occupational Information Development Advisory Panel (OIDAP) working on developing a new occupational information system just for Social Security. However, a National Academy of Science report recommended that Social Security attempt to work with the Department of Labor (DOL) on adapting the O*NET occupational information system to its needs instead of striking off on its own.

Recently, OIDAP gave the public an opportunity to comment on its plans for an occupational information system. That period expired yesterday. However, on June 28, two days before the public comment period ended, OIDAP completed its own review of the National Academy report. No surprise in OIDAP's conclusion: Social Security should press ahead in developing its own occupational information system. David Traver has obtained the review and posted it on SSA CONNECT.

I am pretty sure that OIDAP is not an official Federal Advisory Committee. Even if it were, I do not think that it would be required to give the public an official comment period. As far as I know, there is no legal remedy for OIDAP acting on its own review of the National Academy report -- which is the absolutely critical issue for OIDAP -- before the end of the comment period.

I am tempted to speculate on what is behind OIDAP's odd timing but will not. What I will say is that if it will take many years, lots of money and the support of more than one Commissioner of Social Security for OIDAP to create its own occupational information system. Opponents will have many opportunities to derail the OIDAP train. Treating public comments as a meaningless formality just stiffens the opposition to OIDAP.

OIDAP And The Department Of Labor

I received an e-mail today from the Occupational Information Development Advisory Panel (OIDAP) with an attached copy of the transcript of the Panel's March 25, 2010 meeting. I have no idea how many other people were sent this transcript. There was no explanation of why it was sent to me.

At this meeting, the Panel received the report of the National Academy of Sciences (NAS) that recommended that Social Security work with the Department of Labor on adapting O*NET for Social Security's occupational information purposes instead of Social Security creating its own occupational information system from scratch. I would speculate that this transcript was sent to me to demonstrate that OIDAP considered the NAS report and found good reason to reject it.

I have uploaded the transcript via Yousendit. The first 100 people who wish to do so can download the transcript.

I have not been able to study the transcript in depth but it is clear that the Panel's chair, Mary Barros-Bailey, was unreceptive to the NAS report. I expect she believes that she and others asked questions that demolished the NAS report. I would not agree. Judge for yourself. Take a look especially at pages 68-73 and 99-106.

I was not there but I do notice from the transcript that Barros-Bailey and others seemed quite eager to interrupt Nancy Shor's questions. Nancy Shor is the Executive Director of the National Organization of Social Security Claimants Representatives (NOSSCR). She may have had a different perspective from Barros-Bailey. I did not notice any other panel member being interrupted in the same fashion as Ms. Shor. I do know that transcripts do not always reflect the tenor of what has happened at a hearing or meeting. Perhaps, Ms. Shor had as much opportunity to ask questions and have them answered as she wished but it does not quite seem that way in the transcript.

Below is one small excerpt from the transcript. This is only one small detail but it is interesting. Margaret Hilton of the National Academy of Sciences is speaking:

We do know that the data collection costs [for O*NET] right now are about $6 million a year, and that updates 100 occupations a year. So that gives you some idea. ...

... [W]henever O*NET adds more occupations, whenever it becomes less aggregated, more disaggregated, as it has done, that is always going to increase your data collection costs, because you have more occupations to go after ...

At least one OIDAP member made the point that this means that the Department of Labor is very inefficient. Possibly. It may also mean that creating and maintaining an occupational information system is incredibly expensive. There are different ways of looking at things.

Deadline Day For OIDAP Comments

Today is the deadline for submitting comments on the proposal by Social Security's Occupational Information Development Advisory Panel (OIDAP) for a new occupational information system. Comments may be submitted online or by fax to (410) 597-0825 or by mail to the Office of Program Development and Research, Occupational Information Development Project, Social Security Administration, 3-E-26 Operations Building, 6401 Security Boulevard, Baltimore, MD 21235-6401.

As tedious as this may seem, the OIDAP proposal is vitally important. This is the most important policy matter addressed by Social Security in more than 30 years.

The OIDAP proposal is drawing several lines of criticisms. Maybe the most important line of criticism concerns Social Security's strong desire to develop its very own occupational information system rather than working with the Department of Labor which has vastly more experience with this sort of thing than Social Security. Why is it so important to Social Security to do this on its own unless it does want to control the outcome of disability determinations? I cannot think of a reason. OIDAP has not given us no reason other than to suggest that the Department of Labor will not work with Social Security which is clearly false. Department of Labor seems mystified by Social Security's go it alone attitude.

I do not think that OIDAP staff or Social Security management gets it. We do not trust you. There is no reason why we should trust you. The way you are acting makes us very nervous.