Would this help? Posted as a co-author and with full credit to IARP and multiple authors:
https://skilltran.com/pubs/RehabPro_17_2_pp63-84.pdfSince SSA was charged with administering the Disability programs introduced in the 1960's in the Kennedy and Johnson years, SSA has been the prime mover in funding nearly ALL of the more "recent" fundamental changes in the DOT. Witness the 1965 3rd edition of the DOT with Worker Trait Groups and GATB cutoff scores. The 1977 edition with gender neutral job titles (thanks Gloria Steinem) and lo and behold 12,099 uniquely coded occupational definitions, each coded with copious Strength, Physical Demand, Environmental Conditions, GED-RML, SVP, Aptitude, and Temperament information following a standardized process detailed in the 1972 Handbook for Analyzing Jobs. Followed by the minor 1982 and 1986 updates, culminating in 1991 with more fully broken-out Physical Demand factors, and ultimately a tiny final update in 1998 released by fax with a few more occupations, minor changes and code switches just prior to the roll-out of O*NET v1.0.
Failing an attempt to automate the DOT (ignoring the success of private vendors in this arena), DOL created the Advisory Panel on the DOT - APDOT in 1993, deciding that 12,000 occupations was too much ... and that DOL could really get by with something far less intricate for its primary purposes:
1. Pay unemployment claims
2. Put people back to work.
For Johnny Job Seeker and the typical Job Service employee, the DOT was "too much". So for "DOL-think", 1,000 occupations maximum "ought to suffice" for their purposes. What emerged in 1998 was a new 5-digit occupational coding system known as O*NET, which quickly morphed into the 6-digit Standard Occupational Classification System (SOC) in 2000, as updated in 2010, and most recently in 2018. The Federal Government, through its Uber Fuhrer Office of Inspector General (OIG) has steadily acted to quash all deviation from this core occupational structure, and is imposing this on SSA as well as every other federal government entity. While it allows extension from the SOC (e.g. O*NET 8-digit coding vs. SOC 6-digit coding), this is the force compelling SSA to make the switch to SOC/ORS. SSA, saddled with how many years/decades of "non-leadership" by "Acting Commissioners" made horrible progress adapting to these demands, ultimately deciding to convene a blue ribbon panel of industry experts, chaired by Mary Barros-Bailey. In its nearly 4 year existence, the Occupational Information Development Advisory Panel (OIDAP) - late 2008 to mid 2012 - this blue ribbon panel of highly qualified professionals developed essentially all of the new and more discrete break outs of physical demand and environmental conditions that we see reported in the ORS data collection today. A separate sub-committee was working on the Mental-Cognitive aspects of disability, but unfortunately was not able to complete its work prior to the premature termination of OIDAP in mid-2012.
SSA then funded the Bureau of Labor Statistics (National Compensation Survey - NCS) program for 3 years to see if they could figure out how to do this data collection. NCS is an organization of economists ... not job analysts. In their "studies", they saw no significant difference between collecting data from job site observation of the worker and just talking with HR or maybe an immediate supervisor. This is the level of data collection now underway - collected by economists from interviews, even by phone rather than on-site observation by trained job analysts.
Of course the NCS concluded they could do this data collection, and the first wave of data collection began, despite copious public commentary advising changes to the ambiguous wording of the mental-cognitive questions and sampling strategies undertaken. So the first 3 years (First Wave 2016-2018)) data collection concluded, with no reportable mental cognitive factor data. Rewording and restructuring of these aspects, and the second wave (5 years) was begun 2019-2023. The 4th year data of this second wave was recently released -
https://www.bls.gov/ors - and it covers 427 unique SOC occupations of the 848 SOC occupations. From an economist's viewpoint, this covers more than 90% of the labor force. So what is the problem with that?
What are the odds that this Second Wave data collection will complete collection of data for the remaining 421 SOC occupations? There is already a 3rd wave of data collection rumored to be in the offing. ALL of this being done without input from the private sector, trained/experienced professionals in rehabilitation/testimony, Industrial/Organizational Psychology, Physical Medicine/Therapy, Psychology, etc. This is all happening as self-contrived by SSA and DOL ... with no oversight or independent input or guidance from real professionals in the industry. This is the tragedy unfolding before us. More than $300 million spent so far, with incomplete data collection, no public reporting of any of the details about how their sampling actually was done, no information about sample sizes, industries covered, or breakouts by industry, we are left with interesting data emerging from this study, some that supports historic understanding of these types of SOC groups and sometimes some very interesting divergence (sometimes even completely unexplainable!).
SOC groups contain anywhere from 1 DOT occupation to hundreds of DOT occupations and one "catch all" group with 1,500+ DOT occupations)! Data as currently reported for these groups typically include a mean value with a Standard of Error Measure (SEM). To combine each of these factors (as in a typical SSA hypothetical) requires substantial mathematical computation (see BLS guidance:
https://www.bls.gov/ors/factsheet/calculating-occupational-employment-for-job-requirements.htm) which cannot be timely achieved through reliable manual computation. While SSA claims to have a Vocational Information Tool (VIT) for management of this application, no one outside of SSA has seen this tool, and I have never known of anyone within SSA to have seen/used it, either.
Given the "Preliminary" status of ORS data at this point in time, I would not foresee "official" SSA endorsement or use of this new data set until late 2023 or more likely 2024 at the earliest when the "Final" second wave data set is "completed". The total absence of recent external input/guidance from outside of SSA/ORS continues to concern me greatly.
Jeff Truthan, MS-Rehab Counseling/Certified Vocational Evaluator
President - SkillTRAN LLC –
jtruthan@skilltran.comInformation for Important Evidence-Based Work Decisions
800-827-2182 [Pacific Time Zone]
509-850-3723 [Direct]
Original Message:
Sent: 12/28/2022 9:54:00 AM
From: Robert H. Taylor
Subject: RE: SSA
Wouldn't it be great to see a published response in The Rehab Pro that addressed the points made in the article from a historical and objective educational perspective? The SSVE section and IARP could spearhead this. I think the author of the WAPO article would welcome it.
I have long been disappointed with the obvious shortcomings in the process of adjudicating SSA disability claims for many of the reasons discussed in the article. This could be a great opportunity.
Bob
Bob
Robert H. Taylor
1987 Haven's End
Prescott, AZ 86305-2148
(928) 713-6833
(720) 600-2636
Sent from my iPad
Original Message:
Sent: 12/28/2022 8:26:00 AM
From: Michele Erbacher
Subject: RE: SSA
Michelle, everything you said is in the article is there. All I'm saying is it makes it sound like ALL VEs use Nut Sorter as a Sedentary unskilled job. ALL VEs say things that make the Claim denied at Step 5. This article puts all VEs and all ALJs in a horrible light, and paints us all with a broad negative brush.
Best,
--
Michele Erbacher, MS, CRC, ABVE/F
Erbacher Rehabilitation & Consulting
Cell: (716) 807-6708
Original Message:
Sent: 12/27/2022 10:12:00 PM
From: Michelle Aliff
Subject: RE: SSA
Maybe we are reading different articles, but I did not at all read that VEs are conspiring with ALJs to deny claimants.
What I read is there are VEs still using nut sorter (I have also seen this in decisions) and this is being used as grounds to deny claims. I also read the DOT is out of date and it's being used as a basis to deny claims. Job numbers are all over the place, with no discernible method in some cases. None of these are untrue and are simply statements of facts. Like it or not.
To say these are rare occurrences would be false but to say it's the majority of VEs is also false. It is true many VEs have difficulty explaining a method, seen it in way too many district court decisions to not agree that's a problem.
I think the article painted the picture of how it is. And it's ridiculous SSA hasn't moved forward on this and there are no explanations as to why they aren't moving forward. How much more time needs to be spent? How is it ok to have a system based on a nearly 50 year old source of data? These are all valid questions to ask, whether it be from us or the general public.
ORS has shown how much the unskilled labor market has changed. Our own experiences match up to the changes in the unskilled labor market ORS shows in many cases. Explaining how the labor market has changed since the DOT is a vital role in not only SSVE but also forensic work.
One point that was not made perfectly clear was that the new ORS by itself would not increase denials (Saul and Warshowsky). Rather, it's if the grids are changed or eliminated. If those are changed that will impact approvals or denials more than anything. ORS cannot be used for TSA in its current state.
In regards to updating the DOT, that's a pipe dream. They aren't going to spend that kind of money to update it. The best idea, stop pretending ORS doesn't exist or saying it's not usable. Actually use the data. Look at it. And provide feedback to BLS about issues in the data. Understand no data source is without flaws, the DOT has plenty of them and it's very old (a glaring flaw within itself). We are the experts in this and in my experiences and others who have provided feedback, they listen. I have found BLS to be very responsive. In essence, contribute to the process, even those of you who do not do SSVE work. ORS is incredibly helpful in forensic work as well.
Michelle Aliff, Ph.D, CRC, CVE
Sent from my iPhone
Original Message:
Sent: 12/27/2022 8:46:00 PM
From: Scott T. Stipe
Subject: RE: SSA
Some SSVE ought to go for it. I do miss those rousing SSVE discussions. I wondered if folks had seen it. I'm with you. I suspect that the percentage incidence of technically bad VEs is similar to the incidence of bad accountants, psychologists, lawyers or whatever profession. Most all VEs I know do or have done SSVE and this article should be read by all VEs.
Happy 2023
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Scott T. Stipe, MA, CRC, CDMS, IPEC, D/ABVE
Certified Rehabilitation Counselor
Board Certified Vocational Expert
Scott Stipe & Associates, Inc.
DBA Career Directions Northwest
4110 SE Hawthorne Blvd
#188
Portland, Oregon, 97214
(503)234-4484
(503)234-4126 fax
email: sstipe@careerdirectionsnw.com
website: www.careerdirectionsnw.com
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Original Message:
Sent: 12-27-2022 19:24
From: Michele Erbacher
Subject: SSA
Thanks, Scott. It has been shared in the SSA-VE Section and we had a rousing conversation. Every VE I know updates the definition when necessary in order to best describe how the job is performed in the national economy today. We also research jobs on an ongoing basis and don't return jobs in response to hypotheticals that no longer exist in the labor market. I wish someone would write a counter to that article. It makes it sound like ALJs and VEs conspire to deny people benefits. Stuff and nonsense.
Best Regards,
Michele Erbacher, MS, CRC, ABVE/F
Erbacher Rehabilitation & Consulting
Cell: (716) 807-6708
Sent from my iPhone
Original Message:
Sent: 12/27/2022 4:00:00 PM
From: Scott T. Stipe
Subject: SSA
Just saw this in WP and thought I would share as it relates to SSVE
https://www.washingtonpost.com/politics/2022/12/27/social-security-job-titles-disabled-applicants-obsolete/
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Scott T. Stipe, MA, CRC, CDMS, IPEC, D/ABVE
Certified Rehabilitation Counselor
Board Certified Vocational Expert
Scott Stipe & Associates, Inc.
DBA Career Directions Northwest
4110 SE Hawthorne Blvd
#188
Portland, Oregon, 97214
(503)234-4484
(503)234-4126 fax
email: sstipe@careerdirectionsnw.com
website: www.careerdirectionsnw.com
------------------------------