A variety of documents support the continuing use of the 1991 Dictionary of Occupational Titles (DOT) rather than the O*NET, particularly in the realm of adjudication of disability claims within the Social Security Administration (SSA), most worker compensation programs including the US Federal Office of Worker Compensation, and private insurance industries such as group Long Term Disability management. Other forensic venues may have different guidance on the use of appropriate source foundational documents. The DOT remains a popular source of occupational data and is used in a wide variety of public and private industries (chart developed by Mary Barros-Bailey, Ph.D. and cited with her permission).
DOT as a Valid Resource
While the DOT itself was not originally designed for purposes of adjudication, SSA has formally endorsed the DOT as its primary source of occupational data (Social Security Ruling 00-4p). According to SSR-00-4p, the DOT is to be used as an authoritative reference. Deviation from the DOT by the vocational expert or by SSA’s own vocational specialists must be declared and justified. The Code of Federal Regulations [20 CFR 404.1566(d)] specifically mentions a variety of sources of occupational information that can be taken "under administrative notice". In 2009, Social Security memorandum 09-2139 was distributed to the Regional Chief Administrations Law Judges (ALJ). The memo acknowledges the use of specific electronic software programs within the SSA itself. SkillTRAN's Job Browser Pro, OccuBrowse™, and OASYS software are all listed as acceptable electronic versions of the DOT. These SkillTRAN software programs are available to all ALJs and Senior Attorney Adjudicators through SSA's internal electronic library.
None of these citations acknowledge the challenges of using a document last published in 1991 knowing that many occupations have changed due to a variety of circumstances, including technology rendering certain occupations obsolete, the duties of one occupation being combined with another for efficiency, consolidation, or "right-sizing" or the elimination of the occupation due to off-shoring, automation, or outsourcing to temporary employment agencies, etc.
Current Intended O*NET Users
While O*NET often declares itself to be a "replacement" for the aging DOT, in practice, it has not. O*NET authorizes use of its O*NET Career Exploration Tools "for career exploration, career planning, and career counseling purposes only." (see O*NET Developer Agreement - Section 10). By limiting the use of O*NET data and its tools, O*NET formally disqualifies itself from use in forensic venues. See also O*NET Research and Development, which lists intended users, none of which include SSA, vocational rehabilitation, or disability adjudication. Many new occupational dimensions are built in to O*NET, but the utility for situations in which disability impacts occupational choices is a glaring weakness.
Transition from DOT to O*NET
In 2003, Jeff Truthan (SkillTRAN LLC) and Sylvia Karman (of SSA) authored a popular article identifying many problematic issues during the time of transition from the DOT to O*NET. In 2004, SSA first disclosed its concern about the use of O*NET occupations in the SSA disability adjudication process when it attached this document to a public RFP. In 2009-2012, a special panel of blue-ribbon professionals was chosen as the Occupational Information Development Advisory Panel (OIDAP). A number of publications (See Panel Documents) emerged from the work of this important independent panel and are available at the SSA web site. Among these include a meticulous analysis of the National Academy of Sciences review of the O*NET after its first 10 years. In this OIDAP document, the OIDAP specifically states that O*NET in its current form did not meet the needs of the SSA in its disablity adjudication process [Page 1, Point 1]. Chapter 8 of the NAS review of O*NET is focused on Disability Determination. Click here for the full NAS document.
Efforts to Update DOT/O*NET
SSA has a history of interaction with the US Department of Labor. Through interagency agreements, SSA has long influenced the evolution of the type of data available in the DOT. Such agreements resulted in a major revision of the DOT in 1977, with subsequent supplements issued by DOL in 1982, 1986, and a final Revised 4th Edition of the DOT in 1991. In 2012, SSA entered into a new inter-agency agreement with the DOL - Bureau of Labor Statistics - National Compensation Survey (NCS) program. Continuing work is underway to define SSA's current needs for new information. Such efforts may result in fundamental changes in O*NET to enable it to be more useful to the disability adjudication process. The NCS is studying SSA's requests and testing various methods of data collection. No data collection will start before FY2015. There is no known time table for release of any new consolidated data that could be useful to SSA in its disability adjudication process. Emerging details are available at the www.bls.gov/ors
SkillTRAN is vitally interested in efforts to update the DOT. Its President, Jeff Truthan, co-authored a published paper in 2009 - "A Call to Update the DOT: Findings of the IARP Occupational Database Committee ". SkillTRAN attended many of the OIDAP meetings and contributed written and oral public testimony to the OIDAP in 2010 and 2012.
SkillTRAN continues to carefully monitor the emergence of this new sustained effort between the SSA and BLS-NCS. SkillTRAN has regularly participated by submitting public written comments concerning the work and progress of the ORS. Click here to see SkillTRAN's ongoing commentary.