Vocational case managers, counselors, and experts are faced with a dilemma about Transferable Skills Analysis (TSA) because the U. S. Department of Labor (DOL) is making a transition from the venerable Dictionary of Occupational Titles (DOT) to the new Occupational Information Network (O*NET) system. The DOL is no longer updating the DOT, and it has actively promoted O*NET as a replacement for the DOT for career exploration and workforce investment purposes. Yet, an examination of O*NET reveals that it is not suitable for disability adjudication and vocational rehabilitation use. The DOL acknowledges the fact that O*NET is not designed for forensic use, and has been working with the Social Security Administration for two years to identify types of additional data that are needed to augment O*NET-SOC information for forensic purposes. This article describes the historical context of the DOT, explains some challenges facing both the aging DOT and the new O*NET, identifies the dilemma confronting vocational professionals because of this transition, and most importantly, suggests some interim solutions.
Since its creation in the 1930s, the Dictionary of Occupational Titles (DOT) (United States Department of Labor (US DOL), 1939, 1949, 1965a, 1965b, 1966, 1977, 1991a, 1993b) has undergone considerable metamorphosis to meet changes in the world of work and the needs of its users. It was introduced in 1939 as a simple four-digit coding system to describe occupations in a standardized way for use within Employment Service offices for purposes of labor exchange. The realities of World War II production and personnel requirements underscored the need to develop suitable methods of matching people to job requirements (US DOL, 1944). Extensive testing and research programs by the military and DOL identified a series of core worker trait factors that became part of the DOT and ultimately emerged in 1947 as the General Aptitude Test Battery (GATB). Post-war efforts to match disabled veterans to occupational requirements, and to meet the growing needs of an expanding industrial economy spurred continued occupational research.
In the late 1950’s, Fine (1955, 1957a, 1957b, 1958; Fine & Heinz, 1958) developed the conceptual foundation for modern transferable skills analysis, focusing on the importance of worker functions, work fields, and materials, products, subject matter, and services (MPSMS) when examining post-injury profiles. The third edition of the DOT (US DOL, 1965a, 1965b) unveiled a two-volume set using a new six-digit occupational coding structure designed to group occupations (Occupational Group Arrangement) and worker functions (Data-People-Things). One year later, it was followed by the Selected Characteristics of Occupations (SCO) (US DOL, 1966). This was a landmark release for the vocational industry, because it opened the doors for disability evaluation encouraged by the Social Security Administration (SSA). It also triggered the development of a significant number of commercial vocational evaluation systems. The SCO was expressly produced to assist professionals with disability evaluation. In 1972, DOL published the Handbook for Analyzing Jobs (US DOL, 1972) describing in detail the methodology for conducting on-site surveys for data collection and subsequent aggregation into the DOT. Recognizing the need for more efficient handling of the growing body of occupational knowledge and the need for a non gender-biased publication, DOL published its fourth edition of the DOT (US DOL, 1977), significantly expanding the release of discrete worker characteristic information at the occupational level rather than by occupational group (US DOL, 1981). The 1977 expanded occupational coding system uniquely identified each occupation by nine-digit number (up from six digits), for the purpose of computerized storage and retrieval.
Rehabilitation practitioners and software designers seized this new treasure of data. McCroskey, Wattenbarger, Field, & Sink (1977) developed a method of occupational profiling to take advantage of this new breadth of worker characteristics. Field popularized this approach in the Vocational Diagnosis and Assessment of Residual Employability (VDARE), the first systematic approach to manually use the DOT data to assess skill transferability and residual employability (Field & Sink, 1980). In 1978, the SSA published its regulatory guidelines for medical-vocational assessments of disability claimants and took administrative notice of the DOT, then in its 4th edition, as an authoritative reference for occupational information. SSA defined transferable skills in the Code of Federal Regulations [20 CFR 404.1568(d) and 416.968(d)] and set up its Medical/Vocational grids (20 CFR 404, Subpart P, Appendix 2) to facilitate its review of disability claims. As computing technology moved to the desktop, various commercial software systems were created to automate the arduous manual task of sorting through the various paper volumes of DOT definitions and worker characteristics. Building on Fine’s concept of transferability, Botterbusch (1983, 1986) asserted the use of Work Field and MPSMS as the only true method for transferable skills analysis. This approach became widely recognized as the industry standard for transferability of skills analysis (Brown, McDaniel, Couch, & McClanahan, 1994; Field, 1999; Kontosh, 1999; Dunn & Growick, 2000; Weed & Field, 2001; Bast, Williams, and Dunn, 2002; Darling, Growick & Kontosh, 2002; Gibson, Earhart, & Lento, 2002).
The DOL released a small DOT supplement in 1986 (US DOL, 1986), later replacing it in 1991 with the Revised Fourth Edition DOT (US DOL, 1991a). In 1992, DOL released, in electronic format, more detail about Physical Demands and Environmental Conditions, particularly disaggregating important physical demands detail such as reaching, handling, fingering, and feeling. The DOL had published its procedures in the 1991 Revised Handbook for Analyzing Jobs (RHAJ) (US DOL, 1991b). Many of these disaggregated worker characteristics were later published in the revised SCO (US DOL, 1993b). Since 1992, DOL has made only a few minor modifications to the DOT data electronically, and it has not published the data changes in any widely disseminated printed format.
The steady evolution of the DOT had some interesting side effects. Other government agencies created their own occupational classification systems with levels of occupational detail that could be reliably sampled for purposes of their data collection. These federal agencies included the Bureau of the Census, the Department of Commerce, the Office of Personnel Management, and the Department of Defense. Even within the DOL itself, it created several simpler classification systems, one to gather labor market information based on the Occupational Employment Survey (OES), the other to aggregate occupations for its popular biannual publication - The Occupational Outlook Handbook (OOH) (US DOL, 2002b). Aside from the daunting and expensive task of updating this mountain of DOT data, the DOT data and structure began to age and fall out of step with a changing economic structure (Miller, Treiman, Cain, & Roos, 1980; Botterbusch, 1993). Many DOT occupations have become obsolete or non-existent through business process and technology improvements. Others have combined and collapsed into a single “new” occupation. Information and bio-technology have spawned numerous new, emerging occupations not yet captured by traditional occupational sources. DOL sought alternate methods to collect data to reflect these changes in the workplace. It dismantled its network of Field Analysis Centers and moved to a job-incumbent survey model rather than using trained job analysts to collect occupational data (US DOL, 2002a).
In response to the changing economy and a growing desire for more current data, DOL began in 1991 to receive input from its employment network stakeholders through the Advisory Panel on the DOT (APDOT) (US DOL, 1993a). The various APDOT reports proposed a new "Content Model" for occupational information. After years of research, DOL introduced the Occupational Information Network (O*NET) in 1998 (US DOL, n.d.a). In this first prototype release, O*NET collapsed the 12,700+ unique DOT occupations into a significantly smaller number of occupational groups (846 Standard Occupational Classification (SOC) groups; 1,166 SOC-O*NET groups). The most recent production release, O*NET 4.0 (O*NET 5.0 available in Summer, 2003), has about 950 occupations. This aggregation serves one of the primary objectives of the DOL: to adopt a standardized occupational classification -- the SOC -- that can be used at its Employment Service offices, yet be expanded by using the O*NET-SOC coding system for more career counseling detail. The Office of Management and Budget (OMB) has mandated that all federal agencies use the newly revised SOC for occupational coding when it is appropriate to the mission of the agency (OMB, 1999). Most state Employment Service agencies are converting to the SOC in some way, although each agency is at various stages of deployment (US DOL, 2001).
The new O*NET Content Model (O*NET Consortium, n.d.), while drastically reducing the number of occupations, vastly increases the number of worker and occupational characteristics from 72 to more than 230. The 1998 O*NET prototype coding has already been replaced by the new O*NET 4.0/5.0 coding system that is a direct variant of the newly revised SOC system, the new federal Standard Occupational Classification. The breadth of information being assembled for the O*NET database is taking years to fully develop and deploy by the various agencies.
The O*NET information is intended primarily for purposes of career exploration, and career planning (US DOL, n.d.b). In addition, O*NET information is used for various workforce investment purposes, such as writing skills-based job orders or resumes, curriculum development, on-the-job training contracts, and related purposes. The DOL has indicated that O*NET is not designed for forensic use (P. Frugoli, DOL, personal communication with author S. Karman, June, 2003). Investigation of O*NET confirms that the system, by design, is not suitable for applications where occupation-specific information about the thresholds for physical, mental and skill-level demands of work are needed. Of particular concern to vocational professionals are the aggregation of O*NET data, the manner of data collection and the descriptors of work and worker traits (Cannelongo, 2002a).
The way in which O*NET occupations are aggregated results in a loss of specificity that is critical to vocational professionals. The O*NET taxonomy clusters approximately 9,500 DOT titles into fewer than 1,000 SOC-O*NET occupational groups. Many of the SOC-O*NET occupations contain a large, heterogeneous mix of jobs with a widely diverse range of strength and skill requirements. For example, the strength requirements for an SOC-O*NET occupational grouping may span several ranges of ability: sedentary through heavy. As such, O*NET groups often reflect a cluster of related occupations rather a single, discrete occupation. This high level of data aggregation makes it difficult for vocational professionals to determine if a disability claimant or injured person could perform an occupation when the individual’s residual functional capacity and work history are taken into consideration.
The O*NET data collection methods also differ substantially from the DOT. Rather than deploy trained job analysts to observe jobs on-site, the new approach by DOL is to have job incumbents complete survey forms. Certain dimensions (e.g. “Abilities”) will be rated by job analysts without going on-site to observe or otherwise measure actual performance. Pre-testing of the survey forms provided an estimate of the time required to complete all of the items. To meet OMB guidelines for time burden on individual respondents, DOL divided the survey into 4 separate questionnaires, each of which is completed by 15-20 employees in each occupation, for a total of 60-80. (US DOL, 2000). This approach may introduce problems with internal sample consistency and with reliability for forensic purposes. It appears that the O*NET data collection may not cover enough of the lower skill level segments of the labor market (Cannelongo, 2000a). Beginning mid-2001, DOL initiated its plans to survey about 200 occupations per year, expecting to have O*NET fully populated with new incumbent survey data by 2008.
While data gathering for O*NET has been underway, the initial ratings for characteristics reported in O*NET are derived strictly from researcher efforts to collapse the old DOT data into the O*NET occupational groupings (US DOL, n.d.c). Using factor analysis, DOT titles were arranged into the current O*NET occupational groups. Then, job analysts rated the work and worker traits, or descriptors, for each of the new occupational groupings (Peterson, 1999). While many of the current O*NET descriptors are helpful for career exploration, they pose a particular concern for forensic professionals. For reasons detailed below, it would be difficult for a vocational expert to defend the choices of existing O*NET descriptors used in forensic case analysis. Investigation of O*NET descriptors reveals four areas of concern:
a) Link between demands of work and human function: Many of the descriptors are difficult to observe in the work place and difficult to relate to a client. For example, it is unclear how a job analyst might be able to rate the extent of “static strength” or “problem sensitivity” required to perform an occupation satisfactorily. It is equally unclear how a vocational professional could assess the level of “static strength” or “problem sensitivity” that a client could perform.
b) Terminology: The terminology and definitions of O*NET descriptors appear to reflect mostly industrial organizational psychology, and are unlike those used by SSA, the medical profession and numerous other users, such as vocational rehabilitation and forensic specialists. This does not help to resolve a long-standing communication problem among healthcare, forensic, and disability management professionals.
c) Redundancy: Some of the O*NET physical descriptors seem to describe similar attributes, e.g., explosive strength vs. dynamic strength, and gross body coordination vs. gross body equilibrium (Bainbridge, 2001). It is difficult to accurately measure job demands using terms that may overlap or reflect similar constructs. The problems created by such overlap would be amplified if rehabilitation specialists and SSA adjudicators try to interpret those terms and their measures to evaluate a client’s or SSA disability claimant’s functional abilities.
d) Scales: The measures for O*NET descriptors involve the use of ordinal scales rather than interval scales, and can lead to problems with objective interpretation. For example, it is difficult to quantify Trunk Strength on a scale of 1 to 7, with anchors such as “sit up in office chair,” “shovel snow for half hour,” and “do 100 sit ups” at points 2, 4 and 6, respectively along a 7-point scale. Also, the user cannot know what the descriptor scores mean in terms of the functioning level required to perform the occupation. The Likert scales, used in the O*NET incumbent questionnaires and converted into ratings of 1 to 100 for the online version of O*NET, are not linked to functional measures, such as amount of force required for a specified duration. Therefore, adjudicators and rehabilitation specialists cannot know what a score of 48 in Trunk Strength means, as reported for Food Preparation Worker (O*NET-SOC code 35-2021.00).
Despite the volume of these new characteristics, many physical demand characteristics important to the rehabilitation and forensic community are still not measured. Furthermore, concerns regarding terminology and redundancy affect the extent to which job incumbents may be able to understand the survey questions, which may, in turn, affect the reliability of the responses when survey responses are tallied. The reading level requirement for some questions may be too high for many job incumbents, and may be another source of survey error.
The International Association of Rehabilitation Professionals (IARP) has developed its own internal O*NET subcommittee (Cannelongo, 2000b) to evaluate additional issues. Preliminary statistical analysis by the subcommittee has clearly shown the lack of homogeneity in the various SOC and O*NET-SOC groups when carried out to examine the DOT occupations that comprise each group. There is growing discussion of additional job demand detail beyond the O*NET level. The IARP has spearheaded the formation of a coalition of professional organizations called the Inter-Organizational Task Force (IOTF) interested in this new layer of occupational/worker trait detail (IARP, 2002). The goal of the IOTF is to assist DOL and SSA to establish a common, objective, measurable, and reliable framework that can best describe the physical, mental, cognitive, training and environmental demands associated with occupations. Representing a collective membership of 300,000 diverse professionals interested in these issues, the IOTF is a powerful force for developing a common shared language for more efficient and consistent service delivery (J. Cannelongo, personal communication with author J. Truthan, June, 2003; IARP, 2002). The SSA is continuing to work with DOL to best articulate the needs of the rehabilitation and disability evaluation community.
To encourage its own departments to begin using O*NET-SOC instead of the DOT, DOL launched a significant marketing campaign to declare that the DOT had been replaced by the new 1998 SOC (Mariani, 1999; Levine & Salmon, 1999). Yet this message has been the source of a great deal of misunderstanding in the rehabilitation and forensics communities, creating a significant dilemma. While the O*NET database has the potential to add some new dimensions to understanding and describing an occupation for career exploration purposes, it was not designed for vocational rehabilitation and disability evaluation. As noted, many of the scales for the new dimensions can neither be measured nor quantified and the occupational groups are often far too heterogeneous in composition. If the DOT is "replaced" and O*NET is not adequate for rehabilitation purposes, then how does a case manager or vocational expert build a sound opinion that will be accepted by the court?
Recognizing the concerns of rehabilitation and forensic specialists, in joint meetings during the past two years, DOL staff have indicated to SSA and the IOTF that O*NET information is the successor to the DOT for purposes of career exploration, workforce investment/labor exchange, and business human resources functions (P. Frugoli, DOL, personal communication with author S. Karman, June, 2003). Collaboration among IOTF, SSA and DOL has resulted in an understanding that two modalities of occupational information are necessary: one that is intended for career preparation and exploration, and the other that is useful for forensic and rehabilitation purposes. Toward that end, SSA and DOL are in the process of developing plans to address the need for occupational information for disability evaluation and vocational rehabilitation (SSA, 2003a; 2003b).
In the context of the issues above and until other suitable occupational data are available, SSA indicated that it cannot use O*NET and that it will continue to use the DOT (SSA, 1999a; and SSA, 1999b). In the CFR, SSA takes administrative notice of the DOT as “reliable job information available from various governmental and other publications” (20 CFR 404.1566(d) and 416. 966(d)). Social Security Ruling 00-4p clarifies SSA standards for the use of vocational evidence involving “other reliable sources of occupational information” (SSR, 2000). The ruling states that SSA adjudicators must obtain a reasonable explanation for any conflicts between occupational evidence provided by vocational experts or specialists and the DOT. Adjudicators must then explain in their determinations or decisions how the conflicts were resolved. Also, SSR 00-4p states that SSA regulatory definitions and policy for strength and skill levels and for TSA are controlling in the adjudication. These regulatory definitions are based on DOT constructs.
The SSA definition of skills transferability remains solid, defensible, and relevant today. The SSA and DOL plans are evolving to address the need for occupational information that is suitable for rehabilitation and forensic purposes. The SSA, IOTF, and DOL continue to work cooperatively together. A solution can certainly be derived, but it will take time to assure that the future occupational information does indeed have suitable mechanisms in place to properly examine transferability of skills, particularly for disability and forensic issues. Such efforts may include the introduction of a new layer of occupational detail at the O*NET level. The DOL has already sponsored some research of internet-based training (distance learning) to establish the feasibility of teaching field professionals to reliably perform job analysis. Results solidly point to such an approach with inter-rater reliability extending from .77 to .98 (Cannelongo, Lechner, Keener, Carter, & Johnson, 2002).
Until such time that these collaborative efforts are completed, the DOT cannot be retired or written off for rehabilitation, forensic, and disability adjudication. Aging though it is, trained job analysts followed a clearly defined methodology on-site to validate the DOT, and it is reliable (Cain & Green, 1983). To the extent that vocational professionals use O*NET, its data collection is still underway and will not finish its first cycle of data collection until about 2008. To help rehabilitation and forensic professionals during this time period, the following points are recommended for transferable skills analysis during this transition.
· Continue to use the DOT. It has the longevity and defensible depth required by the courts (Daubert v. Merrill Dow Pharmaceuticals, 1993).
· Carefully examine DOT tasks and worker characteristics to assure continued relevance.
· Add another DOT code/description to work history to help best describe one actual position held. It may take several DOT codes to best capture the responsibilities of each job held in a client’s work history. (Note: SSA Vocational Experts should adhere to current SSA policy).
· Use the proper method for TSA (i.e. Work fields, Specific Vocational Preparation (SVP) and MPSMS), as these taxonomies best fit the SSA definition of transferable skills (20 CFR 404.1568(d)(2) and 416.968(d)(2)). This is the generally accepted and the current industry standard practice. Standard practices do not change overnight. New standards cannot emerge until new methods and data elements have been created and validated. (Note: SSA adjudicators derive information similar to that reflected in Work and MPSMS fields from the DOT description of tasks and tools for given occupations.)
· Carefully screen the results of any search method. No computer system will ever replace the scrutiny of a skilled vocational professional.
· Be aware that some occupations no longer exist nor exist in significant numbers in a specific labor market. (Note: By law, SSA must consider occupations as they exist nationally. Therefore, for SSA cases, do not necessarily exclude occupations that are not prevalent in a given locale, as they may exist in significant numbers in the national labor market (E. Tocco, Office of Disability Programs, SSA, personal communication with author, S. Karman, May, 2003).
· Study all occupational suggestions for changed worker requirements, potential obsolescence, and combination with other occupations in today's economy.
· Augment your understanding of an occupation with information drawn from a variety of sources.
· Examine labor market information for relevant trends, being careful to understand that labor market information usually reflects many discrete occupations, not just one DOT occupation.
· Conduct a labor market survey to validate the continued existence of such occupation(s), current hiring patterns, prevalence, duties, tasks, skill sets, and hiring requirements.
· When possible and appropriate, do an on-site survey/job analysis.
Rehabilitation and forensic professionals should be poised to assist the DOL and the SSA to develop and deploy a variety of creative approaches to gather current occupational data. The DOL and SSA are seeking the active input of the rehabilitation and forensic community to discover the data needed to render opinions on important vocational issues. The IOTF coalition of various rehabilitation, health care and disability associations, and private industry represent a significant number of interested parties. Collectively and cooperatively, these parties can help DOL and SSA shape the next level of evolution necessary to properly address the needs for current, detailed and relevant occupational information in the rehabilitation and forensic communities.
As the opening historical perspective showed, change does happen over a significant period of time. This present time is an enormous opportunity to be heard and to work towards the implementation of worker and occupational characteristics that will truly benefit rehabilitation for generations. The IOTF, the DOL, and the SSA are receptive to the needs of the rehabilitation and forensic communities. Professionals are encouraged to become active in contributing to the continued evolution of a critical component of various public and private service delivery systems.
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SkillTRAN, LLC - http://www.skilltran.com/
3910 S. Union Court – Spokane Valley, WA 99206
Jeff Truthan is President of SkillTRAN, LLC of Spokane, WA. He has designed, developed, and improved many PC and internet-based software products including Job Browser Pro, EZ-DOT, Placement Planning Service (PPS), Pre-Injury/Post-Injury Analysis (PREPOST), Career Consultant Service (CCS), and the Job Search Service (JSS). Jeff’s 30-year career in the rehabilitation industry includes 12 years of experience as a rehabilitation counselor and a vocational evaluator, and 18 years of experience in the design, development, and support of computer software. He draws upon this work experience in his daily interaction with vocational professionals to devise practical and easy-to-use database solutions for efficient handling of complex vocational issues. He earned his BA degree from the University of Notre Dame in 1973, and his MS degree in Rehabilitation Counseling from the Illinois Institute of Technology in 1975.
Sylvia Karman is the Social Security Administration’s lead for a series of projects to research methods to obtain more current information about occupations in the U.S. labor market, and to explore options for updating Social Security’s disability evaluation policy in the face of a changing world of work. Sylvia began her career with the Social Security Administration in 1979 as a college intern. After graduating in 1982 with a BA degree from Towson University in Maryland, her work has involved policy and legislative development and program evaluation for the Supplemental Security Income program under title XVI and for the agency’s disability programs under both titles II and XVI.
The authors gratefully acknowledge the critical input and insights of Pam Frugoli, O*NET/Skill Assessment Team Lead, Employment and Training Administration, U.S. DOL, and Elaine Tocco, Medical Vocational Policy Team Leader, SSA during the final preparation stages of this manuscript.