Spring 2012

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.

The OIDAP conducted a telephonic public meeting on June 4th.  Arising out of panel deliberation at this meeting was final General Recommendation #9 that reads:

~ Continued Transparency and Public Engagement ~

The OIDAP brought transparency to SSA’s occupational information development process that will impact 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. We offer the following advice:

1. publicize reports from leadership of the Office of Vocational Resources Development (OVRD) on the project’s activities, including continued updates regarding the progress with this initiative and strategic goals on agency websites and in public forum webinars and informational sessions, advertised in the Federal Register and agency sources;


2. announce all future strategic research and development plans, as well as findings from the project development and data collection efforts, to researchers for peer review;


3. continue to promote a venue for public comment and a repository for such comment; and,


4. engage and involve stakeholders and the scientific community in the review of research and development activities, as well as issues related to the analysis, usability, and integration of occupational data into the disability adjudication process.

~ The Science ~

The foundation upon which any occupational information database rests is its taxonomy of attributes to be measured and the scales that actually measure them.  As with anything anyone builds, if the foundation is inadequate, the structure will fail.  We reiterate the importance of developing a taxonomic content model that is strong enough to withstand legal challenge. We affirm our belief that:

1. the taxonomy must comprehensively measure the world of work and those attributes applicable to disability adjudication;


2. internal staff trained and experienced in the scientific design and research, and also in disability adjudication application, must work together in this process;


3. the scales used to measure these attributes must be absolute, cross job-relative, and psychometrically-sound;


4. the occupational data must link to other national occupational employment databases through the structure of the Standard Occupational Classification;


5. SSA adopts a carefully-designed sampling strategy that represents all jobs in the national economy (the Occupational Medical-Vocational study conducted by OVRD offers a good starting place);


6. the sampling frame must adequately represent all geographically-diverse sectors of the economy, including emerging sectors, be periodically updated, and correspond to the data collection strategy;


7. data collection modes, subject matter experts, and the training and experience of those involved in data collection is a vital step in the development of data; thus, SSA should pay special attention to this phase of the project, and particularly to the qualifications and training of field job analysts, an area that presents the greatest threat to the validity of the data;


8. SSA should test the resulting data with users for comparability and decision-making effects; and,


9. SSA should periodically update the data to remain relevant and reflective of the world of work in the United States.

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.

As outlined in the OIDAP’s Operating Procedures, any recommendation voted upon by the Panel must go out for public comment.  Given the timeline associated with the charter’s expiration, please expect a Federal Register publication notice soon soliciting written public comment and announcing the OIDAP’s final teleconference, which will include allotted time slots for individuals or organizations who wish to comment by telephone during the meeting.  Space is limited.  If you are unable to offer verbal public comment, feel free to email your written comment to the OIDAP at oidap@ssa.gov. 

All written comment received by the closing date will be reviewed by the Panel and provided to SSA.

Thank you for your engagement in this process that affects millions of Americans.  Your voice is important.

Best regards,

Mary Barros-Bailey, PhD
Chair