individual lives or in several regions in the country. To answer the question of whether or not “work exists in significant numbers” in the national economy, the SSA took administrative notice of the DOT. That is, under the assumption that only occupations that existed in significant numbers were reflected in the DOT, this O*NET predecessor served as a primary tool for determining whether a Social Security claimant had the capacity to work.

In 1996, SSA requested that the Institute of Medicine, in collaboration with the National Research Council’s Committee on National Statistics, conduct an independent review of the statistical design and content of its research plan for redesigning the disability decision process. The study committee concluded that the DOT replacement (i.e., O*NET), “will not meet SSA’s needs to define the functional capacity to work without major reconstruction” (Institute of Medicine, 2002, p. 9). The report continues:

Barring some resolution, SSA will be left with no objective basis upon which to justify decisions concerning an individual’s capacity to do jobs in the national economy. SSA might be cast back into the era when it relied extensively on the testimony of “vocational experts” or their written evaluations. [emphasis in the original]

Given that occupational information is critical for use in disability determination, our panel invited Sylvia E. Karman, a representative of SSA, to make a presentation on this issue. SSA appears to think that O*NET is not able to fulfill the needs of vocational experts and disability adjudicators involved in the process of disability determination. In a letter to administrators of disability determination services, SSA advises disability adjudicators and reviewers not to use O*NET when making disability decisions (Social Security Administration, Office of Disability, 1999). Sylvia Karman (2009) indicated that this view is widely shared, presenting a list of four reports (Government Accounting Office, 2002a, 2002b; Social Security Advisory Board, 2001; Institute of Medicine, 1998) which, she said, either state that “both SSA and DOL acknowledge that O*NET cannot be used in SSA’s process” and/or “recommend that SSA investigate other alternatives.”


Having ruled out the use of O*NET for disability determination purposes, SSA has begun taking steps to develop its own occupational information system. In December 2008, the commissioner of social security established the Occupational Information Development Advisory Panel. The advisory panel was charged with providing independent advice and recommendations on plans and activities to replace the DOT currently used in the SSA disability determination process (Astrue, 2008). The panel’s report,

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