For over a decade, as part of its Occupational Information System (OIS) project, the Social Security Administration (SSA) has been developing a new source of occupational information for making certain disability determinations under the Social Security Disability Insurance (SSDI) and Supplemental Security Income (SSI) programs. Despite ongoing congressional interest in the project’s status, to date, SSA has not fully implemented the new OIS. SSDI and SSI have a work-limiting definition of disability for adults. Under the statutory definition, individuals must have severe and long-lasting impairments that prevent them from performing substantial gainful activity—defined by SSA as work resulting in earnings above a set amount. By law, individuals’ impairments must be of such severity as to prevent them from performing (1) certain work that they have done in the past and (2) any other substantial gainful work that exists in significant numbers in the national economy, considering their vocational factors of age, education, and work experience. Sometimes, medical factors alone are enough for SSA to determine that individuals’ impairments meet the disability criteria in law. In other cases, SSA compares individuals’ remaining work abilities and vocational factors against the requirements of work in the national economy to make medical-vocational determinations about whether individuals can still perform substantial gainful work. To do so, SSA requires information about occupations that exist in the U.S. economy, how they are performed, and their demands, such as the strength and skill levels required to do them. Currently, occupational information from the Department of Labor’s (DOL’s) Dictionary of Occupational Titles (DOT) forms the basis of SSA’s regulations and policies for determining the existence of work in the national economy and its requirements, as well as individuals’ abilities to perform that work. However, the DOT is widely considered to be outdated. The DOT was last updated in 1991 and as such, DOT occupations and their associated requirements do not capture labor market changes that have occurred since that time. Furthermore, the DOT was not designed for SSA disability evaluation and does not contain all the information SSA needs for determining disability. DOL’s replacement for the DOT, called O*NET, does not meet SSA’s adjudication needs either. SSA has been partnering with the Bureau of Labor Statistics (BLS) since FY2012 to develop the Occupational Requirements Survey (ORS). According to SSA, ORS will be the main source of OIS’s updated occupational information along with selected information from other sources. Between FY2012 and FY2024, SSA obligated over $300 million to the OIS project. However, SSA has not fully implemented the new OIS. According to SSA, before it can do so, it must first revise its regulations and internal policies and modify its computer systems.
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