Chapter 8

8

Disability Determination

This chapter discusses the use of occupational information for disability
determination. Although O*NET was envisioned as a replacement for the Dictionary of
Occupational Titles (DOT), the Social Security Administration (SSA) continues to rely on the
DOT when making disability determinations. The chapter first reviews the history of the use
of occupational information in the process of disability determination. It then discusses prior
interagency efforts between the Department of Labor (DOL) and SSA to develop an
occupational information database suited to the process of disability determination and prior
research on the use of O*NET for disability determination. The third section evaluates the
potential use of O*NET data vis à vis the specific types of occupational information required
in the disability determination process, and the final section presents the panel’s conclusions
and recommendations in this area.

OCCUPATIONAL INFORMATION NEEDS OF THE SOCIAL SECURITY
ADMINISTRATION

The Social Security Act (Section 223(d)(2)) establishes that disability determination
requires that an individual’s physical or mental impairment is of such severity that she or he is
not only unable to do his or her previous work but cannot, considering his or her age,
education, and work experience, engage in any other kind of substantial gainful work that
exists in the national economy. “Work which exists in the national economy” is defined as
work found in jobs that exist in significant numbers in either the region where such 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 Social Security Administration
(SSA) took administrative notice of the Dictionary of Occupational Titles (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 rehabilitation
experts and others 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 (General Accountability 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.”

THE FUTURE OF OCCUPATIONAL INFORMATION FOR DISABILITY DETERMINATION

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, issued in September,
2009, recommends the creation of a new “Social Security Administration Occupational
Information System” for use in disability determination (Social Security Administration
Occupational Information Advisory Panel, 2009). The panel recommends developing an
initial, empirically derived work taxonomy; research to examine various job classification
methods; development of internal and external research capacity at SSA; basic and applied
research on work-side and person-side job attributes and demands; development of scales and
measures; and communication with users, the public, and the scientific community.
SSA has concluded that, in its current form, O*NET does not fulfill the needs of the
disability determination process. At the same time, the Department of Labor (DOL) has
concluded that O*NET fulfills its needs for occupational information; other chapters of this
report show that O*NET meets many other occupational information needs. However,
disability determination was an important use of the DOT and because O*NET was created to
replace the DOT, it seems fair to conclude that O*NET has failed to replace the DOT in this
particular usage.
The panel understands that, pending SSA’s response to the advisory panel
recommendations, the jury is still out on the topic of whether and to what extent O*NET
should be changed or expanded to meet SSA’s needs. However, given public demand for
budgetary restraint and efficient government, which acquire additional importance in times of
economic recession and slow economic growth, duplication in government functions should
be prevented. Therefore, the development of parallel, possibly redundant, occupational
information systems, one for general purposes termed O*NET and the other tailored to the
needs of SSA, is of concern to taxpayers. In addition, dual data collection processes would
seem unnecessarily expensive.
The panel is not advocating the adoption of O*NET by SSA or the development of a
hybrid O*NET-Disability system in the disability determination process. However, we
conclude that a considerably modified and expanded O*NET may be capable of informing the
disability determination process. There are also some potential economies of scale to be
derived from the development of a single occupational information system to be used by both
agencies, which may allow cost-sharing of resources in such functions as data collection and
system maintenance.
An occupational information system that facilitates the process through which
individuals with disabilities obtain gainful employment would help relieve the financial
pressure on the SSA system and also contribute to the mental health of those who become
productive members of society.
Not all stakeholders share the opinion that O*NET cannot be amended to meet the
needs of those involved in disability determination. In fact, the Committee to Review the
Social Security Administration’s Disability Decision Process called for interagency
collaboration (Institute of Medicine, 1998). Its 1998 report encouraged SSA to explore some
interagency agreement “to initiate a version of O*NET that would collect information on
minimum as well as average job requirements to better serve SSA’s needs to assess ability to
engage in substantial gainful activity” (p. 24).
We found evidence suggesting that these calls for collaboration between DOL and
SSA were heeded. In 2000, vocational rehabilitation professionals initiated discussions with
DOL and SSA which led to the creation of the Inter-Organizational O*NET Taskforce with
representatives of 16 associations of physicians, psychologists, therapists, counselors, insurers
and educators (Cannelongo, 2009). The group met for 4 years and proposed development of a
modified version of O*NET called O*NET –D (for Disability) that would incorporate
occupational information gathered in the field by disability professionals trained in job
analysis, using standardized questionnaires. A pilot study of the approach funded by DOL
yielded promising results. Although SSA staff initially agreed with the plan and submitted it
to the SSA administrator, the agency later withdrew its support.
At around the same time, SSA commissioned the American Institutes for Research
(AIR) to examine the suitability of O*NET for the disability determination process
(Gustafson and Rose, 2003). Based on an analysis of the initial O*NET database (the
“occupational analyst” database), the AIR research team found that reliability, definitional,
and anchoring issues could lead to problems if O*NET data were used for disability
determination. At the same time, however, the authors identified specific steps for addressing
these problems. For example, they suggested that a disability decision maker could use
Copyright © National Academy of Sciences. All rights reserved.

O*NET task lists and other descriptive information to help determine the activities of
claimants’ current jobs and described an approach to using selected O*NET descriptors that
would adjust for the positively skewed distributions of ratings of these descriptors. Gustafson
and Rose (2003, p. 15) concluded that “SSA could implement into the [disability
determination process] a version of O*NET that is legally defensible and acceptable to
decision-makers and claimants alike.”
Another piece of evidence, suggesting the continued possibility of collaboration
between DOL and SSA, is the testimony provided by former O*NET director, James Woods,
to the SSA advisory panel on January 13, 2009 (Woods, 2009). In his address, he regretted
that earlier efforts to accommodate the SSA needs into O*NET did not bear fruit; however, he
remained hopeful that O*NET
may provide a basis to help SSA focus on a specific set of data needs and to organize
data within the O*NET framework—for SSA’s specific needs. O*NET, or at least the
lessons learned in developing the O*NET system, may provide a starting point rather
than SSA starting from scratch.
In spite of such past interagency efforts, communication and collaboration between
DOL and SSA regarding a common occupational database now appears quite limited. An
inspection of their most recent communications suggests that both agencies have reached the
implicit conclusion that DOL will not modify O*NET to accommodate disability
determination users, and that SSA will build an entirely different occupational information
system for its purposes. The fact that SSA’s newly formed advisory panel does not include a
DOL liaison suggests that the development of an SSA-sponsored system may proceed
relatively independent of O*NET.
It is important to consider why SSA and other stakeholders deem O*NET inadequate
for disability determination purposes. In the next sections, we present the primary issues that
preclude the use of O*NET in the disability determination process in the eyes of stakeholders,
the available evidence, and our conclusions regarding the type and the extent of the O*NET
modifications called for by each of the issues.

MEASUREMENT OF FUNCTIONAL REQUIREMENTS

In recent years, the concept of disability has shifted its focus from diseases,
conditions, and impairments to the functional limitations caused by these factors (Institute of
Medicine, 2002, p. 4). A key element implicit in the contemporary view of the disability
determination process is the need for an increased understanding of the physical and social
factors in the work environment that may impact the Social Security claimant’s functional
capacity.
There are a number of mental, physical, and psychosensory disabilities that affect the
capacity to work. In the context of disability determination, the role of occupational analysis
is to determine the important job behaviors and the type and level of ability that is required to
perform them. The Americans with Disabilities Act (ADA) states that job requirements
should be linked to essential (not marginal or peripheral) job functions, and that alternate
ways of performing job functions that may require reasonable accommodations should be
considered.

In spite of their importance for job performance, physical abilities have not received as
much attention as cognitive abilities have in the occupational analysis literature (Guion and
Highhouse, 2006). Much of what is known about physical abilities appears to have its origins
in the work of Fleishman and his associates (Fleishman and Reilly, 1992). An overall
summary of this work (Hogan, 1991) suggests that physical abilities can be subsumed into
three general fitness factors: (1) muscular strength, or the ability to apply or resist force by
contracting muscles; (2) cardiovascular endurance, or aerobic capacity; and (3) coordination,
or quality of movement.
Physical abilities are not the only type of ability impacted by disability. Cognitive,
psychomotor, and sensory/perceptual abilities can also be impaired. Fleishman’s approach to
abilities is particularly important because his measures of ability requirements—including
cognitive, physical, psychomotor, and sensory abilities—were adopted in O*NET (Fleishman
and Quaintance, 1984). For example, the 52 ability scales used in O*NET were drawn almost
verbatim from Fleishman and Reilly (1992). Even though all of these 52 abilities conceivably
have implications for disability determination, the panel heard from stakeholders who
questioned their utility in the disability determination process.

Comparing the O*NET and SSA Approaches

Sylvia Karman pointed out a series of shortcomings related to disability determination
in the O*NET approach to the measurement of physical requirements (Karman, 2009). These
shortcomings, along with a critical examination of their rationale, are reviewed below.

Physical Abilities Versus Functional Capacity

Fleishman’s physical and sensory-motor measures use rating scales to assess
occupational requirements along each physical ability dimension. As incorporated into the
O*NET content model, these scales provide a definition of the ability as well as examples of
tasks or job behaviors situated at various points on the scale.
This approach is most useful for a construct or a criterion-related approach to the
validation of measures of physical requirements that are used for selection purposes (Hogan,
1991). For example, a number of tests are available to assess each of these abilities that can
be used to identify capable individuals and can be validated in criterion-related studies
(Fleishman and Reilly, 1992). However, from the point of view of disability determination,
these abilities represent nonspecific, psychologically worded, or unobservable constructs that
cannot be easily tied to specific disabilities or specific groups of muscles, such as those
involved in lifting, kneeling, etc.
Consider, for example, the O*NET ability, Static Strength, which is defined as “the
ability to use muscle force in order to lift, push, pull, or carry objects. It is the maximum force
that one can exert for a brief period of time using the hand, arm, back, shoulder, or leg”
(National Center for O*NET Development, no date; see Figures 4-1 and 4-2). Clearly, this
physical ability construct cuts across very different muscle groups and different body limbs.
In contrast to this type of definition of a physical construct, the SSA disability determination
process relies on the notion of Residual Functional Capacity (RFC), which measures the
ability to perform specific physical tasks, such as lifting 20 pounds with hands and arms. In
the RFC assessment of the claimant, the focus is on specific and observable functions or
behaviors related to lifting, standing, sitting, and pushing, as well as similarly verifiable
(medically and otherwise) postural limitations regarding balancing, crouching, and crawling
(Form SSA-4734-BK, 08-2008).
There is a series of O*NET work context descriptors related to how much time the
occupation requires sitting, standing, climbing, walking or running, and keeping one’s balance
(items 34 through 39 in the work context O*NET questionnaire—National Center for O*NET
Development, no date) that have conceptually parallel items in the RFC assessment, even
though the anchors placed at the various points of these scales are quite different in the two
approaches. For example, SSA uses specific time ranges (e.g., “about 6 hours in an 8-hour
workday”), whereas O*NET uses relative scales (e.g., “about half the time”). The panel also
observes that some O*NET descriptors, such as item 38 in the work context questionnaire,
collapses occupational requirements across posturing, such as kneeling-crouching-stoopingcrawling,
whereas the RFC assessment breaks down each one of these postural limitations.

Sensory and Perceptual Abilities

In contrast to the noticeable differences found in the domain of physical abilities, the
panel identified smaller differences between the O*NET and SSA approaches with regard to
sensory and perceptual abilities. Note for example the almost perfect equivalence between the
O*NET descriptors of near vision, far vision, visual color discrimination, and depth
perception and the RFC assessment (descriptors of near acuity, far acuity, color vision, and
depth perception). The scales and definition of scale points, however, are still quite different
between the two scales.

Environmental Conditions

The RFC assessment involves an evaluation of the claimant’s ability to sustain
environmental factors, such as extreme heat, extreme cold, wetness, humidity, noise,
vibration, and others, using scales ranging from “unlimited” to “avoid all exposure.” Although
the panel did not find perfectly equivalent descriptors in O*NET, the O*NET Work Context
domain involves a number of conceptually similar items related to exposure to either very hot
or very cold temperatures (item 23), such contaminants as gases and dust (item 25), and
whole-body vibration (item 27). The anchors in these O*NET scales range from “never” to
“every day,” and the anchors in the RFC range from “unlimited” to “avoid all exposure.”

Use of Behavioral Anchors

O*NET uses the scale format known as Behaviorally-Anchored Rating Scale (BARS),
in which behavioral anchors representing differing degrees of a construct are placed along the
scale continuum (see Chapter 4). The various degrees of the continuum represented by these
scales are illustrated through “anchors” situated at the corresponding scale points. These
anchors are short statements describing tasks purportedly representing the level of the
construct: “light a candle” is placed next to the scale point 2 in the Ability scale termed Arm-
Hand Steadiness,” “thread a needle” is placed next to the scale point 4 in the same scale, and
“cut facets on a diamond” is placed next to the point 6 in the scale.

Clearly, there are variations in the degree of arm-hand steadiness lying between any of
these pairs of proximal anchors. If the O*NET occupational unit score on arm-hand
steadiness is 3 (requiring a level of arm-hand steadiness between 2–light a candle and 4–
thread a needle), it seems nearly impossible to determine the type of task that a potential
claimant should be able to complete to be deemed capable of performing work in this
occupation unit. For example, two Social Security disability claimants, both of them capable
of lighting a candle and unable to thread a needle, may or may not be able to perform an
occupation with a score of 3 on this ability. This could be true because the two claimants
have different limitations in their degree of arm-hand steadiness, despite the fact that both of
them are unable to thread a needle.
Still another issue related to the behavioral anchors employed in the O*NET physical
ability scales is whether ability requirements are scaled at the level of the ability required by
the most demanding task or the typical (average) task. For example, a Social Security
claimant may be capable of performing the occupation because she or he has enough armhand
steadiness to thread a needle, so long as threading a needle represents the maximal level
of ability that would be required on the job; however, that same claimant may be unable to
perform all the work in the occupation if threading a needle represents the level required by
the typical, average, or everyday task.

Source of Physical Requirements Information

Another concern is about the source of the ability requirement information. Karman
viewed the National Center for O*NET Development’s use of trained occupational analysts to
judge ability requirements, using solely a written description of the occupation, as an obstacle
to relying on this information for disability determination purposes (Karman, 2009). This
concern may be accentuated when physical requirements are being determined, because many
of them lend themselves to job observation. The process of disability determination can be
quite litigious, and those in charge of making the determination prefer to minimize the risk of
legal challenges by relying on occupational information gathered directly by trained
vocational or job analysts. As noted in chapter 1, trained occupational analysts gathered
information directly from job incumbents for inclusion in the DOT.

Level of Aggregation in Occupational Categories

According to Karman (2009), the number of occupations included in O*NET is too
small for disability determination purposes, because each occupation involves multiple,
heterogeneous jobs that may have different physical and education requirements. If her
assertion is correct that there is a wide range of physical and education requirements of jobs
within the same O*NET occupation, then SSA would find it nearly impossible to determine
whether or not a given disability precludes a claimant from performing a specific job in the
occupation.
The process used to create and write descriptions for the 1,122 original O*NET
occupations, referred to as “occupational units” was complex, according to a report of the
National Center for O*NET Development (1998). It entailed the use of the occupational
classification system adopted by the Bureau of Labor Statistics to administer the Occupational
Employment Survey, the development of crosswalks to DOT title codes, cluster analyses of

DOT data, analysis and aggregation of DOT task statements, and multiple reviews by subject
matter experts. As described in this report, even though DOT titles and task data contributed
to the original formation of these occupational units, the occupational units were not the
outcome of a simple clustering of DOT titles, nor were they meant to represent simple
aggregations of DOT titles. It is not unreasonable to conclude that, at the end of this process,
each occupational unit had its own identity independent of—though partially informed by—
DOT titles and task content.
Since that time, the O*NET occupational classification system has been revised
several times, so that the current O*NET-SOC 2009 occupations may exhibit less within occupation
variability than did the occupational units created by the research team in the late
1990s. Nevertheless, the reduction from over 12,000 occupational titles in the DOT to the
current 1,102 occupations in O*NET-SOC 2009 will inevitably be accompanied by some
increase in within-occupation variability.
Karman presented a chart indicating wide variability in education and physical
requirements across 553 DOT titles that she said were clustered into a single O*NET
occupational unit (51-9198, Helpers-Production Workers) (Karman, 2009). Harvey (2009)
presented similar data and drew similar implications regarding what in his view constituted
excessive aggregation in the original O*NET occupational units for the purpose of disability
determination. However, as noted above, the occupational units were not intended to be
merely aggregated DOT titles. The question of the extent of variability in current O*NET
occupations deserves further study.

CONCLUSIONS AND RECOMMENDATIONS

The Social Security Administration’s disability determination process currently relies
on assessment of the residual functional capacity of a claimant, focusing on physical functions
or behaviors and postural limitations. Matching the results of the RFC to the descriptors of
physical ability and occupational context employed in O*NET is inherently difficult.
Nevertheless, there are commonalities in the descriptors used in these two systems, even
though substantial differences remain in the level of detail, specificity, and types of scales
employed to measure them. The evidence indicates that occupational descriptors involving
exposure to unusual environmental demands, such as heat or cold, exist in both O*NET and
the RFC assessment used by SSA. However, there is no clear, one-to-one correspondence
between the two types of environmental descriptors, because some environmental factors are
defined and grouped quite differently in the two models. Taken together, the differences and
similarities suggest that continued collaboration between DOL and SSA is in the interest of
efficient use of government resources.
Recommendation: SSA and DOL should create an interagency task force to
study the viability of potential modifications of O*NET to accommodate the
needs of SSA with regard to disability determination. Before implementing these
or similar modifications, however, we recommend that the task force conduct (1)
an in-depth needs analysis of the occupational information required by the
current disability determination process and (2) an interagency cost-benefit and
cost-sharing analysis of the additional resources that would be needed to make
O*NET suitable to the disability determination process.

The reduction from over 12,000 occupational titles in the DOT to the current 1,102
occupations in O*NET-SOC 2009 has been accompanied by some increase in withinoccupation
variability in the physical and mental requirements of the work included in these
two different types of occupational categories. Because the extent of this variability has
important implications for the usefulness of O*NET in disability determination, it should be
studied.
Recommendation: As part of the research on the occupational classification
system recommended in Chapter 3, the Department of Labor should commission
research to determine whether and to what extent O*NET occupations represent
excessively heterogeneous clusters of jobs (in terms of their physical and
education requirements) for the purpose of disability determination. This
research should include gathering evidence from firsthand observations
regarding physical requirements and verifiable survey responses from wellinformed
sources capable of assessing cognitive requirements.

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Copyright © National Academy of Sciences. Permission is granted for this material to be
shared for noncommercial, educational purposes, provided that this notice appears on the
reproduced materials, the Web address of the online, full authoritative version is retained,
and copies are not altered. To disseminate otherwise or to republish requires written
permission from the National Academies Press.

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March 20 Letter From AFGE To Commissioner Astrue

March 20, 2009

Commissioner Astrue:

On February 23, 2009 I sent you a letter regarding the Commissioner’s broadcast that you issued to all SSA employees on February 17, 2009 regarding the Economic Stimulus bill. In this broadcast you stated that SSA would be hiring 5000 to 6000 new employees in 2009. In my letter I urged you to use this hiring authority as an opportunity to provide current SSA employees past due merit promotion opportunities and to use the new hiring authority to backfill vacancies created by promoting current deserving SSA employees to higher graded positions. I made a legitimate request for information asking what positions SSA intended to fill through outside hires and what positions SSA intended to fill through the merit promotion process.

I received a reply to this letter from Milt Beever, Associate Commissioner of Labor and Employee Relations, on March 2, 2009. Mr. Beever failed to answer the information request and stated that it was premature to speculate on the mix of outside hires and merit promotion opportunities that the Agency would utilize to “make the most efficient use of stimulus resources”. He indicated that the Agency would be designing a plan encompassing a combination of new hires and merit promotion opportunities to make the most efficient use of the stimulus budget authority provided by Congress to SSA.

I responded to Mr. Beever on March 3, 2009 expressing skepticism of the Agency’s assurances regarding providing adequate promotional authority and questioning skewed statistical data that Mr. Beever provided in his response of March 2, 2009 that portrayed a false representation of SSA record regarding merit promotion. I asked for accurate information regarding SSA’s hiring and merit promotion record over the past three years so that we could have a meaningful dialogue regarding this issue. I also questioned whether no decisions have been made in this area since you encouraged managers in your 2/17/09 Commissioner’s broadcast to start the hiring process.

On March 9, 2009 Mr. Beever sent me an e-mail and stated that I should receive a response to my March 3, 2009 letter by March 16, 2009. No response has been received to date.

Last week on March 11, 2009 you sent another message to all SSA employees regarding President Obama’s signing of the FY 09 appropriations bill and your decision to lift SSA hiring restrictions. Your broadcast also provided information regarding the FY 10 appropriation request. In the broadcast you assert that President Obama and Congress provided SSA with budgetary support in the stimulus package, the FY 09 and FY 10 budgets due to your efforts to communicate SSA’s budgetary requirements. Your self serving plaudets ignores the work that numerous SSA employees have done to educate and lobby Congress and the Obama administration for more resources for SSA. Your failure to acknowledge such efforts in this broadcast is an insult to those employees who are dedicated advocates of SSA. It also contradicts history which is that your FY 09 budget request was actually less than that requested by your predecessor in FY 08. Congress provided a higher budget than you requested for FY 09 primarily due to efforts of SSA unions, SSA management organizations and retirement and disability constituent groups. All these organizations urged Congress for more resources since your request was too low.

Your March 11 broadcast further urges managers to “begin laying the groundwork for bringing on new employees”. Despite the statements of Mr. Beever that it is “premature for us to speculate” regarding hires and promotions, it is clear that management has already made its decisions regarding how many employees will be hired, what jobs they will be hired to fill and the mix of hires for each SSA component. As is your legacy, you have failed to communicate those decisions to the Union despite clear requests by AFGE for this information. In addition, your agent, Mr. Beever, has failed to tell the truth regarding SSA’s intentions and ignored his own deadlines for providing AFGE requested information.

The Union has learned from numerous sources that SSA has allocated positions to managers with hiring authority and decisions have been made on which positions to fill. Information has been provided to other groups regarding the number of positions SSA intends to fill in each SSA component and in the DDS. In fact the Union has learned that you intend to fill the following vacancies:

• 157 ALJs

• 600-700 ODAR

• 175 PSC

• 125 TSC

• 1450 Field – DCO

• 1000 DDS

If these figures are accurate, rather than hiring 5000-6000 employees in SSA as you stated in your 2/17/09 Commissioner broadcast, the Agency is only hiring about 2600 SSA workers and 1000 DDS workers. The field which is about 58% of the SSA workforce will only receive about 25% of the new employees that you stated in your 2/17/09 broadcast that SSA would hire in 2009. In view of the problems with the inability of the public to reach SSA employees by phone through either the 800 number or at their local office, and in view of the failure of SSA to process significant portions of its Continuing Disability Review and redetermination integrity workloads, and in view of the increased interviewing waiting times in field offices across the country, it is incomprehensible that SSA would devote such a small percentage of jobs to the field/TSC. Please confirm whether the above figures are accurate and please explain why the field is being shortchanged in comparison to its size and the backlog problems.

Your two Commissioner broadcasts regarding the budget, the stimulus package and SSA hiring plans are notable in that neither address merit promotion opportunities that SSA should offer to existing employees in conjunction with this hiring effort. While the existing workforce is anticipating long neglected promotional opportunities, your messages offer no hope to employees that SSA will be afforded any promotional opportunities in conjunction with the Agency’s hiring plans. Lower graded SSA workers have been patiently waiting for promotional opportunities and SSA appears to be telling them to continue to wait, since the stimulus hires will be to jobs in the normal line of promotions. Please confirm or clarify this conclusion.

It is also evident that managers in the field have been instructed to use discredited non competitive hiring authorities such as the Federal Career Intern Program (FCIP) to fill SSA vacancies. Managers are informing employees that they are seeking new hires at colleges and using other non-competitive sources. Jobs are not being posted on the USA jobs network for competitive hires. Despite the use of FCIP, SSA appears to have a strategy to cover up the fact that this has become their primary hiring tool. The SSA National Recruitment Guide of July 2008 states:

SSA will use all available recruitment and retention resources to attract, recruit and retain employees, particularly those with critical and hard-to-fill skills. Do not reference FCIP. (Emphasis added) We do not want to highlight our use of FCIP in light of the pending NTEU suit against OPM which alleges that agencies use FCIP to circumvent merit systems principles. We’re trying to avoid being dragged into the lawsuit.

You should be wary of using non-competitive hiring authorities such as FCIP. SSA’s own statistics indicate that in FY 08 62% of hires in SSA were done under FCIP. Only 4.68% of these hires were veterans. Only 26% of hires in SSA in FY 08 were done under competitive procedures. However, 17.45% of competitive hires were veterans. FCIP clearly discriminates against veterans yet you persist in using it as the primary mechanism for hiring new employees. Reports indicate that FCIP and other non-competitive hiring methodologies will be the exclusive procedure for hiring new employees authorized under the stimulus budget despite the adverse affect this will have on veteran employment opportunities. To use such a discriminatory hiring mechanism during wartime is unfathomable. To hide to avoid lawsuits is disingenuous.

AFGE has also received a number of reports from employees complaining that managers have used FCIP to hire their relatives, friends, neighbors, fellow church members, etc. Examples are the FCIP hire of Ryan Kulinski, son of Milwaukee DT District Manager Mark Kulinski or the FCIP hiring of Mark Fansler, nephew of Seattle Area Director Steve Dymale. Both Kulinski and Fansler were not only FCIP hires but they were quickly selected at the first opportunity to higher graded positions instead of highly qualified veteran employees who were not related to management. It is clear that the FCIP method of selection is corrupt. The FCIP hiring system is unfair to selectees in that it subjects them to a 2 year probationary period instead of the 1 year probationary period that exists for competitive hires. 1 year is a sufficient period of time for SSA to determine whether an employee possesses the necessary tools to succeed as an SSA employee. Requiring an additional year of probationary period is oppressive. I urge you to terminate this corrupt and discriminatory non-competitive system for hiring. If the Agency persists in using FCIP as a hiring mechanism AFGE will seriously consider filing a law suit to force the Agency to terminate this hiring mechanism which was not ever designed for the routine hiring that SSA is using with stimulus revenue.

Your March 11, 2009 Broadcast concludes by touting SSA as “A leader of hiring persons with disabilities and that we should continue our outstanding record in hiring and promoting these employees”. This statement is highly deceptive and distorts the truth. SSA does have a higher percentage of disabled employees than most Agencies. However, SSA’s promotion record for the disabled is miserable. Evidence indicates that the disabled are selected for promotions when they appear on well qualified lists at a significant smaller percentage than non-disabled employees. This poor promotion record has caused many disabled SSA employees to file a class action discrimination case against SSA for its failure to promote the disabled. This case has been certified by the EEOC as a proper class and AFGE is confident that the evidence will show that SSA discriminates against the disabled in the merit promotion process. You should concentrate in eliminating such discrimination rather than ignoring it and issuing false self praising missives.

The union expects you to provide the information that we have requested regarding hires and promotion plans for 2009. AFGE requests that your hiring strategy for 2009 take into account the widespread promotional aspirations of the workforce. AFGE also requests that you reconsider the distribution of staff resources and fill vacancies in the field proportionate to the field’s percentage of employees. The Union also urges you to abandon the FCIP hiring system and to take steps to eliminate discrimination in promotions for SSA’s disabled workforce.

Sincerely

Witold Skwierczynski

AFGE General Committee

Cc: AFGE General Committee

AFGE SSA Local Presidents

J. Gage

M. Beever

L. McMahan

M. Baucus

J. Tanner

AFGE Statement

STATEMENT BY AFGE COUNCIL PRESIDENT WITOLD SKWIERCZYNSKI, REGARDING EAA FACILITIES AT SOCIAL SECURITY ADMINISTRATION HQ, BALTIMORE, MARYLAND

Date: Saturday, February 7, 2009, 12:26 AM

Union leaders:

Yesterday Commissioner Astrue sent an inflammatory message to every SSA and DDS employee regarding the Employee Activity Association (EAA). There are separate Employee Activity Associations within SSA in various locations throughout the SSA universe. Mr. Astrue’s poorly worded communication to every employee has raised questions regarding the survival of these numerous EAA’s. Although I am hardly a spokesperson for Mr. Astrue, I do believe that his message to SSA and DDS employees concerns the Baltimore Headquarters EAA.

The EAA has provided services to SSA employees in the Baltimore area for 68 years. The EAA has run both SSA Headquarters day care centers since 1991. They also ran the Headquarters fitness centers. The EAA also has stores which provide postal services, bill paying services, transportation services, etc. The EAA also sponsors SSA athletic teams and was the ticket vendor for the annual SSA night at the Orioles game.

Last year Commissioner Astrue contended that the Agency had received complaints about child abuse at the day care center and that the Agency conducted a survey regarding child care services and the EAA scored poorly on the survey. Commissioner Astrue initiated an “investigation” and admitted that the child abuse allegations could not be proven. GSA had conducted national day care surveys and the Headquarters EEA run day care centers scored high on the survey. Astrue, however, devised his own unscientific survey, distributed it selectively to parents and used a scoring system that penalized for unanswered questions. He then compared it to the average scores of the GSA survey which asked different questions. This was clearly a bogus attempt to achieve a preordained result – a finding that the EAA run day care centers had poor acceptance from parents.

Astrue then asserted that there were financial irregularities in the management of the day care centers. Although the EAA undergoes an annual audit, they invited Astrue to audit its day care operations. While conducting the day care audit, Astrue’s auditors started demanding records for the fitness center. Users of the fitness center are required to provide medical certification to the fitness center in order to use the facilities. Astrue’s auditors demanded to inspect employee fitness center users’ medical records. The EAA demanded to know on what authority SSA was asking to inspect medical records of fitness center users. SSA terminated their audit and alleged that the EAA was being uncooperative.

Subsequently SSA set up a hand-picked Board of Directors for the day care center and demanded that the board fire the EAA and select a new for-profit business to run the day care centers. Astrue took these actions in violation of Article 20 of the AFGE/SSA contract which provides for union participation in the day care center board. The Agency tried to limit union participation. Astrue completely ignored the monitoring role of the National AFGE/SSA Child Care Committee. The national AFGE/SSA contract requires this committee to monitor all SSA child care centers. The Committee is responsible for monitoring the operations and funding of SSA child care centers and is also responsible for analyzing the results of any surveys regarding such centers. Astrue totally ignored this contractual requirement and sent no information regarding the alleged problems regarding the Baltimore child care centers to the National SSA/AFGE Child Care Committee.

The day care center has been handed over to a for profit corporation from Texas. The “abusive” day care staff was retained but their compensation package was cut. Tuitions are expected to increase in the future.

SSA gave notice to EAA at the end of 2008 that it would take over operations of the fitness center and contract out its operation. SSA also notified the EAA that is must close all its stores by 1/16/08.

Employees at Headquarters were outraged and asked the union to take action to Save the EAA. AFGE Local 1923 called for a rally on January 22, 2008 at Headquarters to protest the Commissioner’s actions to shut down the EAA. Senator Barbara Mikulski had already sent a strongly worded protest to Commissioner Astrue on 1/9/09 urging him to stop all plans to undermine the EAA. She criticized Astrue’s “unsupported claims of financial impropriety and mischaracterized statements made by EAA officials”. The Senator also expressed concern about the audit authorized by Astrue “for the sole purpose of trying to shut down the EAA”.

On the day of the rally over 300 SSA employees were greeted by an overwhelming police presence. Commissioner Astrue had summoned police from Immigration and Customs Enforcement (ICE), the Federal Protective Service (FPS) and contract guards. In addition, demonstrating SSA employees were greeted by police dogs. After speeches, AFGE President John Gage, Local 1923 President Cynthia Ennis, and AFGE NVP Joe Flynn attempted to deliver copies of over 3500 postcards that SSA employees had sent to Senator Barbara Mikulski protesting Commissioner Astrue’s actions to eject EAA from SSA. They were greeted by police in the lobby and on the 9^th floor of the Altmeyer Building which is the location of Commissioner Astrue’s office. The aisle to Astrue’s office was blocked by the police. The Commissioner’s Acting Chief of Staff took the box and the event was over.

Veteran SSA union officials who have attended many union rallies at SSA facilities indicated that they had never seen anything like the Astrue ordered police presence which was obviously summoned in an effort to intimidate the demonstrators. Not only did SSA order scores of police to the rally but unidentified photographers, who apparently worked for either SSA or the police agencies, took pictures of the entire rally. The union has subsequently learned that some employees were advised by their managers that it would not be in their best interest to attend the rally. Other managers appeared to purposely schedule meetings at 11 AM (the time of the rally) so employees could not attend the event. Other employees were denied leave to attend the rally.

Commissioner Astrue responded to the Mikulski letter with unspecific assertions regarding “abuses”, “predatory conduct” lack of “professional care” by the EAA. In the letter he falsely stated that I told him that any change in child care vendors would result in an abrupt increase in
child care fees. I have never had any conversation with Mr. Astrue about the EAA. Such attacks are similar to his false accusations against me last year that I had mischaracterized the fact that SSA closed a record number of offices in 2007 and, according to Linda McMahon, intended to close many more. Facts are facts and the record of 15 closed offices in 2007 is the most SSA closed in any other year.

Congressman Elijah Cummings, whose district includes the SSA Woodlawn Headquarters complex, has subsequently sent a strongly worded reply to Astrue’s response to the Mikulski letter. He specifically criticizes Astrue’s unsupported allegations regarding financial impropriety by the EAA.

Yesterday an AFGE ad appeared in the Baltimore Sun which specifically criticizes Astrue for his views on privatizing SSA and his actions against the EAA. (Although Astrue has remained silent on privatization legislative proposals, he does effusively praise aggressive privatization advocates such as Andrew Biggs and Dorcas Hardy, both with extensive backgrounds in the CATO Institute which supports eliminating SSA.) The ad criticizes the fact that under Astrue’s watch SSA’s staff and budget have been inadequate to meet the needs of the American public. It expressed No Confidence in his continuing ability to lead SSA. This ad mirrored the No Confidence petition that many of you signed.

On the same day an article was published in the Washington Post in which AFGE President Gage indicates that the union is asking President Obama to seek Commissioner Astrue’s resignation and, if he refuses, will be asking the President to remove him for malfeasance and neglect.

Commissioner Astrue’s response to yesterday’s newspaper ad and story was to attack the EAA and attack AFGE in his Commissioner’s Broadcast to all SSA and DDS employees. He attacks AFGE for threatening political retaliation against him and “Social Security’s career civil service”. In response, Commissioner Astrue has done a lot of damage to SSA in the 2 short years that he has been in charge of the Agency. He has submitted inadequate budget requests, has created an iClaims system which cheats hard working wage earners of their hard earned benefits, has transformed SSA from an Agency that prides itself in assisting the public in obtaining the best possible benefit package when they apply for benefits to an Agency that ignores evidence that claimants are making choices guaranteed to cause them to lose benefits and has worked to destroy the community based SSA service structure by closing offices and/orwstripping offices of sufficient staff able to provide adequate services to customers.

He implies that the Union supports dishonesty, opposes transparency and compliance with the law. Yet Mr. Astrue makes false statements regarding conversations with me that never happened. He does not tell the truth about office closings. Now, while attempting to convince Congress to agree to provide $750 million for a new National Computer Center (NCC), Commissioner Astrue has declined to inform the Union, NCC employees or Congress that SSA intends to move the NCC out of the Baltimore commuting area to Frederick or Westminster MD. Commissioner Astrue doesn’t seem concerned about the impact of such a move on either the 4000 employees who work at the NCC or the affect on the community that the loss of 4000 jobs will create. This secret effort to move the NCC into the only Republican Congressional District in MD must be Astrue’s definition of transparency.

SSA officials who undermine the program and are incompetent should be removed. Thus, Astrue should resign and “career civil service” officials who are either incompetent or have harmed the agency like Wells, McMahon and Beever also need to be replaced. President Obama needs SSA leaders who he can work with and not this crew who are actively attempting to undermine SSA. It’s time for a change.

Witold Skwierczynski /s/

President

AFGE Council 220

Social Security Ruling 96-8p As Originally Published

NASI Proposals

PROTECTING SOCIAL SECURITY BENEFITS FROM GARNISHMENT

Because Social Security and Supplemental Security Income (SSI) benefits are essential to meet basic needs, the Social Security Act protects the benefits from garnishment or attachment by creditors. Nevertheless, when benefits are deposited in a bank account, beneficiaries may find that their accounts have been temporarily frozen, or worse, permanently garnished at the behest of a creditor under provisions of statelaw. Because the government encourages direct deposit, over 80 percent of Social Security and SSI recipients receive their benefits electronically. In Safer than the Mattress, John Infranca proposes a five-part legislative and administrative policy solution to ensure that Social Security and other exempt federal benefits remain safe from garnishment, attachment, and freezes when they are deposited in a bank.

HELPING HOMELESS INDIVIDUALS WITH SERIOUS MENTAL ILLNESS GET DISABILITY BENEFITS

Social Security and SSI disability benefits are often the main sources of stable income for people who have serious mental illness. Individuals who are homeless face particular barriers in navigating the application process. They typically lack a mailing address, transportation, and a treatment history from accepted medical sources (physicians or licensed psychologists). In Improving Social Security Disability Programs for Adults Experiencing Long-term Homelessness, Yvonne Perret and Deborah Dennis
propose three strategies to address these barriers: (a) expand the acceptable
medical sources to include professions likely to be available in publicly funded health and mental health care systems; (b) use SSA’s presumptive eligibility for SSI disability benefits for people with schizophrenia who are homeless for at least six months; and (c) modify the administrative process to accommodate homeless individuals consistent with SSA’s Homeless Plan of 2002.

STRENGTHENING SOCIAL SECURITY WAGE REPORTING FOR FARM WORKERS

Farm workers are at risk of not having their work count toward Social Security benefits because their employers may erroneously classify them as independent contractors or simply fail to pay Social Security taxes and report wages. In Strengthening Social Security for Farm Workers: The Fragile Retirement Prospects for Hispanic Farm Worker Families, Barbara Robles supports legislation introduced in the 110th Congress, along with stronger enforcement of existing laws, to strengthen wage reporting. She notes that the changes would increase tax receipts and benefit the Latino farm worker population by increasing their Social Security benefits, providing better access to the Earned Income Tax Credit, and easing the burden on adult children of farm workers who have the triple burden of school debt, raising children and supporting aging parents.

REDUCING ELIGIBILITY REQUIREMENTS FOR RETIREMENT BENEFITS

To qualify for Social Security retired-worker benefits, individuals must have worked at least 40 calendar quarters (ten years) in jobs covered by Social Security. In The Effects of Reducing Eligibility Requirements for Social Security Retirement Benefits, Andrew Biggs examines the impact of eliminating the 40-quarters eligibility requirement. A small group of individuals (about 6 percent of those born in 1950) would gain eligibility for Social Security retired-worker benefits. The increases in benefits would often substitute for means-tested SSI benefits. Much of the new benefits would flow to immigrants who are not otherwise eligible for Social Security.

IMPROVING BENEFITS FOR WIDOWED SPOUSES OF LOW-EARNING COUPLES

Social Security is especially important to older women, particularly widows. Most poor elderly women are widows. Social Security survivor benefits help to bridge the transition to widowhood, but the benefits are less adequate when both the husband and wife had worked at low pay. In Strengthening Social Security Benefits for Widow(er)s: The 75 Percent Combined Worker Benefit Alternative, Joan Entmacher proposes to increase benefits for widowed spouses of low-earning dual-earner couples. The new widowed-spouse benefit would be 75 percent of the combined retired-worker benefits of the husband and the wife, but would be capped to not exceed the benefit for one person who had earned the average wage over a career.

INCREASING THE SOCIAL SECURITY SPECIAL MINIMUM BENEFIT AND UPDATING SSI

A special minimum benefit was added to the Social Security program in 1974, but few receive it today because it does not keep up with wage growth. In Enhancing Social Security for Low-Income Workers: Coordinating an Enhanced Minimum Benefit with Social Safety Net Provisions for Seniors, Laura Sullivan, Tatjana Meschede and Thomas M. Shapiro examine ways to update the special minimum benefit so that individuals with 30 years of work covered by Social Security would receive benefits that meet the updated poverty measure of the National Academy of Sciences, which is about 125 percent of the current official poverty threshold. They also propose to update SSI to reflect inflation since the program began – that is, increase the asset limit for individuals from $2,000 to $6,700 and increase the general income exclusion from $20 to $89.

A NEW SOCIAL SECURITY MINIMUM BENEFIT FOR LOW LIFETIME EARNERS

Despite a lifetime of hard work, many workers end up poor or near poor in
retirement. In A New Minimum Benefit for Low Lifetime Earners, Melissa Favreault examines a new minimum benefit that targets workers with long careers and low lifetime earnings, along with a modest credit that compensates for up to three years of low (or no) earnings due to caregiving, unemployment, or poor health. The benefit at the full retirement age would pay 60 percent of the poverty threshold for a worker with 20 years of Social Security covered work and increase to 110 percent of the poverty threshold for a worker with 40 years of work. Caregiver credits would be available only in years when a child is under age 4 and only to one parent. The credit
would be 60 percent of the average wage in the first such year, 50 percent in the second year and 40 percent in the third year.

A SOCIAL SECURITY SUPPLEMENT FOR LOW-INCOME WORKING PARENTS

Social Security provides benefits for spouses and widowed spouses, but does not provide credit for raising children. A growing portion of retiring women will not qualify for spousal benefits because they are divorced (with less than 10 years of marriage) or never married, yet will have earnings records that are limited because of time spent caring for their children. In Crediting Care in Social Security: A Proposal for an Income-Tested Care Supplement, Pamela Herd proposes to supplement Social Security benefits for retirees who have raised one or more children. The supplement would be an additional 75 percent of the worker’s benefit (80 percent if two or more children were raised) but would be capped to not push the retiree’s household income above 125 percent of the poverty threshold. The benefit and income testing would be administered through individual tax returns, similar to the Earned Income Tax Credit.

INCREASING SOCIAL SECURITY BENEFITS FOR FAMILY ELDER CAREGIVERS

Informal care provided by family members improves quality of life for frail elders, allows them to remain in the community instead of in nursing homes, and saves Medicaid dollars. Providing the care also imposes opportunity costs on caregivers that weaken their own retirement security. In Retirement Security for Family Elder Care Givers, Shelley I. White-Means and Rose M. Rubin propose to provide up to four years of Social Security credit to individuals who provide care to elders. The elders must be certified to need levels of care that would qualify for Medicaid coverage. The value of the credit would be the caregiver’s average wage in the three years before caregiving interrupted earnings. The authors suggest the credit could be financed based on the reduction in public spending for nursing home care.

INCREASING SOCIAL SECURITY BENEFITS FOR LOW-WAGE SINGLE RETIREES

Single retirees (that is, never married, divorced or widowed) are at high risk of being poor in old age. The decline in private pensions, rising out-of-pocket health costs, and declining housing values can be expected to make the already precarious financial situation of unmarried retirees even worse. In Restoring Old Age Income Security to Low-Wage Single Workers, Patricia Dilley proposes a change to the basic Social Security retired-worker benefit formula that would increase benefits for single retirees with at least 30 years of covered employment and low lifetime earnings. A second change would target single beneficiaries over age 85. Those who had at least 30 years of covered work, and received relatively low benefits (less than 75 percent of the average benefit), would receive a 10 percent benefit increase at age 85.

INCREASING SOCIAL SECURITY BENEFITS AT ADVANCED AGES

People who live into their 80s and 90s face a growing risk of becoming poor. They rely more and more on Social Security because their other sources of income decline as they age: private pensions, if received, are eroded by inflation; income from work is very rarely an option; and financial assets may have been spent. In Longevity Insurance, Strengthening Social Security at Advanced Ages, John Turner proposes increasing benefits at age 82 (about the average life expectancy at age 65) for beneficiaries with low Social Security benefits and long work histories. This longevity insurance would improve financial security for individuals who live longer than the
average life span.

EASING THE IMPACT OF INCREASING THE RETIREMENT AGE: OCCUPATIONAL DISABILITY

Legislation in 1983 increased from 65 to 67 the age at which Social Security pays full retirement benefits. The change lowers retirement benefits at each age they are claimed. Disabled-worker benefits remain unreduced, but are not available to individuals who fail to meet a strict test – “inability to engage in any gainful activity” – yet are unable to continue in their jobs. In Strengthening Social Security for Workers in Physically Demanding Jobs, Eric Klieber proposes a benefit for such individuals based on an occupational disability test – “inability to perform the essential duties of one’s current occupation.” Making such an occupational disability benefit available at age 62 could protect recipients from retired-worker benefit reductions (or part of such reductions) due to increasing the full benefit age.