If you did not attend NOSSCR in San Diego either in person or virtually, you missed out on a very important message from Jeff. He detailed the incomplete nature of the Occupational Requirements Survey (ORS) and data conflict within the ORS. SkillTRAN holds me out as an important reviewer and co-presenter with Jeff. I have standing to comment.
- The ORS covers 477 of 848 civilian Standard Occupational Classification (SOC) codes. It does cover 90% of the jobs in the national economy and additional SOC codes get covered in the third wave.
- The ORS does not cover General Educational Development (GED) and therefore does not cover Reasoning, Math, and Language (RML). It does cover limited education under the heading of no minimum education required as well and literacy in not required.
- The ORS does not cover either Aptitudes or Temperaments. SSA rejects them anyway.
- The ORS does not cover Balancing, Feeling, or Tasting. In 40 years, theses physical requirements have never been an issue.
- The ORS does not cover visual Accommodation, Color Vision, or Depth Perception. The need for depth perception does arise in some cases.
- The ORS does not consistently report Specific Vocational Preparation (SVP). This is a problem if the case turns on transferability of skills, which is less and less likely with the short past relevant work period.
- The ORS does not consistently merge educational and certificate requirements into SVP. This is a problem because it could lead to the misidentification of work as unskilled when it is not.
- The ORS does not consistently report Strength. Not all strength levels matter so the criticism lacks context. The DOT also contains exertion mistakes -- escort vehicle driver for instance.
- The ORS does not cover Work Fields or Materials, Products, Subject Matter, or Services (MPSMS). This is again a transferability issue; SSA recognizes this data in POMS but does not ask witnesses to use the data.
- The ORS does not cover Guide to Occupational Exploration (GOE) codes. The DOT and SCO do report the GOE codes. No one uses them. They are potentially relevant in the little or no adjustment issues for older workers in transferability. But no one uses them.
- The ORS does not cover job duties or tasks. Jeff suggests that the Occupational Wage and Employment Statistics and O*NET cover this data. For our purposes, actual job duties come up under SSR 00-4p, which is now rescinded.
We have some data. Some data is better than no data. New data is better than out-of-date data. Where the data is missing or the analysis of that data is incomplete, we still have the DOT. And SSA needs to grow up and start using the O*NET for the data points that are unrelated to exertion -- for the same reasons. Some data is better than no data or out-of-date data. The Courts must start enforcing the administrative notice regulation. 20 CFR 404.1566(d).
If you missed the San Diego conference, get the sessions from NOSSCR. Not just this session but certainly including this session.
Just do it.
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Suggested Citation:
Lawrence Rohlfing, The Problems with the ORS -- Jeff Truthan Speaks at NOSSCR, California Social Security Attorney (September 12, 2025) https://californiasocialsecurityattorney.blogspot.com
The author has been AV-rated since 2000 and listed in Super Lawyers since 2008.
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Suggested Citation:
Lawrence Rohlfing, Boonthong -- Replicating Vocational Witness Methodology at the Appeals Council, California Social Security Attorney (September 1, 2025) https://californiasocialsecurityattorney.blogspot.com
The author has been AV-rated since 2000 and listed in Super Lawyers since 2008.
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