Mr. Johns began his discussion by running through the Hierarchy of SSA Instructions. This began with the Social Security Act, which introduced the definition of disability and established the basis of the disability program. From there, laws were passed known as the Code of Federal Regulations. These regulations were interpreted or explained through Social Security rulings. Once these rulings were made they were added to the POMS and OHA’s version called the HELIX. Changes made in the POMS or regulations are issued as an EM or emergency message. Reminders of these regulations are distributed through program circulars. The last step in the hierarchy is memoranda, which are not policy, but rather answers to a question about a specific case.

The 2001 SSA Vocational Conference was held from September 11 though September 13 and included over 40 representatives from the DDS, RO, DQB, OHA, and CO. At the conference they performed an initial review of six vocation Social Security regulations and looked at ways to consolidate and eliminate numerous memoranda. At the 2002 conference they will unveil the new Social Security regulations, conduct training on the new regulations, and get a consensus on problem issues with the proposed regulation changes.

Mr. Johns discussed two of the proposed changes that were developed during the 30-Day Workgroup. The first one would be to reduce documentation of a claimant’s work history from 15 years to five years. The pluses of doing this would be to reduce the reporting burden on the claimants, save time and resources for the DOs and DDS, reduce reporting errors, and to become more consistent with changes in the workforce. The drawbacks of this proposal would be elevated program cost due to an increase in allowances, the possibility that this is not an accurate reflection of the changes in the workforce, and the possibility that it would be more sound to reduce this to 10 years instead.

The second proposed change that was discussed was the possibility of combining steps 4 and 5 of the sequential evaluation process and only looking at whether or not the claimant can do any SGA. What this would mean would be that a claimant can be denied at any point if they cannot engage in SGA and they can be allowed at any point if they cannot engage in SGA. The benefits to this proposal would be a reduction of documentation needed for past relevant work, savings of time, money, and resources, and there would be no disadvantage to any claimant.

Mr. Johns also discussed the process that proposed regulation changes must go through before being changes. First draft changes must be prepared. These changes are revised as necessary and signed off on. They are published as NPRM and submitted for external comments. Any revisions are made and signed off on and then they are published as final regulations.

Discussion of the O-Net and its benefits and drawbacks also took place. The O-Net is the occupational information network. The O-Net is a comprehensive database of worker attributes and job characteristics. The benefits to using the O-Net would be easy access from the Internet; ease in usage and understanding; fast, efficient, and consistent computer searches; the usage of common language; and updates every six months. The drawbacks would be that the current information is taken from the DOT, the combination of over 12,000 occupations into 900 units, new rating descriptions with many more than SSA needs, the use of a numerical rating scale, and less description than the DOT. The O-Net is more of a job locator and the information is gathered through questionnaires rather than by individuals in the field. Mr. Johns mentioned three different options that SSA has. They can modify O-Net to meet our needs, use the existing DOT alternatives, or develop their own DOT. Every option will require program changes. Web addresses were also given for anyone who would like to see the O-Net. The two addresses are www.onetcenter.org and http://online.onetcenter.org.