NAFSA Recommends Improvements to Standard Occupational Classification (SOC) Manual

July 21, 2014 Download pdf

 

NAFSA submitted this comment letter to the U. S. Department of Labor's Standard Occupational Classification Policy Committee, recommending the following improvements to the Standard Occupational Classification (SOC)Manual which is used in the prevailing wage determination process:

  • Add "detailed occupations" for medical, pharmacy, and veterinary residents and fellows
  • Add "detailed occupations" for postdoctoral fellows and research associates
  • Revise category 11-9039 Education Administrators, Postsecondary
  • Add new interdisciplinary occupations
  • Provide a thorough explanation of the "all other" category in order to enhance its use by the Department of Labor

Read NAFSA’s 2014 comment letter

Read Government Responses to Comments Received on the 2014 Notice

Here is an extract of the Government responses to the 2014 comments that address comments of the type made by NAFSA:

Docket Number 1-0093.02 -- Postdoctoral Fellows and Research Associates (Multiple)

Docket 1-0093.02 requested new detailed occupations for Postdoctoral Fellows and Research Associates. The SOCPC did not accept this recommendation based on Classification Principle 2 which states that occupations are classified based on work performed and on Classification Principle 7 which states that trainees are classified with the occupations for which they are being trained.

Docket Number 1-0093.01 -- Residents, Fellows, and Interns (29-1060)

Multiple dockets requested new detailed occupations for Medical, Pharmacy, and Veterinary Residents, Fellows, and Interns. The SOCPC did not accept this recommendation based on Classification Principle 2 which states that occupations are classified based on work performed. The daily activities of Residents, Fellows, and Interns typically mirror the daily activities of physicians.

Docket Number 1-0093.03 -- Education Administrators, All Other (11-9039)

Docket 1-0093.03 requested new detailed occupations under 11-9039 Education Administrators, All Other for managerial and non-managerial education administrators. The SOCPC did not accept this recommendation based on Classification Principle 2 which states that occupations are classified based on work performed and Classification Principle 3 which states that workers primarily engaged in planning and directing are classified in major group 11-0000 Management Occupations. Occupations within major group 11-0000 are not distinguished by the size of the program being managed and such information is not collectable. Workers who do not have planning and directing responsibilities should not be classified in major group 11-0000.

Docket Number 1-0093.04 -- Interdisciplinary Occupations (Multiple)

Docket 1-0093.04 requested new detailed occupations for interdisciplinary occupations such as bioinformaticians, biotechnologists, and geobiologists, for purposes of determining prevailing wages. The SOCPC did not accept this recommendation because the SOC is designed solely for statistical purposes. According to Coding Guideline 2, when workers in a single job can fall into more than one occupation, they should be coded to the occupation that requires the highest level of skill. If there is no difference in skill level, they should be coded to the occupation in which they spend the most time. The examples provided by the commenter can fit into multiple occupations, so they cannot be added to the direct match title file.

Docket Number 1-0121 -- Faculty (25-1000)

Docket 1-0121 requested clarification on coding postsecondary faculty in higher education. The SOCPC did not accept this recommendation because it acknowledges that postsecondary faculty should be coded based on the work they do, not on their work status (part time vs. full time) or the credit-bearing status of the courses they teach. "Faculty" is a designation that refers to teachers, researchers and those who are administrators in both postsecondary and pre-college institutions. Individuals who are faculty should be coded based on their work activities. The docket also requested more information on sources of training on coding in postsecondary institutions, which will be provided in the final 2018 SOC manual.

Docket Number 1-0181 -- Postsecondary staff (11-1011, 11-3011, 13-1111, 13-2071, 21-1012, 25-0000)

Multiple dockets requested new occupational categories within postsecondary faculty for research and public service staff. The SOCPC did not accept this recommendation. According to Classification Principle 2, research and public service staff should be classified based on the work performed, so they belong in major groups other than 25-0000. Research scientists should be classified under the science field they work in. Multiple dockets also requested clarification on coding occupations in student and academic services that are not instruction. The SOCPC proposes a number of changes to clarify coding in this area. First, to make it clear that not all personnel at postsecondary institutions should be placed in major group 25-0000 Education, Training, and Library Occupations, the SOCPC proposes changing the name of the major group to Educational Instruction and Library Occupations. Second, the SOCPC proposes the following changes to make coding of postsecondary staff clearer: (1) Modify the definition for 21-1012 Educational, Guidance, School, and Vocational Counselors to include workers who provide student services and change the title to 21-1012 Educational, Guidance, and Career Counselors and Advisors. (2) Add University Registrar as an illustrative example for 11-3011 Administrative Services Managers since workers who manage postsecondary admissions and enrollment services are coded there (The clerical workers who work for the Registrar would be coded in 43-4199 Information and record Clerks, All Other, which already lists Student Admissions Clerk as an illustrative example; and the supervisors of these workers, who work under the Registrar, would be included in 43-1011 First-line Supervisors of Office and Administrative Support Workers. (3) Add University Institutional Researcher as an illustrative example for 13-1111 Management Analysts. (4) Revise the definition for 13-2071 Credit Counselors to clarify inclusion of college financial aid counselors. (5) Add University President as an illustrative for 11-1011 Chief Executives.

Docket Number 1-0216 -- Postsecondary Teachers, classification principles, general/non-specific (25-1000)

Docket 1-0216 requested guidance on coding postsecondary faculty who are cross-disciplinary. Based on Coding Guideline 2, these faculty should be coded in the occupation where they spend the most time (e.g. postsecondary teacher or research occupation). For example, a faculty member in the "Plant Science and Landscape Architecture" department whose teaching and research is mainly in plant science would be coded in "25-1041 Agricultural Sciences Teachers, Postsecondary."

Docket Number 1-0093.05 -- Residuals (Multiple)

Docket 1-0093.05 requested changes to Classification Principle 8 to better articulate the usefulness of 'all other' residual categories. The SOCPC agreed and recommended changes to Classification Principle 8.