On May 19, 2016, the Department of Labor’s Bureau of Labor Statistics (BLS) published a notice of Proposed changes to occupation, industry, and area detail in the OES survey. The Occupational Employment Statistics (OES) survey is the default source of wage data utilized by DOL's Office of Foreign Labor Certification (OFLC) to make prevailing wage determinations for the H-1B and other temporary programs, as well as the PERM permanent labor certification program.

The current OES program uses the 2010 Standard Occupational Classification (SOC) system to classify occupational wage information. BLS has proposed "changing the occupation, industry, and area detail used in the OES survey. The proposed changes... consist of replacing some detailed data with less detailed aggregations of the occupations, industries, or areas currently published."

  • The first proposed change of concern to the higher education community would aggregate the detailed postsecondary teaching occupations, which are currently surveyed and reported on separately, into a single "postsecondary teachers" category.
  • The second proposed change, which could impact higher education as well as other employers regionally, would aggregate a number of smaller geographical data groupings into larger geographical groupings.

In its June 13, 2016 comment letter, NAFSA urged BLS to refrain from making these changes and offered examples of how they might impact institutions who must request prevailing wage determinations. NAFSA further suggested that before making any such changes BLS should explain the basis for the changes, provide a more detailed explanation of the changes, and use the notice and comment process in the Federal Register so that stakeholders and the public have an ample opportunity to analyze the proposed changes and provide feedback to BLS.

NAFSA also submitted a joint comment letter with the following organizations: American Association of State Colleges and Universities, Association of American Universities, Association of Community College Trustees, Association of Public and Land-grant Universities, Council for Christian Colleges & Universities, and CUPA-HR: College and University Professional Associations for Human Resources.

This proposal is part of the larger 2018 SOC revision process. A similar process occurred in the years leading up to the last SOC revision in 2010. You can learn more about the overall 2018 SOC revision process in DOL's Revising the Standard Occupational Classification document, which also describes the history and structure of the SOC.