Statement Regarding SOC Testing

January 22, 2013

Response to OMB from the Dept. of Labor regarding the incorporation of SOC codes into the NASS’s Agricultural Labor Survey.

1. The Department of Labor (DOL) has already entered into a financial agreement to support the USDA-NASS Farm Labor Survey (FLS) for calendar year (CY) 2013, which explicitly collects employer wage survey data in the same manner that it has been collected for many years and consistent with our regulatory requirements under the H-2A visa program.

2. During CY 2013, DOL would find it acceptable for the USDA-NASS to begin the process of developing a methodology for conducting a pilot test against the new SOC codes and sometime during the fall (Oct-Nov) of 2013 delivering a proposal to our office, including level of effort and cost, for implementing a pilot program during CY 2014.

3. This is the same approach DOL followed when implementing a revised collection method every 6 months as opposed to every 3 months and the DOL Departmental legal counsel was able to sign-off that the results of the revised collection would not compromise our under statutory and regulatory requirements under the H-2A visa program.

Once DOL has secured funding for CY 2014, the pilot test program will be implemented by NASS. Following the test, the data will be assessed and the results shared with DOL. Following the test the USDA-NASS will prepare a report and will discuss with DOL the level of effort, burden, and cost s that would be associated with a nationwide implementation. The DOL will provide any additional funding needed to implement the revised survey.