APA Letter on BLS Measure of Employment Figures for Persons with Disabilities

February 25, 2008

Keith Hall
Commissioner
Bureau of Labor Statistics
2 Massachusetts Avenue, NE
Washington, DC 20212

Dear Commissioner Hall:

On behalf of the 148,000 members and affiliates of the American Psychological Association (APA), I would like to thank you for the opportunity to comment on the Bureau of Labor Statistics’ development of a “statistically reliable and accurate” measure of the employment status of persons with disabilities. APA appreciates the Bureau’s commitment to reliable and accurate data collection on the employment of persons with disabilities and increased coordination across the federal statistical system.

APA is the largest scientific and professional organization representing psychology in the United States and is the world’s largest association of psychologists. Comprised of researchers, educators, clinicians, consultants, and graduate students, APA works to advance psychology as a science, a profession, and a means of promoting human welfare. As such, issues impacting individuals with disabilities are of great importance to our members. This is reflected in part by the Committee on Disability Issues in Psychology, and various other elected governance groups charged with addressing disability such as APA’s divisions on rehabilitation psychology, mental retardation, and developmental disabilities. Psychological research and access to valid statistical data has played a pivotal role in our understanding of the social, emotional, and physiological aspects of human behavior, including disability.

APA strongly supports the inclusion of the additional questions regarding disability status to the Current Population Survey (CPS) in 2009. The CPS has been the principal foundation of official Government statistics with regard to employment and unemployment for more than 60 years. This survey is the only source of monthly data on total employment and unemployment, including data on the basic status and characteristics of persons not in the labor force. Of specific interest is the demographic information on the labor force that can be extracted such as sex, age, race and ethnic origin, marital status, family composition, and educational level.

The proposed collection of information is critical to effectively evaluate the proper performance of programs and functions of the Department of Labor. The wide interest in CPS data among government policymakers, legislators, economists, the media, researchers and the general public reflects the importance of data collected through the survey. In addition, the prevalence of disability in the country’s population highlights the need for disability to be included as a relevant demographic factor.

Efforts have been made to increase employment for persons with disabilities. Data on labor force participation rates could be a valuable indicator with regard to the participation of persons with disabilities. In addition, the inclusion of questions related to disability status may provide an opportunity to evaluate the impact of specific policy efforts.

These new questions may also be used in conjunction with other demographic and labor force data collected in the CPS to examine the characteristics of the population of persons with disabilities such as racial and ethnic minority status. Furthermore, it could also assist in comparisons to the population of persons without disabilities. APA also supports the availability of the maximum amount of information possible to support research without compromising confidentiality to survey respondents.

In closing, APA would like to thank you again for the opportunity to provide comments to this important effort. If you have any questions, please contact Day Al-Mohamed, J.D., in our Public Interest Government Relations Office at (202) 336-6061 or DAl-Mohamed@apa.org

Sincerely,

Annie Toro, J.D., M.P.H.
Associate Executive Director
Public Interest Directorate