Advocacy Archive

Letter to the Office of Management and Budget Recommending Changes in Classifications

October 9, 1998

Katherine K. Wallman
Chief Statistician
Office of Management and Budget
10201 New Executive Office Building
Washington, DC 20503

Dear Ms. Wallman:

I am writing on behalf of the 15,000 members of the American Psychological Society (APS), the vast majority of whom are psychological scientists conducting research at colleges and universities across the country. Much of the research is federally-funded by agencies such as the National Institutes of Health, the Department of Defense, and the National Science Foundation. It is from the perspective of this scientific community that we are requesting changes in the occupational classification system proposed in the final recommendations of the Standard Occupational Classification Revision Policy Committee (SOCRPC), as published in the Federal Register on August 5, 1998 (pages 41895-419243).

Our comments pertain to Major Group 19, "Life, Physical, and Social Science Occupations." To summarize our concerns: The classifications for psychologists as currently written do not capture the distinction between psychologists who are practitioners -- providers of psychological services, and psychologists who are scientists -- those engaged in the conduct of psychological research. Further, in the current version, psychology is classified solely as a social science, when in fact as many or more psychologists conduct behavioral or biological research as conduct social science research. These issues are discussed in detail below.

In order to ensure that the occupational classification system reflects these distinctions, we propose adding a separate minor group for "Psychological Scientists" in Major Group 19, and removing psychologists from the existing "Social Scientists" classification group. These changes, outlined below, clarify the existing occupations in the field of psychological science, and would significantly enhance the accuracy of data collection on those occupations.

Proposed Classification

[new title]

19-0000 LIFE, PHYSICAL, PSYCHOLOGICAL, AND SOCIAL SCIENCE OCCUPATIONS

[new section]

19-3000 PSYCHOLOGISTS

19-3010 Psychological Scientists
19-3011 Experimental/Cognitive Psychologists
19-3012 Biological/Physiological Psychologists
19-3013 Social/Developmental Psychologists
19-3014 Industrial-Organizational Psychologists
19-3015 Psychological Scientists, All Other
19-3020 Psychologists
19-3031 Clinical, Counseling, and School Psychologists
19-3039 Psychologists, All Other

[renumbered]

19-4000 SOCIAL SCIENTISTS AND RELATED WORKERS

19-4010 Economists
19-4020 Market and Survey Researchers
19-4030 Sociologists etc.

[renumbered, and new title]

19-5000 LIFE, PHYSICAL, PSYCHOLOGICAL, AND SOCIAL SCIENCE TECHNICIAN

19-5001 [19-5010 through 19-5050 are unchanged]

[new]

19-5060 Psychological Science Research Assistants
19-5061 Psychological Science Research Assistants

[renumbered]

19-5070 Social Science Research Assistants
19-5090 same

Rationale for the requested changes. Let me provide some additional detail on why we are asking that these changes be made in the classification system:

To reflect the distinction between psychological scientists and psychological practitioners. Just as biologists are different from physicians, researchers in psychology are engaged in very different occupations than practitioners in psychology. They perform different work using different skills, and in many cases have received different education and training. Further distinguishing these categories is the fact that clinical, counseling, and school psychologists are subject to licensure requirements to engage in professional activities, while psychological scientists are not. Because of these differences, it would be inaccurate to include psychologists conducting research in the same occupational category as clinical psychologists who deliver services in health care or other settings, just as it would be inaccurate, for example, to place a microbiologist in the same occupational category as an orthopedic surgeon.

One source of confusion is that both researchers and practitioners in the field are commonly known as "Psychologists." In order to make clearer the differences between these two areas, we propose that the classification system use "Psychological Scientist" for occupations in science, and "Psychologist" for occupations involved in the practice of psychology.

(For the record, I should acknowledge that of course there are clinical psychologists actively involved in research, including many APS members. But for the purposes of classifying occupations, it is essential to make the distinctions discussed above.)

To allow classification that recognizes the distinctly different categories of occupations within scientific psychology. As in other areas of science, scientific psychology consists of a range of subdisciplines that focus on distinct subjects. The categories we use in our proposed classification reflect major categories of activity within psychological science. Broadly defined, experimental/cognitive psychology is laboratory research aimed at determining the causes of behavior, particularly around learning, thinking, remembering, etc., whether at the level of an organ system, an individual, or a group of individuals; biological/physiological psychology focuses on the relationship between behavior and physical systems such as the nervous system, the brain, or the cardiovascular system; social/developmental psychology focuses on the psychological, environmental, and physical factors that influence behavior at different stages of life and in different social contexts; and industrial/organizational psychology looks at behavior in the context of the workplace. While there is of course overlap in the research in these areas, most scientific psychologists have their primary identity in one of these categories.

To reflect the current classification of psychological science as a separate scientific field. We are proposing a separate section for "Psychological Scientists" to reflect the fact that, as noted earlier, the majority of psychological scientists focus on behavioral and biological phenomena as well as social phenomena. For instance, at the university level, it is just as likely for a psychology department to be housed in a life sciences division as in a social sciences division, and in many cases, a psychology department anchors a broader behavioral sciences division. Recognizing this, the National Academy of Sciences (NAS), which annually reports on the number of doctoral degrees received in science and engineering,1 treats psychology as a separate field from social sciences. The changes we are requesting would bring the occupational classification system more in line with the NAS system and, more importantly, with the definitions and distinctions that are used within the field itself.

Thank you for the opportunity to address these issues. We appreciate your consideration of our requested changes, and we would be pleased to provide additional information.

Sincerely,
Alan G. Kraut, Executive Director