Modernizing America’s Workforce Infrastructure for an Era of Continuous Change

Response to:

U.S. Department of Labor

Employment and Training Administration

Request for Information:

Modernizing the O*Net Program and CareerOneStop

Submitted:

August 2026

Submitted by

Ian Davidson

Co-Founder & CEO, Signol Labs, LLC

Board Member, HR Open Standards Consortium

Chair, Trusted Career Profile Adoption Committee

Rogers, AR

Email: ian@signollabs.com

Stakeholder Group

Workforce Technology Strategist, Standards Leader, and Founder of Signol Labs

The recommendations in this response are informed by work across state workforce modernization initiatives, national interoperability efforts, open standards organizations, employers, educators, and workforce technology providers.

Recommendations at a Glance

1. Modernize O*NET as the nation’s trusted representation of work.

• Separate occupational descriptions from capability definitions.
• Establish a National Human Capability Ontology.
• Enable faster, more consistent updates as work evolves.

2. Modernize CareerOneStop as the Department’s reference architecture for a Portable Understanding of Human Capability.

• Build on Learning and Employment Records.
• Enable portable, individual-controlled career information.
• Demonstrate how systems can work together without replacing them.

3. Build upon existing national interoperability investments.

• Leverage W3C, 1EdTech, HR Open, Credential Engine, and related standards.
• Focus on public infrastructure rather than new federal systems.
• Enable AI and future technologies through trusted, portable information.

Introduction

The Department of Labor’s Request for Information presents an opportunity to modernize two foundational components of America’s workforce infrastructure: O*NET and CareerOneStop.

The challenge facing the Department is not that workforce disruption is new. Throughout history, technological innovation, globalization, demographic shifts, and economic cycles have continually reshaped work. Workers have adapted by learning new capabilities, changing occupations, and pursuing new opportunities. Employers have redesigned jobs. Educational institutions have developed new programs. Workforce agencies have helped people navigate these transitions.

What has changed is the pace.

Artificial intelligence is accelerating the rate at which work evolves. Occupations are changing more rapidly. New capabilities are emerging more quickly. Workers will transition between roles more frequently throughout their careers. While AI is today’s catalyst, it will not be the last. The nation is entering an era in which workforce disruption will become more frequent, more complex, and more difficult to predict.

When workforce infrastructure adapts more slowly than the economy, workers take longer to reconnect with opportunity, employers struggle to find qualified talent, educational investments become less responsive to labor market demand, and workforce programs face increasing pressure to serve more people using information that is often fragmented, incomplete, or outdated.

The question facing the Department is therefore no longer whether work will continue changing. It is whether America’s workforce infrastructure can adapt quickly enough to help the nation respond.

We believe the answer lies not in replacing the existing workforce ecosystem, but in strengthening the public infrastructure that enables it to adapt.

Two observations should guide this modernization effort.

First, people adapt faster than workforce systems. Individuals continuously develop new capabilities through education, work, military service, caregiving, entrepreneurship, community engagement, and countless other experiences. Yet every workforce system understands only part of that journey. Resumes, credentials, licenses, assessments, employment histories, and job applications each capture valuable information, but none provides a complete understanding of an individual’s capabilities or potential. As people move between employers, educators, workforce agencies, and technology platforms, they are repeatedly asked to recreate the same information because systems cannot effectively build upon one another.

Second, society’s workforce challenges are solved through coordination between systems, not by any single system. Educational institutions develop talent. Employers create opportunity. Workforce agencies provide services. Credential providers verify achievement. Technology platforms connect participants. Each system is designed to solve a specific problem. The nation’s ability to respond to labor shortages, economic disruption, career mobility, and lifelong learning depends upon how effectively these systems work together. That requires trusted information that moves with individuals rather than remaining trapped within institutions.

These observations lead to three recommendations.

• Modernize O*NET as the nation’s trusted representation of work.
• Modernize CareerOneStop as the federal government’s reference architecture for a portable understanding of human capability.
• Build upon existing national interoperability standards rather than creating new trust, privacy, or data exchange frameworks.

These recommendations are intentionally evolutionary rather than revolutionary. They build upon substantial investments already made across the workforce ecosystem while providing a clearer architectural direction for future modernization.

Together, these recommendations strengthen the Department’s existing investments while creating workforce infrastructure capable of adapting as rapidly as the economy it serves.

The Department does not need to own the workforce ecosystem to improve it. It simply needs to strengthen the public infrastructure that allows it to work together.

Modernizing O*NET

O*NET has become one of the nation’s most successful workforce information assets.

For more than twenty years it has provided the shared language used by employers, educators, workforce agencies, researchers, and technology providers to understand occupations. We believe this role should not only continue—it should be strengthened.

The opportunity before the Department is therefore not to replace O*NET, but to modernize the architecture upon which it is built.

Today, O*NET serves two distinct purposes. It describes occupations while also defining much of the language used to describe them. Skills, knowledge, abilities, work activities, tools, technologies, and related concepts are embedded throughout occupational profiles, often duplicating information across hundreds of occupations.

This architecture has served the nation well, but it becomes increasingly difficult to maintain as the pace of workforce change accelerates.

We recommend separating these two responsibilities over time. This can be accomplished incrementally while preserving O*NET’s existing role as the nation’s authoritative source for occupational information.

The Department should establish a National Human Capability Ontology that defines the common language used to describe human capability. O*NET should continue serving as the nation’s authoritative representation of work, but instead of embedding capability definitions within every occupational profile, occupations should reference shared capability definitions maintained within this common foundation.

This distinction is architectural rather than philosophical.

The ontology defines the language.

O*NET describes how that language comes together to perform work.

This separation provides several important benefits.

First, it dramatically improves the Department’s ability to maintain O*NET as work evolves. Today, emerging technologies or capabilities may require updates across numerous occupational profiles. Under this architecture, new or changing capability definitions can be updated once and immediately become available wherever they are referenced.

Second, it enables occupations to evolve more rapidly. Emerging occupations increasingly combine existing capabilities in new ways rather than representing entirely new forms of work. A shared capability foundation allows occupational profiles to be assembled from reusable components while introducing new concepts only when necessary.

Third, it provides a consistent semantic foundation for artificial intelligence. AI systems increasingly reason across occupations, credentials, capabilities, education, and labor market information simultaneously. A shared public ontology enables those systems to reason consistently using common definitions rather than proprietary mappings created independently by each technology provider.

Most importantly, this approach preserves O*NET’s greatest strength.

O*NET should remain the nation’s trusted representation of work.

It should not become the nation’s representation of people.

The Department’s opportunity is to clarify these responsibilities rather than expanding O*NET beyond its intended purpose.

One example illustrates the value of this approach.

Generative AI capabilities are rapidly appearing across occupations ranging from software engineering and financial analysis to marketing, customer service, education, and healthcare. Under today’s architecture, these changes require repeated updates across numerous occupational profiles. Under a shared capability architecture, emerging AI capabilities would be defined once and referenced wherever they become relevant, allowing O*NET to evolve more rapidly while maintaining consistency across occupations.

Modernizing O*NET is therefore not simply about updating occupational content.

It is about creating an architecture capable of continuously adapting as work itself evolves.

Modernizing CareerOneStop

O*NET provides the nation’s shared understanding of work.

The Department now has an opportunity to establish an equally important public asset: a trusted, portable understanding of human capability.

CareerOneStop is uniquely positioned to serve this role.

For more than two decades, CareerOneStop has helped millions of Americans explore occupations, identify training opportunities, and connect with workforce services. Those services remain valuable and should continue. However, the opportunity before the Department extends beyond modernizing a website or adding new career exploration tools.

The workforce system continues to place the burden of interoperability on individuals.

Every time people interact with a workforce system, they are asked to recreate themselves. They rebuild resumes. Re-enter employment histories. Re-list credentials. Re-describe their skills. Re-identify career interests and goals. The same information is repeatedly collected because each system understands only the portion of a person’s journey that occurred within its own boundaries.

This is not because workforce systems are failing. It is because they were designed to solve different problems. CareerOneStop should not attempt to replace those systems. It should demonstrate how they can work together while allowing each participant to continue doing what it already does well.

This approach becomes increasingly unsustainable as workers change jobs more frequently, pursue lifelong learning, and navigate multiple workforce, education, and employment systems throughout their careers.

We recommend that CareerOneStop evolve from primarily delivering workforce information to demonstrating how individuals can build and maintain a portable understanding of human capability that grows throughout their lives.

This recommendation is not about creating a national resume.

Nor is it about reducing people to a list of skills.

Human capability is multidimensional. It includes formal education, work experience, military service, industry credentials, licenses, assessments, projects, volunteer activities, entrepreneurship, languages, interests, career goals, demonstrated accomplishments, and countless other experiences that shape an individual’s potential.

No single workforce system can capture that understanding on its own.

Instead, CareerOneStop should demonstrate how multiple trusted organizations can progressively contribute to an individual’s career record over time.

• Educational institutions should contribute verified learning achievements.
• Employers should contribute verified employment information.
• Licensing agencies should contribute certifications and professional credentials.
• Workforce programs should contribute program participation and outcomes.
• Individuals should continue contributing experiences, goals, interests, and accomplishments that cannot be verified by institutions but remain essential to understanding who they are and where they want to go.

Rather than repeatedly asking people to start over, each interaction with the workforce system should leave them with a richer understanding of themselves than when they began.

This approach builds upon substantial national investments already underway.

Over the past several years, significant progress has been made through Learning and Employment Records (LERs), Verifiable Credentials, and interoperable workforce data standards. These initiatives have established practical approaches for issuing, exchanging, and verifying trusted career information across organizations.

CareerOneStop should build upon this foundation rather than creating an independent approach.

Verified records alone, however, are not sufficient.

A person’s capabilities extend beyond the experiences that result in formal credentials. Career decisions are also influenced by interests, aspirations, preferences, transferable experiences, and goals that may never appear on a transcript or certificate.

For this reason, we recommend that CareerOneStop demonstrate how verified Learning and Employment Records can be combined with progressively enriched personal information through an open, portable profile built upon existing standards such as the Trusted Career Profile. Together, these approaches provide a more complete and useful understanding of human capability than either could provide independently.

Importantly, this profile should belong to the individual—not to CareerOneStop.

The Department does not need to establish a new federal identity system or create a new privacy framework.

Instead, CareerOneStop should build upon the ownership, consent, and trust models already established through national interoperability efforts, including W3C Verifiable Credentials, Learning and Employment Records, 1EdTech, HR Open Standards, and related initiatives. Individuals should determine when and with whom their information is shared. CareerOneStop should demonstrate how trusted, portable career information can move across the workforce ecosystem rather than becoming another destination where information remains isolated.

This distinction is critical.

The value of CareerOneStop is not what happens within CareerOneStop itself.

Its greatest value is what becomes possible across the broader workforce ecosystem.

A learner should be able to carry verified achievements into a state talent marketplace without recreating their history.

A veteran should be able to combine military experience, civilian credentials, and employment history into a single portable career record that supports career transitions.

A displaced worker should be able to receive AI-assisted guidance based upon trusted evidence of what they already know and can do rather than beginning a new assessment process each time they seek assistance.

A workforce counselor should spend less time collecting information and more time helping individuals interpret opportunities, evaluate career pathways, and navigate change.

Artificial intelligence makes this opportunity even more important.

AI systems are increasingly capable of providing personalized career guidance, identifying transferable capabilities, recommending education and training, and connecting workers with emerging opportunities. However, the quality of those recommendations depends upon the quality of the information available.

CareerOneStop should therefore demonstrate how trustworthy, portable, evidence-based career information can enable AI to assist workers and workforce professionals responsibly while preserving human judgment, individual choice, and privacy.

The Department has successfully built one of the nation’s most trusted sources for understanding work.

CareerOneStop now has the opportunity to become the nation’s reference architecture for understanding people—not by centralizing information, but by demonstrating how trusted career information can move with individuals throughout their lives.

Modernize Through Public Infrastructure, Not New Systems

The recommendations we’ve described don’t require the Department to build a new workforce system. In many respects, the country has already done the hard part. We’ve learned how to issue trusted information directly from the institutions that know it best. We’ve developed standards for making that information portable. We’ve created practical approaches for ownership, trust, and interoperability. The opportunity now isn’t to start over. It’s to connect those pieces into public infrastructure that allows the workforce ecosystem to work together more effectively.

That’s what governments do well. They don’t build every business or every destination. They build the infrastructure that allows independent organizations to create value. Roads allow commerce to flourish. Communication networks allow information to move. Standards allow organizations to innovate without first negotiating how to talk to one another. America’s workforce infrastructure should work the same way.

Educational institutions should continue educating. Employers should continue hiring. Workforce agencies should continue serving their communities. Technology companies should continue innovating. The Department’s role is not to replace those systems. It’s to enable them to do what they already do, only better.

That begins with a shared understanding of work through O*NET. It continues with a shared language for describing human capability through a National Human Capability Ontology. CareerOneStop then becomes the Department’s reference architecture for demonstrating how individuals can build a portable understanding of human capability that grows throughout their lives and moves with them between systems. Those three pieces work together. O*NET explains work. The ontology provides the language for describing human capability. CareerOneStop demonstrates how that language can be used to create richer, portable career records that belong to the individual instead of the systems they happen to use.

Artificial intelligence makes this work more urgent, but it isn’t the reason for it. Our workforce systems are becoming capable of understanding people at a much deeper level than resumes, job titles, or degrees have ever allowed. They’re simply not being given the infrastructure to do it. AI can only reason over the information we provide. If that information is fragmented, incomplete, or trapped inside disconnected systems, we’ll simply build more sophisticated versions of the workforce system we already have.

The greatest opportunity here isn’t automation. It’s coordination. When systems begin with a richer, more trustworthy understanding of people, they can stop asking individuals to recreate themselves and start creating more value for them. Educational institutions can better understand how learning connects to opportunity. Employers can make more informed hiring decisions. Workforce professionals can spend less time collecting information and more time helping people navigate change. Technology providers can compete by building better services instead of competing on who can collect and lock away the most information.

One of the strengths of the workforce ecosystem is that no single organization owns it. States innovate. Employers innovate. Educational institutions innovate. Standards organizations innovate. Technology providers innovate. The Department’s unique opportunity is to provide the common public infrastructure that allows all of those innovations to reinforce one another rather than fragment the ecosystem further.

Ultimately, this paper isn’t recommending a new workforce system. It’s recommending better public infrastructure. Public infrastructure is successful when people stop thinking about it because it simply works. We don’t think about the internet every time we send an email, or the highway system every time we drive to work. The same should be true of workforce infrastructure. People shouldn’t have to understand which system they’re using or recreate who they are every time they encounter another workforce program, educational institution, or employer.

People adapt remarkably well. They learn new capabilities. They change careers. They reinvent themselves throughout their lives. Our workforce infrastructure should be just as adaptable.

Let’s make people’s lives easier. Let’s reduce the friction that exists not because people fail to adapt, but because the systems designed to help them cannot yet work together. If we build the infrastructure that allows those systems to understand people more completely, trust that understanding more confidently, and share it more responsibly, every participant in the workforce ecosystem will be able to do their job better—and the people they serve will benefit most.