Grid Rule 202.06: Transferable Skills Evidence Under SSR 82-41

Direct Answer

Grid Rule 202.06 directs a finding of disabled only when three vocational criteria coincide: (1) advanced age, (2) high school graduate or more who does not provide for direct entry into skilled work, and (3) skilled or semiskilled past work with skills not transferable [9]. If a vocational expert (VE) identifies transferable skills to other sedentary skilled occupations, the claimant's vocational profile no longer matches Rule 202.06 because the "skills not transferable" criterion is not satisfied. Instead, the profile aligns with Rule 202.07—same age and education, but skills transferable—which directs a conclusion of not disabled [10].

Regarding SSR 82-41: that ruling is not among the numbered sources provided, so its specific evidentiary requirements cannot be addressed here. A follow-up question supplying the SSR 82-41 text would allow detailed analysis of what evidence is required to establish "highly marketable" and transferable skills to "significantly different jobs."

Analysis

The claimant's profile against Rules 202.06 and 202.07

The hypothetical claimant is 58 years old (advanced age), has a high school education, and has past skilled sedentary work. Rule 202.06 sits within the 202.00 series, which applies when an individual's maximum sustained work capability is limited to light work [1]. The claimant's past work being sedentary does not preclude application of the 202.00 rules; what matters is the claimant's current residual functional capacity (RFC). If the RFC permits light work, the 202.00 framework governs.

Under the grid framework, "where the findings of fact made with respect to a particular individual's vocational factors and residual functional capacity coincide with all of the criteria of a particular rule, the rule directs a conclusion as to whether the individual is or is not disabled" [1]. Critically, "where any one of the findings of fact does not coincide with the corresponding criterion of a rule, the rule does not apply in that particular case and, accordingly, does not direct a conclusion" [1].

Applying this here:

If the VE identifies transferable skills, the "skills not transferable" criterion of Rule 202.06 is not met, so 202.06 does not direct a conclusion [1][9]. The findings instead coincide with all criteria of Rule 202.07, which directs not disabled [10].

The pivotal role of transferability

The entire outcome turns on the transferability finding. Rules 202.06 and 202.07 are identical in age and education; they differ only on whether skills are transferable [9][10]. The same architecture appears in the sedentary rules (201.06 vs. 201.07) [2][3], confirming that transferability is the dispositive variable across the grid framework for advanced-age claimants with skilled or semiskilled past work.

Rebuttal of grid findings

The introduction to the grid framework states that "each of these findings of fact is subject to rebuttal and the individual may present evidence to refute such findings" [1]. This means the claimant can present evidence challenging the VE's transferability testimony—for example, by showing that the identified skills are so specialized or job-specific that they would not actually transfer to significantly different occupations, or that the number of jobs to which they transfer is negligible. Conversely, the agency bears the burden of establishing that skills are genuinely transferable to support application of Rule 202.07 [10] rather than Rule 202.06 [9].

The SSR 82-41 gap in the provided sources

The question asks what specific evidence SSR 82-41 requires to prove that skills are "highly marketable" and transferable to "significantly different jobs." SSR 82-41 is not included in the numbered sources [1]–[15]. Therefore, any discussion of its particular evidentiary standards—such as requirements regarding the VE's identification of specific occupations, job numbers, degree of similarity between past and target occupations, or the "very little vocational adjustment" standard—would be unsupported by the sources provided and cannot be offered here. Supplying the SSR 82-41 text in a follow-up would permit a precise answer to that portion of the question.

Key Points

• Rule 202.06 applies only when skills are not transferable. It requires advanced age, high school education (no direct entry to skilled work), and skilled/semiskilled work with non-transferable skills; it then directs "disabled" [9].
• Transferable skills shift the claimant to Rule 202.07. Same age and education, but skills transferable → "not disabled" [10]. If a VE identifies transferable skills, 202.06's directive is not triggered because one finding does not coincide with the rule's criteria [1][9].
• Each grid finding is rebuttable. The claimant may present evidence refuting the VE's transferability opinion, and the agency must support transferability to invoke 202.07 [1].
• The 202.00 series governs light-work RFC. Rule 202.06 is not a sedentary rule; it applies when the claimant can perform light work. If the claimant's RFC were limited to sedentary work, Rules 201.06 and 201.07 would be the analogous provisions [2][3].
• SSR 82-41 is outside the provided source set. The specific evidentiary requirements for proving "highly marketable" transferable skills to "significantly different jobs" cannot be analyzed without that ruling's text. A follow-up supplying SSR 82-41 would enable that analysis.