Grid Rules: Closely Approaching Advanced Age with Non-Transferable Skilled PRW

Direct Answer

The applicable grid rule depends on the claimant's residual functional capacity (RFC) level—specifically whether the claimant is limited to sedentary, light, or medium work. Under the provided sources, the rules apply as follows:

• Sedentary RFC: Rule 201.14 applies and directs a finding of Disabled [2].
• Light RFC: Rule 202.14 applies and directs a finding of Not disabled [8].
• Medium RFC: Rule 203.22 applies and directs a finding of Not disabled [5].

Regarding how transferability is determined under 20 C.F.R. § 404.1568, the provided sources do not contain the text of that regulation or any substantive criteria for determining skill transferability. Therefore, the specific regulatory standard for transferability cannot be addressed based on the supplied source material.

Analysis

The medical-vocational guidelines (the grid rules) direct a conclusion of disabled or not disabled by analyzing vocational factors (age, education, and work experience) in combination with the claimant's maximum sustained work capability [1]. For a claimant who is closely approaching advanced age with a high school education and skilled past relevant work (PRW) with non-transferable skills, the outcome hinges entirely on the RFC level and the specific educational subtype.

Sedentary Work (Rule 201.14) At the sedentary exertional level, Rule 201.14 applies where the claimant is closely approaching advanced age, has a high school education or more that "does not provide for direct entry into skilled work," and has skilled or semiskilled work experience with non-transferable skills. Under this precise combination of factors, the rule directs a finding of disabled [2]. If the skills were transferable, Rule 201.15 would direct a finding of not disabled [3]. Similarly, if the education provided for direct entry into skilled work, Rule 201.16 would direct a finding of not disabled despite non-transferable skills [4].

Light Work (Rule 202.14) At the light exertional level, Rule 202.14 applies to a claimant who is closely approaching advanced age, has a high school education or more, and has non-transferable skills. Unlike the sedentary rules, Rule 202.14 does not specify whether the education provides for direct entry into skilled work and directs a finding of not disabled [8].

Medium Work (Rule 203.22) At the medium exertional level, Rule 203.22 applies where the claimant is closely approaching advanced age, has a high school education or more that "does not provide for direct entry into skilled work," and has non-transferable skills. This combination directs a finding of not disabled [5].

Transferability Under 20 C.F.R. § 404.1568 While the grid rules provided explicitly categorize past work experience as either "skills transferable" or "skills not transferable" (e.g., comparing Rule 201.14 [2] with Rule 201.15 [3]), the actual legal standard and methodology for making that determination under 20 C.F.R. § 404.1568 are not included in the source material. Practitioners must look outside the provided sources to the regulatory text of § 404.1568 for the framework on how skills are deemed transferable.