When I have a client over the age of 55 with physical impairments, this is typically the final paragraph of my brief for the disability adjudicator or the administrative law judge:
At Step 5 of the sequential evaluation, Mr. Jones is 58 years old. He does not have acquired job skills that transfer to a significant range of skilled or semi-skilled work within his RFC (please see Section 202.00 (e) of the Medical-Vocational Guidelines). Also, his mental health symptoms would prevent the transfer of any acquired job skills. Mr. Jones does not have recent education allowing direct entry to skilled work. Under these circumstances, Medical-Vocational Rule 202.06 directs a finding of “disabled” at the Light exertional level. As the regulations explain, “the limitations in vocational adaptability represented by functional restriction to light work warrant a finding of disabled.” See Section 202.00(c) of the Medical-Vocational Guidelines.
If the client’s limitations are adequately established, this is a winning argument every time.