ORDER

JOLIE A. RUSSO, Magistrate Judge.

Plaintiff brings this proceeding to obtain judicial review of the Commissioner's final decision denying plaintiff's application for disability insurance benefits.

Plaintiff asserts disability beginning May 31, 2013 due to: post-traumatic stress disorder, chronic obstructive pulmonary disease, bipolar disorder, sleep apnea, high blood pressure, knee pain, shoulder pain, and hip pain. Tr. 175, 179.

After a hearing, an administrative law judge (ALJ) determined plaintiff was not disabled. Plaintiff asserts the ALJ erred in relying on vocational expert (VE) testimony without addressing plaintiff's post-hearing objections to the testimony.

The ALJ found plaintiff has the residual functional capacity (RFC) to perform light exertion work with certain limitations including only occasional contact with the public, coworkers, and supervisors. Tr. 38. The ALJ asked a VE if an individual of plaintiff's age, education, experience, and RFC could perform jobs existing in the national economy. Tr. 43, 73. Based upon the VE's testimony, the ALJ determined that plaintiff could perform the jobs of "Assembler, small products;" "Inspector, electric equipment;" and "Packager." Tr. 43, 73-74. The VE specifically referred to the Dictionary of Occupational Titles (DOT) in expressing her opinion. Tr. 73-74.

After the hearing, but before the ALJ reached a decision, plaintiff's counsel submitted a post-hearing memorandum and objections to the VE's testimony. Tr. 242-66. Among the objections was the argument that current labor market research and sources of job information dictate the identified jobs require more than superficial interaction with co-workers and supervisors. Tr. 246. Plaintiff offered the expert opinion of Paula Santagati that a person limited to only occasional interaction with coworkers and supervisors would be unable to successfully transition from the training and probationary period of the identified jobs. Tr. 247, 265. Plaintiff also argued the Department of Labor's current tool for assessing occupations is through O*NET given that the DOT has not been updated in decades. Tr. 244-45; see Tr. 262-63. Plaintiff further argued that under the O*NET, the identified jobs no longer appear to be unskilled.

In the ALJ's decision, she overruled the objections stating:

Tr. 32.

SSR 00-04p provides that the Social Security Administration primarily relies on the DOT for information about work requirements and that evidence provided by VEs should be consistent with the DOT. When there is a conflict between the VE and the DOT, an ALJ must elicit reasonable explanation for the conflict before relying on the VE to support a decision about whether a clamant is disabled. See https://www.ssa.gov/OP_Home/rulings/di/02/SSR2000-04-di-02.html.2

In this case, the VE who testified at the hearing relied on the DOT and thus her testimony did not conflict with it. Plaintiff's objection was based on the assertion that the DOT is outdated and provided his explanation, though another VE, as to why the conflict should be resolved against the DOT in favor of the O*NET. The ALJ accepted the DOT requirements without addressing the specific objection regarding its current applicability.

The ALJ appears to reject the objections because they were not made at the hearing. Plaintiff primarily relies on the Hearings, Appeals, and Litigation Manual (HALLEX) § I-2-5-55 (2015)3 for the preposition that the ALJ is required to rule on the objection regardless of whether it was made orally at the hearing or in writing post-hearing. HALLEX does not have the force and effect of law, it is not binding, and courts generally do not review allegations of noncompliance with the manual. Moore v. Apfel, 216 F.3d 864, 869 (9th Cir. 2000). However, the Commissioner, while arguing that HALLEX is not binding, argues the ALJ sufficiently considered the objections. The objections are part of the record and therefore it is appropriate to consider whether the ALJ's decision to adopt the VE's opinion, which is based on the DOT, is supported by substantial evidence. Cf. Rahe v. Astrue, 840 F.Supp.2d 1119, 1137-39 (N.D. IA. 2011) (Due process requires allowance of cross-examination of post-hearing VE opinion for full development of the record).

In this case, the ALJ did not sufficiently address whether the VE's testimony, supported by the DOT, was current and reliable despite plaintiff's argument that it was not. The court cannot determine, based on the record before it and the ALJ's decision, whether the VE's opinion constitutes substantial evidence in light of her reliance on possibly obsolete data in the DOT. See Johnson, 2017 WL 4542228 at *2 (decision reversed "in light of the fact that the vocational expert's testimony about the two jobs did not appear to constitute substantial evidence in light of his reliance on occupational descriptions in the DOT that likely were obsolete.").

The Administration is required to take administrative notice of reliable job information available from various governmental and other publications. 20 C.F.R. § 404.1566. While the regulation specifically refers to the DOT, the O*NET is considered to be reliable information by the Department of Labor and, as noted above, the Social Security Administration itself is aware that the DOT is outdated. Moreover, information contained in the DOT is not conclusive evidence of the existence of jobs in the national economy; it is used to establish a rebuttable presumption. DeLoatche v. Heckler, 715 F.2d 148, 151 (4th Cir.1983). Testimony based on an outdated edition, of the DOT should not be recognized as substantial evidence to support a determination as to the existence of jobs in the national economy. See English v. Shalala, 10 F.3d 1080, 1085 (4th Cir. 1993). Because plaintiff has presented evidence rebutting the reliability of the DOT, the ALJ must address that evidence before relying on testimony supported by the DOT in making a disability determination.4

CONCLUSION

Pursuant to Sentence 4 of 42 U.S.C. § 405(g), the decision of the Commissioner is reversed and remanded for further proceedings.