MEMORANDUM OPINION & ORDER

GREG WHITE, Magistrate Judge.

Plaintiff Christina Popp ("Popp") challenges the final decision of the Acting Commissioner of Social Security, Carolyn W. Colvin ("Commissioner"), denying her claim for a Period of Disability ("POD"), Disability Insurance Benefits ("DIB"), and Supplemental Security Income ("SSI") under Title(s) II and XVI of the Social Security Act ("Act"), 42 U.S.C. §§ 416(i), 423, 1381 et seq. This matter is before the Court pursuant to 42 U.S.C. § 405(g) and the consent of the parties entered under the authority of 28 U.S.C. § 636(c)(2).

For the reasons set forth below, the final decision of the Commissioner is VACATED and the case is REMANDED for further proceedings consistent with this opinion.

I. Procedural History

On April 1, 2010, Popp filed an application for POD, DIB, and SSI alleging a disability onset date of November 1, 2009. (Tr. 27.) Her application was denied both initially and upon reconsideration. Popp timely requested an administrative hearing.

On November 10, 2011, an Administrative Law Judge ("ALJ") held a hearing during which Popp, represented by counsel, and an impartial vocational expert ("VE") testified. (Tr. 27.) On December 5, 2011, the ALJ found Popp was able to perform a significant number of jobs in the national economy and, therefore, was not disabled. (Tr. 36-37.) The ALJ's decision became final when the Appeals Council denied further review.

II. Evidence

Personal and Vocational Evidence

Age 35 at the time of her administrative hearing, Popp is a "younger" person under social security regulations. See 20 C.F.R. § 404.1563(c) & 416.963(c). Popp has at least a high school education and past relevant work as a customer service representative and secretary. (Tr. 35.)

III. Standard for Disability

In order to establish entitlement to DIB under the Act, a claimant must be insured at the time of disability and must prove an inability to engage "in substantial gainful activity by reason of any medically determinable physical or mental impairment," or combination of impairments, that can be expected to "result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months." 20 C.F.R. §§ 404.130, 404.315 and 404.1505(a).1

A claimant is entitled to a POD only if: (1) she had a disability; (2) she was insured when she became disabled; and (3) she filed while she was disabled or within twelve months of the date the disability ended. 42 U.S.C. § 416(i)(2)(E); 20 C.F.R. § 404.320.

Popp was insured on her alleged disability onset date, November 1, 2009, and remained insured through the date of the ALJ's decision, December 5, 2011 . (Tr. 29.) Therefore, in order to be entitled to POD and DIB, Popp must establish a continuous twelve month period of disability commencing between these dates. Any discontinuity in the twelve month period precludes an entitlement to benefits. See Mullis v. Bowen, 861 F.2d 991, 994 (6th Cir. 1988); Henry v. Gardner, 381 F.2d 191, 195 (6th Cir. 1967).

A disabled claimant may also be entitled to receive SSI benefits. 20 C.F.R. § 416.905; Kirk v. Sec'y of Health & Human Servs., 667 F.2d 524 (6th Cir. 1981). To receive SSI benefits, a claimant must meet certain income and resource limitations. 20 C.F.R. §§ 416.1100 and 416.1201.

IV. Summary of Commissioner's Decision

The ALJ found Popp established medically determinable, severe impairments, due to seizure disorder, headaches, chronic obstructive pulmonary disease (COPD), and depression. (Tr. 29.) However, her impairments, either singularly or in combination, did not meet or equal one listed in 20 C.F.R. Pt. 404, Subpt. P, App. 1. (Tr. 30.) Popp was found incapable of performing her past relevant work, but was determined to have a Residual Functional Capacity ("RFC") for a full range of work at all exertional levels with some non-exertional limitations. (Tr. 31, 35.) The ALJ then used the Medical Vocational Guidelines ("the grid") as a framework and VE testimony to determine that Popp was not disabled. (Tr. 36.)

V. Standard of Review

This Court's review is limited to determining whether there is substantial evidence in the record to support the ALJ's findings of fact and whether the correct legal standards were applied. See Elam v. Comm'r of Soc. Sec., 348 F.3d 124, 125 (6th Cir. 2003) ("decision must be affirmed if the administrative law judge's findings and inferences are reasonably drawn from the record or supported by substantial evidence, even if that evidence could support a contrary decision."); Kinsella v. Schweiker, 708 F.2d 1058, 1059 (6th Cir. 1983). Substantial evidence has been defined as "[e]vidence which a reasoning mind would accept as sufficient to support a particular conclusion. It consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance." Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966); see also Richardson v. Perales, 402 U.S. 389 (1971).

The findings of the Commissioner are not subject to reversal merely because there exists in the record substantial evidence to support a different conclusion. Buxton v. Halter, 246 F.3d 762, 772-3 (6th Cir. 2001) (citing Mullen v. Bowen, 800 F.2d 535, 545 (6th Cir. 1986)); see also Her v. Comm'r of Soc. Sec., 203 F.3d 388, 389-90 (6th Cir. 1999) ("Even if the evidence could also support another conclusion, the decision of the Administrative Law Judge must stand if the evidence could reasonably support the conclusion reached. See Key v. Callahan, 109 F.3d 270, 273 (6th Cir. 1997).") This is so because there is a "zone of choice" within which the Commissioner can act, without the fear of court interference. Mullen, 800 F.2d at 545 (citing Baker v. Heckler, 730 F.2d 1147, 1150 (8th Cir. 1984)).

In addition to considering whether the Commissioner's decision was supported by substantial evidence, the Court must determine whether proper legal standards were applied. Failure of the Commissioner to apply the correct legal standards as promulgated by the regulations is grounds for reversal. See, e.g.,White v. Comm'r of Soc. Sec., 572 F.3d 272, 281 (6th Cir. 2009); Bowen v. Comm'r of Soc. Sec., 478 F.3d 742, 746 (6th Cir. 2006) ("Even if supported by substantial evidence, however, a decision of the Commissioner will not be upheld where the SSA fails to follow its own regulations and where that error prejudices a claimant on the merits or deprives the claimant of a substantial right.")

Finally, a district court cannot uphold an ALJ's decision, even if there "is enough evidence in the record to support the decision, [where] the reasons given by the trier of fact do not build an accurate and logical bridge between the evidence and the result." Fleischer v. Astrue, 774 F.Supp.2d 875, 877 (N.D. Ohio 2011) (quoting Sarchet v. Chater, 78 F.3d 305, 307 (7th Cir.1996); accord Shrader v. Astrue, 2012 WL 5383120 (E.D. Mich. Nov. 1, 2012) ("If relevant evidence is not mentioned, the Court cannot determine if it was discounted or merely overlooked."); McHugh v. Astrue, 2011 WL 6130824 (S.D. Ohio Nov. 15, 2011); Gilliam v. Astrue, 2010 WL 2837260 (E.D. Tenn. July 19, 2010); Hook v. Astrue, 2010 WL 2929562 (N.D. Ohio July 9, 2010).

VI. Analysis

Listing 11.03

In her first assignment of error, Popp argues that the ALJ erred in the Step Three analysis with respect to Listing 11.03. (ECF No. 17 at 15-16.)

The relevant listing provides as follows:

20 C.F.R. Part 404, Subpart P, App. 1.

At the third step in the disability evaluation process, a claimant will be found disabled if his impairment meets or equals one of the Listing of Impairments. 20 C.F.R. §§ 404.1520(a)(4)(iii), 416.920(a)(4)(iii); Turner v. Comm'r of Soc. Sec., 2010 WL 2294531 at * 3 (6th Cir. June 7, 2010). The Listing of Impairments, located at Appendix 1 to Subpart P of the regulations, describes impairments the Social Security Administration considers to be "severe enough to prevent an individual from doing any gainful activity, regardless of his or her age, education, or work experience." 20 C.F.R. §§ 404.1525(a), 416.925(a). In other words, a claimant who meets or equals the requirements of a Listed Impairment will be deemed conclusively disabled, and entitled to benefits.

Each listing specifies "the objective medical and other findings needed to satisfy the criteria of that listing." 20 C.F.R. §§ 404.1525(c)(3), 416.925(c)(3). A claimant must satisfy all of the criteria to "meet" the listing. Id.; Rabbers v. Comm'r of Soc. Sec., 582 F.3d 647, 652 (6th Cir. 2009). However, a claimant is also disabled if his impairment is the medical equivalent of a listing, 20 C.F.R. §§ 404.1525(c)(5), 416.925(c)(5), which means it is "at least equal in severity and duration to the criteria of any listed impairment." 20 C.F.R. §§ 404.1526(a), 416.926(a). An ALJ must compare the medical evidence with the requirements for listed impairments in considering whether the condition is equivalent in severity to the medical findings for any Listed Impairment. See Reynolds v. Comm'r of Soc. Sec., 2011 WL 1228165 at * 3-4 (6th Cir. April 1, 2011) (emphasis added); Hunter v. Comm'r of Soc. Sec., 2011 WL 6440762 at * 3-4 (N.D. Ohio Dec. 20, 2011). In order to conduct a meaningful review, the ALJ must make sufficiently clear the reasons for his decision. See Reynolds, 2011 WL 1228165 at * 4-5; Marok v. Astrue, 2010 WL 2294056 at *3 (N.D. Ohio Jun. 3, 2010); Waller v. Comm'r of Soc. Sec., 2012 WL 6771844 at * 3 (N.D. Ohio Dec. 7, 2012); Keyes v. Astrue, 2012 WL 832576 at * 5-6 (N.D. Ohio March 12, 2012).

Here, the ALJ found that Popp suffered from a seizure disorder, as it was included among Popp's severe impairments. (Tr. 29.) On April 27, 2009, neurologist Gary Kutsikovich, M.D., noted that electroencephalography (EEG) performed a few days earlier revealed intermittent right temporal sharp waves, "which may be consistent with the diagnosis of complex partial seizure disorder." (Tr. 543.) On March 1, 2010, neurologist Norman So, M.D., indicated that magnetic resonance imaging (MRI) revealed relative atrophy of the right hippocampus, which he believed may support a diagnosis of right temporal epilepsy. (Tr. 526.) According to Dr. So, a second MRI performed on October 22, 2009 revealed a "formal report normal," but he indicated that the images themselves revealed the right hippocampus was flattened with enlarged right temporal horn.2 (Tr. 737.) Dr. So's impression was "presumed Focal epilepsy, with complex partial seizures. Repeat MRI Head ... may support a diagnosis of R temporal epilepsy." (Tr. 739.) On several occasions, Dr. Kostikovich noted that Popp and her mother both reported several episodes of altered awareness per week. (Tr. 538-40.) On May 3, 2010, Dr. So noted a seizure frequency of 4-6 per month. (Tr. 737.)

The Commissioner maintains that substantial evidence supports the ALJ's finding that Popp did not meet or equal Listing 11.03. (ECF No. 19 at 14-17.) Significantly, the Commissioner's argument does not discuss whether the ALJ's Step Three analysis complied with Sixth Circuit law cited above. Id. Furthermore, much of the Commissioner's argument consists of a post hoc analysis of the requirements of Listing 11.03 and citations to the medical record which, she argues, supports a finding that the requirements were not met. Id. Unfortunately, the ALJ did not include any meaningful analysis at Step Three and the Court cannot engage in post hoc rationalizations. See S.E.C. v. Chenery, 332 U.S. 194, 196 (1947) (a reviewing court must judge the propriety of agency action "solely by the grounds invoked by the agency"). As this Court has previously observed, "arguments [crafted by defense counsel] are of no consequence, as it is the opinion given by an administrative agency rather than counsel's `post hoc rationale' that is under the Court's consideration." Waller, 2012 WL 6771844 at * 3. See also May, 2011 WL 3490186 at * 9. While the Commissioner may ultimately be correct that Popp does not suffer from a listing level impairment, this Court cannot make such a determination without an appropriate Step Three analysis. In his opinion, the whole of the ALJ's Step Three analysis is as follows:

(Tr. 30.)

At Step Three, the ALJ was required to consider whether Popp's mental and physical impairments, alone or in combination, met or equaled one of the listed impairments in 20 C.F.R. 404, Subpart P, Appendix 1. With regard to Popp's seizure disorder, the ALJ did nothing beyond restating the requirements of the Listing. As the ALJ concluded no listing was met, the Court naturally presumes that one of the requirements was found to be lacking. The ALJ, however, does not point to any such deficiency and this Court can only guess as to why the listing was not satisfied. In other words, the ALJ did not compare the medical evidence with the requirements. While the Commissioner argues that other portions of the decision discuss some of the medical evidence concerning Popp's seizures, there remains a glaring absence of any explanation as to why the evidence failed to meet or equal the listing.

In Reynolds v. Comm'r of Soc. Sec., 424 Fed. App'x. 411, 2011 WL 1228165 (6th Cir. April 1, 2011), the Sixth Circuit explained the importance of the Step Three analysis:

Id. at * 3-4 (emphasis added). Since Reynolds, numerous district courts have vacated and remanded ALJ decisions because of the failure to conduct a meaningful Step Three analysis which evaluates the medical evidence, compares it to the applicable listing, and provides an "explained conclusion" as to why the claimant's impairments fail to meet or equal a listed impairment. See e.g. Waller v. Astrue, 2012 WL 6771844 at * 2-5 (N.D. Ohio Dec. 7, 2012) adopted, 2013 WL 57046 (N.D. Ohio Jan. 3, 2013); May v. Astrue, 2011 WL 3490186 at * 7-10 (N.D. Ohio June 1, 2011) adopted, 2011 WL 3490229 (N.D. Ohio Aug. 10, 2011); Keyes v. Astrue, 2012 WL 832576 at * 5-6 (N.D. Ohio March 12, 2012); Hunter v. Astrue, 2011 WL 6440762 at *3-4 (N.D. Ohio Dec. 20, 2011); Marok v. Astrue, 2010 WL 2294056 at * 5 (N.D. Ohio June 3, 2010) (finding ALJ's passing reference to ME testimony that claimant did not meet a Listing was insufficient to describe the reasons for his Step Three determination because "[t]o decipher what the medical expert said, the reader must travel back to the transcript — something not immediately accessible to the typical reader, including [claimant]"); Hakkarainen v. Astrue, 2012 WL 398595 at * 10-13 (N.D. Ohio Jan. 19, 2012) adopted 2012 WL 396970 (N.D. Ohio Feb. 7, 2012); Shea v. Astrue, 2012 WL 967088 at * 8-11 (N.D. Ohio Feb. 13, 2012) (finding Step Three analysis insufficient when ALJ mentioned, without describing, the findings and opinions of "treating or examining physicians" and "State agency medical consultants" to find claimant did not meet Listing), adopted 2012 WL 967072 (N.D. Ohio Mar. 21, 2012).

In the instant case, the ALJ failed to sufficiently articulate how he reached his conclusion that Popp's seizure disorder did not meet or equal Listing 11.03. While the decision states that the ALJ considered the listing and recites the requirements, it did not compare those requirements with the medical evidence of record. Therefore, the Court cannot ascertain why the ALJ found Listing 11.03 was neither met nor equaled.3 As such, the ALJ's discussion at Step Three was insufficient to satisfy the ALJ's duty to discuss the evidence and provide an "explained conclusion" per the holding in Reynolds.

Furthermore, the ALJ's failure to explain how he reached the conclusion that Popp's seizure disorder did not meet or medically equal a listing is not harmless error because, if Popp is found to meet a listed impairment, he would be disabled within the meaning of the regulations and entitled to benefits without any additional analysis. 20 C.F.R. § 404.1520(a)(4)(iii). See also Reynolds, 2011 WL 1228165 at * 4. Moreover, without discussing the voluminous medical evidence, there does appear to be evidence that, if credited, could support a finding that Popp met or equaled the listing. As such, this is not a case where the record is devoid of any medical evidence that might support a finding of listing-level severity.

Because the Court cannot discern the reasons for the ALJ's decision, this matter is remanded for a more thorough Step Three determination regarding Popp's seizure disorder.4

VII. Decision

For the foregoing reasons, the Court finds the decision of the Commissioner not supported by substantial evidence. Accordingly, the decision of the Commissioner is VACATED and the case is REMANDED, pursuant to 42 U.S.C. § 405(g) sentence four, for further proceedings consistent with this opinion.

IT IS SO ORDERED.