Social Security has issued a new form SSA-1695 which attorneys and others representing claimants before the agency must file in order to get withholding of fees. The form asks for the claimant's Social Security number, as well as the attorney's or representative's Social Security number. This will allow Social Security to produce 1099 forms for those representing claimants and to use direct deposit for payment of the fees.
The problem with the form is that it includes a section that asks the attorney or representative to "List below the Social Security Numbers and names of all other claimants not mentioned above. " Does this mean that the attorney or representative must list the name and Social Security number of all of the claimant's dependents who might receive benefits on the account? If it does not mean this, what does it mean? What is the point of requiring this information? Requiring it dramatically increases the compliance difficulty for the attorney or representative. Many attorneys and representatives routinely take down the names of their clients' dependents but it has not been routine to take down their Social Security numbers. For an attorney with a modest Social Security practice, which might be 200 clients, getting this information would take a good deal of effort. There would certainly be clients who would resist giving the information. Many claimants do not like the idea of their attorney or representative getting a fee out of the dependent benefits. There are many claimants who do not know their children's Social Security numbers and cannot readily obtain them because the children live with their mother and the claimant is estranged from the mother. What happens if the attorney does not list all of the children or does not get all of the Social Security numbers down accurately? Does the attorney or representative just not get a fee from those benefits? Why would Social Security want to go to the trouble of entering all this information in its own database anyway? What happens if the attorney or representative supplies the form to Social Security, but the data is not properly entered in Social Security's database? Social Security has problems already with data entry. This would add several hundred thousand new data entry items each year to Social Security's burden.
The problem with the form is that it includes a section that asks the attorney or representative to "List below the Social Security Numbers and names of all other claimants not mentioned above. " Does this mean that the attorney or representative must list the name and Social Security number of all of the claimant's dependents who might receive benefits on the account? If it does not mean this, what does it mean? What is the point of requiring this information? Requiring it dramatically increases the compliance difficulty for the attorney or representative. Many attorneys and representatives routinely take down the names of their clients' dependents but it has not been routine to take down their Social Security numbers. For an attorney with a modest Social Security practice, which might be 200 clients, getting this information would take a good deal of effort. There would certainly be clients who would resist giving the information. Many claimants do not like the idea of their attorney or representative getting a fee out of the dependent benefits. There are many claimants who do not know their children's Social Security numbers and cannot readily obtain them because the children live with their mother and the claimant is estranged from the mother. What happens if the attorney does not list all of the children or does not get all of the Social Security numbers down accurately? Does the attorney or representative just not get a fee from those benefits? Why would Social Security want to go to the trouble of entering all this information in its own database anyway? What happens if the attorney or representative supplies the form to Social Security, but the data is not properly entered in Social Security's database? Social Security has problems already with data entry. This would add several hundred thousand new data entry items each year to Social Security's burden.
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