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Jun 2, 2008

New Regs On Reps Coming

The Social Security Administration has filed two items with the Office of Management and Budget seeking approval to publish them in the Federal Register as proposed regulations. One is entitled "Authorization of Representative Fees", but no further description is available so far.

The second item is more fully described:

SSA RIN: 0960-AG56 Publication ID: Spring 2008
Title: Representation of Parties (3396P)
Abstract: We are proposing several revisions to our rules on Representation of Parties. These proposed rules would recognize entities as representatives, mandate the use of Form 1696 to appoint or revoke the appointment of a representative, define the roles of a principal representative and a professional representative, require professional representatives to file Form 1696 electronically, and require a representative to keep paper copies of certain documents that we may require. We are proposing these revisions to reflect changes in representatives' business practices and to become more efficient in processing claims for benefits.

This second item has potentially dramatic effects upon the practice of representing Social Security claimants. While it would simplify matters for the many law firms and other entities employing more than one attorney or representative, its biggest effect would be upon the largest entities representing Social Security claimants, namely Allsup and Binder and Binder, both of which are regarded warily by most who represent Social Security claimants. This would dramatically advance the interests of those who wish to nationalize the representation of Social Security disability claimants.

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