New Regulation Proposed -- And Others Still Hanging

The Office of Management and Budget (OMB), which is part of the White House, must approve all proposed regulations before they are published in the Federal Register. The Social Security Administration just filed the following proposal with OMB:

We proposed to improve the operational efficiency of field offices by reducing the number of individuals who must be interviewed, face-to-face, in the office. Specifically, we will eliminate the requirement to re-interview individuals who became a representative payee (rep payee) for more than one beneficiary. Current policy requires a face-to-face interview for all proposed rep payees. This regulation will eliminate the requirement for that interview where an individual is already serving as a rep payee for another beneficiary.

Let me add a couple of "by the ways" which are probably more important. First, OMB cleared -- with changes -- new proposed mental impairment listings on July 9, 2008. Normally, once OMB clears a Notice of Proposed Rule-Making (NPRM), it appears in the Federal Register within a few days, but not this one. I wish I knew why. Second, another NPRM to "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" has been pending at OMB since May 30, 2008. The OMB's own rules require that they take action on this within 90 days. The 90 days are up tomorrow.