My official comments on the proposed new rules on representation of claimants before the Social Security Administration have finally appeared on the Regulations.gov website. My official comments are a reorganized and re-edited version of what I had earlier posted on this blog.
The deadline for comments on this proposal is November 7. Few comments have been posted so far. This is an important proposal that deserves the careful study of everyone who represents claimants. Comments may be posted online. I suggest that you not walk away without filing a comment if you review the proposal and find it confusing. Everyone whom I have talked to who has read this proposal has found it confusing. Commissioner Astrue appears to have conceded that there were drafting problems with the proposal when he spoke at the conference of the National Organization of Social Security Claimants Representatives (NOSSCR) recently. The confusing nature of the proposal is worth commenting on.
The deadline for comments on this proposal is November 7. Few comments have been posted so far. This is an important proposal that deserves the careful study of everyone who represents claimants. Comments may be posted online. I suggest that you not walk away without filing a comment if you review the proposal and find it confusing. Everyone whom I have talked to who has read this proposal has found it confusing. Commissioner Astrue appears to have conceded that there were drafting problems with the proposal when he spoke at the conference of the National Organization of Social Security Claimants Representatives (NOSSCR) recently. The confusing nature of the proposal is worth commenting on.
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