Some time ago Social Security published a Notice of Proposed Rule-Making (NPRM) on entities as representatives of claimants. The NPRM was confused, particularly when it came to definitions, because Social Security had not thought through the issues. The agency has promised final regulations by February 2010. A recent issuance in Social Security's Program Operations Manual Series (POMS) may suggest where the agency is heading since it provides definitions for terms such as "advocacy services", "entity", "representative" and "representational services", but I have to say that I cannot tell much from it. Maybe you can.
I think it's pretty clear that SSA finally noticed how B & B does business and realized that having an individual representative, as opposed to a firm or group, is simply not a common practice. What I find interesting is that this POMS entry suggests that paralegals and legal assistants who wish to use the electronic database must register for it the same as the attorneys/reps who actually represent the claimant.
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