Dec 21, 2016

Proposed Final Regs Fail To Clear OMB In Time To Come Into Effect Before Change Of Administration

     The Office of Management and Budget (OMB) has not yet acted on two packets of proposed final regulations submitted by the Social Security Administration. One packet was on Revisions to Rules of Conduct and Standards of Responsibility for Appointed Representatives and the other on Revisions to Rules Regarding the Evaluation of Medical Evidence. Since the Administrative Procedure Act requires a 30 day waiting period before new regulations take effect it's now too late for these proposed regulations to become final before President Obama leaves office. This doesn't mean that these proposed final regulations are dead. The incoming administration will almost certainly put any proposed final regulations pending at OMB or which have been approved but not come into effect through a new review before they can become final. The review of these regulations may not even start until there's a new Commissioner of Social Security. The regulations could be modified or withdrawn as a result of the review.

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