Social Security Ruling 19-3p will be in the Federal Register tomorrow. It's on requesting reconsideration or a hearing. The regulations require that these appeals be in writing. The Ruling, as best I can tell on a first reading, is designed to make it clear that the agency considers an appeal filed through its online systems to be in "writing."
6 comments:
Hmm...I might be paranoid, but just to confirm, any "superseding" language would be contained in an unpublished version, right? I do not see any.
Hmm, as a representative who wants to receive direct payment of fees I must use the electronic version when available. Seems as though there is a more stringent requirement as to what must be submitted with the electronic appeal as opposed to paper. Not sure it will have an impact on my practice but I find it interesting that SSA felt the need to issue this. Makes me wonder what motivation is behind it and whats coming next. You are not paranoid if they are really out to get you.
The 'abandoned appeals' might help explain. People can appeal a case electronically and SSA's system cold lose the filing, so the system eventually find the appeal after a new app is filed and tadah, some old app is resurrected. It taxes the system because the system didn't work right.
This ruling is a draconian response to the following situation. Lots of Recon appeals were filed electronically without all of the supplemental information. SSA claims that such appeals are not perfected until all of the forms are completed.
WRONG
They are now changing their policies to make it so for appeals that are filed electronically.
How Orwellian.
Pretty hard to take action on a case with no 827, no current address or phone number, no current sources
@ 9:14PM. Its strange that SSA will accept a paper appeal form as being filed without a complete Disability Report Appeal form or 827 but the rules are different if you file electronically. I think there needs to be uniformity across all processes.
I'm not sure the issue is that big of a deal with the electronic process as it is now constituted. The appeal isn't actually completed online until you get thru the disability report appeal as it is now one process. When things first went electronic, they had a two step process which I am sure lead to a lot of 1/2 completed appeals.
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