I’m finding Social Security's new form 1696, the one a claimant uses to appoint an attorney to represent them, to be a pain. They’ve got it set up
so you can’t edit the form. You can’t even delete the two pages of instructions.
I imagine I'm not the only one who has the packets of
forms I ask new clients to sign set up so as one document so that we enter the basic
information, such as name, address, SSN, etc. once and it propagates to all the
forms. That’s not hard to do with Acrobat Professional. You can’t do that with
the new 1696 because it’s locked. You can’t edit the fields in any way or even
see their names so you can use the same field names on other forms. It won’t
even let you combine the new 1696 with any other forms into a single document.
If you're at Social Security can you understand how it saves labor to have the 1696, the 827, a medical release and a fee agreement combined into one document so that if you enter basic information like the claimant's name once, it propagates to all the forms? In fact, don't you do something similar to this when you send out forms to sign?
Unless they unlock the 1696, the only way to deal with this problem will be to print out the 1696, scan it and laboriously re-enter the fields. This seems so unnecessary. I can't imagine that having their other forms unlocked has ever caused Social Security any difficulty. Locking the 1696 is pointless.
Even if they did the form right, there is still the problem that someone in the SS DO has to reenter the info from he paper form (or even PDF) submitted. What is really needed is the ability to enter the Rep ID (which should link to the EIN and all other rep contact information) in the online application and/or appeal so that rekeying isn't needed and the information is part of the file.
ReplyDeleteWill be waiting for that for as long as we are waiting for recognition that law firms exist and access to files at the State Agency.
I am enjoying this weeks Mt Molehill, as you have to have something that is going to cause the sky to fall. Anything new has problems, chill out a little bit, maybe switch to decaf of some tea and have a Snickers. You get absurdly overwrought when your hungry.
ReplyDeleteEveryone knows there is a problem. FO/DO are not sure what to do with the forms, nobody is being denied representation and it has only been a few days. Stuff like this happens all the time in insurance, healthcare, finance and nearly every type of business. Chill.
Typing the same information over and over is nothing new for Social Security. Claims reps here constantly have to retype names, SSNs, birthdates, etc. Not much propagates on our systems and there is constant rekeying of the same information. I welcome the day when the marriage information propagate between spouses and systems so we only have to type it once when taking a new application.
ReplyDeleteWill this new form eliminate the need for a 1695?
ReplyDeleteCharles,
ReplyDeleteMost of the forms on SSA.Gov are locked from editing. The only ones that are not are older forms that haven't been updated in a long time. Even the forms SSA employees use internally are almost all similarly locked. This has actually been the case for many years now - you just haven't run into it until this form.
The software SSA uses to create and edit the forms is Adobe Livecycle. It has rights management extensions that allow form authors (i.e. the Agency) to prevent end users from making multiple types of changes to the forms. It allows them to set the forms so that you, as an end user, can fill out only the provided form fields and print the forms. You can't delete pages, add form fields, change the assembly of the forms, etc.
To see the security limitations applied to a particular form, open it in Acrobat Reader. Under the file menu, choose "Properties". On the dialog box that pops up, choose the "Security" tab. The restrictions summary at the bottom of the tab will list the restrictions applied to that form by the Agency.
anon@2:58pm,
ReplyDeleteYes it will - the new 1696 is simply the old 1696 merged with the 1695. They are using your Rep ID in place of your SSN so you do not have to enter your SSN on anything that will end up in the claimant's file.
Until now, there has been no requirement that a lawyer sign a 1696, but this form requires the representative (lawyers appear to be included)to initial this "Representative's Certification":
ReplyDeleteI accept this appointment and certify the following:
• I understand and agree that I will comply with SSA's laws and rules on the representation of parties, including the Rules of Conduct and Standards of Responsibility for Representatives; I will not charge, collect, or retain a fee for representational services that SSA has not approved or that is more than SSA approved unless a regulatory exclusion applies. • I understand that if I fail to comply with any of SSA's laws and rules I may be suspended or disqualified as a representative before SSA. • I will not disclose any information to any unauthorized party without the claimant's specific written consent. • I am not currently suspended or prohibited, for any reason, from practicing before the Social Security Administration. • I am not disqualified from representing the claimant as a current or former officer or employee of the United States. • I accept appointment as the representative for the claimant named in Section 2 of this form in connection with the claims and asserted rights described in Section 6 of this form. • I agree that a copy of this signed form SSA-1696 will have the same force and effect as the original. • I declare under penalty of perjury that I have examined all of the information on this form and on all accompanying statements or forms, including any information, attestations and certifications provided to SSA in registration, and that they are all currently true and correct to the best of my knowledge.
If I intend to seek direct payment of the authorized fee on this claim - • I have registered for and obtained a Rep ID, and my registration information is up-to-date. • I have provided up-to-date information on my registration concerning whether I have been suspended or prohibited from practice before SSA or any other Federal program or agency, disbarred or suspended by a court or bar, and convicted of a violation under Section 206 or 1631(d) of the Social Security Act.
I CERTIFY TO ALL OF THE ABOVE (Representative's Initials)
-It all looks OK except for this sentence: "I declare under penalty of perjury that I have examined all of the information on this form and on all accompanying statements or forms, including any information, attestations and certifications provided to SSA in registration, and that they are all currently true and correct to the best of my knowledge". What does "provided to SSA in registration" mean? And what "accompanying statements" does it refer to?
Question: If a representative fails to initial this Certification, will SSA refuse to process the 1696?
anon@3:45pm,
ReplyDelete"Provided to SSA in registration" refers to the information that you provided to SSA when you registered for direct payment of your fees. "Accompanying statements" means anything you submit in addition to the 1696.
Now, for the bigee: You don't have to use an SSA-1696. Any statement appointing a representative that meets SSA requirements is sufficient. As a consequence, if you are a licensed attorney you still don't have to sign the form.
The only people that are required to sign/initial are the unlicensed non-attorney reps.
https://secure.ssa.gov/apps10/reference.nsf/links/02072020014149PM
A 4 page form now has to be mailed to the client and returned. One page wasnt good enough. You just made this practice area much more expensive. what ever happened to simplification?
ReplyDelete5:39pm has already answer the main question.
ReplyDeleteThe only thing that seems to have really changed with the new 1696 for representatives is appointing multiple representatives and requesting payment for court representatives (due to a RASR limitation?):
"-NOTE: With the incorporation of the RepID into the SSA-1696, we can no longer accept multiple names on a single notice of appointment. " (EM B. NOTE).
Seems this applies to written notice, too and not just to the 1696 process, which is a change in policy.
I unlocked the 1696 in less than 5 minutes with this trick.
ReplyDeletehttps://www.wikihow.com/Unlock-a-Secure-PDF-File
Thank you the tip, I was able to unlock it.
ReplyDeleteYou can install most print-to-PDF printers (like CutePDF, NitroPDF, etc) and print the file to PDF again to move the restrictions. Additionally, loading and printing the file in a web browser that has a Save-as-PDF option when printing (Google Chrome or Chrome-based browsers like Chromium, Vivaldi, the new Chrome-based Microsoft Edge, or even Firefox with a save as PDF extension installed) will also work just fine to accomplish this as well.
ReplyDeleteDo note that these options will get you the PDF file without editing restrictions only because most 3rd party PDF printer applications don't adhere to the Adobe PDF security model and also because it is handling the chore of converting the form from its actual XML format back to PDF. The downside of this method is that it will wipe all the fillable form fields, so you have to manually add them back using the PDF software of your choice.
Do note that Adobe's own Adobe PDF printer application that installs with Acrobat WILL NOT work. Adobe made it compliant to their security model, so it will normally error-out and refuse to create an unlocked PDF from a secured or rights-permission locked PDF.
anon@6:52pm,
ReplyDeleteThe problem with the old form is that it doesn't match up with the RASR system used by the agency to control appointments of representative. That means that agency technicians were having to translate (i.e. nice language for "creatively interpreting your intentions") to get the forms into RASR. Given some of the idiots the agency hires, that isn't a good thing for either you or the agency.
While it is possible to do this with the old forms if they were completely filled out, it is bad if they were not completed properly. And, while you may be a very conscientious rep who is careful that every 'i' is dotted and 't' is crossed on your paperwork, you'll be shocked to know that curiously not all of your colleagues are all that careful when completing the form that defines their legal relationship to the client and that control their eligibility for fees.
Since the SSA-1696 is not a required form, you can make your own appointment form as long as it meets SSA's appointment of representative requirements. Just make sure that it contains all the information requested in the SSA-1696 to ensure it can be used in RASR to link you to your client. And, be prepared to argue with the agency idiots who don't bother to learn that the 1696 isn't required and that you are allowed to do this.
Or, just keep using the old 1695/1696 form combo. While the agency doesn't want you to and won't distribute the old forms anymore, they can't legally refuse to accept them because the POMS policy on representation hasn't changed - the last version of the old 1696 was compliant with that policy, so they can't stop you from using the old form if you want to (with the understanding that you'll need an idiot-umbrella to wade through the excrement that will be spouted at you by various agency idiot employees who don't take the time to read their policy updates and know how to do their jobs).
love how in an effort to reduce paperwork 2 one page forms have become 1 4 page form.
ReplyDeleteIt cracks me up how many people are complaining about doing a few extra minutes of mind numbingly simple work keying in a few numbers on a page, when those same people are so quick to jump on employees of the agency complaining about losing telework and staying open late on Wednesdays. Some of the comments were along the lines of “lazy, don’t want to work, do you job etc” and now the sky is falling over filling out some of the few forms you actually work in in a claim. It’s actually funny to me that having to type a few items into a form is causing such problems. Remember everyone who was blaming SSA for losing work and not filing papers etc? Maybe now it seems it seems it will take so much overwhelming work to fill out these papers that maybe the reps won’t send 5 copies of the same forms to the FO. Good luck with the extra minute per form. Good thing you always work for the good of the claimants and to keep them off the streets since SSA only wants to deny the poor and the homeless. Oh wait, since this take some time to compete now, maybe you should get to increase your fees for this.
ReplyDeleteWe started using the form this week, and it's just not very user-friendly. First, it would be great if the form would pick up the rep ID and claimant SSN after it is entered once, and copy it to the other areas of the form. Second, like the original post states, it would also be helpful if the form could be edited. With the old 1696 and 1695, we saved the form with the things that don't change (our name, address, etc.) and would add the client's information with each new case. It's just more efficient that way. We've played around with the form quite a bit this week and haven't really come up with ways to make it practical. We are even thinking about just printing the form with our information on it and hand-writing in the claimant's info. Hopefully improvements will be made. Good idea but not so great application.
ReplyDeleteI hope 9:03 pm has some vacation time coming up. Just sayin'.
ReplyDeleteFYI: Easy tool to allow editing of SSA forms while keeping form fields:
ReplyDeletePDF forms can have two different passwords set - a user password (that keeps you from opening the file unless you know the password) and an owner password (that allows you to restrict how the form is used and how it can be edited).
SSA forms all have the owner password set to prevent editing.
To reset the owner password on the SSA form to allow editing while also maintaining the form fields, do the following:
1) Download a copy of the form you want to edit from SSA.gov
2) Go to https://pdfcandy.com/rearrange-pdf.html
3) Upload the SSA form to the website using the "Upload" button, or just drag and drop the form on the webpage where indicated.
4) Do not make any changes to the form on the website - just hit the "Rearrange Pages" button
5) When this process completes, it will let you re-download the form from the website and save it.
6) The resulting form will be identical to the original but with the owner password wiped and is no longer be restricted from editing in any way. It will also retain all the existing form fields.
Caveats: Please don't upload any forms containing data to this website, as I know nothing about the company (there is no backing company information available, so who knows who they are). I don't know if I'd trust the downloadable software (from what I have read, the download is free but then upsells you to a "Pro" version for certain features). However, the free web tool appears to work well for any SSA form with an owner password setting use restrictions. The "Unlock PDF" tool removes user passwords, but leaves owner passwords set.
Hope this helps.
1. Take the original document and "print" it as a Microsoft XPS Writer document. 2. Take the XPS document and "print" it as an Adobe document.
ReplyDeleteVolila. Unlocked. 30 seconds of work.