The Social Security Administration has issued a new version of the SSA-1696 form used to appoint an attorney or other representative. I wish they'd give us some advance notice before they do this.
It looks like they eliminated one instance of the Claimant's SSAN on page 3 and in teh process made it necessary to enter all teh information over again without any propagation within the form
I will keep using the earlier version until someone tells me not to.
They just edited the form to fix or change something.
As long as what was changed is not anything material, just keep using the old version. Heck, if you are an attorney, you can even use the old SSA-1695/1696 combo and the agency can't refuse to accept it under their own policies.
Or, create your own appointment of representative form. While SSA prefers you use their form, it isn't required. As long as the form you send contains the same information as the SSA form (for linking your client with you), SSA has to accept and process it.
A word of warning:
Some of you reps don't realize it, but the way you word your fee agreements actually results in the fee agreement itself being a legally valid appointment of representative. It isn't a problem, though, unless you are in one of those firms that has multiple reps and requires that all reps in the firm sign every single fee agreement (in case another rep in the firm should need to become involved in the case). For those folks, when the agency finally catches it, it is totally going to mess up your fees. You've just been lucky so far, but when they do catch it, they'll have to divide the fee equally among all the signing reps. The one rep that submitted SSA1695 data will be paid directly his/her share, and the rest of the fee will have to be sent directly to the claimant where your colleagues will have to to attempt to collect their shares directly from the claimant. It will eventually come to pass, once the agency starts enforcing its own rules.
I'm just glad the SSA1696 and SSA1695 were combined. Now SSA does not have to deal with several attorneys from the same firm signing the SSA-1696 but only one attorney registering for direct payment on SSA1695.
This resulted in an enormous amount of wasted time trying to get SSA-1695's from all the unregistered attorneys, as fee is divided between each attorney listed on SSA1696.
I have a question regarding the new 1696. Our Firm utilizes contract attorneys that are not associates in our law firm. I am confused regarding whether they sign the 1696 (Section 5) as we do not want the fee or a portion of the fee to go to the contract attorney. We do note the principal representative as the managing partner in our firm.(Section 3)
It looks like the only change is one question asking if the Rep works for legal aid.
ReplyDeleteIsn't this the same one that was issued in March?
ReplyDeleteSays 08/2020
ReplyDeleteIt looks like they eliminated one instance of the Claimant's SSAN on page 3 and in teh process made it necessary to enter all teh information over again without any propagation within the form
ReplyDeleteI will keep using the earlier version until someone tells me not to.
"Says 08/2020"
ReplyDelete-- So does the one issued in March.
They just edited the form to fix or change something.
ReplyDeleteAs long as what was changed is not anything material, just keep using the old version. Heck, if you are an attorney, you can even use the old SSA-1695/1696 combo and the agency can't refuse to accept it under their own policies.
Or, create your own appointment of representative form. While SSA prefers you use their form, it isn't required. As long as the form you send contains the same information as the SSA form (for linking your client with you), SSA has to accept and process it.
A word of warning:
Some of you reps don't realize it, but the way you word your fee agreements actually results in the fee agreement itself being a legally valid appointment of representative. It isn't a problem, though, unless you are in one of those firms that has multiple reps and requires that all reps in the firm sign every single fee agreement (in case another rep in the firm should need to become involved in the case). For those folks, when the agency finally catches it, it is totally going to mess up your fees. You've just been lucky so far, but when they do catch it, they'll have to divide the fee equally among all the signing reps. The one rep that submitted SSA1695 data will be paid directly his/her share, and the rest of the fee will have to be sent directly to the claimant where your colleagues will have to to attempt to collect their shares directly from the claimant. It will eventually come to pass, once the agency starts enforcing its own rules.
ReplyDeleteI'm just glad the SSA1696 and SSA1695 were combined. Now SSA does not have to deal with several attorneys from the same firm signing the SSA-1696 but only one attorney registering for direct payment on SSA1695.
This resulted in an enormous amount of wasted time trying to get SSA-1695's from all the unregistered attorneys, as fee is divided between each attorney listed on SSA1696.
I have a question regarding the new 1696. Our Firm utilizes contract attorneys that are not associates in our law firm. I am confused regarding whether they sign the 1696 (Section 5) as we do not want the fee or a portion of the fee to go to the contract attorney. We do note the principal representative as the managing partner in our firm.(Section 3)
ReplyDeleteAny guidance would be appreciated.