A Notice of Proposed Rule-Making (NPRM) from today's Federal Register:
We propose to revise our regulations to enable us to directly pay entities fees we may authorize to their employees, as required by the decision of the United States Court of Appeals for the First Circuit (First Circuit) in Marasco & Nesselbush, LLP v. Collins. To make direct payments, issue the necessary tax documents, and properly administer these rules, we propose to require all entities that want to receive direct payment of assigned fees and all representatives who want to be appointed on a claim, matter, or issue to register with us. We also propose to standardize the registration, appointment, and payment processes. We expect that this proposed rule will help us implement the changes required by the Marasco decision, increase accessibility to our electronic services, reduce delays, and help us prepare for more automation, thereby improving our program efficiencies.
This should have been done over 30 years ago but better late than never.
By the way, I have no idea how this got into the Federal Register. These things have to be approved by the Office of Management and Budget and OMB never listed this as pending approval on its website. I don't think I've ever seen this before. It's not listed now as having been approved by OMB even though the NPRM itself shows that OMB was involved.
9:49, since some banks do provide this information to accountholders, it would behoove reps to use those banks. NOSSCR and NADR would be helpful in publicizing the banks that are helpful and advocating with other banks to provide the information reps need. I don't think SSA needs to change its practices.
ReplyDeleteThe bigger concern I see in this proposed rule is the requirement that all reps register. Not a big deal for fee-charging reps, or even legal services folks, but sometimes a relative or clergy person or friend helps someone apply for benefits and registration is another hurdle they would have to overcome. I don't know if those folks would even be able to use ERE anyway, at least not at the initial and recon levels.
Not sure about the site you posted but the proposed rule was definitely on the Unified Agenda: https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202304&RIN=0960-AI22
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