Proposed Regs On Representatives Coming Soon

     Social Security's proposed Rules of Conduct and Standards of Responsibility for Appointed Representatives have already cleared the Office of Management and Budget (OMB). It only took a little over a month. Some change was made in the proposal while it was pending at OMB but we'll probably never know what. The proposed regs should appear in the Federal Register in the near future. Remember, it's just proposed regulations.

     By contrast, the final regs that would change the mental impairment Listings are still pending at OMB. They were submitted on May 23.

     

    

Two Factor Identification Not Working Well So Far

     As of yesterday Verizon customers couldn't receive the text messages they need to access Social Security's online systems.

Being Disabled Often Means Being Poor

Not Just For Old Folks

New Security Requirements

     From Social Security:

The Social Security Administration (SSA) has added an extra layer of security for our customers when they interact with us online using the my Social Security suite of services. my Social Security account holders are required to use their cell phone, in addition to their username and password, as an additional authentication factor during online registration and every sign in. 

We implemented multifactor authentication (MFA) to comply with Executive Order 13681, which requires federal agencies to provide more secure authentication for their online services. We are committed to using the best technologies and standards available to protect our customers’ data. MFA is just one of the ways we ensure the safety and security of the resources entrusted to us. Since we launched my Social Security in May 2012, we have provided this added security of MFA as an option to our customers.

Now, all new and current my Social Security account holders will need to provide a cell phone number able to receive text messages. People will not be able to access their personal my Social Security account if they do not have a cell phone or do not wish to provide the cell phone number. We expect to provide additional options in the future, dependent upon requirements of national guidelines currently being revised.

     Don't anybody tell Social Security that it's possible to get text messages without a cell phone. 

A Social Security Casebook

     There's old saying that law school isn't set up to teach people the law. It's set up to teach people how to think like a lawyer. This won't make much sense to you if you're not a lawyer but, trust me, it does make sense to anyone who's gone through law school only to realize that they really didn't know much about the law. Given that the focus of law school has more to do with modes of thinking and less with the practical aspects of practicing, you'd expect that Social Security law wouldn't be taught much and you'd be right. However, some law schools do teach the subject. Professor Jon Dubin of Rutgers Law School was kind enough to send me a copy of a Social Security casebook that he and Frank Bloch, Emeritus Professor at Vanderbilt Law School, put together. Actually, this is at least the second edition of the book. It's quite good. I would recommend it to anyone learning Social Security law. 

     I have to say that looking at the price of the book brought home to me how long it's been since I was in law school. I think I remember casebooks being about $30-$40 back then but, of course, we were studying by whale oil lamps back then!

Mind Boggling

     There's a report out that AARP, which bills itself as Social Security's most ardent supporter, is helping fund the American Legislative Exchange Council (ALEC), a sinister far right group which has long advocated privatization of Social Security.

List Of Those Disqualified From Representing Claimants

     Social Security has recently posted a list of attorneys and others who have been sanctioned for misconduct in representing claimants before the agency. It's a longer list than I would have thought although it does go back more than 30 years. I only counted five names added to the list in the year before this was posted. He's not representing clients before the agency now anyway but Eric Conn's name isn't on the list.