I recently received the message reproduced below. I'm sure that other attorneys who represent claimants have received the same message.
It sounds as if I and my firm need to file new forms SSA-1694 (registration of law firm or other entity) and SSA-1699 (registration of individual attorney or representative) and need to start using a new form SSA-1696 (appointment of representative). The thing is that when I look online for these new forms, all I find are old versions of the forms. Does Social Security intend to issue new versions of these forms? Why would they send out a mass e-mail like this when they haven't completed the new forms yet?
When I think about the "changes" that have been announced, I can't figure out why new forms would be required anyway since the "changes" seems to amount to little more than lip service to a federal court decision.
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Changes to Rules for
Claimant Representation and Provisions for Direct Payment to Entities
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On August 21, 2024,
we published a final rule, Changes
to the Administrative Rules for Claimant Representation and Provisions for
Direct Payment to Entities, in the Federal Register. We’ve made changes to our
regulations to allow representatives of Social Security claimants to assign
direct payment of their authorized fees to an entity with which they are
affiliated. We will implement this final rule in two phases. To learn more
about both phases, including requirements for representatives and entities,
please visit our webpage: https://www.ssa.gov/representation/2024NewRule.htm. Here are some key changes:
- Starting September 30,
2024, anyone who has not previously registered with us and who wants
to be appointed as a representative must register with us using Form
SSA-1699 (Representative
Registration) before we will recognize a new appointment request.
- Starting December 9, 2024,
representatives must use Form SSA-1696 (Claimant’s Appointment of a Representative) for
new or updated appointments.
- Starting December 9, 2024,
consistent with Marasco & Nesselbush,
LLP v. Collins, 6 F.4th
150 (1st Cir. 2021), we will directly pay authorized fees to a
registered entity when a representative assigns direct payment of
their fee to that entity.
Generally, for direct
payment to an entity:
- The entity must register
with us using our revised Form SSA-1694 (Entity Registration and Taxpayer Information).
- The representative must
register with us and affiliate with the entity using Form
SSA-1699 (Representative
Registration).
- The representative must
assign direct payment of the fee to the entity using the revised Form
SSA-1696 (Claimant’s
Appointment of a Representative).
- The representative and the
entity must both be eligible for direct payment.
Please share this
information with other interested parties. We appreciate your support.
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