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We propose to make changes to the requirements for representing claimants. Specifically, we plan to impose a deadline(s) on when representatives must file their fee petitions and all supporting documents and to prohibit representatives from merely stating their intent to file a fee petition. We also propose to mandate registration and use of a prescribed form (SSA-1696) from all representatives who are or wish to be appointed as a representative. Additionally, we proposed to add educational requirements at the Associate’s level for direct pay non-attorney representatives.

Statement of Need:

This regulation will address procedures we intend to implement regarding how we handle representatives, which improves our administrative efficiency. We will change to the representative fee petition and alleviate a significant workload burden on Office of Hearings Operations (OHO) and Operations. We will mandate representative registration and completion of Form SSA-1696, critical requirements for our implementation of the Registration, Appointment and Services for Representatives system (RASR). We will add educational requirements for non-attorneys who seek direct fee payment.

Summary of the Legal Basis:

42 U.S.C 902(a)(5)

42 U.S.C. 406

Alternatives:

Anticipated Costs and Benefits:

We are in the early planning stage and data gathering for this rulemaking. Anticipated costs and benefits are too early to formally project, but we expect no more than a de minimis costs, if any, at this time.

Risks: