Social Security has added a new section to its POMS manual on representation of claimants. I'm not sure how much is new. Here are a few things I noticed on a quick read through:
... [A]n appointed representative may not:An appointed representative cannot delegate to an associate the performance of tasks that require taking legally significant actions about the claimant's case such as:
- sign an application on behalf of the claimant. ...
A claimant must sign a written notice of appointment.
- appearing at a hearing and presenting the claimant's case in proceedings before us ...
The claimant's signature must be in ink. We do not accept signatures generated from electronic software programs (e.g., DocuSign or HelloSign) or rubber-stamped signatures from claimants on written notices of appointment. [Problematic at this time]
Return a notice of appointment if the claimant's signature is electronic. ...
The following individuals cannot appoint or revoke a representative on behalf of a claimant:
the representative payee ...
If a claimant dies before we complete action in a pending claim, matter, or issue, the representative's appointment continues until it is ended by one of the events listed in GN 03910.060B.
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