CPS HR Consulting
Social Security Administration

SSA LogoDirect Payment to Non-Attorney Representatives

What's New for Representatives Who Were Eligible for Direct Payment Non-Attorneys (EDPNAs) as of June 2009

Updating your information

Beginning September 14, 2011, CPS HR Consulting is the new contractor for administering your eligibility requirements. CPS HR will collect your information to determine if you meet the requirements to be eligible for direct fee payment.

You must update your mailing and email address, phone number, or a name change by contacting the contractor who will be administering all aspects of the direct payment provisions for non-attorney representatives. You can contact CPS HR to update your information through any of the following methods.

You must also update your mailing and email address, phone number, name change or payment information through the SSA-1699 process, Submitting a completed Form SSA-1699. In addition, you should continue to notify your local field office of any changes.

If at any time you have a name change, you must first fill out an application for a social security card (Form SS-5). You can get the form by visiting www.socialsecurity.gov on the Internet or any Social Security office or by calling Social Security's toll-free number, 1-800-772-1213.

The New Regulation

You can review the requirements in the new regulation, Revisions to Direct Fee Payment Rules at www.gpo.gov/fdsys/pkg/FR-2011-07-28/pdf/2011-19026.pdf. The regulation was effective August 29, 2011.

Liability Insurance Requirement

If you want to receive direct fee payment, you must have professional liability insurance or equivalent insurance, which we determine to be adequate to protect claimants in the event of malpractice by you.

At various times, we will require you to provide proof that you have maintained continuous professional or business liability insurance coverage in the amounts we prescribe. Therefore, it is very important for you to keep historical information about your professional or business liability insurance coverage. You will receive a notice from us when it is time to verify your insurance coverage. You can send your insurance documents to us through our email address or mailing address before the deadline.

If you do not maintain continuous coverage since the last time we requested verification, you will be ineligible for direct payment for at least six (6) full calendar months. You have the opportunity to protest our finding that you have not provided sufficient proof that you maintained continuous liability insurance coverage. If you do not protest, you will be ineligible for direct fee payment for six (6) full calendar months beginning with the month after the month the protest period ends. If you file a protest and the action we take in response to the protest confirms our earlier finding, you will be ineligible for direct payment for six (6) full calendar months beginning with the month after we uphold our finding. You must provide us with documentation that you have the required liability insurance coverage no earlier than the sixth month of the period of ineligibility. After the 6-month period of ineligibility is over, you will be eligible for direct fee payment in the first month after the month we find that you have the required insurance coverage.

Continuing Education Course Requirement

To receive direct fee payment the PRA requires you to demonstrate ongoing completion of qualified courses of continuing education, including education regarding ethics and professional conduct. These courses should enhance your professional knowledge in matters related to entitlement to, or eligibility for, benefits based on disability under titles II and XVI of the Act. The continuing education courses must meet the standards that we prescribe. We select courses that we deem necessary to enhance your professional knowledge in matters such as benefits, ethics, the listings of impairments, and other disability topics under titles II and XVI.

Early in the first quarter of each calendar year, we will announce on our website what course (s) you must take. You will have until September 30 of each year to complete the course (s). Once you have completed the course (s) you must send confirmation to us through our email address or mailing address no later than October 31 of each year. If we prescribe more than one (1) course, you must wait until you take all the courses before you send confirmation to us.

If you do not take the prescribed continuing education courses by the deadline we provide or if you fail to provide us with the necessary proof that you completed the prescribed courses, you will be ineligible for direct fee payment for at least six (6) full calendar months. You have the opportunity to protest our finding that you have not taken and provided documentation of the required continuing education courses. If you do not protest, you will be ineligible for direct fee payment for six (6) full calendar months beginning with the month after the month the protest period ends. If you file a protest and the action we take in response to the protest confirms our earlier finding, you will be ineligible for direct payment for six (6) full calendar months beginning with the month after we uphold our finding. After the 6-month period of ineligibility is over, you be eligible for direct fee payment in the first month after the month you demonstrate that you meet the continuing education requirement. You may submit the required documentation at any time during or after the end of the 6-month period of ineligibility.

False or Misleading Information

If we find that you provided false or misleading information about your bachelor's degree or equivalent qualifications, or would fail our criminal background check if we conducted one today, you will be permanently ineligible to receive direct fee payment. You have the opportunity to protest our action. If you do not protest, you will be permanently ineligible to receive direct fee payment beginning with the month after the month the protest period ends. If you protest and we confirm our earlier finding, you will be permanently ineligible to receive direct fee payment the month after the month we uphold our finding. If we find that, you have misrepresented information about your education, background, continuing education courses, or liability insurance coverage we may refer this information to our Office of the General Counsel for their decision about initiating a sanction action against you.