A suspended or disqualified representative may not charge or collect a fee for representational services performed on or after the effective date of the suspension or disqualification. This limitation applies even if the sanctioned individual validly assigned direct payment of his or her fee to an entity as described in Program Operations Manual System (POMS) GN 03920.021. See also POMS GN 03970.060. The Social Security Administration (SSA) does not withhold benefits for potential direct payment of fees to any representative whose appointment is no longer in effect because that individual has been disqualified or suspended from representing claimants before SSA. A representative may be entitled to payment for services provided before the suspension or disqualification, but collection of the authorized fee is a matter between the representative and the claimant. See Hearings, Appeals, and Litigation Law (HALLEX) manual HA 01120.009.

The hearing officer or the Appeals Council (AC) will promptly transmit any decision on charges following a hearing or AC review to Law & Policy (LP) and to the representative against whom charges were brought. When a suspension or disqualification decision becomes final and binding, SSA components take the following actions:

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  LP will notify all appropriate SSA components of the sanction. When the suspended or disqualified representative is an attorney, LP will provide a copy of the decision to the attorney's disciplinary authority in every State or Territory in which the attorney is known to be admitted to practice.

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  LP will document the suspended or disqualified representative's name and other information in the Registration, Appointment and Services for Representatives (RASR) application. Legacy unregistered representatives (whose appointments began before September 30, 2024) will appear in the Appointed Representative (AR) Sanctions List in RASR, but they will not have a Representative ID (RepID) and their appointments will not be recorded in RASR. If a sanctioned representative was unregistered, LP will include this information in the notification it sends to SSA components.

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  Hearings and AC staff will ensure that the applicable case processing system(s) accurately reflects the information added or updated in RASR.

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  When the sanction information is recorded in RASR, if the sanctioned representative was registered, RASR automatically terminates all of the sanctioned representative's active appointments and sends automated notices that SSA no longer recognizes the individual as a representative to all claimants with pending claims associated with the sanctioned representative. If the sanctioned representative was unregistered, hearings and AC staff must send manual notices for all pending claims at their respective levels using the sample notice language in POMS GN 03970.065. At the hearings level, upon notification of the sanction, the hearing office(s) with jurisdiction over the pending cases associated with an unregistered sanctioned representative will send a written notice to the claimant(s). At the AC level, a designated branch chief will send a written notice to the claimant(s).

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  See also POMS GN 03970.060D regarding the field office's responsibility to notify claimants of a representative's suspension or disqualification in claims pending below the hearings level and see POMS GN 03970.065 for the sample notice language.

A claimant cannot appoint any individual who has been suspended or disqualified from practice before SSA as a representative. If a sanctioned representative attempts to act as a representative for claimants in any matter before SSA, staff must advise the sanctioned representative in writing that SSA does not recognize the individual as a representative. SSA staff must also notify the claimant that SSA does not recognize the suspended or disqualified representative as the claimant's representative. If the sanctioned representative still insists on serving as a representative, SSA staff must refuse to recognize the individual as a representative and prepare a referral following the instructions in HALLEX HA 01110.050A.

See POMS GN 03970.060B for a discussion of indirect representation and the receipt of indirect fees by suspended or disqualified representatives.