A decision to suspend a beneficiary's benefits pending payee development is not an
            initial determination subject to the administrative appeals process. These suspensions
            are administrative actions rather than adverse actions. When there is a resolution
            for the representative payee issue, we will release all benefits due. According to
            provisions of the Omnibus Budget Reconciliation Act of 1990 (OBRA 90), we will reinstate
            benefits within 1 month unless direct payment is precluded.
         
         Additionally, when we appoint the representative payee, we send them Form SSA–4164, Advance Notification of Representative Payee , containing information on their rights to appeal our decision. The S8/S08 notices
            mailed when benefits are suspended pending representative payee development no longer
            contain appeal rights information.
         
         EXCEPTION: Sometimes beneficiaries in direct pay are erroneously suspended. Because they have
            not received an advance notice with appeal rights, the S8/S08 notice provides them
            with the right to appeal the need for a representative payee.