The rules for eliminating dual social security coverage described in RS 02001.060 and RS 02001.065 cover the majority of situations where a worker would otherwise be subject to both U.S. and Italian coverage. However, the rules for eliminating dual social security coverage may have unintended results in certain cases. For this reason, the U.S. - Italian agreement includes a special exception provision.

An employee, employer, or a self-employed person may request a "special exception" to the normal coverage rules of the U.S. - Italian agreement. The United States and Italy must both agree before either country can grant a special exception. If either country does not agree with a requested special exception, the person's work is subject to the agreement's applicable coverage rule.