Last Update: 2026-09-11 TN 011-115

HA 01120.049 Incorrectly Approved Fee Agreement

A. Effectuating Component Actions

1. Referral Procedures

Occasionally, a hearings or Appeals Council (AC)-level fee decision maker may have incorrectly approved a fee agreement when the agreement does not meet the requirements of the Social Security Act (Act) or an exception to the fee agreement process applies, as described in the Hearings, Appeals, and Litigation Law (HALLEX) manual HA 01120.012. Processing center (PC) and field office (FO) personnel may not reverse a fee agreement decision made by a hearings or AC-level decision maker. When the PC or FO technician responsible for effectuating a favorable or partially favorable decision by a hearings or AC-level decision maker believes that the decision maker incorrectly approved a fee agreement, the technician will take the following actions with immediacy:

  • Process the claim to payment;

  • Continue withholding 25 percent of past-due benefits if the representative is eligible for direct fee payment;

  • For Title II only claims, request an incomplete notice to the claimant, deferring action on the fee agreement (See Program Operations Manual Systems (POMS) GN 03940.025B.5.);

  • Prepare a protest memorandum, addressed to the Disability Compliance, Hearings In-Line Quality Review (Hearings ILQR); and

  • Email the memorandum, and as appropriate when the claim(s) file is non-electronic, a copy of the decision, the appointment(s) of representative(s), the fee agreement, the order approving the fee agreement, and any relevant documents, to ^DA DICompliance Hearings ILQR Fees.

For detailed information about the PC or FO process for incorrectly approved fee agreements, see POMS GN 03940.025B.5. (Title II instructions) or GN 03940.046F (Title XVI instructions). For sample memoranda templates, see POMS GN 03905.065B.4. (for hearings-level decisions) or POMS GN 03905.065B.5. (for AC-level decisions).

If the effectuating component does not receive a response within 45 days, it will:

  • Follow up with Hearings ILQR; and

  • Diary the claim(s) pursuant to the timeframes specified in POMS GN 03940.025B.5. (Title II) or GN 03940.046F (Title XVI).

2. Procedures After Hearings ILQR Acts on Referral

  • If Hearings ILQR reverses the fee agreement determination, the PC or FO will diary the case for receipt of a fee petition and fee authorization from the hearings or AC-level fee authorizer.

  • If Hearings ILQR affirms the fee agreement determination, the PC or FO will follow standard procedures for processing an approved fee agreement.

B. Hearings ILQR Actions

If a PC or FO technician believes the decision maker incorrectly approved a fee agreement, they will refer the case to ^DA DICompliance Hearings ILQR Fees.

Within 30 days, the Director of Hearings ILQR or a designee will review the disputed action to determine whether the agreement meets the provisions in section 206(a)(2)(A) of the Act, and is not excepted from the fee agreement process, as set forth in HALLEX HA 01120.012.

If the Director of Hearings ILQR or designee concludes the decision maker incorrectly approved a fee agreement, they will:

  • Issue an order to the claimant disapproving the fee agreement, advising that if the representative intends to charge and collect a fee, they must file a fee petition;

  • Send a copy of the order disapproving the fee agreement to each representative who signed the fee agreement with a cover letter;

  • Advise the claimant and representative that they may request review of the disapproval of the fee agreement within 15 days of receipt of the notice (see HALLEX HA 01120.041C).;

  • If there is a valid assignment as described in POMS GN 03920.021, send a copy to the entity's point of contact (POC); and

  • Send notification that a copy of the corrective action is available in the claim(s) file or the Online Retrieval System (ORS) to the respective PC or FO and the decision maker who signed the prior order (see HALLEX HA 01120.096 for a list of PC email addresses).

NOTE 1: 

In the limited circumstances described in HALLEX HA 01120.053A, the POC is the only individual able to submit a fee petition. Failure to provide a copy of the notice described above to the POC may frustrate the POC's effort to file a timely fee petition or notice of intent and cause the Social Security Administration to fail to withhold past-due benefits for direct payment of the representative's fee to the entity.

If the Director of Hearings ILQR or designee affirms the fee agreement approval, he or she will alert the PC or FO to process the representative's fee under the fee agreement process.

Additionally, if hearings or AC level personnel become aware that a fee agreement was erroneously approved, the decision maker who issued the decision may issue an amended fee order disapproving the fee agreement if:

  • Neither the claimant nor representative has submitted a request for administrative review of the approval of the fee agreement;

  • The PC or FO has not submitted a protest of the fee agreement approval;

  • The representative has not submitted a fee petition; and

  • The fee agreement approval was issued within the previous 15 days.

If all four conditions are not met, the hearings or AC-level staff must notify Hearings ILQR at ^DA DICompliance Hearings ILQR Fees. Hearings ILQR will then take the steps in HALLEX HA 01120.049B above, as if they had received a protest from the effectuating component.


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http://policy.ssa.gov/poms.nsf/lnx/2501120049
HA 01120.049 - Incorrectly Approved Fee Agreement (I-1-2-49) - 09/11/2026
Batch run: 09/11/2026
Rev:09/11/2026