Effective Dates: 3/26/2026 - Present

Identification Number:
GN 03316 TN 9
Intended Audience:See Transmittal Sheet
Originating Office:LP
Title:Disclosure to Administer SSA Programs and Other Miscellaneous Disclosures
Type:POMS Full Transmittals
Program:All Programs
Link To Reference:
 

PROGRAM OPERATIONS MANUAL SYSTEM

Part GN – General

Chapter 033 – Disclosure/Confidentiality of Information

Subchapter 16 – Disclosure to Administer SSA Programs and Other Miscellaneous Disclosures

Transmittal No. 9, 03/17/2026

Audience

PSC: BA, CS, CTE, DE, DEC, DS, ICDS, IES, PETE, RECONR, SCPS, SPIKE, TSA, TST;
OCO-OEIO: BET, BTE, BTE TE, CR, CTE, CTE TE, FCR, FDE, RECONE, RECONR, RECOVR;
OCO-ODO: BTE, CR, CST, CTE, CTE TE, DE, DEC, DES, DS, IS, LCC, PAS, PETE, PETL, RCOVTA, RECONE, RECOVR;
OEO: DOSPA, OSSPA, WBDOCPA;
FO/TSC: CS, CS TII, CS TXVI, CSR, CTE, FR, OA, OS, RR, TA, TSC-CSR;

Originating Component

OPD

Effective Date

Upon Receipt

Background

An individual may authorize a third party to act on their behalf in dealings with us. The individual must name the appointed representative in writing. An appointed representative can be an attorney or non-attorney, but must be a designated individual or individuals, not a firm or entity.

Summary of Changes

GN 03316.125 Disclosure to Attorneys and Representatives

We updated the title of this subsection to "Disclosure to Representatives and Designated Associates."

Subsection A - We deleted references to "or written equivalent," as it pertains to Form SSA-1696, Claimant's Appointment of Representative. We also clarified that SSA established a routine use that permits disclosures to an appointed representative's designated associates (e.g., partners, associates, clerks, call centers, contractors).

Subsection B - We clarified that the appointed representative's name must appear in SSA records when identifying an appointed representative by telephone.

Subsection C - We clarified that the caller must provide their relationship to the appointed representative when identifying a representative's designated associate by telephone.

Subsection D - We clarified that SSA does not consider disclosures to appointed representatives as access, but rather, disclosures made upon a routine use authority. We added guidance that appointed representatives must request information in person if there is a SPIN 6 on the subject individual's Numident record.

Subsection E - We deleted all existing policy for limiting disclosures, except the NOTE.

Subsection F - This is a new section, which provides policy on disclosures to appointed representatives and designated associates when the appointment ends.

GN 03316.125 Disclosure to Representatives and Designated Associates

An individual may appoint a representative to act on their behalf in dealings with us. The individual must appoint the representative using Form SSA-1696 (Claimant's Appointment of a Representative). An appointed representative can be an attorney or non-attorney, but must be an individual, not a firm or entity.

On behalf of the claimant, an appointed representative may:

  • •

    obtain information about the claim that SSA would generally provide the claimant (the appointed representative may also utilize designated associates to obtain this information);

  • •

    examine any documents to which the claimant would have access;

  • •

    appear at any interview, conference, or hearing;

  • •

    be informed of all additional evidence needed to support the claim;

  • •

    make a request about the proceedings before SSA; and

  • •

    be notified of any decision made in the claim, including decisions regarding auxiliary beneficiaries, if applicable.

For a more complete list regarding the authority of a representative, see GN 03910.025.

A. Using Form SSA-1696, Claimant's Appointment of a Representative

Claimants use the Form SSA-1696 to appoint an individual as a representative. Entities may not be appointed as representatives. Once a valid appointment is established with the Form SSA-1696, we can disclose to the appointed representative based on routine use authority.

This routine use also permits us to disclose claim-related information to an appointed representative's designated associates, who are other individuals the appointed representative works with (e.g., partners, associates, clerks, call centers, contractors) for the duration of the claim(s). The technician must identify the requester as well as their relationship to the representative, per the instructions in GN 03316.125C and GN 03380.010B. These disclosures, made upon routine use authority, do not require the claimant to submit an SSA-3288 or other written consent.

NOTE: Except in limited circumstances (see GN 03920.021), to authorize the disclosure of their information or records to an entity, claimants must submit Form SSA-3288, SSA-3288-OP1, or another valid written consent. A valid consent must also be obtained in order to disclose any information the appointed representative requests that is not needed by the representative to perform their official duties in representing a claimant before SSA, or if the appointed representative asks for information about the claimant after their official representation has ended.

Although an “appointed representative” and a “designated representative” may be one individual, the functions of these two types of representatives are distinctly different. These individuals are also distinct from "designated associates."

For information regarding a designated representative, refer to GN 03340.035.

For information on appointed representatives, see GN 03305.025 and GN 03900.000.

B. Verifying the identity of an appointed representative requesting claimant information by telephone

When an appointed representative requests claimant information by telephone, we must verify that the claimant has appointed this representative and verify that the caller is a current appointed representative of record. To verify that the caller is an appointed representative of record, obtain a query or access the Form SSA-1696. Compare the information in SSA records with the information provided by the caller. The caller must provide:

  • •

    their first and last name, and

  • •

    the claimant's identifying information listed in GN 03380.010B.2, and

  • •

    the appointed representative's Representative Identification (Rep ID) number established upon the representative's registration with the agency (i.e., via SSA-1699).

C. Verifying the identity of an appointed representative's designated associate requesting claimant information by telephone

Consistent with instructions in GN 03380.010B.2, the caller must provide:

  • •

    their first and last name;

  • •

    the appointed representative's first and last name as shown on the SSA-1696 or query;

  • •

    the appointed representative's Rep ID number established upon the representative's registration with the agency (i.e., via SSA-1699);

  • •

    the caller's relationship to the appointed representative; and

  • •

    the claimant's identifying information listed in GN 03380.010B.2.

NOTE: If the caller cannot provide you with the required information, the associate should have the appointed representative call or visit the field office. Alternatively, the associate may submit an SSA-3288, SSA-3288-OP1, or other valid written consent signed by the beneficiary or claimant.

D. Circumstance of disclosure

We may disclose any information an applicant, claimant, beneficiary or representative payee is entitled to receive to an appointed representative, subject only to any limitations imposed by the individual.

IMPORTANT: If SPIN code 6 is present on the individual's Numident record, do not release any information to the appointed representative or their associate by telephone, mail, or fax. Notify the appointed representative or their associate that they must make the request for information in person at the individual's local field office.

We do not consider disclosures to appointed representatives as access requests (see GN 03340.015 for more information about access requests), but rather, disclosures made upon routine use authority.

We provide more information on the authority of a representative and when authority expires in GN 03910.025 and GN 03910.060.

NOTE: Because of the sensitivity of medical information, we must identify records containing medical information as "medical records" when we disclose them. Attach a completed Form SSA-1994 (Cover Sheet Confidential Medical Information) as a cover sheet for any medical records. If an SSA-1994 is not available, make a cover sheet to identify the records as “Confidential - Medical Information.”

E. Limiting Disclosure

We generally do not provide documents such as Master Beneficiary Record (MBR) printouts and other output query screens (administrative) to the appointed representative. If the appointed representative specifically requests that copies of such screens or queries be included, provide the information in another format, other than a copy of the query screenshot if possible. If we can provide the specific information the appointed representative requests in another manner, there is no obligation to provide a query. Disclosure of queries to appointed representatives should be a rare occurrence. When disclosing queries to appointed representatives, we should follow the same procedures described in GN 03305.004B and GN 03305.004C for disclosing queries to third parties with consent.

F. Disclosure to the appointed representative and designated associates when the appointment ends

We will honor an individual’s request to disclose records to the appointed representative and the representative's designated associates as long as the appointed representative’s appointment has not ended. Please see GN 03910.060 for information on when a representative’s appointment ends. If an appointment has ended, the individual must provide written consent for any subsequent disclosure of their records to the representative or designated associate.


GN 03316 TN 9 - Disclosure to Administer SSA Programs and Other Miscellaneous Disclosures - 3/26/2026