PROGRAM OPERATIONS MANUAL SYSTEMPart GN – GeneralChapter 002 – Applications and InterviewsSubchapter 01 – Program - Related Claims PracticesTransmittal No. 38, 08/27/2025
Audience
Originating Component
OISP
Effective Date
Upon Receipt
Background
This transmittal adds the Foreign Enforcement Questionnaires (SSA forms SSA-7161 and SSA-7162) to the list of foreign program forms approved for signature proxy. It also removes duplicative information about the attestation process and adds detailed procedure for using attestation on eligible foreign program forms.
Summary of Changes
GN 00201.100 SSA Foreign Program Forms Authorized for Post-Entitlement Signature Proxy
Throughout the section, we removed references to "post-entitlement" (PE) because the instructions apply to initial claims as well as post-entitlement situations.
Subsection A: We simplified this background subsection to remove unnecessary historical information about the expansion of signature proxy to foreign program forms. We also removed the previous subsection B - about signature proxy in PE situations - because it was no longer needed.
Subsection B: In this Policy subsection, we removed general information about the attestation process because that is located in a different section of POMS. We added forms SSA-7161 and SSA-7162 to the list of foreign forms approved for signature proxy. We removed forms SSA-308, SSA-7163, and SSA-7163A from that list because those forms no longer require a signature.
Subsection C: We expanded this Procedure subsection with detailed procedure for interviewing, documenting, and submitting eligible foreign program forms using attestation. The procedure includes mailing a copy of the attested form to the form respondent, along with a form attestation cover letter.
In 2004, SSA adopted alternative signature methods to the traditional pen-and-ink or wet signature for domestic forms and application processes. We have since expanded the use of alternative signature methods to include several SSA foreign program forms.
For general information about alternative signature methods, see GN 00201.015.
SSA has adopted several alternative signature methods as listed in GN 00201.015. Signature proxy, using the “attestation” process, is the only type of alternative signature method currently used for foreign forms. To use attestation, the interviewer must read the penalty clause notice, and confirm the individual’s intent to submit the information and sign the document. Once complete, the interviewer “attests” to the fact that the individual agreed to the truthfulness of the information they provided and agreed to sign the form.
SSA-21 (Supplement to Claim of Person Outside the United States);
SSA-7161 (Report to the United States Social Security Administration by Person Receiving Benefits for a Child or for an Adult Unable to Handle Funds); and
SSA-7162 (Report to the United States Social Security Administration).
All SSA employees in U.S. Social Security offices who take and input initial claims and post-entitlement changes; and
Outside the United States, only the Federal Benefits Units (FBUs) within Foreign Service Posts (FSP).
Currently, signature proxy (using the attestation process) is the only alternative signature method used for foreign forms. Attestation is the action taken by the authorized employee to confirm:
the individual’s intent to complete the form,
affirmation under penalty of perjury that the information provided is correct, and
agreement to sign the form.
Follow this procedure during the interview:
Verify the identity of the individual according to relevant procedures for in-person or telephone interviewing.
Inform the individual that SSA has an alternative method to collect a signature in lieu of a pen-and-ink signature on the form and that our annotation of their:
intent to provide the information,
agreement to sign the form in SSA records will constitute a valid legal signature.
Read the following scripted language: “During this interview, we will ask you questions that will be used to complete your [insert name of form]. At the end of the interview, we will ask you to confirm the truthfulness of your answers under penalty of perjury and we will record your response. You should be aware that you can be held legally responsible for giving us false information.”
Confirm the individual’s intent to complete and sign the form using attestation.
Complete the form by obtaining and recording the individual’s responses.
At the end of the interview, read the following scripted language:
“You will receive a printed copy of the information being used to process your [name of form] to retain for your records. Do you understand that you must review all of this information carefully and let us know right away if anything needs to be corrected OR if any of the information changes?”
“Do you understand that the information you have provided will be used to process your [insert name of form]? Do you declare under penalty of perjury that this information is true and correct to the best of your knowledge?”
The individual must answer “yes” to all of the requirements above (i.e., intent to provide information, truthfulness of it, and agreement to sign it under penalty of perjury) in order to accept the form as a “signed form.” Individuals answering “no” to any of the requirements will need to submit the form with a pen-and-ink signature.
Follow the procedure below to document that you attest to the claimant’s agreement to all requirements and signing of the form:
Annotate the form’s signature field with the following: the individual’s name and “Attested by (your full name). Office code: (your office code).”
Reminder for the SSA-21: The signature block in item 18 of the form will need to be annotated for each beneficiary listed in item 3 of the form.
Fax actionable forms to the Division of International Operations (DIO) Paperless.
Store non-actionable forms in the Evidence Portal (EP). For an overview of the EP, see MS 09701.001.
For the SSA-7161 and SSA-7162: Send the completed form to Wilkes-Barre Direct Operations Center (WBDOC) via the multifunction device (MFD) process. If the “FEQ to WBDOC” button is unavailable on the MFD, e-fax the completed form to WBDOC’s FEQ Scan Only eFax inbox.
IMPORTANT: Refer to the Electronic Disability Guide (eDG), DI 81000.000 for operational procedures specific to updating the Certified Electronic Folder.
Give or mail a copy of the completed form to the respondent, along with the Document Processing System (DPS) cover letter, "Attestation Cover Letter."