TN 1 (09-18)

GN 03980.070 SSA Employee as Applicant or Representative Payee

An SSA employee may be a representative payee for a parent, spouse, minor child or an incapable individual for whom the SSA employee serves in a fiduciary position (i.e., guardian, trustee). However, the SSA employee may not take any action in any manner (formal or informal) as an SSA employee in connection with the claim, such as participating in the development or prosecution of the claim. Services by an SSA employee serving in this capacity are limited to filing for and receiving benefits on behalf of an individual and associated actions.

It is the responsibility of the SSA employee to inform the DO that she is an SSA employee when filing a claim. If it comes to the attention of the DO in any other manner that the prospective representative is an SSA employee, determine why the employee did not disclose this fact at the initial filing and document the file.

To avoid any instances where an employee may attempt to use this procedure to circumvent the conflict-of-interest provisions, thoroughly document the claims file to show that the employee selected is the individual best qualified to serve as representative payee. When an SSA employee files a claim on behalf of an individual, evidence will be required on every factor of entitlement and do not apply any assumptions or presumptions of fact with regard to establishing entitlement.