The CPAS process is used only with the following agency forms and writings (collectively referred to in this section as “forms”):

• •

  SSA-1696 Claimant’s Appointment of a Representative

• •

  SSA-1693 Fee Agreement for Representation Before the Social Security Administration, and other written fee agreements

• •

  SSA-16 Application for Disability Insurance Benefits (DIB). This includes the online version sent to the claimant with the SSA-L2 cover letter after a third party completes and submits the DIB/SSI internet claim

• •

  SSA-8000 Application for Supplemental Security Income (SSI)

• •

  SSA-8001 Application for Supplemental Security Income (SSI) (Deferred or Abbreviated)

• •

  SSA-820 Work Activity Report - Self Employment

• •

  SSA-821 Work Activity Report - Employee

IMPORTANT: Forms submitted through the e1696 and e1693 AdobeSign portals (SSA-1696 APP & SSA-1693 APP) or Upload Documents are not processed under this section because they are completed and submitted through the portal. Process these forms following the established procedure for each form.

In this section, "signatures" refers to that of the appropriate signers. See chart in subsection D for more information about appropriate signers.

1. a. 

   To be acceptable, the commercial product must:

   i. Affix a signer’s name in the signature area of the form;

   ii. Affix the date the form was signed in the signature area of the form or on an appended signature certificate page; and

   iii. Affix the time the form was signed in the signature area of the form or on an appended signature certificate page.

2. b. 

   To determine whether the signature is a valid CPAS, consider the following:

   i. Signature

   The signature area includes the signature box and the space directly surrounding the signature and date boxes.

   The signature must be in the signature area of the form. It cannot be appended on a separate signature certificate page.

   ii. Date and time stamp

   The date AND time of the signature must be included at the time of the submission. They may appear either in the signature area or on an appended signature certificate page submitted with the form.

   iii. Appended signature certificate page

   If the time or date are missing from the signature area of the form, an individual may include an appended signature certificate page to meet those CPAS requirements.

   If the submission includes multiple forms that require an appended signature certificate page, the submitter must append a separate signature certificate page to each of these forms at the time of submission.

   DO NOT accept the signature certificate page if it is submitted separately or later.

   If an appended signature certificate page is needed to meet CPAS requirements and it is not appended to the form at the time the form is submitted, REJECT the form.

3. c. 

   If these criteria are met, accept the CPAS and process the form following the form's established procedure.

4. d. 

   If the criteria are not met, do not process the form. Follow existing policy to dispose of the form, notify the submitter the form cannot be accepted, and explain why the criteria are not met. Follow existing procedures to obtain a policy-compliant signature.

   To notify the submitter that the form cannot be accepted, the field office or payment center will send the following notice:

   [Submitter's Name]

   [Submitter's Address]

   We cannot accept your form(s) because the signer’s signature on [*F1 or *F2] does not meet the commercial product alternative signature (CPAS) requirements described in DI 11005.017 “Commercial Product Alternative Signature Process for Certain Forms and Writings.” Specifically, your [*F3 or *F4 or *F5 or *F6].

   Please resubmit [*F1 or *F2] ensuring that our signature requirements are met.

   REF C01

   REF167

   Fill-ins:

   *F1: Form SSA-XXXX

   *F2: Your forms

   *F3: Form is not approved for commercial product alternative signature under DI 11005.017.

   *F4: Form is missing required information (i.e., date and/or time) and it is not accompanied by an appended signature certificate page that includes this information.

   *F5: Submission includes one or more forms that did not include all the required information (i.e., date and/or time) and each was not accompanied by an appended signature certificate page that included this information.

   *F6: Submission includes one or more forms that are missing the required information (i.e., date and/or time), and only includes one appended signature certificate page, thus disqualifying the entire submission from being accepted. Note that each form missing this information must be accompanied by an appended signature certificate page that contains this information.

1. a. 

   Use of a CPAS does not affect the method(s) by which the forms listed in this section must be submitted. Individuals may submit a CPAS-signed form using any method currently accepted for that form.

2. b. 

   Do not accept faxed submissions of forms SSA-16, SSA-8000, or SSA-8001 as valid applications, see GN 00204.001. However, a faxed benefit application form will establish a protective filing date, see GN 00204.010F.1.

1. a. 

   After verifying that the CPAS requirements are met, document the CPAS per the instructions in subsection E.

2. b. 

   Process the form following established agency procedures for the specific form.

3. c. 

   If an appended signature page is used to meet the CPAS requirements, ensure that the appended page remains with the form in the claim(s) folder.

1. a. 

   In this section, “submitter” means the individual who files any or all the forms listed in this section.

2. b. 

   The submitter must ensure the commercial product used can generate an audit trail and must maintain a digital certificate that shows the following:

   • •

     The form was signed using a commercial product,

   • •

     The signature details, i.e., name of the person(s) who signed the form, date the form was signed, and time the form was signed,

   • •

     The email address(es) and IP address(es) associated with each signature,

   • •

     Whether the form was changed after signature, and

   • •

     An identifier that connects the audit trail to the signed form to which it applies.

   IMPORTANT: Agency staff are not responsible for confirming that the commercial product used to sign the form can generate an audit trail with a digital certificate that meets these requirements. The audit trail with a digitial certificate is different from an appended signature page containing the date and/or time used to complete the criteria to use CPAS.

3. c. 

   The submitter must retain the audit trail with a digital certificate for at least three years from the date they submit the form to the agency and, if requested, they must show the unredacted digital certificate in its entirety. If the agency rejects or questions the signature, staff may ask the submitter for additional information (including information about the process used to obtain the signature).

When multiple forms listed in this section are received together:

• •

  Each CPAS for each of the forms must meet the requirements in this section.

• •

  If an appended signature certificate page is needed to meet the CPAS requirements for one or more forms in a bundle, each such form must include its own appended signature certificate page.

IMPORTANT: DO NOT accept multiple forms bundled together with only one appended signature certificate page for the entire bundle if multiple forms in the bundle require an appended signature certificate page to meet the CPAS requirements. Each form must meet the CPAS or other agency signature requirements individually.

SSA-827 forms submitted with a CPAS require attestation before they can be accepted. To obtain attestation follow applicable policy and procedure, see DI 11005.056D and DI 22501.007.

Process new notices of appointment in RASR per existing policy. If the form meets CPAS criteria, select the checkbox that reads, “Select this box if the claimant signed with a Commercial Product Alternative Signature (CPAS)” on the signature screen, see screenshot.

Input the current date as the receipt date.

• •

  For initial claims, add the CPAS issue on the MCS DW01 screen and the Development Worksheet in CCE SSI.

• •

  If a hearing office is unable to make the change in RASR, it will send an assistance request to a field office to complete the action.

• •

  For post-entitlement cases, establish an SSA-5002 and store in the electronic folder associated with the claim.

• •

  For paper folders, store in Evidence Portal.

Follow the instructions in GN 00201.015.