How to Fill Out Form SSA-1691 (w/Examples) + FAQs

Form SSA-1691 is the Social Security Administration’s official application that lets a non-attorney representative ask to receive direct payment of approved fees from a claimant’s past-due Social Security or SSI benefits. You complete it by giving your personal data, certifying your education and good character, attaching exam and bonding proof, and signing under penalty of perjury, all of which the SSA’s Office of Budget, Finance, and Management reviews under the rules created by the Social Security Disability Applicants’ Access to Professional Representation Act.

The core problem this form addresses is that, before 2005, only attorneys could receive direct payment of approved fees out of a claimant’s past-due benefits. Non-attorney representatives had to chase clients for their fee after the case ended, which created cash-flow risk and discouraged skilled advocates from entering the field. Congress fixed that gap with Public Law 111-142, and the SSA built the Eligible for Direct Payment Non-Attorney (EDPNA) program around Form SSA-1691 to screen who qualifies.

According to SSA’s own Annual Report on the Representative Payee Program and related representation data, non-attorney representatives now handle hundreds of thousands of disability claims each year, and roughly one in four hearings before an Administrative Law Judge involves a non-attorney advocate. That growth is why getting Form SSA-1691 right matters so much, and why the SSA reviews each application closely under 20 C.F.R. § 404.1717.

Here is what you will learn in this guide:

• 📋 The exact line-by-line meaning of every box on Form SSA-1691 and how to answer it without triggering a denial.
• ⚖️ How the EDPNA statute interacts with the SSA-1696 appointment form and the SSA-1699 registration form so you do not mix them up.
• 💼 The bonding, liability insurance, and continuing education proof you must attach, plus what underwriters look for.
• 🧠 The exam, education, and good-character standards the SSA uses to decide your application.
• 🛡️ The most common mistakes that cause SSA to revoke direct-pay status, and the simple steps that keep you compliant for life.

What Form SSA-1691 Actually Is

Form SSA-1691 is titled Request for Direct Payment to Eligible Non-Attorney Representatives, and it is the application a non-lawyer files to join the EDPNA roster. The SSA created the form under authority granted by Section 303 of the Social Security Protection Act of 2004 and expanded under Public Law 111-142, which made direct payment permanent in 2010. You can find the official PDF on the SSA’s forms page and on the dedicated non-attorney representative page.

The form is not the same as a one-time fee request. It is an eligibility application that, once approved, lets you collect fees directly from withheld past-due benefits in every future case you handle, as long as you stay in compliance. SSA’s Office of Budget, Finance, and Management runs the program and publishes the annual filing window in the Federal Register, usually opening in the spring with a deadline near the end of summer.

You should not confuse Form SSA-1691 with three related forms that often appear in the same matter. The Form SSA-1696 is the claimant’s appointment of representative. The Form SSA-1699 is the representative’s one-time registration with SSA so the agency can pay you. The Form SSA-1693 is the fee agreement. Form SSA-1691 sits above all of those because it is what lets you receive money directly from SSA in the first place.

The consequence of skipping Form SSA-1691 is simple. You can still represent claimants, but the SSA will pay any approved fee to the claimant, not you. You then have to invoice the client yourself, which is exactly the situation Congress wanted to fix.

A common misconception is that passing the SSA exam alone makes you an EDPNA. It does not. The exam is one of five separate elements, and you must satisfy every one of them on the SSA-1691 application before SSA will issue your approval letter.

The Legal Framework Behind the Form

The Social Security Disability Applicants’ Access to Professional Representation Act of 2010 is the controlling statute. It made permanent a demonstration project that began under the Social Security Protection Act of 2004, and it added the bonding and insurance requirement that now appears on the form.

The implementing regulations live at 20 C.F.R. § 404.1717 for Title II disability claims and at 20 C.F.R. § 416.1517 for SSI claims under Title XVI. Those rules tell SSA exactly what to verify on the SSA-1691, and they bind both the agency and the applicant.

Procedurally, SSA enforces the form through its POMS GN 03920.018, which is the public Program Operations Manual System section that walks SSA staff through reviewing each application. The HALLEX I-1-1-10 provisions add hearing-level guidance for Administrative Law Judges who interact with EDPNAs.

The consequence of ignoring this framework is that SSA can deny, suspend, or revoke your status under 20 C.F.R. § 404.1745, and you can be barred from practice before the agency entirely. A revoked EDPNA loses every pending fee, not just future ones.

A real-world example helps. Jordan, a non-attorney advocate in Ohio, let his $25,000 bond lapse for six weeks while switching carriers. SSA learned of the lapse through a fee-petition audit and revoked his direct-pay status for the rest of the calendar year, costing him an estimated $48,000 in fees that flowed back to the claimants instead.

The common misconception about the legal framework is that state paralegal certification or a non-attorney advocacy certificate substitutes for federal EDPNA status. It does not. Only the SSA can authorize direct payment, and only through Form SSA-1691.

Who Can File Form SSA-1691

You can file Form SSA-1691 only if you meet five threshold requirements under 20 C.F.R. § 404.1717(a). First, you must hold a bachelor’s degree from an accredited institution, or have equivalent qualifications from training and work experience, as described in the SSA’s non-attorney eligibility page.

Second, you must pass the SSA-administered written examination, which the agency contracts out and offers through approved testing centers. Third, you must secure professional liability insurance or an equivalent surety bond in an amount SSA sets each year, currently no less than $698,000 per the most recent Federal Register notice on representative conduct.

Fourth, you must complete continuing education each year, with a minimum number of hours focused on Social Security disability law and ethics. Fifth, you must pass a criminal background check, because SSA must confirm you are of good character and reputation under 20 C.F.R. § 404.1705(b).

The consequence of filing without meeting all five is automatic denial, and SSA does not refund the exam or bonding costs. The plain-English version is that you should treat Form SSA-1691 like a professional license application, not a routine filing.

A common misconception is that attorneys can file Form SSA-1691 if they want extra security. They cannot. Attorneys use a different track under Section 206(a) of the Social Security Act and the SSA-1699 registration, and they should never submit an SSA-1691.

Step-by-Step: Filling Out Form SSA-1691

The form has six numbered parts plus a signature block, and every part has its own traps. The official PDF is on the SSA forms portal, and you should download a fresh copy each filing cycle because SSA updates the OMB control number and revision date annually.

Part 1: Identifying Information

Part 1 asks for your full legal name, current business address, business phone, business email, Social Security number, and date of birth. Use the exact name on your government ID, because a mismatch with your background-check report triggers a manual review under POMS GN 03920.018.

The consequence of using a nickname or a DBA in Part 1 is a delay of four to eight weeks while SSA reconciles the records. If your business operates under a trade name, list the legal name first and add the DBA in the Other Names Used line. SSA’s appointed representative services page explains why consistent identity matters across SSA-1691, SSA-1699, and the eFolder.

A real-world example: Maria, a non-attorney from Texas, listed her married name on the SSA-1691 but her maiden name on her bachelor’s degree transcript. The SSA paused her file for six weeks until she submitted a certified marriage record. She avoided denial, but she missed the filing window for that year.

Part 2: Education and Equivalent Qualifications

Part 2 asks where you earned your bachelor’s degree, when you earned it, and whether the institution is accredited by a body recognized by the U.S. Department of Education. If you rely on equivalent qualifications instead of a four-year degree, you must describe the training and experience and attach supporting documents.

The SSA evaluates equivalent qualifications on a case-by-case basis under 20 C.F.R. § 404.1717(a)(1). The agency generally looks for a combination of paralegal certification, multi-year claims experience, and formal coursework in Social Security law.

The consequence of overstating your education is severe. SSA treats a false statement on Part 2 as grounds for permanent disqualification under 20 C.F.R. § 404.1740(c)(3), and the agency may refer the matter to the Office of the Inspector General.

A common misconception is that an associate’s degree plus any paralegal certificate equals a bachelor’s degree. It does not, unless SSA specifically credits the combination as equivalent in writing.

Part 3: Examination

Part 3 asks for the date you passed the SSA examination and the score report number. The exam covers SSA disability law, ethics, claims procedure, and confidentiality rules drawn from the Privacy Act of 1974 and Section 1106 of the Social Security Act.

You must pass the exam within the application cycle SSA announces, and you cannot use a score older than the lookback period stated in the current Federal Register notice. Attach the official score report as a PDF, not a screenshot, because SSA rejects unverifiable images.

The consequence of an expired score is that you must retake the exam and pay the fee again, currently around $1,150 per the contractor’s published rate. Devon, a non-attorney in California, learned this the hard way when he tried to reuse a score from a prior cycle and had to wait an entire year for the next testing window.

Part 4: Professional Liability Insurance or Bond

Part 4 asks for the name of your insurance carrier or surety, the policy or bond number, the policy limits, the effective date, and the expiration date. SSA requires continuous coverage, which means no gaps even of a single day, under 20 C.F.R. § 404.1717(a)(4).

The minimum coverage amount changes annually. SSA publishes the current floor on the non-attorney representative page, and recent cycles have set it near $698,000 per occurrence with an aggregate at or above that figure. Carriers familiar with the EDPNA market include the carriers listed on the National Organization of Social Security Claimants’ Representatives vendor pages.

The consequence of a lapse in Part 4 coverage is automatic suspension of direct-pay status, and the suspension stays until you cure the gap and notify SSA in writing.

Part 5: Continuing Education

Part 5 asks for the courses, providers, dates, and credit hours you completed in the prior year. SSA accepts courses approved by state bar associations, by NOSSCR, or by other recognized continuing-legal-education providers, as long as the content is substantively related to Social Security disability practice.

You must average a minimum number of hours per year, currently set at 16 hours under the most recent Federal Register notice. Attach certificates of completion that show provider name, course title, date, and credit-hour count.

The consequence of falling short on CE is denial of the current-year application, but it does not bar you from reapplying once you make up the hours.

Part 6: Certifications and Attestations

Part 6 contains a series of yes/no certifications about criminal history, prior SSA sanctions, prior bar discipline, and current good standing. Answer every question, even if the answer is no, because blank responses trigger a default denial.

If you must answer yes to any item, attach a written explanation with court records or disciplinary orders. SSA evaluates the underlying facts under the good character and reputation standard at 20 C.F.R. § 404.1705(b)(1).

The consequence of a hidden conviction or undisclosed bar discipline is permanent disqualification and possible criminal referral under 18 U.S.C. § 1001 for false statements to a federal agency.

Signature, Date, and Submission

You must sign Part 7 in ink or by SSA-approved electronic signature, date it, and submit it to the address listed in the current Federal Register notice. Most cycles use the SSA’s Office of Budget, Finance, and Management mailing address in Baltimore, Maryland.

The consequence of an unsigned form is rejection without review, and the rejection does not toll the annual deadline. A common misconception is that you can e-file SSA-1691 through the Business Services Online portal. You cannot. As of the most recent cycle, SSA requires paper or scanned PDF submission to the address in the notice.

Three Common Scenarios Filers Face

Filer Situation	Likely SSA Outcome
Bachelor’s degree plus current bond plus 18 CE hours plus passing exam score plus clean record	Approval letter issued within 60–90 days, EDPNA status effective the date SSA signs the letter under POMS GN 03920.018
Equivalent qualifications plus expired exam score plus current bond plus 12 CE hours	Denial under 20 C.F.R. § 404.1717(a)(2) for exam, with permission to refile after retaking the test
Bachelor’s degree plus current exam score plus lapsed bond plus disclosed misdemeanor from 12 years ago	Conditional review with possible approval if the bond is restored and the misdemeanor does not involve dishonesty, per 20 C.F.R. § 404.1705(b)

Three Named Examples to Illustrate the Form

Aisha, a paralegal in Atlanta with eight years at a disability firm, filed Form SSA-1691 in her first eligible year. She held a bachelor’s in social work, passed the exam with a 92, secured a $700,000 errors-and-omissions policy through the NOSSCR insurance vendor list, and logged 22 CE hours. SSA approved her in 71 days, and she received her first direct-pay fee of $7,200 on a fully favorable ALJ decision three months later.

Carlos, a former SSA claims representative in Phoenix, retired from the agency and filed Form SSA-1691 to start a private practice. Because he had 24 years of agency experience, SSA credited his work as equivalent qualifications under 20 C.F.R. § 404.1717(a)(1). His prior federal employment also satisfied the background check quickly, and he was approved in 54 days.

Priya, a non-attorney advocate in New Jersey, tried to file Form SSA-1691 without disclosing a 2014 disciplinary letter from a state paralegal association. SSA discovered the letter through the background check, denied her application under 20 C.F.R. § 404.1740(c)(3), and barred her from reapplying for two years. She later refiled with full disclosure and was approved on the third try.

Mistakes to Avoid

Avoiding these errors is often the difference between a 60-day approval and a multi-year setback.

• Filing after the annual deadline in the Federal Register notice, which causes automatic rejection without review and forces a full one-year wait.
• Listing policy limits below the current SSA floor, which makes Part 4 invalid and voids the entire application under 20 C.F.R. § 404.1717(a)(4).
• Attaching screenshots of exam scores instead of the official PDF report, which causes SSA to reject Part 3 documentation.
• Omitting CE certificates from non-NOSSCR providers without showing the course relates to SSA practice, which causes denial of Part 5.
• Failing to disclose old criminal matters that the background check will find anyway, which converts a manageable issue into a permanent disqualification under 18 U.S.C. § 1001.
• Mixing up Form SSA-1691 with Form SSA-1699, which means you registered for payment but never applied for EDPNA status and therefore never get direct pay.
• Letting your bond lapse for even a single day after approval, which triggers suspension under 20 C.F.R. § 404.1745.
• Using a paper form from a prior year, which carries the old OMB control number and is rejected automatically.
• Skipping the SSA-1696 appointment in individual cases after approval, which means SSA has no authority to release fees to you even with EDPNA status.
• Forgetting to update your address with the SSA’s appointed representative services team, which causes you to miss the annual recertification notice.

Do’s and Don’ts for SSA-1691 Filers

Do’s

• Do download a fresh copy of Form SSA-1691 each filing cycle, because OMB approval dates change and stale forms are rejected on intake.
• Do keep a calendar reminder for bond renewal at least 30 days before expiration, because SSA gives no grace period under 20 C.F.R. § 404.1717.
• Do front-load CE hours in the first quarter of the year, because rushing in December causes paperwork errors and missed certificates.
• Do keep digital and paper copies of every attachment for at least six years, because SSA audits direct-pay fees and can demand documentation under POMS GN 03970.000.
• Do read the annual Federal Register notice line by line, because dollar thresholds and CE minimums change each year.

Don’ts

• Don’t assume passing the exam alone makes you an EDPNA, because the statute requires all five elements.
• Don’t sign Part 7 before completing every certification in Part 6, because incomplete certifications make the signature a false statement.
• Don’t rely on a state bar CLE that has no Social Security content, because SSA disallows unrelated courses under 20 C.F.R. § 404.1717(a)(5).
• Don’t share your SSN on the form by hand-printing it in pencil, because illegible entries delay processing by weeks.
• Don’t use a personal email address that you may abandon, because SSA sends recertification and audit notices to the address on file.

Pros and Cons of EDPNA Status

Pros

• Direct payment of approved fees from withheld past-due benefits, which improves cash flow and reduces collection risk under Section 206 of the Social Security Act.
• Professional credibility with claimants who recognize EDPNA designation as a federal credential.
• Access to the appointed representative services portal for electronic case management and eFolder review.
• Eligibility for two-tier fee agreements that mirror what attorneys can use under the SSA fee agreement process.
• Networking and training access through NOSSCR and similar national organizations that often limit certain programs to EDPNAs and attorneys.

Cons

• Annual cost of bonding or insurance, which typically runs $1,500 to $4,500 depending on coverage and history.
• Annual CE burden of at least 16 hours, which costs both time and tuition.
• Ongoing background-check exposure, because SSA can demand updated records at any time under 20 C.F.R. § 404.1745.
• Public listing on SSA disciplinary rosters if you are sanctioned, which is searchable through SSA’s representative sanctions page.
• No reciprocity with state-level paralegal credentials, which means EDPNA work outside SSA practice gives you no extra license.

State Nuances on Top of Federal Rules

Although the SSA-1691 process is purely federal, state law can still shape your practice. Some states, including California and Texas, restrict who can use the title paralegal outside attorney supervision, which affects how you market your EDPNA services. Other states, like Arizona, now license non-attorney legal practitioners directly, and those licenses can complement your EDPNA status but never replace it.

State unauthorized-practice-of-law statutes can still apply if you advise clients on non-SSA matters such as workers’ compensation offsets or long-term-disability insurance claims. The American Bar Association tracks state UPL enforcement, and most state bars publish opinions clarifying that SSA practice is governed by federal preemption under Sperry v. Florida, 373 U.S. 379 (1963), the seminal case allowing non-attorneys to practice before federal agencies.

The consequence of ignoring state UPL rules is that even with valid EDPNA status, you can face state-level enforcement for non-SSA advice. The plain-English version is to keep your scope tight to SSA matters and refer everything else to a licensed attorney.

A common misconception is that Sperry gives non-attorneys blanket protection. It does not. Sperry protects practice before the specific federal agency that authorized the non-attorney, nothing more.

Recap of Key Rulings and Authorities

The most important case is Sperry v. Florida, 373 U.S. 379 (1963), which held that a state cannot prohibit a non-attorney from practicing before a federal agency when the federal agency has authorized the practice. That ruling is the constitutional backbone of the EDPNA program.

Another key authority is the Social Security Disability Applicants’ Access to Professional Representation Act, which made direct payment permanent. The act amended 42 U.S.C. § 406 to add the bonding and insurance requirement that now anchors Part 4 of Form SSA-1691.

On the regulatory side, the Revisions to Rules of Conduct and Standards of Responsibility for Appointed Representatives update SSA’s expectations and apply directly to EDPNAs. That rulemaking tightened conflict-of-interest rules and increased reporting obligations.

The consequence of failing to track these authorities is professional risk. A representative who does not know the current bond floor or current CE minimum will be the last to know when SSA raises the bar.

Key Entities You Should Know

The Social Security Administration is the federal agency that administers the program. Inside SSA, the Office of Budget, Finance, and Management runs the EDPNA application process, and the Office of Hearings Operations supervises representatives at the ALJ level.

The Office of the Inspector General investigates fraud and false statements, including those on Form SSA-1691. The Office of the General Counsel handles enforcement actions against representatives.

Outside SSA, the National Organization of Social Security Claimants’ Representatives is the largest professional association serving both attorney and non-attorney representatives, and it publishes CE programs that SSA accepts for Part 5. The National Association of Disability Representatives is a similar organization focused specifically on non-attorney advocates.

The Federal Register is where SSA publishes the annual EDPNA notice with dollar thresholds and deadlines. The eCFR is where you find current versions of 20 C.F.R. Parts 404 and 416.

After SSA Approves Your SSA-1691

Once SSA approves your application, you receive a letter that names you an EDPNA effective on the date of signature. You must then register for payment using Form SSA-1699, and for each individual case you must file Form SSA-1696 signed by the claimant.

You must also recertify your bond, CE hours, and good-character status each year. SSA sends a recertification packet to your email of record, and you must return it within the timeframe stated in the notice. Missing recertification is the single most common reason EDPNAs lose status, according to SSA’s annual representative reports posted on the legislation and reports page.

The consequence of a missed recertification is suspension under 20 C.F.R. § 404.1745, and reinstatement requires a fresh application in the next annual cycle. The plain-English version is that EDPNA status is a living credential, not a one-time award.

A real-world example: Renee, a non-attorney in Florida, missed her recertification email because it landed in her spam folder. She lost direct-pay status for the next 14 months and had to refile the entire SSA-1691 packet, including a new exam if her score had expired.

How Fees Actually Flow After Approval

When SSA approves a claim and a fee agreement under the two-tier fee process, the agency withholds up to 25% of past-due benefits, capped by the statutory ceiling at 42 U.S.C. § 406(a)(2)(A). The current cap, last raised in late 2024, sits at $9,200 per case per the latest Federal Register notice on representative fees.

SSA then assesses a user fee on the direct payment to cover administrative costs, currently capped at $117 per case and adjusted annually for inflation under Section 206(d) of the Social Security Act. The user fee comes out of the representative’s fee, not the claimant’s benefit.

The consequence of not understanding the user fee is a billing surprise on every case. A common misconception is that the user fee is a separate invoice. It is not. SSA simply nets it against the direct payment and sends the balance to the EDPNA’s bank account.

FAQs

Is Form SSA-1691 the same as Form SSA-1696?

No. Form SSA-1691 is the EDPNA eligibility application for non-attorneys, while Form SSA-1696 is the claimant’s appointment of a specific representative in a single case.

Can attorneys file Form SSA-1691?

No. Attorneys are not eligible because they qualify for direct payment under a separate statutory track using Form SSA-1699, and filing SSA-1691 would be rejected.

Does the SSA-1691 cost money to file?

No. SSA charges no filing fee for Form SSA-1691 itself, but you must pay for the exam, the background check, the bond or insurance, and the continuing education hours separately.

Can I file Form SSA-1691 electronically?

No. As of the most recent Federal Register notice, SSA requires paper or scanned PDF submission to the address in the annual notice, not the Business Services Online portal.

Will SSA reimburse my exam fee if I am denied?

No. The exam fee, the bond premium, and the CE tuition are not refundable if SSA denies your application, regardless of the reason for denial.

Can a non-attorney use a two-tier fee agreement?

Yes. Approved EDPNAs may use the standard two-tier fee agreement under the SSA fee process, subject to the annual statutory cap.

Does an old misdemeanor automatically disqualify me?

No. SSA evaluates criminal history case by case under 20 C.F.R. § 404.1705(b), focusing on offenses involving dishonesty or fraud.

Is recertification required every year?

Yes. EDPNAs must recertify each year to confirm bond coverage, CE hours, and good-character status, and missing a recertification triggers suspension.

Can I appeal a denial of my SSA-1691?

Yes. You may request reconsideration under SSA’s internal procedures and ultimately seek federal-court review under the Administrative Procedure Act.

Does EDPNA status let me practice in any federal agency?

No. EDPNA status authorizes practice only before the Social Security Administration, and other agencies have their own non-attorney rules, such as the IRS enrolled agent program.

Can my law firm pay me as a non-attorney EDPNA?

Yes. Firms may employ EDPNAs and direct fees to the firm account, provided the firm complies with the conflict-of-interest rules in the 2024 Federal Register notice.

Will SSA notify my clients if my EDPNA status is suspended?

Yes. SSA notifies claimants in active cases when a representative loses status, and the notice appears on the public sanctions page accessible through SSA’s representation portal.