The Social Security Administration has long required Claimants to provide “wet signatures” on appointments of representative and fee agreements. This requirement has continued even though the federal government consistently recognizes the validity of e-signatures in many many other applications. As of 05/21/2020, it appears that the first cracks in this policy are beginning to develop. On Thursday, the SSA issued EM-20022, Temporary Instructions for the documentation of the Appointment of a Representative during the Coronavirus Disease 2019 (COVID-19) Pandemic). The original text may be found here: https://secure.ssa.gov/apps10/reference.nsf/links/05212020012614PM
While this does not represent carte blanche acceptance of e-signatures, it creates a method by which e-signatures may be employed and verified in the appointment process. This is progress, and it will hopefully continue.
What is not perfectly clear is whether this is a response to the closure of field offices for the COVID-19 situation, or whether this is in response to recent litigation filed in the US District Court for the District of Columbia by the National Federation of the Blind (https://www.prnewswire.com/news-releases/wet-ink-signature-requirement-endangers-social-security-disability-applicants-and-recipients-during-covid-19-lawsuit-says-301053983.html). Either way, this appears to be progress, and it will be interested to see whether the policy is retracted or continued as both situations develop.
