TN 23 (11-15)

A. Background on signature proxy for SSA foreign program forms

SSA uses the following approved signature alternatives or signature proxies:

• witnessed signature,

• click and sign, and

• attestation.

On November 20, 2004, signature proxy became available for initial claims taken in Foreign Service Posts (FSPs) that have access to the Modernized Claims System (MCS).

On July 12, 2006, signature proxy expanded to the following SSA foreign program forms when taken in connection with an initial claim:

• SSA-308 (Modified Benefit Formula Questionnaire-Foreign Pension)

• SSA-7163 (Questionnaire About Employment or Self-Employment Outside the United States)

• SSA-7163A (Supplemental Statement Regarding Farming Activities of Person Living Outside the United States)

• SSA-21 (Supplement to Claim of Person Outside the United States)

For more information about Alternative Signature Methods, see GN 00201.015.

B. Use of post-entitlement signature proxy for SSA foreign program forms

Effective August 2014, as part of SSA’s commitment to paperless processing, we expanded signature proxy for certain SSA foreign program forms in post-entitlement situations. Form attestation is the only type of signature proxy used for post-entitlement actions on SSA foreign program forms.

C. Policy on post-entitlement signature proxy for SSA foreign program forms

Form attestation is documenting information obtained from the claimant by authorized personnel. The act of attesting to these facts is documentation of the proper beneficiary’s signature. We consider attestation equivalent to a signature.

Form attestation can be over the phone or in person. For in person and telephone reports, the interviewer:

• confirms the proper claimant’s intent to file and sign the form;

• provides and reviews the penalty clause notice; and

• attests to the proper beneficiary’s intent to sign the forms.

IMPORTANT: This policy does not change any requirement for an in-person interview for enumeration or claims purposes, or the requirements for special payment in an SSA restricted country per RS 02650.040.

1. SSA foreign program forms approved for post-entitlement signature proxy

The following is a list of SSA foreign program forms approved for post-entitlement signature proxy:

• SSA-308 (Modified Benefit Formula Questionnaire-Foreign Pension)

• SSA-7163 (Questionnaire About Employment or Self-Employment Outside the United States)

• SSA-7163A (Supplemental Statement Regarding Farming Activities of Person Living Outside the United States)

• SSA-21 (Supplement to Claim of Person Outside the United States)

2. Persons authorized use post-entitlement signature proxy for SSA foreign program forms

• All SSA employees in U.S. Social Security offices who take and input initial claims and post-entitlement changes can use form attestation for the approved SSA foreign program forms listed in GN 00201.100C.1 in this section.

• Outside the United States, only the Federal Benefits Units (FBUs) within the FSPs may use form attestation.

D. Procedure for form attestation for in-person and telephone interviews on SSA foreign program forms approved for post-entitlement signature proxy

Authorized SSA employees and FBU personnel must complete the following steps when using form attestation during in-person or telephone interviews on SSA foreign program forms approved for post-entitlement signature proxy:

1. Follow instructions for interviewer responsibilities in GN 00201.015F.1

2. For in-person interviews, use the form attestation interview script in GN 00201.015F.2

3. For telephone interviews, use the form attestation interview script in GN 00201.015F.3

4. Follow documentation requirements in GN 00201.015F.4

5. Complete the following after the interview:

   1. Annotate the “Signature Page” on the form with “ATTEST,” along with the interviewer’s name and office code.

   2. When using signature proxy for Form SSA-21, annotate “ATTEST” in a signature block in item 18 for each beneficiary (or the representative payee of a beneficiary) listed in item 3 of the form. Only annotate “ATTEST” once for:

      • an individual who is the representative payee for more than one beneficiary listed in item 3

      • an individual who is a beneficiary listed in item 3 in addition to being the representative payee for one or more beneficiary listed in item 3.

   3. Fax actionable attested forms to Division of International Operations (DIO) Paperless.

   4. Store non-actionable attested forms in Non-Disability Repository as Evidentiary Documents (NDRED).

   IMPORTANT: Refer to the Electronic Disability Guide (eDG) — DI 81010.120 for operational procedures specific to updating the Certified Electronic Folder.