Comment from Martin, Charles, Martin & Jones

I disagree with the proposed rule's assumption that the only reason to regulate fees of representatives is to avoid claimants paying excessive fees. The regulation of fees is one of the few ways the Agency has to assure that representatives are diligent, competent, and ethical in their representation. Removing this check on the conduct of representatives is unwise, as the very people who would no longer need to seek approval are the ones who, in my experience, are most likely to be deficient in the areas of diligence, competence, and ethics. I have represented individuals in Social Security claims for over 30 years, and am paid by my clients. The change would retain authority over my fees, but not over individuals who work for insurance companies and hospitals or other providers. But individuals who work for entities other than the claimant have inherent conflicts of interest. This change reduces regulation over the very people who most need regulating, and retains it over those who already are subject to regulation (at least in the case of attorneys).