Direct Payment to Eligible Non-Attorney Representatives

Important Information

EDPNA Continuing education courses

The 2024 Requirements for Continuing Eligibility for EDPNAs are now available. To remain eligible for direct payment, an EDPNA must certify the completion of each of these courses by email to StratComm, Inc. on or before September 30, 2024

The EDPNA program is now being serviced by StratComm, Inc. For any questions that are not answered on this website, please contact StratComm at:

Stratcomm, Inc.
24 Superior Drive, Suite 103
Natick, MA 01760

What is an Eligible for Direct Pay Non-Attorney (EDPNA)

An EDPNA is a non-attorney representative who provides representation for claimants during the Social Security disability adjudicatory process. Qualified EDPNAs are eligible for direct payment of authorized fees for representing claimants. The EDPNA’s scope of representation is specified in writing by the claimant and determines the EDPNA’s authority in a pending claim, matter, or issue that they have been appointed to handle. An EDPNA can be appointed by a claimant to represent them with a pending claim or issue at any level of administrative review.


Requirements for Direct Payment to Non-Attorney Representatives

The rules for representation of claimants before the Social Security Administration (SSA) can be found in 206 [42 U.S.C. 406] of the Social Security Act (Act) and 20 CFR 404.1700 and 416.1500. Specifically, Section 206(e) of the Act and 20 CFR 404.1717 and 416.1517 provide the rules for the Eligible for Direct Payment Non-Attorney (EDPNA) program.

To receive direct payment of fees authorized under Titles II and XVI of the Act, a non-attorney representative must:

  • Complete and sign an application;
  • Submit the completed application with payment of the application fee;
  • Have the required education, which is:
    • a bachelor's degree from an U.S. accredited institution of higher learning, or
    • at least four years of relevant professional experience and either a high school diploma or General Education Development (GED) certificate;
  • Pass our criminal background investigation;
  • Attest under penalty of perjury that they have not:
    • Been suspended or disqualified from practice before us, or disbarred from the practice of law in any jurisdiction;
    • Had a judgment or lien assessed against them by a civil court for malpractice or fraud;
    • Been convicted of a felony; and
    • Misrepresented information provided on their application or supporting materials for the application;
  • Pass a written examination that we administer. This examination tests the knowledge of the relevant provisions of the Act and any recent changes in SSA policy and court decisions affecting Titles II and XVI of the Act;
  • Secure and maintain continuous professional liability insurance or equivalent insurance that we determine to be adequate to protect claimants in the event of malpractice by the representative; and
  • Demonstrate the ongoing completion of qualified courses of continuing education, including education regarding ethics and professional conduct, which are designed to enhance professional knowledge in matters related to entitlement to, or eligibility for, benefits based on disability under titles II and XVI of the Act.


Beginning in 2024, applicants must provide the above documentation within 12 months of our notification regarding their test results; otherwise, they must reapply to the EDPNA program in a subsequent application period, pay the application fee, and retake the EDPNA examination. For additional information, please visit our website at:

We will conduct a current background check (for sanctions and criminal records) for applicants who passed the EDPNA examination in 2023 or earlier but did not complete the application process by providing proof of education or professional experience and professional liability insurance. To complete the current background check, applicants must submit page 11 of Form SSA-1691 (Eligible Non-Attorney Representative Application) and all required documentation as explained at:

We have authorized StratComm, Inc., to manage the EDPNA program, including administering our examinations and ensuring non-attorney representatives meet and maintain the requirements for direct fee payment. For all inquiries regarding the EDPNA program contact StratComm, Inc.

Application to the EDPNA Examination

We accept applications for the EDPNA examination each year from February 1 through February 28. If February 28th falls on a Sunday, we will extend the application period to the following Monday. We may change or extend the application period if we find that it is in the interest of the program. Any changes to the application period will be posted in the news updates on the main appointed representatives and EDPNA home pages.

Applicants to the EDPNA program must complete and submit Form SSA-1691 (Eligible Non-Attorney Representative Application). We will only accept applications that are received or postmarked on or before the last day of the application period, and we will return any applications that are postmarked after this date without consideration. All application packages must be submitted to StratComm, Inc.

An application package is complete only if it includes all the following:

  • A completed and signed application Form SSA-1691;
  • A completed and signed applicant authorization for release of information form (page 11 of SSA-1691); and
  • An application fee payment of $1,000.  
Application Form Requirements

Be sure to complete and sign your application form before submitting it. If you submit an incomplete application, you will be required to resubmit another complete application within ten calendar days. This may delay your background check and your acceptance to the examination.
If we find your re-submitted application defective for any reason, we cannot approve your application and we will refund your fee. In this situation, you will be permitted to submit a new application with payment by the last day of the current application period or in any subsequent year.

NOTE: We require documentation that you meet the educational and any equivalent professional qualifications and the liability insurance requirements detailed below, after you take and pass the examination.
Application Fee

The Social Security Act allows us to assess a reasonable fee to cover the cost of administering the written examination and conducting background checks. The application fee is currently $1,000.00 and is due no later than the last day of the application period. This fee must accompany your application form and applicant authorization for release of information. Acceptable forms of fee payment are:

  • Personal check; and
  • Money order.

We cannot refund your application fee for the following reasons:

  • You take and do not pass the examination; or
  • You fail to begin the examination on time without good cause.

Make application fee payable to StratComm, Inc. If you choose to pay by check and your check is returned for non-sufficient funds, we require that your resubmitted payment be in the form of a money order.

Application Completion Checklist
Section A - Background Information
  • You must provide your full legal name, any other names used, Social Security Number, date of birth, and citizenship status.
    • If you are a naturalized citizen or alien authorized to work in the U.S, we may request proof of your citizenship or work permit for the background check.
  • Your contact information must include a valid mailing address, phone number, and email address.
    • An email address is required for setting up the online exam.
  • You must provide a Yes or No response to each of the Background Information questions (1 through 9, as well as answer any applicable follow-up questions).
Section B – Education/Equivalent Qualifications
  • If you have a bachelor's degree from a post-secondary institution accredited by an accreditation body recognized by the United States Department of Education, you must include the name and location of the institution, the dates attended, and the degree granted.
  • If you have a high school diploma or General Education Development (GED) certificate, you must provide the name and location of the institution and the date your diploma or GED was issued. In this case, you must also provide details regarding your relevant professional work experience including your title, name of employer, employer contact information, and a detailed description of your duties. 
  • You may gain this experience in professions such as teaching, counseling or guidance, social work, personnel management, public administration, public employment services, nursing, or health care. We will also consider relevant professional experience to include work involving claims for benefits under Titles II or XVI of the Act. You can include work experience obtained outside the United States if you demonstrate that the work qualifies as relevant professional experience. You may use Section D for extra space.
Section C – Examination Information
  • We administer the EDPNA examination through a remotely proctored online portal (see Requirements for Your Examination Environment below).
  • As of 2024, we no longer offer the examination at testing center locations. Applicants do not need to complete Section C of Form SSA-1691 unless requesting special accommodations.
  • If you require any special accommodation, you must request this on the application and provide supporting documentation as required. Your request for ADA accommodations must follow the requirements on the homepage.  You may use Section D for extra space.
Section D – Additional Information

You may use this section for additional information for work experience or special accommodation needs.

  • Using your initials, you must acknowledge that you have read and understand the following statements:
    • Privacy Act Statement;
    • Paperwork Reduction Act Statement;
    • Substantial Misrepresentation or Material Discrepancy Statement;
    • Application Fee Statement; and
    • Statement of Understanding.
  • We require a dated, handwritten signature in acknowledgement of the Penalty of Perjury Statement. 
Applicant Authorization for Release of Information
  • You must complete the Applicant Authorization for Release of Information in its entirety.
  • Ensure that you enter all your personal information and that it is consistent with the information you provide on Page 4 of the application.
  • You must provide residency information for the past five years, including the first and last months and year of residency.
  • You must provide a dated, handwritten signature, and daytime phone number in acknowledgement of the Application Authorization for Release of Information form.
  • REVIEW your application for completeness. Remember to sign both the application and the authorization form.


Educational or Relevant Professional Experience

Before taking the examination, you must indicate on the application that you meet the educational or equivalent professional experience requirement as listed in 20 CFR 404.1717 and 416.1517. We will ask for proof of your education, appropriate training, or work experience after you pass the examination. You will not qualify for direct fee payment until you submit evidence that you meet the educational or relevant work experience requirement.

Examples of relevant documentation we may accept include, but are not limited to:

  • Copies of an official education transcript;
  • Letters from an applicant's employer verifying the length and type of employment:
  • Copies of an Internal Revenue Service (IRS) Form W–2 (Wage and Tax Statement); and
  • IRS Form 1099-NEC, and unmasked transcripts of federal or state tax returns. Please note that copies of masked transcripts of tax returns will not be acceptable.

Education Requirement

To receive direct fee payment, The Act requires that you have:

  • A bachelor's degree from an accredited U.S. college or university; or
  • A high school diploma or GED certificate and equivalent qualifications derived from work experience.

You must provide proof of your education and any relevant professional work experience after you pass the examination. The kinds of proof we accept to verify the education requirement include, but are not limited to, an official copy of either a college or university degree, a high school diploma, or a GED certificate.

Relevant Professional Work Experience

If you do not have a bachelor's degree from an accredited U.S. college or university, you must demonstrate that you have at least four years of relevant professional work experience and either a high school diploma or GED certificate.

We will consider relevant professional experience for the EDPNA program to be four years of full time work, or the equivalent, through which the applicant reviewed and analyzed medical reports and demonstrated the ability to describe and assess mental or physical limitations. We will also continue to consider relevant professional experience to include work involving claims for benefits under title II or XVI of the Act.

Types of work that may qualify as relevant professional experience may be in fields such as teaching, counseling or guidance, social work, personnel management, public employment service, nursing, or health care professions when that experience meets the requirements above.

Note: Please ensure when providing relevant work experience to be as detailed as possible (Including a timeline of relevant experience).

EDPNA Examination

The EDPNA examination consists of fifty (50) multiple-choice questions. You have up to three hours to complete the examination and must obtain a score of seventy percent or greater to pass.

During the examination, the Electronic Code of Federal Regulations (20 CFR, Chapter III, Part 400-499) will be available as a reference source.

Test Question Examples
  1. Short Question Format


Into which education category does a person who obtained a 7th grade through 11th grade level of formal education generally fall?


  • Limited education (Correct)
  • High school education and above (Incorrect. High school and above education require formal schooling at a 12th grade level or above, or a GED)
  • Marginal education (Incorrect.  Marginal education includes schooling at a 6th grade level or less)
  • Illiteracy (Incorrect.  Illiteracy includes only people who cannot read or write a simple message, even though they may be able to sign their name)


20 CFR 404.1564 and 416.964.

  1. Scenario Format


A client comes to you asking for representation for their Title II claim for benefits due to chronic heart failure.  In reviewing the claimant’s medical records, you see that recent medical evidence shows your client has diastolic failure with left ventricular posterior wall plus septal thickness of 2.7 cm and an enlarged left atrium of 4.3 cm with normal elevated ejection fraction during periods of stability.  The record also shows that your client has experienced three episodes of acute congestive heart failure within the last year.
Does your client’s chronic heart failure meet a Listing?


  • No, because chronic heart failure is not considered in the Listings. (Incorrect. Chronic heart failure is listed under section 4.02)
  • Yes, because their impairment meets either subsection A or B of the appropriate Listing. (Incorrect. 4.02 requires that both sections A and B be met)
  • No, because their impairment does not meet or medically equal the requirements for both subsections A and B of the appropriate Listing. (Correct)
  • Yes, because their impairment meets subsections A, B, and C of the appropriate Listing. (Incorrect. There is no subsection C for 4.02)


Appendix 1 to Subpart P of Part 404 – Listing of Impairments.

Requirements for the Examination
Requirements for Your Examination Environment

Find a quiet, distraction-free area to take your exam. You may take the test from a location of your choice during the time you scheduled. No other individuals are allowed in the room with you during the online exam.

Ensure you have current valid government-issued photo ID. You must show identification to be admitted into the online exam session. Examples of acceptable documents may include state driver's license or identification card, passport, civil service ID, permanent resident card, employment authorization card, or military identification card. Expired photo ID(s) will not be accepted.

Obtain an erasable hand-held whiteboard and erasable marker. This may be used in place of scratch paper. Absolutely no scratch paper will be permitted. After completing your exam, the proctor will verify that you have completely erased the whiteboard. These types of boards can be purchased inexpensively through retail stores and online retailers.

Familiarize yourself with electronic reference materials before the examination. The Electronic Code of Federal Regulations will be accessible to you during the examination, which you may refer to as needed, within the examination platform. You should familiarize yourself with the Electronic Code of Federal Regulations before the examination. We discourage the use of reference materials, notes, or other forms of information during your online examination session.

Prohibited items: You must silence and cannot use your cell phone during the examination. You must also remove all internet accessible devices from the examination area, except for your computer used to take your examination.

Area Check: Verification will be conducted via webcam to ensure an appropriate testing environment, meaning the webcam will need to be able to clearly see you and your surroundings at all times.

Technical Requirements by Vendor

Mandatory system requirements check: StratComm will provide you with a link to test your equipment. You must have a reliable personal computer with a high-speed internet connection with a minimum upload speed of 1.5 Mbps, a microphone, speakers, and a webcam (internal or external).

Supported operating systems: Windows 8 and higher, Mac OS X and higher, Chrome OS and many Linux distributions.

Supported browser: Ensure that your system is updated to run latest version of Google Chrome.

Important: You must take your exam on the same equipment that you completed the system check. If your equipment fails before you begin on the day of the exam you must contact StratComm immediately. If your equipment fails to meet requirements on the day of your examination, you will fail the examination.

Log on early: On your examination day, you should log in to the examination 15 minutes early to allow time to launch the online exam portal and get logged in. You will not be permitted to take the examination if you are late to your scheduled examination time and will not be eligible for a refund of your application fee.

Registering and Updating Your Personal Information

Once you receive your notice of eligibility, you must register with us using Form SSA-1699 (Registration for Appointed Representative Services and Direct Payment) to receive direct payment. If your information or status changes, you must update your name, physical address, email, phone number, and payment information by submitting Form SSA-1699 again. Be aware that submitting Form SSA-1699 is only part of the process.  You must also submit your updated information directly to StratComm, Inc. to keep their files updated.

Requirements for Continuing Eligibility

To retain eligibility, you must take and certify annual continuing education courses and continuously maintain professional liability insurance.

Continuing Education

All continuing education courses must meet the standards that we prescribe. We select courses with the goal of enhancing your professional knowledge in matters such as benefits, ethics, the listings of impairments, and other disability topics under Titles II and XVI of the Social Security Act. These courses may be completed in person, online, or by reviewing written course materials, but must be completed during the current reporting period.

You must take and certify the continuing education courses linked below and one ethics course as described under Ethics and Professional Conduct Course. We announce all required courses on our website on or before March 31 each year.

You must certify completion of all your continuing education courses for our review and approval by September 30 each year. To certify courses that you have completed, you must send an email or letter to StratComm, Inc.

To certify your mandatory courses offered by us, you must include:

  • Exact title of course; and
  • Date taken.

Your certification for your ethics course must include the following information:

  • Exact title of the course(s);
  • Date the course(s) was completed;
  • The organization that provided the course; and
  • Syllabus or short description from the course(s).

Note: We require the above information for all ethics courses including those courses, we have previously reviewed and approved.

If you do not complete and certify the required continuing education courses by September 30, you will be ineligible for direct fee payment for at least six full calendar months, beginning the first day of the month after the month the protest period ends, or the month after the month we uphold our finding of ineligibility.

Ethics and Professional Conduct Course

You must complete an ethics and professional conduct course that meets our requirements listed below and is provided by:

  • An accredited college or university,
  • A state bar association,
  • An organization accredited by a state bar,
  • A government agency, or
  • A professional organization.

Note: We cannot accept any course or training created by your employer unless they meet the criteria above.

To qualify as an ethics and professional conduct course, the course’s official syllabus must indicate that the course’s primary focus is to cover at least one of the following criteria:

  • The rules of conduct and standards of responsibility for representatives listed in 20 CFR 404 Subpart R and 416 Subpart O and related sub-regulatory guidance;
  • Maintaining a professional representative-claimant relationship as it relates to the personal ethics of a representative, such as maintaining appropriate boundaries with clients;
  • Ethics of billing and/or receiving fees for representing clients;
  • Ethical use of technology in the representation of claimants (e.g., Cybersecurity and data breaches, best practices for data storage, or using social media); or
  • Ethical handling and application of records and evidence (e.g., protecting clients' privacy, personally identifiable information, or representative/client communications).

Courses may be online, in-person, or written, and they may be live or pre-recorded.

All ethics courses must be consistent with our most recent ethics requirements to receive credit. We cannot provide credit for any ethics course that you have attended more than once. Finally, we will reject any course if we determine that the course does not meet our requirements.

Please take a few minutes to complete the optional end of course survey.
Professional or Business Malpractice Liability Insurance

If you pass our examination and we determine that you meet the eligibility requirements for direct pay, we will issue you a Notice of Eligibility. You must submit proof of your professional or business liability insurance to us before you can be eligible for direct payment.

In addition to providing proof of your professional or business liability insurance to establish eligibility for direct pay, you must provide proof of professional or business liability insurance indicating coverage for the minimum amounts per incident and annual aggregate amounts listed below whenever:

  • You change insurance providers;
  • After any period of ineligibility;
  • Your insurance policy is renewed;
  • You change employment status; and
  • We request proof of professional or business liability insurance during an audit.

All insurance documents must be submitted to us through StratComm, Inc.

You must carry professional liability insurance coverage of at least $100,000 per incident and a minimum annual aggregate coverage of $500,000 (see 2005 FR Vol 70 No.136). For a business liability malpractice insurance policy, the minimal annual aggregate amount is determined in accordance with the following schedule:

Number of Covered Employees Minimum Aggregate Amount

1 to 10


11 to 25

$1 million

26 to 50

$2 million

51 to 100

$3 million

101 to 200

$4 million

201 or more

$5 million

We consider business liability insurance to constitute insurance equivalent to professional liability insurance provided the business liability insurance provides coverage that satisfies the required minimum per-incident and aggregate amounts.  You must submit your certificate of insurance, binder of insurance, or other actual policy containing the following information:

  • Effective dates of the insurance policy;
  • Policy number; and
  • Limits of professional liability insurance for malpractice.

Proposals, quotes for professional or business liability insurance, or any other documents that do not clearly establish that a policy meeting our requirements has been purchased, are not acceptable. Your professional or business liability insurance must be in effect at the time you submit proof to us. If you fail to submit proof of sufficient professional or business liability insurance, you will not be eligible for direct payment.

You will not be eligible for direct payment until your evidence of professional or business liability insurance is both submitted and approved by us.  If we do not receive and approve your documents on or before the final day of the month by the 3:00 p.m. EST deadline, you will not be eligible for direct fee payment until the month after the month we receive and approve your documents.

If you are establishing eligibility for direct pay for the first time, you must submit a completed Form SSA-1699 on or after your assigned date of eligibility.

Annual Insurance Audit

To protect claimants and maintain the integrity of the EDPNA program, we periodically audit insurance coverage and conduct additional background checks for program participants. Failure to meet our requirements during an audit will make you ineligible for direct fee payment for at least six months.

If you are selected for an insurance audit, we will send you a notice requesting proof of insurance coverage before the deadline set out in the notice. A lapse in your insurance coverage, except as described below, is a violation of the EDPNA program rules that will result in a period of ineligibility and preclude you from receiving direct payment from us for no less than six months.

“Prior Act” insurance coverage is not compliant with the statutory and regulatory requirement that you maintain continuous liability insurance coverage.
We will not consider a lapse of coverage a violation of the EPDNA program rules, for temporary periods of pre-approved inactivity).

If your professional or business liability insurance status changes, you must promptly notify us in writing at StratComm, Inc. After receiving the necessary information, we will determine whether you may discontinue your professional or business liability insurance coverage during the period of inactivity without adverse action by us. You must also notify us if you wish to resume eligibility for direct payments. Before we will change your status to resume eligibility for direct payment, you must first submit to us proof of professional or business liability insurance and certification of current continuing educational courses.

NOTE: You may continue to represent claimants during a period of ineligibility for direct payment; however, you will be unable to receive direct payment during any such period.

If you do not maintain continuous professional or business liability insurance coverage or do not provide sufficient proof of continuous coverage within our deadline, and we have not informed you that you are excepted from this requirement while inactive, we will find you ineligible for direct payment for at least six full calendar months. You can find information about our ineligibility and protest procedures below.

Examples of Breaks in Insurance Coverage

Example 1:

You represent claimants before us as an EDPNA but temporarily stopped practicing and cancelled your professional or business liability insurance. However, you did not inform us that you were no longer practicing at this time. Later, when you started practicing before us again, you purchased new insurance. Because each EDPNA is required to maintain continuous professional or business liability insurance, you will be ineligible for direct payment per 20 CFR 404.1717 and 416.1517 for at least 6 months.

Example 2:

You temporarily stopped working as an EDPNA and properly informed us that you would be inactive. We then changed your status to inactive, after which you were no longer able to receive direct payment. Once you were ready to represent clients as an EDPNA again, you purchased and submitted your proof of professional or business liability insurance and current continuing education courses. Upon receiving your documentation, we returned your status back to eligible for direct payment. Later, we selected you for an insurance audit and found that you had a period of lapsed insurance. Because you notified us in advance of your break in representation as an EDPNA, and because you have been continuously insured since you started to work again, you will remain eligible for direct payment (see 20 CFR 404.1717 and 416.1517).

False or Misleading Information

We will find you permanently ineligible to receive direct payment of fees if we discover that you have falsified or misrepresented information in your application, or subsequent communications with us. Examples include false or misleading information about:

  • Any suspension or disqualification from practice before us, or suspension or disbarment from the practice of law in any jurisdiction;
  • A judgment or lien assessed against you by a civil court for malpractice or fraud;
  • A felony conviction; or
  • Information provided on the application or supporting materials for the application.

If we find you ineligible for direct payment resulting from a false or misleading statement, and you believe we have made an error, you can protest our action(s). If you do not protest, you will be permanently ineligible to receive direct fee payment beginning with the month after the month the protest period ends. If you protest and we confirm our earlier finding, you will be permanently ineligible to receive direct fee payment the month after the month we uphold our finding. You can find information about our ineligibility and protest procedures below.

If our background check concludes that you have misrepresented information about your education, background, continuing education courses, or liability insurance coverage, we may refer this information to our Office of the General Counsel for consideration of further sanctions.

Ineligibility for Direct Payment

If you do not meet the requirements above, you will become ineligible for direct payment.

For findings leading to temporary periods of ineligibility, after the 6-month period of ineligibility is over, you will again be eligible for direct fee payment in the first month after the month you meet the requirements for direct payment. You may submit required documentation at any time during, or at the end of the 6-month period of ineligibility.

If you do not pass our criminal background check or provide us with false or misleading information, you will be permanently ineligible for direct payment.

Protest Procedures

If you disagree with a finding of ineligibility, you may file a protest. To do so, you must provide all relevant supporting documentation to us within ten calendar days after the date we notify you of our finding of ineligibility. If our review confirms our original finding, you will be ineligible for direct payment as explained in Ineligibility for Direct Payment above.

You must send all protests to StratComm, Inc.