Jennifer Cronenberg, NOSSCR Senior Counsel and Director of Legal Information

In April 2025, SSA sought and OMB approved an Emergency Request to increase the “level of identity proofing needed for respondents to make payment method changes during phone interactions for direct deposit changes.” This Emergency Request created a process where individuals who phoned SSA for “new initial claims taken over the phone or filed online and flagged as anomalous, as well as for post-entitlement/post-eligibility actions, or for direct deposit enrollments, updates or cancellations” would be required to login to their mySocialSecurity account, access a link within their mySocialSecurity account generated by SSA’s phone technician, and reveal a PIN that they would then relay to the technician before the call could continue. If the individual did not have a mySocialSecurity account set up, the technician would instruct the caller to set one up and call back (waiting on hold again), or to visit a local Social Security office in-person (after waiting on hold to schedule an appointment) if the caller was unable or unwilling to set up a mySocialSecurity account.

Almost immediately Social Security walked this Emergency Request back slightly, indicating that they only intended to apply the new Security Authentication PIN (SAP) policy to calls where individuals were seeking to change their direct deposit information. NOSSCR signed-on to the Consortium for Constituents with Disabilities’ Social Security Task Force’s Comments expressing concerns and asking additional questions about these changes.

Thereafter, on July 21, 2025, the Social Security Administration issued a “Proposed Request and Comment Request” in the Federal Register seeking to “initiate the full information collection request renewal for the SAP process.” In an accompanying document to this Proposed Request, the agency indicated that “the agency has determined further need to expand the use of the SAP process for other telephone transactions. Specifically, SSA will use the SAP process for the following additional telephone services: 1) Generating a Benefit Verification Letter; 2) Obtaining a Tax Statement or replacement Form 1099; 3) Change of Address; 4) Request for Claims Status.” There was much public outcry to this proposed expansion, led most poignantly by our friends over at the Center on Budget and Policy Priorities.

Likely because of this public response, the agency again walked back these proposed changes, withdrawing the original accompanying document and replacing it, on August 1, 2025, with a supplemental document clarifying that they intended “the overall use of the SAP to include only direct deposit changes.”

NOSSCR, along with many of our allies, submitted comments highlighting the problems with the original proposal and encouraging the agency to consider liberal exceptions to the SAP policy for those who lack digital literacy, and those comments can be read below.

There are a few key takeaways from this Federal Register saga:

1. NOSSCR is constantly working to serve our members and your clients through zealous advocacy—which sometimes takes the form of digging through multiple dense documents submitted, without announcement, to OMB.
2. NOSSCR’s relationships, both within the agency and with other advocacy organizations, are crucial to our success.
3. When the agency issues problematic proposed changes, they are open to feedback and willing to walk things back if there is enough of a public outcry.
4. The agency is clearly moving in the direction of placing more and more services behind the mySocialSecurity login, so it remains imperative that you, your staff, and your clients establish these accounts whenever possible.