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The Social Security Administration's (SSA) Claims Manual is not a regulation. It has no legal force, and it does not bind the SSA.
A woman met for about 15 minutes with a field representative of the Social Security Administration and inquired as to her eligibility for "mother's insurance benefits" under 202(g) of the Social Security Act. The representative erroneously told her that she was not eligible and did not recommend that she file a written application nor advise her of the advantages of doing so, even though the Administration's Claims Manual instructed field representatives to advise applicants of the advantages of filing written applications and to recommend to applicants who are uncertain about their eligibility that they file written applications. She later learned that in fact she was eligible, filed a written application, and began receiving benefits. Pursuant to 202(j)(1) of the Act, which entitles an eligible recipient to receive benefits for up to 12 months preceding an application, she also received retroactive benefits for the 12 months preceding her application. She contended that she should receive retroactive benefits for the 12 months preceding her interview with the field representative, but an administrative law judge rejected this claim, concluding that the representative's erroneous statement and neglect of the manual did not estop the Secretary of Health and Human Services from determining the woman's eligibility for benefits only as of the date of her written application. The Social Security Appeals Counsel affirmed. The woman then filed an action for judicial review in the United States District Court for the District of Vermont, and the District Court held that the written-application requirement was unreasonably restrictive as applied to facts of her case. On appeal, the United States Court of Appeals for the Second Circuit affirmed, finding that the written-application requirement was a mere procedural requirement of lesser importance than the fact that the woman had been substantively eligible for the benefits when she met with the representative and that, in such circumstances, misinformation provided by a government official combined with a showing of misconduct should be sufficient to require estoppel.
Did the Social Security Administration employee's erroneous statement that the woman was ineligible for benefits and failure to advise her to apply for them, estop the Administration from denying her retroactive benefits?
The Court held that the representative's erroneous statement to the woman that she was ineligible for "mother's insurance benefits" and his failure to recommend that she file a written application or advise her of the advantages of doing so did not estop the Secretary of Health and Human Services from denying retroactive benefits to the woman under 202(j)(1) for the period in which she was eligible for the benefits but had not filed a written application, even though the Social Security Administration's internal handbook instructed field representatives to advise applicants of the advantages of filing written applications and to recommend to applicants who are uncertain about their eligibility that they file written applications. The Court held that it did not amount to affirmative misconduct so as to permit the Court to abnegate its duty to observe the conditions defined by Congress for charging the public treasury. Further, the Court rejected the lower court's reasoning that estoppel was warranted because the woman’s substantive eligibility for the benefits, as they existed when she first met with the field representative, outweighed the mere procedural written-application requirement. The Court ruled that it was without authority to bypass the valid regulation that required the filing of a written application prior to disbursement of the benefits at issue.