EDPNA Dual-Version Certification Exam
VERSION A: SSA Eligible for Direct
Payment Non-Attorney Program
150 Questions & Answers | Aligned with 2026–2027 SSA Regulations & Policies
Section 206(e) of the Social Security Act | 20 CFR 404.1717 & 416.1517 | A+ Graded Verified
Version A Examination Instructions: This 150-question multiple-choice exam covers the SSA EDPNA
program, covering: (1) EDPNA Program Fundamentals and Eligibility; (2) Social Security Act Title II (SSDI)
and Title XVI (SSI); (3) Sequential Evaluation Process (Steps 1-5); (4) Evidence Evaluation and
Medical/Vocational Considerations; (5) Appeals Process, HALLEX, and ALJ Procedures; (6) Ethics,
Professional Conduct, and Fee Agreements. Cognitive level: ~30% recall, ~50% application, ~20% analysis.
Question style: ~70% recall/application, ~20% scenario, ~10% case analysis. Open-book format (POMS,
HALLEX, 20 CFR, SSRs); 70% passing score; 3-hour time limit. Each question includes a comprehensive
rationale explaining why the correct answer is right and why distractors are wrong, with SSA regulatory
references.
Section 1: EDPNA Program Fundamentals and Eligibility (Q1–Q28)
Q1: Under what statutory authority was the Eligible for Direct Payment Non-Attorney (EDPNA) program
established by the Social Security Administration?
A. Section 206(a) of the Social Security Act
B. Section 206(e) of the Social Security Act [CORRECT]
C. Section 1631(d) of the Social Security Act
D. Section 221 of the Social Security Act
Correct Answer: B
Rationale: The EDPNA program was established under Section 206(e) of the Social Security Act, which authorizes the
Commissioner to prescribe regulations allowing qualified non-attorney representatives who meet specific eligibility criteria to
receive direct payment of fees for services rendered in proceedings before the SSA. Section 206(a) governs general
representative fee payments but does not specifically authorize direct payment to non-attorneys. Section 1631(d) relates to
general administrative provisions for SSI. Section 221 defines disability but does not address representative payments.
Q2: Which of the following regulatory citations correctly authorizes the EDPNA program under Title II of the
Social Security Act?
A. 20 CFR 404.1717
B. 20 CFR 404.1725
C. 20 CFR 416.1517
D. Both 20 CFR 404.1717 (Title II) and 416.1517 (Title XVI) [CORRECT]
Correct Answer: D
Rationale: The EDPNA program is implemented under two parallel regulations: 20 CFR 404.1717 (governing Title II SSDI
claims) and 20 CFR 416.1517 (governing Title XVI SSI claims). Both regulations establish identical eligibility criteria and
procedural requirements for non-attorney direct payment. 20 CFR 404.1725 separately governs fee agreements and is not the
EDPNA Dual-Version Certification Exam | Version A: SSA Legal (150 Q) + Version B: Nephrology Nursing (150 Q) | Page 1
, authorizing regulation for the EDPNA program itself. A representative must meet the criteria under the appropriate title
depending on the type of claim being represented.
Q3: An applicant seeking EDPNA status must submit several forms as part of the application process. Which
combination of forms is correctly required for EDPNA application?
A. Form SSA-1695 and Form SSA-1694
B. Form SSA-1691 (EDPNA Application) and Form SSA-1699 (Representative Registration)
[CORRECT]
C. Form SSA-3288 and Form SSA-827
D. Form SSA-1696 and Form SSA-561
Correct Answer: B
Rationale: The EDPNA application requires submission of Form SSA-1691 (the EDPNA Application form) and Form
SSA-1699 (Representative Registration form, which registers the representative for direct fee payment and assigns a
representative ID). In addition, applicants must undergo a criminal background check. Form SSA-1695 is used for tax-related
identification of non-attorney representatives, SSA-1694 is for appointed representative services, SSA-3288 is for consent to
release information, SSA-827 is medical authorization, SSA-1696 is appointment of representative, and SSA-561 is a
reconsideration request — none of these constitute the EDPNA application itself.
Q4: What is the minimum amount of professional liability insurance an EDPNA must maintain to remain
eligible for direct payment?
A. $50,000 per incident
B. $100,000 per incident [CORRECT]
C. $250,000 per incident
D. $500,000 per incident
Correct Answer: B
Rationale: EDPNA regulations require the non-attorney representative to maintain professional liability insurance of at least
$100,000 per incident. This insurance protects claimants in the event of negligence or professional misconduct by the
representative. Failure to maintain this coverage at any time during enrollment results in loss of EDPNA status. Lower
amounts ($50,000) are insufficient, and higher amounts ($250,000 or $500,000), while permissible, exceed the regulatory
minimum.
Q5: Which of the following correctly describes the educational or experience prerequisite for EDPNA
eligibility?
A. A juris doctor (JD) degree from an accredited law school
B. A bachelor's degree OR four years of relevant experience in Social Security disability representation
[CORRECT]
C. A high school diploma plus completion of a vocational rehabilitation program
D. A master's degree in social work
Correct Answer: B
Rationale: EDPNA eligibility requires either a bachelor's degree (in any field) OR at least four years of relevant experience
representing claimants in Social Security disability proceedings. A law degree (JD) is not required — that is the path for
attorneys, who are separately eligible for direct payment under Section 206(a). Relevant experience can substitute for the
formal educational requirement, providing a pathway for experienced non-degreed representatives. A high school diploma
alone is insufficient, and a master's degree in social work, while helpful, is not specifically required.
Q6: A non-attorney representative wishes to apply for EDPNA status. When during the year can the
representative submit the application, and how long is the application period?
A. Applications are accepted year-round with no deadline
B. During an annual application period of approximately four weeks each year [CORRECT]
C. Only during the month of January each year
D. Applications are accepted every other year
EDPNA Dual-Version Certification Exam | Version A: SSA Legal (150 Q) + Version B: Nephrology Nursing (150 Q) | Page 2
,Correct Answer: B
Rationale: The SSA opens an annual application period for EDPNA status lasting approximately four weeks each year,
typically in the summer. Applications are only accepted during this window, and applicants must pass a written examination
after their application is accepted. There is no year-round application process, and missing the annual window requires waiting
until the following year. This structured cycle allows the SSA to administer and process all applications efficiently and to
schedule the annual examination.
Q7: After passing the EDPNA examination, when must a representative complete continuing education, and
how often?
A. Once every 5 years, by December 31
B. Annually, with the reporting period ending September 30 [CORRECT]
C. Only upon initial application, no ongoing requirement
D. Every 2 years, with no specific deadline
Correct Answer: B
Rationale: EDPNA representatives must complete continuing education annually, with the reporting period ending
September 30. Representatives must timely complete and report the required hours to maintain EDPNA status. Failure to
meet the continuing education requirement by the September 30 deadline results in termination of EDPNA status. The annual
cycle aligns with the federal fiscal year. Unlike some professional licenses that have multi-year cycles or no ongoing education
requirement, EDPNA status requires yearly recertification of professional development.
Q8: Which of the following actions would result in the immediate loss of EDPNA eligibility?
A. Representing a claimant in an SSI matter while EDPNA-eligible under Title II only
B. Failing to maintain the required $100,000 professional liability insurance coverage [CORRECT]
C. Charging a claimant a fee below the maximum allowable amount
D. Filing a fee petition rather than using a fee agreement
Correct Answer: B
Rationale: Failing to maintain the required $100,000 professional liability insurance coverage at all times during EDPNA
enrollment results in immediate loss of eligibility. The insurance requirement is continuous and must be reported to SSA if
lapsed or cancelled. EDPNA status applies to both Title II and Title XVI representations once granted, so representing an SSI
claimant is permissible. Charging a lower fee is permissible (only the maximum is capped). Filing a fee petition is an
authorized alternative to fee agreements and does not affect eligibility.
Q9: An EDPNA represents a claimant in a Title II disability claim and the claim is allowed with past-due
benefits. Under what conditions will SSA pay the representative's fee directly from the claimant's past-due
benefits?
A. Only if the claimant signs Form SSA-1696
B. If the representative is EDPNA-eligible at the time of the favorable decision, has a qualifying fee
agreement or approved fee petition, and the claimant has not revoked the fee authorization [CORRECT]
C. Only if the fee is less than $3,000
D. Direct payment is automatic upon a favorable decision regardless of fee agreement
Correct Answer: B
Rationale: SSA will directly pay an EDPNA's fee from past-due benefits only when ALL of the following are met: (1) the
representative is EDPNA-eligible at the time of the favorable determination or decision, (2) there is a qualifying fee
agreement approved by SSA or an approved fee petition, and (3) the claimant has not revoked the fee authorization. Form
SSA-1696 is the appointment of representative form, not the fee authorization itself. There is no $3,000 threshold for direct
payment eligibility (the fee agreement cap is $7,200). Direct payment is not automatic — it requires the qualifying fee
instrument.
Q10: A non-attorney representative fails the EDPNA examination. What is the consequence and the pathway
to future eligibility?
A. Permanent bar from reapplying
EDPNA Dual-Version Certification Exam | Version A: SSA Legal (150 Q) + Version B: Nephrology Nursing (150 Q) | Page 3
, B. May reapply during a future annual application period and must retake and pass the examination
[CORRECT]
C. Automatic re-test within 30 days
D. Appeal to the Appeals Council within 60 days
Correct Answer: B
Rationale: A non-attorney representative who fails the EDPNA examination is not permanently barred — the representative
may reapply during a future annual application period and must retake and pass the examination to obtain EDPNA status.
There is no automatic 30-day re-test provision; the representative must wait for the next annual cycle. Failure on the
examination is not an adverse determination subject to Appeals Council review — it is an eligibility requirement that must be
satisfied through reapplication and successful retesting.
Q11: Which of the following individuals would NOT be eligible to apply for EDPNA status?
A. A non-attorney with a bachelor's degree and 3 years of disability representation experience
B. A non-attorney with no college degree but 5 years of full-time disability representation experience
C. An attorney in good standing with a state bar association [CORRECT]
D. A non-attorney with a bachelor's degree who has never represented a Social Security claimant
Correct Answer: C
Rationale: Attorneys in good standing with a state bar are already eligible for direct payment of fees under Section 206(a) of
the Social Security Act and do not need EDPNA status — the EDPNA program is exclusively for non-attorney
representatives. The other options describe non-attorneys who would be eligible to apply: a bachelor's degree alone qualifies
(regardless of representation experience); four or more years of relevant experience substitutes for the degree; and a
bachelor's degree holder with no prior representation experience can still apply because the educational requirement alone is
sufficient.
Q12: The EDPNA examination is administered annually. What is the minimum passing score required to
achieve EDPNA status?
A. 60%
B. 70% [CORRECT]
C. 80%
D. 90%
Correct Answer: B
Rationale: The EDPNA examination requires a minimum passing score of 70%. This threshold ensures that EDPNA
representatives demonstrate a level of competence in Social Security disability law, regulations, and procedure comparable to
that expected of attorneys representing claimants. A score below 70% results in failure and the representative must reapply in
a future annual cycle. Higher thresholds (80%, 90%) are not required. The 60% threshold is below the regulatory minimum.
Q13: Which of the following best describes the EDPNA examination format and time limit?
A. Closed-book, 50 questions, 1 hour
B. Open-book, multiple-choice questions, approximately 3 hours [CORRECT]
C. Oral examination before an ALJ panel, 2 hours
D. Take-home written essay, no time limit
Correct Answer: B
Rationale: The EDPNA examination is an open-book, multiple-choice examination with an approximately 3-hour time limit.
The open-book format reflects the practical reality that representatives routinely consult references (POMS, HALLEX, 20
CFR, SSRs) in practice, and the exam emphasizes the ability to navigate and apply these references rather than memorize
section numbers. The exam is not closed-book, oral, or an essay format. The multiple-choice structure allows objective
scoring and consistent application of the 70% passing threshold.
Q14: A claimant wishes to revoke a fee agreement with an EDPNA after a favorable decision but before SSA
has paid the fee. What is the effect on the EDPNA's eligibility for direct payment?
A. SSA will still pay the fee directly to the EDPNA
EDPNA Dual-Version Certification Exam | Version A: SSA Legal (150 Q) + Version B: Nephrology Nursing (150 Q) | Page 4
VERSION A: SSA Eligible for Direct
Payment Non-Attorney Program
150 Questions & Answers | Aligned with 2026–2027 SSA Regulations & Policies
Section 206(e) of the Social Security Act | 20 CFR 404.1717 & 416.1517 | A+ Graded Verified
Version A Examination Instructions: This 150-question multiple-choice exam covers the SSA EDPNA
program, covering: (1) EDPNA Program Fundamentals and Eligibility; (2) Social Security Act Title II (SSDI)
and Title XVI (SSI); (3) Sequential Evaluation Process (Steps 1-5); (4) Evidence Evaluation and
Medical/Vocational Considerations; (5) Appeals Process, HALLEX, and ALJ Procedures; (6) Ethics,
Professional Conduct, and Fee Agreements. Cognitive level: ~30% recall, ~50% application, ~20% analysis.
Question style: ~70% recall/application, ~20% scenario, ~10% case analysis. Open-book format (POMS,
HALLEX, 20 CFR, SSRs); 70% passing score; 3-hour time limit. Each question includes a comprehensive
rationale explaining why the correct answer is right and why distractors are wrong, with SSA regulatory
references.
Section 1: EDPNA Program Fundamentals and Eligibility (Q1–Q28)
Q1: Under what statutory authority was the Eligible for Direct Payment Non-Attorney (EDPNA) program
established by the Social Security Administration?
A. Section 206(a) of the Social Security Act
B. Section 206(e) of the Social Security Act [CORRECT]
C. Section 1631(d) of the Social Security Act
D. Section 221 of the Social Security Act
Correct Answer: B
Rationale: The EDPNA program was established under Section 206(e) of the Social Security Act, which authorizes the
Commissioner to prescribe regulations allowing qualified non-attorney representatives who meet specific eligibility criteria to
receive direct payment of fees for services rendered in proceedings before the SSA. Section 206(a) governs general
representative fee payments but does not specifically authorize direct payment to non-attorneys. Section 1631(d) relates to
general administrative provisions for SSI. Section 221 defines disability but does not address representative payments.
Q2: Which of the following regulatory citations correctly authorizes the EDPNA program under Title II of the
Social Security Act?
A. 20 CFR 404.1717
B. 20 CFR 404.1725
C. 20 CFR 416.1517
D. Both 20 CFR 404.1717 (Title II) and 416.1517 (Title XVI) [CORRECT]
Correct Answer: D
Rationale: The EDPNA program is implemented under two parallel regulations: 20 CFR 404.1717 (governing Title II SSDI
claims) and 20 CFR 416.1517 (governing Title XVI SSI claims). Both regulations establish identical eligibility criteria and
procedural requirements for non-attorney direct payment. 20 CFR 404.1725 separately governs fee agreements and is not the
EDPNA Dual-Version Certification Exam | Version A: SSA Legal (150 Q) + Version B: Nephrology Nursing (150 Q) | Page 1
, authorizing regulation for the EDPNA program itself. A representative must meet the criteria under the appropriate title
depending on the type of claim being represented.
Q3: An applicant seeking EDPNA status must submit several forms as part of the application process. Which
combination of forms is correctly required for EDPNA application?
A. Form SSA-1695 and Form SSA-1694
B. Form SSA-1691 (EDPNA Application) and Form SSA-1699 (Representative Registration)
[CORRECT]
C. Form SSA-3288 and Form SSA-827
D. Form SSA-1696 and Form SSA-561
Correct Answer: B
Rationale: The EDPNA application requires submission of Form SSA-1691 (the EDPNA Application form) and Form
SSA-1699 (Representative Registration form, which registers the representative for direct fee payment and assigns a
representative ID). In addition, applicants must undergo a criminal background check. Form SSA-1695 is used for tax-related
identification of non-attorney representatives, SSA-1694 is for appointed representative services, SSA-3288 is for consent to
release information, SSA-827 is medical authorization, SSA-1696 is appointment of representative, and SSA-561 is a
reconsideration request — none of these constitute the EDPNA application itself.
Q4: What is the minimum amount of professional liability insurance an EDPNA must maintain to remain
eligible for direct payment?
A. $50,000 per incident
B. $100,000 per incident [CORRECT]
C. $250,000 per incident
D. $500,000 per incident
Correct Answer: B
Rationale: EDPNA regulations require the non-attorney representative to maintain professional liability insurance of at least
$100,000 per incident. This insurance protects claimants in the event of negligence or professional misconduct by the
representative. Failure to maintain this coverage at any time during enrollment results in loss of EDPNA status. Lower
amounts ($50,000) are insufficient, and higher amounts ($250,000 or $500,000), while permissible, exceed the regulatory
minimum.
Q5: Which of the following correctly describes the educational or experience prerequisite for EDPNA
eligibility?
A. A juris doctor (JD) degree from an accredited law school
B. A bachelor's degree OR four years of relevant experience in Social Security disability representation
[CORRECT]
C. A high school diploma plus completion of a vocational rehabilitation program
D. A master's degree in social work
Correct Answer: B
Rationale: EDPNA eligibility requires either a bachelor's degree (in any field) OR at least four years of relevant experience
representing claimants in Social Security disability proceedings. A law degree (JD) is not required — that is the path for
attorneys, who are separately eligible for direct payment under Section 206(a). Relevant experience can substitute for the
formal educational requirement, providing a pathway for experienced non-degreed representatives. A high school diploma
alone is insufficient, and a master's degree in social work, while helpful, is not specifically required.
Q6: A non-attorney representative wishes to apply for EDPNA status. When during the year can the
representative submit the application, and how long is the application period?
A. Applications are accepted year-round with no deadline
B. During an annual application period of approximately four weeks each year [CORRECT]
C. Only during the month of January each year
D. Applications are accepted every other year
EDPNA Dual-Version Certification Exam | Version A: SSA Legal (150 Q) + Version B: Nephrology Nursing (150 Q) | Page 2
,Correct Answer: B
Rationale: The SSA opens an annual application period for EDPNA status lasting approximately four weeks each year,
typically in the summer. Applications are only accepted during this window, and applicants must pass a written examination
after their application is accepted. There is no year-round application process, and missing the annual window requires waiting
until the following year. This structured cycle allows the SSA to administer and process all applications efficiently and to
schedule the annual examination.
Q7: After passing the EDPNA examination, when must a representative complete continuing education, and
how often?
A. Once every 5 years, by December 31
B. Annually, with the reporting period ending September 30 [CORRECT]
C. Only upon initial application, no ongoing requirement
D. Every 2 years, with no specific deadline
Correct Answer: B
Rationale: EDPNA representatives must complete continuing education annually, with the reporting period ending
September 30. Representatives must timely complete and report the required hours to maintain EDPNA status. Failure to
meet the continuing education requirement by the September 30 deadline results in termination of EDPNA status. The annual
cycle aligns with the federal fiscal year. Unlike some professional licenses that have multi-year cycles or no ongoing education
requirement, EDPNA status requires yearly recertification of professional development.
Q8: Which of the following actions would result in the immediate loss of EDPNA eligibility?
A. Representing a claimant in an SSI matter while EDPNA-eligible under Title II only
B. Failing to maintain the required $100,000 professional liability insurance coverage [CORRECT]
C. Charging a claimant a fee below the maximum allowable amount
D. Filing a fee petition rather than using a fee agreement
Correct Answer: B
Rationale: Failing to maintain the required $100,000 professional liability insurance coverage at all times during EDPNA
enrollment results in immediate loss of eligibility. The insurance requirement is continuous and must be reported to SSA if
lapsed or cancelled. EDPNA status applies to both Title II and Title XVI representations once granted, so representing an SSI
claimant is permissible. Charging a lower fee is permissible (only the maximum is capped). Filing a fee petition is an
authorized alternative to fee agreements and does not affect eligibility.
Q9: An EDPNA represents a claimant in a Title II disability claim and the claim is allowed with past-due
benefits. Under what conditions will SSA pay the representative's fee directly from the claimant's past-due
benefits?
A. Only if the claimant signs Form SSA-1696
B. If the representative is EDPNA-eligible at the time of the favorable decision, has a qualifying fee
agreement or approved fee petition, and the claimant has not revoked the fee authorization [CORRECT]
C. Only if the fee is less than $3,000
D. Direct payment is automatic upon a favorable decision regardless of fee agreement
Correct Answer: B
Rationale: SSA will directly pay an EDPNA's fee from past-due benefits only when ALL of the following are met: (1) the
representative is EDPNA-eligible at the time of the favorable determination or decision, (2) there is a qualifying fee
agreement approved by SSA or an approved fee petition, and (3) the claimant has not revoked the fee authorization. Form
SSA-1696 is the appointment of representative form, not the fee authorization itself. There is no $3,000 threshold for direct
payment eligibility (the fee agreement cap is $7,200). Direct payment is not automatic — it requires the qualifying fee
instrument.
Q10: A non-attorney representative fails the EDPNA examination. What is the consequence and the pathway
to future eligibility?
A. Permanent bar from reapplying
EDPNA Dual-Version Certification Exam | Version A: SSA Legal (150 Q) + Version B: Nephrology Nursing (150 Q) | Page 3
, B. May reapply during a future annual application period and must retake and pass the examination
[CORRECT]
C. Automatic re-test within 30 days
D. Appeal to the Appeals Council within 60 days
Correct Answer: B
Rationale: A non-attorney representative who fails the EDPNA examination is not permanently barred — the representative
may reapply during a future annual application period and must retake and pass the examination to obtain EDPNA status.
There is no automatic 30-day re-test provision; the representative must wait for the next annual cycle. Failure on the
examination is not an adverse determination subject to Appeals Council review — it is an eligibility requirement that must be
satisfied through reapplication and successful retesting.
Q11: Which of the following individuals would NOT be eligible to apply for EDPNA status?
A. A non-attorney with a bachelor's degree and 3 years of disability representation experience
B. A non-attorney with no college degree but 5 years of full-time disability representation experience
C. An attorney in good standing with a state bar association [CORRECT]
D. A non-attorney with a bachelor's degree who has never represented a Social Security claimant
Correct Answer: C
Rationale: Attorneys in good standing with a state bar are already eligible for direct payment of fees under Section 206(a) of
the Social Security Act and do not need EDPNA status — the EDPNA program is exclusively for non-attorney
representatives. The other options describe non-attorneys who would be eligible to apply: a bachelor's degree alone qualifies
(regardless of representation experience); four or more years of relevant experience substitutes for the degree; and a
bachelor's degree holder with no prior representation experience can still apply because the educational requirement alone is
sufficient.
Q12: The EDPNA examination is administered annually. What is the minimum passing score required to
achieve EDPNA status?
A. 60%
B. 70% [CORRECT]
C. 80%
D. 90%
Correct Answer: B
Rationale: The EDPNA examination requires a minimum passing score of 70%. This threshold ensures that EDPNA
representatives demonstrate a level of competence in Social Security disability law, regulations, and procedure comparable to
that expected of attorneys representing claimants. A score below 70% results in failure and the representative must reapply in
a future annual cycle. Higher thresholds (80%, 90%) are not required. The 60% threshold is below the regulatory minimum.
Q13: Which of the following best describes the EDPNA examination format and time limit?
A. Closed-book, 50 questions, 1 hour
B. Open-book, multiple-choice questions, approximately 3 hours [CORRECT]
C. Oral examination before an ALJ panel, 2 hours
D. Take-home written essay, no time limit
Correct Answer: B
Rationale: The EDPNA examination is an open-book, multiple-choice examination with an approximately 3-hour time limit.
The open-book format reflects the practical reality that representatives routinely consult references (POMS, HALLEX, 20
CFR, SSRs) in practice, and the exam emphasizes the ability to navigate and apply these references rather than memorize
section numbers. The exam is not closed-book, oral, or an essay format. The multiple-choice structure allows objective
scoring and consistent application of the 70% passing threshold.
Q14: A claimant wishes to revoke a fee agreement with an EDPNA after a favorable decision but before SSA
has paid the fee. What is the effect on the EDPNA's eligibility for direct payment?
A. SSA will still pay the fee directly to the EDPNA
EDPNA Dual-Version Certification Exam | Version A: SSA Legal (150 Q) + Version B: Nephrology Nursing (150 Q) | Page 4
