SSA-OHO.
SSA Office of Hearings Operations (SSA). Internal-only AI guidance; no published rule for representatives as of May 2026.
SSA-OHO AI policy status. #
The Social Security Administration's Office of Hearings Operations (SSA-OHO) — the disability-appeals adjudicative body, with administrative law judges hearing initial-denial appeals and the Appeals Council reviewing ALJ decisions — has issued internal AI guidance via memoranda to ALJs and staff. As of May 2026, no published rule addresses representative AI use. The SSA representative regime (attorneys + non-attorney representatives) is governed by 20 CFR Part 404 / 416, which has not been updated to address AI specifically.
Authoritative source: https://www.ssa.gov/appeals/
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Why SSA-OHO matters. #
SSA-OHO is the largest US adjudicative body by case volume. ALJs decide approximately 600,000 disability appeals per year (down from over 1 million pre-pandemic). Representative practice is heavy and increasingly AI-assisted, particularly in case theory, medical-evidence summary, and drafting. The absence of a published policy on representative AI use is a significant gap given volume and given that disability claimants depend heavily on representative work product.
Practice implications. #
In the absence of published guidance, representatives should default to the principles in ABA Formal Opinion 512 (July 2024), apply the verification duty per Rule 3.3 / Rule 11 equivalents under their state bar rules, and treat AI-generated content as drafted by a non-lawyer assistant subject to the representative's supervision. Watch for the Chief ALJ's office to publish formal guidance, expected 2026-2027.