Business Guide

Lesson Six
Introduction to the
The Representative Fee Structure

This lesson describes the Social Security representative fee structure. We'll explain the procedures for charging and collecting fees when representing a disability case. Please also review the "Fee Data" segment in your online syllabus.

The Social Security Fee Structure:

The Social Security Administration has directed a unique fee structure for those who wish to act as claimant representatives and be paid for their services.  We strongly encourage you to follow these rules in order to avoid problems with Social Security over fees. Disability Associates has created a means of following the Social Security payment guidelines while simultaneously eliminating much of the frustration often experienced when dealing with government-based fee structures.

Social Security Fee Regulations:

Any individual, who has met the basic requirements of a representative and has performed as an authorized representative for a disability applicant, may charge a fee for his/her services upon the successful completion of the case.

The amount of the fee is subject to review by Social Security and can be altered up or down. This rarely happens if you stay within the guidelines.  A representative may not collect more than the amount authorized by Social Security or collect the fee in advance of that authorization, except under certain conditions.  In order for the representative to collect a fee, he/she must submit a written fee contract and/or fee petition to Social Security.

The Social Security Administration will review the fee contract or petition and attachment before giving you approval of the fee amount.  The representative will be notified of fee approval by mail. The above statements summarize the basic fee structure as outlined in the Code of Federal Regulations.  Now we’ll show you how to make the billing process easier while remaining inside Social Security regulations. 

Before discussing the actual fee process, let's discuss a few important factors that can affect the amount of a fee.

Competition and Your Fee:

As a disability representative you will discover that there is little or no real competition in this field as of yet. The attorney is the closest you'll come to competition and this is not true competition. Attorneys usually do not specialize in Social Security disability, although there are a few company’s that do.  The low number specializing in this field means less exposure of the service overall, reducing competitive pressure.   

Currently, there are more disability advocates representing disability cases than there are attorneys.  Despite this, the number of non-attorney representatives remains low when compared to the size of the market.  If you've read my Seven Pillars text, you know why these ex-employees and other non-attorney representatives are lagging behind in the market.  However, using my approach to this service gives you a competitive advantage over both ex Social Security employees and attorneys.  Your most powerful competitive advantage over them is the focused advice and expertise offered in this course.

Usually an attorney will take a disability case on a contingency basis and collect 25% of the claimant's back benefits upon the successful completion of the case.  Some attorneys also tack on additional fees related to case development.  Disability Associates has a different approach to case development costs. While advocates also charge the 25% fee, we use a set case development fee to cover case development this costs. 

If more is spent than is available in the development fee, this can be worked out at the end of the case.  The case development fee is best collected at the beginning of the case and placed into an escrow account.  Be sure to explain the reason for the development fee to the claimant and that any unspent funds will be returned after the case is completed.   

The Attorney Disadvantage:

Some attorneys recognize that if they are working for a percentage of back benefits, there is little or no incentive to get a case done in a timely manner.  The longer a case takes to reach a successful outcome, the larger the attorney's fee.  This greedy attitude has not gone unnoticed by students of our program or the disability market.  The key to the success in this service lies in your ability to move these cases quickly.  Your final fee for any given case may be a bit smaller, but your reputation for acquiring benefits in a timely fashion will actually attract more clients to your service.

With the growing availability of trained disability advocates, claimants have more options. The claimant can and should expect the same result from a disability advocate as he would receive from an attorney. The difference will be that the advocate processed the case in less time, saving the client money.  This difference if emphasized, can give the advocate a strong advantage over any competitor in this market.

Demographics:

Understanding certain key characteristics about your potential clients will help you build and expand your business faster. The average individual applying for disability benefits has a twelfth grade education.  He may be a white or blue collar worker performing a full range of skilled to unskilled work. Twenty to thirty percent of the claimants will be minorities depending on your area of the country. There are roughly equal numbers of male and female applicants. The average client is proud, hard working, anti-welfare and often concerned about his financial future.

Sixty-five percent of applicants have physical impairments. Thirty percent have purely mental impairments and up to seventy-five percent can have a mixture of both.  The average client family income is about thirty to sixty thousand dollars a year.  Claimants are found in all settings from large U.S. cities to small rural communities.

The ability to speak Spanish will also become an important asset due to a rapidly growing Hispanic population.  Future demographic changes can be a real plus for our business and should not be ignored.  For more information about using demographic information in niche marketing, view our online e-commerce marketing program.

The Advocate Fee Structure Overview:

There are three basic fee structures that can be utilized with a Social Security disability case.  These are:

A.  The Advance Fee.  Used in about 5-15% of cases.

B.  Times or Times Monthly Fee.  With this fee approach, the advocate charges the claimant an amount equal to his monthly benefit times one, two or three.  This fee structure is used primarily with SSI cases or SSDI cases with no back benefits.  Since SSI cases are not your primary customer base, you can expect to use this approach roughly 10-15% of the time.

C. Contingency Fee:  Used in 80-90% of SSDI cases.

Advance Fee:

With the exception of the contingency fee approach, all other fee approaches are non-policy.  A non-policy fee approach means that the approach is not known or sanctioned by Social Security.  The advance fee is a non-policy approach.  It is best used with cases that are easy allowances.  For example, if a claimant has suffered two heart attacks within a one year period, has continuing symptoms, is incapacitated and under intense treatment, this case will probably result in an allowance.  If the evidence is highly supportive of a disabling condition, this case falls within the category of an easy win.

These quick turn around cases usually require very little work on the part of the advocate, which is why you use the advance fee approach. Offering the advance fee approach is actually to the claimant's advantage because it provides a much cheaper fee alternative.  We usually charge less than $1500 for cases using the advance fee approach. Cases that are easy to win in a short period of time will become obvious to you as you grow in experience.

The second circumstance for using the Advance fee approach relates to speed of processing.  If a case is already fully documented, it will take much less time to reach a decision.  Therefore, use the Advance fee approach when a case appears to be both documented and an apparent easy win.  

Please recognize that using the Advance fee approach means making less money per case. You should not ask for more than $1500 for services under the advance fee approach.  This relatively low fee will keep the fee amount within a reasonable level for the client and also supply adequate compensation for your work.

The advance fee option is unique and will require a bit of preparation. You will find that approximately five to fifteen percent of your customers will be financially capable of using this fee option. However, even at five percent of your total customer base, this fee option can be a significant source of income.

The advance fee option is also best used with individuals with strong work histories who have suddenly become disabled and have only been disabled for a short period of time -- less than six months.  If the customer has worked and has only been disabled for a short period of time, that person probably still has the resources available to pay an up front fee.  Also remember that the Advance fee can only be kept if you win the case. Therefore, try to restrict this fee approach to cases that are apparently easy wins with rapid decision potential.

The Advance Fee and the Escrow Account:

An escrow account is a segregated or trust account that should be used if you wish to charge a fee in advance of your performing work as a disability advocate. You are required to deposit the advance fee into an escrow account until the case is completed. Utilizing this type of account will help save you collection headaches later. The escrow account is the only way SSA will allow you to be paid in advance.

Setting up an escrow account is easy.  Simply deposit a small sum of your own money into a new interest bearing bank account and use the account exclusively as a business escrow account.  If you open up a bank defined escrow account, the banks will charge you an arm and a leg.  When the claimant pays for your services in advance, deposit the entire amount of the fee into the escrow account. You may draw interest on the funds that also become part of your income if the case is won.  Otherwise, the entire amount must be returned to the claimant.

The escrow account moneys can be used to cover any on going expenses like case development cost, incurred as a result of representing a case. If this occurs, charge the claimant the difference after winning his benefits. You can charge a development fee up front, but this makes little sense in a case where the claimant is paying you in advance. After the fee has been authorized by Social Security upon the successful completion of the case, you may then remove the fee from the escrow account as your payment.

Times or Monthly Based Fee:

The Times or Times Monthly fee option is a little more versatile than the Advance fee approach.  For this reason it is used a great deal more in disability consulting. However, the designation times or monthly based fee can be misleading. Using this fee option, you are in fact working for a fee that will amount to two or three times a claimant's monthly cash benefits. This fee is usually paid as a single payment, but you may accept monthly payments if you like.

The Times Monthly benefit fee option can be used with any disability case. However, it is best used in cases with current onset dates such as that seen in SSI claims or SSDI cases with no back benefits.  Keep in mind that this fee approach is a non-policy approach.  If you send Social Security a fee contract stating the use of this fee, it will be rejected.  Social Security will not authorize any non-policy fee approach. 

To around this, the fee agreement is made between you and the claimant in cases where there are no back benefits.  Upon the successful completion of the case, you send SSA a fee petition with attachment indicating the amount and reasons for the fee.  The actual reason for the fee amount, which is not mentioned to SSA, is based upon one, two or three times the claimant’s monthly benefit.  Therefore, only you and the claimant really understand why you charged what you charged in this case. Make sure that the fee attachment shows enough work hours to justify the fee to Social Security.

In the Times Monthly approach, you should also charge a small upfront development fee ranging from $50-$150 dollars.  This fee is used for acquiring medical evidence, phone calls and other activities associated with the processing of the case.  All development costs are the claimant's responsibility.  It is a good idea to mention this fact in your fee agreement materials. Development fee funds not spent can be incorporated into your final fee or returned to the claimant. However, if the case is not won and all of the development funds were not used, you should refund the remaining difference to the claimant.

The development fee should also be placed in an escrow account and used to pay costs associated with the representation of the case.  The development fee is a useful business tool because it essentially locks the customer into your service.  It also demonstrates the customer's intent and commitment to your service.

The Contingency Fee

The contingency fee approach is the most common fee structure used in the disability consulting industry.  Keep in mind that all three fee approaches described in this lesson are in fact contingent upon the successful outcome of the case. Therefore, all three approaches can be incorporated into one fee contract.

The contingency fee approach requires that you accept a case with an agreement for payment if and only if the case is won. Using this common approach, you may charge up to twenty-five percent of the claimant's back benefits or a specified amount, whichever is less.  Please also note that Social Security will expect you to submit a fee petition attachment unless you’re using a fee agreement that specifies the 25% agreement.

Example:  You have agreed to represent a case under contract for twenty-five percent of the claimant's back benefits or $3500, whichever is less. The case is won, and twenty-five percent of the claimant's back benefits equal $2400. Your fee would be $2400.

What we like most about the contingency fee approach is that SSA likes it too!  Social Security considers this fee approach to be the ultimate in fairness for the claimant.  Social Security feels this way about the contingency fee approach because there is no way the claimant can lose. The contingency fee approach is Social Security's way of protecting the claimant from misrepresentation.  It is also the only policy fee approach available to representatives. 

The contingency fee approach can be a gold mine if you learn how to properly utilize it. The secret to using this fee approach successfully can be described in three words:  Win the case!

At this point, I’m sure you’re asking yourself:  How do I increase my chances of winning and getting paid?   Answer:  The case assessment process.  The assessment process allows us to screen out cases that do not have a fairly good chance of being won.  By screening out weak cases, you are in affect increasing your overall chances for success.

Another advantage of the contingency approach is that any claimant regardless of his or her financial circumstance can afford to use it.  This fact can significantly expand your market and is therefore worth keeping in mind when choosing a payment option.

Using the Contingency Fee Approach

Using the contingency fee approach is not difficult.  Simply get the claimant to sign the fee petition form 1560 and your fee contract specifying the use of this fee approach.  It’s also a good idea to have a responsible third party sign these form if the claimant has a mental disorder or is to sick to comprehend what he’s signing.  Since SSA will request a copy of the contract and/or fee petition with attachment at the end of the case, you are effectively entering into a three-way contract.  I will explain how this three-way relationship can protect you from nonpaying clients later in this lesson.

Be sure to ask the claimant for a small development fee when taking a case on contingency.  If the claimant refuses, then don't take the case.  Explain to the claimant both verbally and in your contract the reason for the development fee and under what circumstance you will provide a refund of the fee.  Most claimants will not resist paying the development fee if you explain why it is required.

The contingency fee approach can be used with any case. However, it is best to use it with clients who have remote onset dates.  That is, the claimant's onset date is one or more years in the past.  If a case with a remote onset date is won, the claimant will receive benefits going back at least one year, minus the waiting period. 

Social Security will no longer pay back benefits that exceed one full year, so make sure that the onset isn’t too remote.  Even with the full year limit, a claimant could receive a substantial cash settlement that would result in a substantial fee for your service.

Getting Paid:

Experience has shown that the overwhelming majority of claimants pay their representatives without issue.  However, there are always those individuals who feel they can take advantage of the system. To protect your fee from these dishonest types, here is some practical advice:

1.  Keep a signed, stamped and dated copy of the Authorization to Represent form 1696 in your records. This document proves that you did indeed act as the claimant's authorized representative and are entitled to a fee.

2.  Keep a signed and dated copy of the fee petition SSA Form 1560.  This document establishes the commercial relationship between you and the client and is documented proof of your agreement with the claimant.

Social Security is increasingly requiring the use of the fee petition with attachment because it is a great way of seeing exactly what the representative has done for the claimant during the case.  If you do not submit a contract to Social Security during the case, Social Security will require that you provide a signed copy of the fee petition with attachment upon the successful conclusion of the case. A fee petition attachment is a detailed list of all activities performed by the advocate during the representation period.

Providing a detailed fee petition attachment is a tedious and time-consuming job. To address this problem, we have created the Advocate Client Manager Pro software.  This software allows an advocate to track every single billable action, date and time spent while representing the case.  You simply enter your actions into the ACM software as they occur.  At the end of the case, you simply generate the fee petition attachment and send it to Social Security.  We use an open system approach for the fee petition which allows you to make any adjustments you like before printing.

3. When you sign up a claimant, explain to him that he has just signed a three-way contract that includes himself, you and Social Security. Tell the claimant that Social Security will require a copy of the contract in case there is a later disagreement between the client and the representative. Tell the claimant that this three-way relationship also gives you a legal right to challenge his benefits if the agreed payment is not made as agreed.  Most claimants will get the hint and give you no payment problems upon case completion.

4. Get the signature of a responsible third party on the fee contract and/or fee petition if the claimant has any hint of a mental disorder.  Do this even if the claimant sounds or appears perfectly normal. If the claimant's primary diagnosis is a mental disorder, either get a responsible third party signature or do not take the case! This simple action will give you a target if a fee dispute occurs later.  It is considered politically incorrect to go after a certified nut that has just placed on disability benefits.  An effective business owner thinks ahead in order to maintain a good public image even as he/she kicks butt in the background.

5.  If the claimant has received SSDI benefits, and refuses to pay you, here is what you should do.  Send a letter to the claimant politely requesting your fee.  One week later send a second stronger letter demanding your fee and indicating that failure to pay up will result in a legal challenge of his benefits that could result in a cut off of payments.  Do not use this approach in an SSI case.  These SSI clients are indigent and this approach may make you look bad.

If this does not work, send Social Security a letter complaining about the claimant's lack of response. Ask Social Security to assist you collecting your fee.  Send a copy of this same letter to the claimant.  This action usually results in payment despite the fact that Social Security will usually do nothing about you’re your request.

6.  If you believe that the claimant may have problems paying his fee, consider setting up a payment plan at the beginning of the case.  You also have the option of creating a payment at the end of the case if the claimant is willing.  Of course, the payment plan would not go into affect until the claimant is awarded benefits.  If you use the payment plan approach, ask for a substantial first payment.  Say thirty percent of the total amount of the award and the rest in 12 equal monthly payments.

In order to be successful, you must be willing to offer a service that can accommodate the majority of customer.  To attract a large number of potential customers, you must be willing to offer fee flexibility.  I’m not just referring to the price of your service, but more importantly the types of payment options you are willing to accept.  The more payment options you can offer, the more customers you'll attract.

7.  If nothing you do results in payment, you may be forced to write it off as a bad debt and take the tax deduction.  If this occurs, deduct the maximum fee possible to help your service to survive.  See your accountant for details and tax advice.  Our most powerful fee protection approach can be found in the Executive Support web site under “Protecting your Fee.” 

Determining Fee Amount:

It's your business, so you determine the fee within certain parameters. However, you will not need to determine a fee amount in most cases.  The actual fee paid is based on the client's pay history and several other factors determined by Social Security.  So, don't get hung up trying to set fee amounts.  The easiest way to set a fee is to simply indicate the fee structure you have agreed to use. 

Example:  You decide to use the contingency fee approach at twenty-five percent of the claimant’s back benefits paid upon the successful completion of the case with a current maximum of $5,300.

With the advance fee approach, the fee amount is usually $550 to $1500 for a win.  The percentage fee approach will usually be two or three times the claimant's monthly benefit in a standard SSI or SSDI case. 

The Fee Contract or Fee Agreement

A fee contract, also known as a fee agreement, is a contract between an advocate and a claimant for representational services.  A fee contract need not specify a specific fee amount.  However, a service contract should specify the fee structure being used to determine the fee amount.  There is nothing mysterious or threatening about a fee contract. You can certainly write your own service contract, but this might not be the best approach.

We suggest that you use a local attorney to make sure that your contract meets local legal standards.  To protect yourself and your service, write a list of those issues you feel should be included in your fee contract.  We provide a short list of contract issues below.  Take this list to your attorney.  This contract issues list will allow your attorney to create a custom contract that protects you and the interests of your service.  Make sure that your attorney is at least somewhat informed about Social Security policy.

Here are some examples of service contract items that should be included in your fee contract:

a. The claimant's name and SSN.

b. The date of the contract.

c. Names of the parties to the contract.  Include a responsible third party if needed.

d. The fee approach used and all details associated with due dates, time frames, collections, payments, penalties, percentage rates, late charges, etc.  Optionally, you can add all three fee approaches to one contract in the form of check boxes. This allows you to easily adapt the document to all three fee approaches.

Reminder:  The two non-policy fee approaches are used only as an alternative method of calculating a fee when there are no back benefits.  How you derive at a fee amount using these approaches is a matter between you and the claimant.  When using a non-policy fee approach, you would always submit a fee petition and attachment to Social Security upon the successful completion of the case.

e. Provide a description of the specific service you’re providing.  

f.  Indicate the adjudicative levels covered by the contract.

g. Use simple terms and plain English in your contract.

h.  Be sure to indicate “that no fee will be charged unless you win the case.” 

i.  Make sure to indicate the amount and reason for the development fee. 

j.  Address the issue of service cancellation and reimbursement.

k.  Address the issue of travel costs for adjudicative purposes.

l.  Use protective clauses that protect your interests while staying within the boundaries of State and Social Security regulations.  A protective clause usually addresses the issues of service termination or non payment.  For sample protective clauses, see Executive web, under "Protecting Your Fees".

m.  Copyright your contract.  This action will protect you from those who would simply copy your contract and use it without your permission.

Pending Death of a Client

If you're representing a person with a terminal disease, it may be a good idea to do one or more of the following to protect your fee:

a)  Have a responsible family member of the client sign your representational contract.  This action makes the family member responsible for your fee if the case is successful.  Get both the client and the family member's signature before you begin representation.

b)  Instruct the responsible family member who signed the contract in how to become the client's representative payee.  This usually occurs when the client is too ill to handle his/her own funds.  The Representative payee will then be responsible for paying your fee even if the client dies shortly after receiving benefits.

c)  If there is no responsible family member, you can become the client's representative payee.  This is an action of last resort because it requires that you handle the client's financial affairs.  Becoming a representative payee can be an awesome responsibility so only use this approach if there is absolutely no other person within the client's family that can handle this liability.  To learn more about becoming a representative payee, visit http://www.ssa.gov/payee/

The Fee Petition:

Even if you have an excellent fee contract, we recommend that you also use a fee petition in every case.  SSA has recently begun placing a greater value on the fee petition because it allows them to more easily determine if the fee requested is fair.  For this reason, SSA now requires that a fee petition form 1560 be accompanied by a detailed fee petition action report.  This summery action report is called a fee petition attachment.

After you have received notice of an allowance decision, you are ready to submit your fee petition with attachment to Social Security.  A fee petition is submitted to Social Security for payment after the case has been successfully adjudicated.  However, you can send Social Security a copy of the signed fee petition form prior to a decision if you wish. 

A fee petition is different from a fee contract, although they have the same purpose. A fee contract is your formal agreement with the client for representational services.  The contract does not indicate an exact fee amount because you will not know the exact amount until the case has been allowed. 

A fee petition with attachment contains information as to the actions taken in a case and the time spent executing these actions on behalf of the client.  This detailed information is usually provided with the fee petition form at the end of the case.  The details about actions taken in the case are presented in the petition attachment.  Social Security will review the fee petition attachment to determine if the amount of your fee is justified by the work you have performed.  See fee petition form in the Forms Buddy II.
 

Special Representative Qualifications

On occasion, Social Security may ask what your qualifications are to represent a case as part of your fee petition report.  Don’t be intimidated by this request. To our knowledge, there is no rule directing what background an advocate should have in order to represent a case.  Here is a generic statement that you can use if this circumstance arises:

On the fee petition form, there is an area that request information about your background.  In this instance, Social Security wants to know how your background or training helped you to help the claimant pursue his Social Security disability claim.  It’s your decision as to what information you wish to supply on this fee petition. 

Here are some examples of information you can provide that Social Security will respect:

1. Indicate your experience as an advocate if appropriate.
2. Indicate experience in other related fields if appropriate. 
3. Indicate your level of educational and/or professional background if appropriate.
4. Indicate your work history if it adds to your credibility in this field.
5. You may also indicate that you were trained by Disability Associates.

I have never seen an intense where Social Security challenged a person's background, education or experience in this field.  I think this is more of a survey question to determine what types of people are entering this field.


Completing a Fee Petition:

In our Forms Buddy II software, we provide a copy of a fee petition form.  This form also includes an instruction sheet for completing a fee petition.  The fee petition form is fairly simple.  However, the attachment is what is really important.  In completing a fee petition attachment, you must indicate what, when and how long you spent on a particular action within a given case.  Again, SSA will use this fee petition attachment to determine what actions you have performed on behalf of the claimant. 

Please note that in many cases, SSA will request a fee petition even if you have submitted a fee contract. This usually occurs with larger fees where SSA wants to review your actions in a case.  If this occurs, relax, complete a fee petition with attachment and send it in per Social Security's instructions.   

Social Security Challenges Fee:

In my many years of experience as a disability advocate and business owner, I have only had two instances where Social Security challenged the amount of my fee.  If this occurs in your service, don't panic and don't feel hostile toward Social Security.  These things happen when working with large government agencies.

In both of my fee challenges, the reason given by Social Security was an excessive fee.  However, the fee charged in both instances was well below the regulatory maximum, which was $4000 at the time.  I simply provided Social Security with a detailed fee petition attachment and allowed them to reconsider their challenge.   

If you present Social Security with one of the non-policy fee approaches offered in this program, Social Security will challenge your fee.  The trick is to keep any non-policy fee agreement between you and the claimant.  Remember, a non-policy fee approach is nothing more than a formula used to determine the amount of a fee if there are no back benefits.

Example:

The claimant has agree to be represented by me on a contingency basis (no fee unless we win). The claimant agrees to pay 25% of back benefits, not to exceed $5,300, upon the success completion of the case.  However, if there are no back benefits, both the claimant and I must agree upon some alternative level of payment that would not exceed Social Security’s maximum payment amount. 

Therefore, both the claimant and I agree that if there are no back benefits, the amount of my fee will be no more than (Two Times) the claimant’s monthly SSDI or SSI benefit amount, not to exceed say $1800.  With this incidental information, both the claimant and the representative are aware of what bases is being used to determine the amount of the fee requested.  Before you can collect this fee, you must win the case and submit a fee petition with attachment showing Social Security that your fee is reasonable given the amount of work performed.

Notice that I did not refer to this (Times Monthly) fee approach by name when communicating with Social Security. That's because Social Security would not know what I was referring to because the (Times Monthly) fee approach is non-policy.  Non-policy means that you will not find it in the Code of Federal regulations. 

But, what about the fee the customer owed me during the challenge?  During my fee challenge, I billed the client as usual and collected my fee.  The reason I felt comfortable doing this is because there was simply no way that the fee I charged was excessive.  Social Security did decide in my favor and life went on.

If you have taken a fee from a client in advance of Social Security's approval, you'll probably get away with it.  However, if for any reason, the fee is mixed with other obligations, delayed or challenged, place the funds into an Escrow savings account and wait for Social Security's final fee approval before actually collecting the fee.  If Social Security asks about the fee, indicate that it is in escrow awaiting their decision.  By placing the fee in escrow, you're taking an important step toward avoiding a serious fee conflict with Social Security.

Fee Amount Lowered by SSA

If the fee approved by Social Security is lower than your original requested fee, accept the lower fee and move on.  Don't waste valuable time trying to change Social Security's mind just to acquire an extra couple of hundred bucks.  Challenging a fee with SSA is a process that can take many months and a lot of your spare time.  It's not usually worth it.

Preview Lesson Seven:

In Lesson Seven we'll describe Social Security's confidentiality rules and other miscellaneous issues related to case processing.  You’ll learn how to practice safely within these important guidelines.

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Copyright © 2011.  Disability Associates, Inc.  All Rights Reserved.