About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline
LOG IN
LOG IN

B-202655 1 (1981-11-03)

handle is hein.gao/gaobacsrh0001 and id is 1 raw text is: UNITED STATES GENERAL ACCOUNTING OFFICE WASHINGTON, D.C. 20548 OFFICE OF GENERAL COUNSEL B-202655 November 3, 1981 Mr. Larry Carton 3004 Old Court Foad Baltimore, Maryland 21208 not make a to pibli.c reading Dear Mr. Carton: We are in receipt of your letter asking the General Accounting Office to investigate whether legal requirements were met by the Social Security Administration in implementing section 209(o) of the Social Security Act (codified at I.R.C. § 3121(a)). Your specific concern is that in response to an I.R.S. Ruling concerning interpretation of this section, the Administration chose to revise its claims manual to reflect the new interpretation of the section rather than first amend its regulations on the subject. You had offered the latter alternative as an employee suggestion. Based on your description of the situation, we have no cause to investigate further the proposed amendments. The manner in which this new policy is being pursued is neither prima facie illegal nor outside the realm of reasonable administrative practice. The Adminis- tration has indicated its intention to amend its regulations to eliminate any discrepancies between its internal instructions and its regulations. Insofar as your suggestion was not adopted and/or that you were not rewarded for it through the employee suggestion program, we note that your agency has determined that.you raise questions out- side the normal suggestion system and that they relate more to your normal job responsibilities. On the facts you have given us, this determination appears reasonable. However, even if we were to dis- agree, we have no authority to compel the adoption of your suggestion and we would not involve this Office in what is strictly and internal judgment as to the merits and value of a suggestion. We regret that we are unable to assist you in this matter, Sincerely yours, Fobert H. Hunter, Assistant General Counsel

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Contact us for annual subscription options:

Contact Us

Already a HeinOnline Subscriber?

Log In

profiles profiles most