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@itonewbie wrote:

But it wouldn't make sense because the Code is written by Congress.  As usual, it grants authority to the Secretary to prescribe regulations.  If that is just an option, they could have easily left out the statutory language and left it to the IRS for how they want to implement it.

That's why I am still of the opinion that this should be implemented.  As you said, time will tell.

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I agree.  I just didn't pay attention to the word "may" the first dozen or so times I read it.  I dismissed the IRS FAQ saying that SSA recipients should file a "simple" return in order to get paid, thinking that's not what Congress said.  But now I'm more open to the possibility that it's correct if we allow the possibility that the IRS has a choice.

Another possibility I considered is that the whole 2018 / SSA-1099 use might just refer to the method of disbursement.  After rereading that section another half-dozen times though, I concluded that it should apply to both the timing and manner of payment.  While SSA has bank info, the SSA-1099 itself provides no bank info.  It's only purpose in implementing this law would be to provide information regarding qualifying income (and possibly a current mailing address for the required notice in 6428(f)(6)).