ART Supporting Statement 7.8.2015 (2)

ASSISTANCE REPORTING TOOL (ART) - SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION

A. JUSTIFICATION

1. Needs and Uses

In accordance with the Department of Defense Instruction Number 6015.23, October 30, 2002, TRICARE Management Activity is required to develop and maintain a database allowing Beneficiary Counseling and Assistance Coordinators and Debt Collection Assistance Officers to track, refer, reflect, and report workload associated with resolution of beneficiary and/or provider inquiries pertaining to TRICARE. Additionally, it supports the Government Accountability Office recommendation that the Department of Defense develop a centralized system to track beneficiary feedback across the Military Health System (DOD Could Improve Its Beneficiary Feedback Approaches HEHS-98-51, Feb 6, 1998).

The TRICARE Operations Manual 6010.56-M, February 1, 2008 Chapter 16, Addendum C and Chapter 17, Addendum B, require the Military Medical Support Office to use a system to provide the contractor with necessary information to authorize health care for TRICARE Prime Remote service members, line of duty care, and care under the Department of Defense/Department of Veterans Affairs Memorandum of Agreement.

2. Purpose and users of the information

The Assistance Reporting Tool (ART) is a web-based system that captures feedback on and authorizations related to TRICARE benefits.

Users are comprised of customer service personnel, to include Beneficiary Counseling and Assistance Coordinators, Debt Collection Assistance Officers, personnel, family support, recruiting command, case managers, and others who serve in a customer service support role. The ART is also the primary means by which Military Medical Support Office (MMSO) staff capture medical authorization determinations and claims assistance information for remotely located service members, line of duty care, and care under the Transitional Care for Service-related Conditions benefit.

The beneficiary or provider initiates contact and voluntarily provides information collected via the ART when he or she has a TRICARE-related question. Information is received from the individual via a verbal (phone or in person) or written exchange (email or letter). Authorized users then use the information to query other databases/systems to obtain and verify TRICARE eligibility, treatment, payment, and other healthcare operations information to facilitate case resolution. The data collected may be used to develop tailored educational materials and improve beneficiary assistance efforts.

3. Information Collection Techniques

The collection of information does not involve the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.

4. Duplication and Similar Information

We aren’t aware of any other systems that collect the same information as ART.

5. Small Business

This collection of information will not impact small businesses or other small entities.

6. Consequence if Collection Is Not Conducted or Is Conducted Less Frequently

If this information is not collected, the Military Medical Support Office staff would be unable to approve Line of Duty care, issue medical authorization determinations, or review requests for care under the Transitional Care for Service-related Conditions benefit. This would impact the readiness mission by limiting service members´ timely access to needed specialty care services. Customer service support staff would be hindered in providing and tracking timely resolution of beneficiary inquires. This would lead a decrease in beneficiary satisfaction which could result in increased congressional and media inquiries. This could also decrease the TMA regional offices from being able to assess contractor performance in the customer service support realm. Users would have to resort to a manual process, therefore increasing the risk of Health Insurance Portability and Accountability Act/Personally Identifiable Information/Protected Health Information violations. Additionally, users would have to establish a hard copy file system or create individual, secure systems to protect and track case information - thus increasing labor and secure site development across the Military Health System.

7. Special Circumstances

There are no special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.5 (d) (2).

8. Federal Register Notice/Consultations

The Federal Register Notice for this collection of information was published on November 29, 2012, 77 FR 71172, pages 71172 -71173. No public comments were received. The Federal Register Notice was republished on June 30, 2014, issue number 79 FR 78409 due to timing out of the original notice. Separately, the respondent cost section in this document (item 13) was later edited to reflect the public respondents, only, and as such, is a lesser amount than originally documented in the Federal Register Notices.

9. Payment/Gift to Respondents

Payments or gifts are not provided to respondents.

10. Confidentiality

ART received an Authority to Operate in compliance with the Department of Defense Information Assurance Certification and Accreditation Process on June 2, 2012. The system undergoes an annual risk assessment to ensure protective controls are maintained during the lifecycle of the system. ART maintains a Privacy Impact Assessment on file with the TMA Privacy and Civil Liberties Office.

All information collected is voluntarily given by the individual. At any time during the case resolution process, individuals may object to the collection of Personally Identifiable Information (PII) and Protected Health Information (PHI) via verbal or written notice. Individuals will be informed that, without PII/PHI, the authorized user may not be able to assist in case resolution, and that answers to questions/concerns would be generalities regarding the topic at hand. Individuals can verbally or in writing consent or authorize secondary uses of their PII/PHI in accordance with the Privacy Act and Health Insurance Portability and Accountability Act (HIPAA). In addition, a process is in place for individuals to access, question, and correct the PII/PHI in the application by means of the HIPAA Privacy Rule, Freedom of Information Act or a Privacy Act request.

Only authorized personnel are allowed access to data in the system. Requests to access to the system are provided in writing to TMA Beneficiary Education & Support. Verification is made that the individual works within the MHS and assists beneficiaries with the aspects of the TRICARE benefit. Once verified, individuals are granted access privileges based on their level of responsibility. Various user levels exist for each of the system’s sections, including read/write access, and administrative access.

ART data is stored on a secure database server. Physical controls have been adopted for the ART servers. These controls include identification badges, key cards, and cipher locks. Only authorized individuals are permitted to access servers. Information stored in the database is provided a high level of security and data integrity through encryption via the Oracle 11g Triple Data Encryption Standard (3DES) when transmitted to and from the Web server. Oracle Transparent Data Encryption is used to encrypt columns containing personal data. Backups are 3DES and AES-256 encrypted. All PII/PHI stored in the system is assigned a High Impact Category and protected at a Confidentiality Level of Sensitive, unless specifically cleared for public release.

11. Sensitive Questions

ART will not collect information based on questions of a sensitive nature.

12. Burden Estimated (hours)

As previously stated, the beneficiary or provider initiates contact and voluntarily provides information collected via the ART when he or she has a TRICARE-related question. The burden of the collection of information depends on the complexity of the individual’s question or issue.

Number of respondents: 169,606 in Fiscal Year 2012

Responses per respondent: 1

Frequency: On occasion

Average burden per response: 15 minutes

Annual burden hours: 42,402 ((15 min x 169,606)/60)

13. Cost to Respondents

$307,415 (annual burden hours (42,402) x federal minimum wage ($7.25))

Federal minimum wage found at http://www.dol.gov/dol/topic/wages/minimumwage.htm

14. Cost to Federal Government

Total Capital/Startup Costs – The costs to develop and maintain ART were a part of an overall personal services contract requirement for TMA BE&S. Separate costs cannot be broken-out.

Costs of all non-labor activities used to prepare and complete the report/study:

Activity	Description	Units	Unit Value	Actual Cost ($k)
Contractor/FFRDC Costs	FY13 Costs	1	$413,513.00	$413.5
Other Costs	Risk Assessment for Servers – FY13 costs	2	$24,040.00	$48.1
Other Costs	MOA with Enterprise Infrastructure – FY13 costs	1	$43,709.00	$43.7
Software/Hardware Purchases	Document Imaging Maintenance & Server Maintenance License – FY13 costs	1	$1,767.00	$1.8
Software/Hardware Purchases	Oracle Database License – FY13 costs	1	$18,566.00	$18.6
TOTAL				$525.6

Total DoD Manpower Required for Oversight of Report/Study Execution:

The rates below were obtained from the “Cost of Report and Study Calculator” found at the DoD Cost Guidance Portal (https://www.cape.osd.mil/costguidance/).

Oversight/Activity	Description	Grade	Manpower	Qualifier	Estimate Cost ($k)
Government Oversight	Oversight	GS-13	6	Man Months	$50.5
Government Oversight	Oversight	GS-14	4	Man Months	$39.7
TOTAL					$90.2

15. Change in Burden

The increase in burden is due to this being a new collection with requirements to collect this information as stated in the Needs and Uses section of this document.

16. Publication/Tabulation

Information gathered through this collection will not be published.

17. Expiration Date

DoD is not seeking an exception to displaying the expiration date of this information collection.

18. Exception to the Certification Statement of OMB Form 83-I

There are no exceptions to the certification statement in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

B. Collections of Information Employing Statistical Methods

This collection does not employ statistical methods.

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