Chcs Pia

PRIVACY IMPACT ASSESSMENT (PIA)

For the

Theater Composite Health Care System (CHCS) Caché (TC2)
Defense Health Agency (DHA)

SECTION 1: IS A PIA REQUIRED?
a. Will this Department of Defense (DoD) information system or electronic collection of
information (referred to as an "electronic collection" for the purpose of this form) collect,
maintain, use, and/or disseminate PII about members of the public, Federal personnel,
contractors or foreign nationals employed at U.S. military facilities internationally? Choose
one option from the choices below. (Choose (3) for foreign nationals).
(1) Yes, from members of the general public.
(2) Yes, from Federal personnel* and/or Federal contractors.
(3) Yes, from both members of the general public and Federal personnel and/or Federal contractors.
(4) No
* "Federal personnel" are referred to in the DoD IT Portfolio Repository (DITPR) as "Federal employees."

b. If "No," ensure that DITPR or the authoritative database that updates DITPR is annotated
for the reason(s) why a PIA is not required. If the DoD information system or electronic
collection is not in DITPR, ensure that the reason(s) are recorded in appropriate
documentation.
c. If "Yes," then a PIA is required. Proceed to Section 2.

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SECTION 2: PIA SUMMARY INFORMATION
a. Why is this PIA being created or updated? Choose one:
New DoD Information System

New Electronic Collection

Existing DoD Information System

Existing Electronic Collection

Significantly Modified DoD Information
System

b. Is this DoD information system registered in the DITPR or the DoD Secret Internet Protocol
Router Network (SIPRNET) IT Registry?
Yes, DITPR

Enter DITPR System Identification Number

Yes, SIPRNET

Enter SIPRNET Identification Number

164 (TMIP-J)

No

c. Does this DoD information system have an IT investment Unique Project Identifier (UPI), required
by section 53 of Office of Management and Budget (OMB) Circular A-11?
No

Yes
If "Yes," enter UPI

UII: 007-000001913 (TMIP-J)

If unsure, consult the Component IT Budget Point of Contact to obtain the UPI.

d. Does this DoD information system or electronic collection require a Privacy Act System of
Records Notice (SORN)?
A Privacy Act SORN is required if the information system or electronic collection contains information about U.S. citizens
or lawful permanent U.S. residents that is retrieved by name or other unique identifier. PIA and Privacy Act SORN
information should be consistent.

No

Yes
If "Yes," enter Privacy Act SORN Identifier

EDHA 07

DoD Component-assigned designator, not the Federal Register number.

Consult the Component Privacy Office for additional information or

access DoD Privacy Act SORNs at: http://www.defenselink.mil/privacy/notices/

or
Date of submission for approval to Defense Privacy Office
Consult the Component Privacy Office for this date.

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e. Does this DoD information system or electronic collection have an OMB Control Number?
Contact the Component Information Management Control Officer or DoD Clearance Officer for this information.
This number indicates OMB approval to collect data from 10 or more members of the public in a 12-month period
regardless of form or format.

Yes
Enter OMB Control Number
Enter Expiration Date
No
f. Authority to collect information. A Federal law, Executive Order of the President (EO), or DoD
requirement must authorize the collection and maintenance of a system of records.
(1) If this system has a Privacy Act SORN, the authorities in this PIA and the existing Privacy Act
SORN should be the same.
(2) Cite the authority for this DoD information system or electronic collection to collect, use, maintain
and/or disseminate PII. (If multiple authorities are cited, provide all that apply.)
(a) Whenever possible, cite the specific provisions of the statute and/or EO that authorizes
the operation of the system and the collection of PII.
(b) If a specific statute or EO does not exist, determine if an indirect statutory authority can
be cited. An indirect authority may be cited if the authority requires the operation or administration of
a program, the execution of which will require the collection and maintenance of a system of records.
(c) DoD Components can use their general statutory grants of authority (“internal
housekeeping”) as the primary authority. The requirement, directive, or instruction implementing the
statute within the DoD Component should be identified.
10 U.S.C. Chapter 55, Medical and Dental Care; 32 CFR Part199, Civilian Health and Medical Program
of the Uniformed Services (CHAMPUS); DoDI 6015.23, Foreign Military Personnel Care and Uniform
Business Offices in Military Treatment Facilities (MTFs); and E.O. 9397 (SSN), as amended.

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g. Summary of DoD information system or electronic collection. Answers to these questions
should be consistent with security guidelines for release of information to the public.
(1) Describe the purpose of this DoD information system or electronic collection and briefly
describe the types of personal information about individuals collected in the system.
TC2 provides military health care providers an environment to access and document inpatient healthcare,
ancillary services order-entry, and results retrieval in the military’s deployed environment. TC2 delivers an
effective, interoperable health care system that mirrors a subset of capabilities from the legacy Composite
Health Care System (CHCS) to support the deployed medical business practice.
Data elements include beneficiary information collected and used to support the delivery of health care to
TRICARE beneficiaries. In addition, user data is collected to support authentication, authority, and access to
TC2.
Personally identifiable information (PII) and protected health information (PHI) is collected to determine
eligibility and administer health care delivery services. User data, which contains some PII and PHI, is
collected to support administration and clinical practice authorization and access. Clinical patient data is
documented and stored in the patient files in TC2. Data is used for patient care management.
The types of personal information about individuals collected in this system include the following: personal
descriptors, ethnicity, identification numbers, life, education, employment, financial, and health information.
The individuals whose information is stored in this system include active duty military (all services + Coast
Guard and Reserve), veterans, dependents, retirees and/or their dependents, active-duty, contractors,
foreign nationals, former spouses, reservist, national guard personnel, and prisoners of war.
The system is located at Service Military Treatment Facility, Medical Centers and Hospitals: Uniformed
Services Treatment Facilities. CHCS is accessed at multiple locations by users affiliated with Defense
Health Clinical System (DHCS) and by users at 105 MTFs.
The system does not host a Web site accessible by the public.
A PIA has been previously submitted for this system with a final signature date of June 4, 2012.

(2) Briefly describe the privacy risks associated with the PII collected and how these risks are
addressed to safeguard privacy.
TC2 is susceptible to the same privacy risks inherent in any system collecting, using, and sharing PII/PHI. If this
system is not properly protected then the PII/PHI contained therein could be accessed by unauthorized individuals
through various methods such as data interception, unauthorized access, internal threats, and external threats.
TC2 data is encrypted in transit by the Theater Framework (TF) when transmitted outside the network enclave to
protect against data interception. Data transmitted within the enclave is not encrypted because it is secured by the
enclave. Unauthorized access is mitigated by limiting the access to PII/PHI to trusted individuals only; these
individuals have clearance and a "need to know" in order to access data. External threats are mitigated by following
Defense Information System Agency (DISA) provided checklists as part of the TC2 accreditation efforts under DoD
Information Assurance Certification & Accreditation Program (DIACAP). This ensures that all necessary checks are
followed to maintain the security of the TC2 system.
Therefore, all applicable security and privacy processes and regulations (e.g., DIACAP, HIPAA, etc.) required of a DoD
system in operation have been defined and implemented, reducing risks to the maximum extent possible and to
the point that any remaining risk has been accepted by the TC2 Designated Approving Authority (DAA). TC2 is
currently accredited with a 3 year Authority to Operate (ATO).

h. With whom will the PII be shared through data exchange, both within your DoD Component and
outside your Component (e.g., other DoD Components, Federal Agencies)? Indicate all that apply.
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Within the DoD Component.
Specify.
Other DoD Components.

Specify.

Army, Navy, Air Force
AHLTA-T is the source system for patient demographics. TC2 Lab Interop
(Lab Interop, Lab Sharing with Landsthul Regional Medical Center), Digital
Imaging Network - Picture Archiving and Co (DINPACS (MedWeb)).
To the U. S. Coast Guard (USCG) for USCG beneficiaries treated at DoD
MTFs.

Other Federal Agencies.

Specify.

To permit the disclosure of records to the Department of Health and Human
Services (HHS) and its components for the purpose of conducting research
and analytical projects, and to facilitate collaborative research activities
between DoD and HHS.
To federal offices and agencies involved in the documentation and review of
defense occupational and environmental exposure data, including the
National Security Agency, the Army Corps of Engineers, National Guard, and
the Defense Logistics Agency.
To the Congressional Budget Office for projecting costs and workloads
associated with DoD medical benefits.
To the Department of Veterans Affairs (DVA) for the purpose of providing
medical care to former service members and retirees, to determine the
eligibility for or entitlement to benefits, to coordinate cost sharing activities,
and to facilitate collaborative research activities between the DoD and DVA.
To the National Research Council, National Academy of Sciences, National
Institutes of Health, Armed Forces Institute of Pathology, and similar
institutions for authorized health research in the interest of the Federal
Government and the public. When not essential for longitudinal studies,
patient identification data shall be deleted from records used for research
studies. Facilities/activities releasing such records shall maintain a list of all
such research organizations and an accounting disclosure of records released
thereto.

State and Local Agencies.

Specify.

To local and state government and agencies for compliance with local laws
and regulations governing control of communicable diseases, preventive
medicine and safety, child abuse, and other public health and welfare
programs.

Contractor (Enter name and describe the language in the contract that safeguards PII.)

Specify.

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Data Exchange occurs between TC2 and individual Service readiness applications,
contractor systems providing clinical results, personnel systems, workload
management systems, Defense Manpower Data Center (DMDC), other developers
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and help desk support.
When access to PII/PHI is required there is a supporting Data Use Agreement (DUA)
in place (e.g. Science Applications International Corporation (SAIC), DHCS, etc).
Other (e.g., commercial providers, colleges).

Specify.
i. Do individuals have the opportunity to object to the collection of their PII?
Yes

No

(1) If "Yes," describe method by which individuals can object to the collection of PII.
Submission of information is voluntary. If an individual chooses not to provide PII/PHI information, no
penalty may be imposed, but absence of the requested information may result in administrative delays.

(2) If "No," state the reason why individuals cannot object.

j. Do individuals have the opportunity to consent to the specific uses of their PII?
Yes

No

(1) If "Yes," describe the method by which individuals can give or withhold their consent.
Consent to the specific uses of PII is obtained as necessary, in accordance with DoD 5400.11-R, DoD
Privacy Program, C4.1.3. PHI is collected for permitted uses and disclosures as set forth in DoD 6025.18-R,
DoD Health Information Privacy Regulation. Individuals are informed of these uses and are given the
opportunity to restrict the use of their PHI based on the procedures in place at the local facility where the
data is collected and maintained, in accordance with DoD 6025.18-R, C10.1.
For uses other than treatment, payment and healthcare operations, individuals can authorize the use of their
PHI by submitting DD Form 2870. For uses other than treatment, payment and healthcare operations,
individuals can request restrictions on the use of the PHI by submitting DD Form 2871.

(2) If "No," state the reason why individuals cannot give or withhold their consent.

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k. What information is provided to an individual when asked to provide PII data? Indicate all that
apply.
Privacy Act Statement

Privacy Advisory

Other

None

Describe TC2 collects data through direct entry by health care providers/administrators, who solicit the
information from individuals via paper format, fax, and face-to-face contact. Information is also
each
applicable collected via system interfacing with AHLTA-T.
format.
Because TC2 collects PII and PHI directly from individuals, a Privacy Act Statement (PAS) is
required. Below is a recommended PAS for use with TC2.
The PAS should be provided in a conspicuous manner, at or before the point that PII is collected,
regardless of the medium used for collection. On paper forms, the PAS is typically placed at the
beginning of the form, immediately following the title, before the first official heading/section, or
immediately prior to the collection fields.
AUTHORITY: 10 U.S.C. Chapter 55, Medical and Dental Care; 32 CFR Part 199, Civilian Health and
Medical Program of the Uniformed Services (CHAMPUS); DoDI 6015.23, Foreign Military Personnel
Care and Uniform Business Offices in Military Treatment Facilities (MTFs); and E.O. 9397 (SSN), as
amended.
PURPOSE: Your information is collected to determine your eligibility, as well as document and
administer delivery of health care within the theater environment.
ROUTINE USES: Your records may be disclosed to Federal, state, and local government agencies
on matters relating to eligibility, coordination of benefits, authorized health research, and compliance
with local laws relating to public health and welfare. Use and disclosure of your records outside of
DoD may also occur in accordance with the DoD Blanket Routine Uses published at http://dpcld.
defense.gov/Privacy/SORNsIndex/BlanketRoutineUses.aspx and as permitted by the Privacy Act of
1974, as amended (5 U.S.C. 552a(b)).
DISCLOSURE: Voluntary. If you choose not to provide your information, no penalty may be
imposed, but absence of the requested information may result in administrative delays.

NOTE:
Sections 1 and 2 above are to be posted to the Component's Web site. Posting of these
Sections indicates that the PIA has been reviewed to ensure that appropriate safeguards are in
place to protect privacy.
A Component may restrict the publication of Sections 1 and/or 2 if they contain information that
would reveal sensitive information or raise security concerns.

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