SSN Memo

DEFENSE HEALTH AGENCY
7700 ARLINGTON BOULEVARD, SUITE 5101
FALLS CHURCH, VIRGINIA 22042-5101
KELETA.RAHWA.
AMDEMARIAM.12
98456431

Digitally signed by
KELETA.RAHWA.AMDEMARIA
M.1298456431
Date: 2019.02.21 15:48:40
-05'00'

DHA Privacy
Office Review

MEMORANDUM FOR DEFENSE PRIVACY, CIVIL LIBERTIES AND TRANSPARENCY
DIVISION
SUBJECT: Justification for the Use of the Social Security Number (SSN) in DD Form 2527,
Statement of Personal Injury - Possible Third Party Liability, Office of Management and Budget
#0720-0003
This memorandum is to satisfy the requirements of the Department of Defense
Instruction (DoDI) 1000.30, Reduction of Social Security Number (SSN) Use Within DoD, dated
August 1, 2012, that requires justification of the collection and use of SSNs in DoD
DD Form 2527, Statement of Personal Injury - Possible Third Party Liability (Attachment A).
DD Form 2527 collects data, including the SSN of the sponsor, on beneficiaries who
suffer personal injuries that may result in third party liability (TPL) in favor of the US
Government. The form is then sent to the appropriate TRICARE managed care support
contractor (MCSC) and the information used to determine which third parties may be liable for
the medical care resulting from that injury, and to recover the cost of treatment from those found
liable. As private entities, the primary identifier used for verification in MCSC systems is the
sponsor's SSN.
The sponsor's SSN is also collected in order to identify the primary insured for an injured
TRICARE beneficiary for collection from other non-DoD entities. Health plans, liability
insurers, and other sources of TPL for healthcare provided by the Military Health System (MHS)
to an individual do not recognize or use, as an identifier, DoD Identification (ID) Numbers or
other internal DoD specific personal identifiers. Rather, actual and potential sources of third
party reimbursement to the MHS, including government agencies such as the Department of
Health and Human Services, the Department of Veterans Affairs, and the Social Security
Administration, will require DoD to provide the SSN of a sponsor as part of the agency
determining the extent, if any, to which it may be liable for MHS healthcare provided to the
sponsor or an individual insured through him or her. The same need for an SSN will arise in
identifying an individual to a private insurance company or health plan against which third party
liability may be claimed. Without collection of the sponsor's SSN on DD Form 2527, DoD's
ability to identify potential TPL claims, and to collect those claims from third parties, would be
severely limited.
The System of Records Notice applicable to DD Form 2527 is EDTMA 04
Medical/Dental Claim History Files (October 27, 2015, 80 FR 65720) (Attachment B). DD 2527
is subject to the Paperwork Reduction Act, and is registered under the OMB Control Number
0720-0003 (Attachment C).

Based on the forgoing, and in accordance with DoDI 1000.30, continued collection and
use of SSNs through DD Form 2527 is justified under Acceptable Use case 2.c(13), Other Cases.
Acceptable Use Case 2.c(13) allows for the continued collection of SSN where it is
required by law, but not specified in use cases 2.c(1) through 2.c.(12). Under 10 U.S.C. 1095,
(Attachment D) as well as the Federal Medical Claims Recovery Act (42 U.S.C. 2651, et seq.),
(Attachment E) DoD is authorized to recover the cost of medical care provided to individuals
when a third party may be liable. When interacting with third parties from other agencies and
private entities, the DoD ID Number or other DoD identifier will not suffice as it will be
unknown to the third party. Because all parties in a TPL claim will have access to the sponsor's
SSN, it must still be collected through DD Form 2527 in order to allow DoD to recover funds as
authorized by statute.
To the extent that DD Form 2527 provides information for the administration of the
Federal Worker Compensation System, or is otherwise required to interact with other
government agencies using the SSN as a primary identifier, Acceptable Use Cases 2.c(6);
Administration of Federal Workers' Compensation, and 2.c(8); Computer Matching will also
apply.
The DHA Component/Office point of contact for this program is Bridget Ewings, Chief,
Claims Collection, who can be reached at (303) 676.3402 or [email protected].
signed by
BRADLEY.LEIG Digitally
BRADLEY.LEIGH.A.1075715567
H.A.1075715567 Date: 2019.02.15 14:11:22 -05'00'

Leigh Bradley
General Counsel
Defense Health Agency

Attachments:
As Stated