BMISS PIA_Privacy_Impact_Assessment - Attachment F

BMISS PIA_Privacy_Impact_Assessment - Attachment F.pdf

Health Workforce Connector

BMISS PIA_Privacy_Impact_Assessment - Attachment F

OMB: 0906-0031

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 0906-0031 can be found here:

2023-09-08 - Revision of a currently approved collection

Document [pdf]

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Privacy Impact Assessment (PIA): HRSA - BMISS - QTR3 - 2020 - HRSA609657
Created Date: 7/15/2020 12:35 PM Last Updated: 7/21/2020 12:10 AM

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Instructions
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General Information
PIA Name:

HRSA - BMISS - QTR3 - 2020 - HRSA609657

PIA ID:

609657

Name of
Component:

BHW Management Information System Solution

Name of ATO
Boundary:

BHW Management Information System Solution

Overall Status:

PIA Queue:

Submitter:

Kendawi, Osman

# Days Open:

Submission
Status:

Submitted

Submit Date:

7/17/2020

Next
Assessment
Date:

Expiration Date:

Office:

HRSA

Security
Categorization:

Moderate

Legacy PIA ID:

P-7664500-803392

OpDiv:

HRSA

Make PIA
available to
Public?:

Yes

PTA
PTA
PTA - 1A:

Identify the Enterprise Performance Lifecycle Phase of the system

Operations and Maintenance

PTA - 1B:

Is this a FISMA-Reportable system?

Yes

PTA - 2:

Does the system include a website or online application?

Yes

PTA - 2A:

Are any of the URLs listed accessible by the general public (to
include publicly accessible log in and internet websites/online
applications)?

PTA - 3:

Is the system or electronic collection, agency or contractor
operated?

Contractor

PTA - 3A:

Is the data contained in the system owned by the agency or
contractor?

Agency

PTA - 5:

Does the system have or is it covered by a Security Authorization
to Operate (ATO)?

Yes

PTA - 5A:

If yes, Date of Authorization

1/31/2019

PTA - 5B:

If no, Planned Date of ATO

PTA - 6:

Indicate the following reason(s) for this PTA. Choose from the
following options.

PIA Validation (PIA Refresh)

PTA - 7:

Describe in further detail any changes to the system that have
occurred since the last PIA

The Bureau of Health Workforce (BHW)
Management Information System Solution
(BMISS) supports the BHW Loan and
Scholarship Programs, as well as the Shortage
Designation Management System (SDMS).
SDMS is a map-based system for Primary Care
Officers to create and manage designations for
Health Provider Shortage Areas (HPSAs) and
Medically Underserved Area and Populations
(MUA/Ps). Additional mechanisms added to
support the LRP and Scholarship programs are
Tableau dashboards as well as Unified
Interactive Map. Both were incorporated for the
BMISS platform system to provide visual as well
as clear information displayed for HRSA
personnel to identify trend and ways to best
serve the public.
A public facing site is also available for the
general public designated as Health Workforce
Connector (HWC). Its purpose is to assist the
public to search jobs nationally which allows
participants of BHW's loan repayment programs
(LRPs) and scholarship programs (SPs) to
apply for open positions at sites located in areas
of need of medical professionals. Although the
Connector is geared towards BHW's program
participants, the website is open to the general
public, and allows anyone to search for jobs at
over 20,000 medical facilities across the nation.

PTA - 8:

Please give a brief overview and purpose of the system by
describing what the functions of the system are and how the
system carries out those functions?

PTA - 9:

List and/or describe all the types of information that are collected
(into), maintained, and/or shared in the system regardless of
whether that information is PII and how long that information is
stored.

HRSA's Bureau of Health Workforce (BHW) and
stakeholders such as Primary care offices,
Sites, Applicants, Participants, and Ambassador
currently review, update and maintain data
specific to the Nation Health Service Corps
Loan Repayment Program (NHSC LRP), the
Nation Health Service Corps Scholarship
Program (NHSC SP), the Nursing Corps Loan
Repayment Program (NCLRP), Faculty Loan
Repayment Program (FLRP), Student to
Service Loan Repayment (S2S LRP), and the
Nursing Scholarship Program (NSP). All
external BMISS users can call the BMISS call
center whose staff has been trained to manually
enter the inquiries in BMISS. The call center is a
separate system from BMISS and is managed
by Verizon. Also, applicants may submit
inquiries online within BMISS allowing HRSA
internal officers to provide answers directly
through the system in a secure way. The phone
number is to the BMISS Call Center which is
managed by Verizon call center staff who has
limited access to BMISS to assist users with the
following: Reset passwords Update email
addresses Assist in resolving technical issues
with the applications or within the portal Enter
inquiries on behalf of customers Answer
program questions BMISS provides a process
for staff to edit and manage the data, and
provides functionality facilitating ranking of
applications, selecting potential awardees,
confirmation of interest, and the calculation and
processing of award financial information.
BMISS processing collects the following
application data: Name address(es) telephone
number(s) email address(es) Social Security
Number (SSN) Date of birth (DoB) Loan

Information Employment information
Commercial credit reports Educational data
Medical data Financial data Payment data
Discipline and Specialty Health professions
Licensure Tax information Military status
Personal Statement Experience Training and
Certifications An interface between BMISS and
UFMS has been established. The interface
works as a drop box process without a direct
link to either system. Files are picked-up and
processed manually. UFMS provides tax
documents to BHW program participants
regarding the funds provided by HRSA for their
service. Using the interface, BMISS exports the
following information to UFMS: SSN, tax year,
whether the user wants to receive their tax
documents electronically or by mail, and the
amount of loans the user owes to banks.
Program participants have the option to receive
hard copy tax documents or to receive them
electronically. If the participant elects to receive
and electronic version, UFMS passes the
individual???s tax document to BMISS in a file
and BMISS provides the document in a secure
environment. UFMS is managed by the
Program Support Center (PSC). The PSC is the
largest multi-function shared service provider to
the federal government. It is hosted by
HHS/OS/ASFR/Office of Finance and covered
by their PIA. PII collected from users/system
administrators in order to access the system
consists of user credentials. The system collects
National Provider Identifier (NPI). It is an
optional field that is used primarily for reporting
purposes so we can track the applicants after
they apply to one of BMISS programs. The
Health Workforce Connector collects
Professional and Education information,
including but not limited to collection of
employment, training, education, and
certification information and gives the user the
ability to control privacy settings. The following
type of information are collected: Personal
Information - location, title, field of practice,
email address, phone number Experience Residency location, position, time period
Training and Certifications Picture, email
address, phone number.
PTA -9A:

Are user credentials used to access the system?

Yes

PTA - 9B:

Please identify the type of user credentials used to access the
system.

HHS User Credentials
HHS Email Address
HHS/OpDiv PIV Card
Non-HHS User Credentials
Email address
Password
Username

PTA - 10:

Describe why all types of information is collected (into),
maintained, and/or shared with another system. This description
should specify what information is collected about each category
of individual

BMISS is used to collect personal, site, school,
and financial information from Applicants,
Schools, Sites, Participants and program
stakeholders via a web-based front end and
provides the ability to review, update and
manage the data as well as record and update
inquiry, compliance and self-service related
information during and after participation in a
BHW Loan Repayment or Scholarship program.
Program stakeholders of BMISS are: Nation
Health Service Corps Loan Repayment
Program (NHSC LRP), Nation Health Service
Corps Scholarship Program (NHSC SP),
Nursing Corps Loan Repayment Program
(NCLRP), Faculty Loan Repayment Program
(FLRP), Nursing Scholarship Program (NSP)
The data collected contains, and is not limited
to, mandatory personal information related to
the applicant, SSN, address, and school
information, DOB, military status, credit report,
address, phone number, email address, first
and last name, DOB, emergency contact
(names, phone number, email address), marital
status, ethnicity, gender, language, race.
Inquiries are sent by phone and via application.
The Health Workforce Connector (HWC), which
is the successor to the former NHSC Jobs
Center, is designed to be a job search platform
which allows participants of BHW???s loan
repayment programs (LRPs) and scholarship
programs (SPs) to search for open positions at
sites located in areas of need. Although the
Connector is geared towards BHW's program
participants, the website is open to the general
public, and allows anyone to search for
thousands of jobs at over 20,000 medical
facilities across the nation. Site Admins (also
called Site POC's) need the following
information in order to review the applicant's
skills, experience, etc. for that site's openings.
Personal Information - location, title, field of
practice, email address, phone number
Experience - Residency location, position, time
period Training and Certifications Picture, email
address, phone number.

PTA - 10A:

Are records in the system retrieved by one or more PII data
elements?

Yes

PTA - 10B:

Please specify which PII data elements are used.

PTA - 11:

Does the system collect, maintain, use or share PII?

Yes

PIA
PIA
PIA - 1:

Indicate the type of PII that the system will collect or maintain

Social Security Number
Name
E-Mail Address
Phone numbers
Certificates
Education Records
Military Status
Taxpayer ID
Date of Birth
Mailing Address
Financial Account Info
Employment Status
Others - Medical notes,

PIA - 2:

Indicate the categories of individuals about whom PII is collected,
maintained or shared

Grantees
Employees/ HHS Direct Contractors
Public Citizens

PIA - 3:

Indicate the approximate number of individuals whose PII is
maintained in the system

Above 2000

PIA - 4:

For what primary purpose is the PII used?

1. To identify and select qualified individuals to
participate. The process includes verifying
program applicant’s or participant’s credentials
and educational background, previous and
current professional employment data and
performance history information. The process
also verifies that all claimed background and
employment data are valid and all claimed
credentials are current and in good standing
from selection for an award through the
completion of service, perform loan repayment
and scholarship program administrative
activities, including, but not limited to, payment
tracking, deferment of the service obligation,
monitoring a participant’s compliance with the
service requirements, determination of service
completion, review of suspension or waiver
requests, default determinations, and
calculation of liability upon default. There is an
option to import data from Department of
Education system National Students Loan Data
System (NSLDS) containing student and
student loan information to the applicant’s data
fields for convenience as well as accurately
collecting PII.
2. To monitor the services provided by the
programs’ healthcare providers.
3. To transfer information to the Unified
Financial Management System (UFMS) for
purposes of effecting payment of program funds
(through the Department of the Treasury) and
preparing and maintaining financial
management and accounting documentation
related to obligations and disbursements of
funds (including providing notifications to the
Department of the Treasury) related to
payments to, or on behalf of, awardees.
4. The system collects user credentials from
system users/ administrator in order to access
the system.
5. To support a job search platform that allows
participants of BHW’s loan repayment programs
(LRPs) and scholarship programs (SPs) to
search for open positions at sites located in
areas of need. Although the Connector is
geared towards BHW’s program participants,
the website is open to the general public, and
allows anyone to search for jobs at over 20,000
medical facilities across the nation. These
medical facilities, also known as ‘sites’, each
feature a ‘site profile’ containing a variety of
information intended to educate the viewer and
inform them of any open opportunities at the
site.
To support search by the Site POCs to review
applicant profiles for job openings at the site.
The search can only be based on type of skill
requirements and not on individual names.

PIA - 5:

Describe any secondary uses for which the PII will be used (e.g.
testing, training or research)

Research, Statistical information.

PIA - 6:

Describe the function of the SSN/Taxpayer ID.

Required to make payments to awardees, for
Tax documentation and matching of records
between BMISS and external systems (i.e.,
HHS Program Support Center (PSC)).

PIA - 6A:

Cite the legal authority to use the SSN

IRC (Internal Revenue Code) 6109
Section 846 of the Public Health Service Act, as
amended

PIA - 7:

Identify legal authorities, governing information use and disclosure Section 846 of the Public Health Service Act, as
amended
specific to the system and program

PIA - 8:

Provide the number, title, and URL of the Privacy Act System of
Records Notice (SORN) that is being used to cover the system or
indicate whether a new or revised SORN is in development.

System of Record Notice 09-15-0037.
URL: https://www.hrsa.gov/about/privacyact/09-15-0037.html
There are revisions and updates in progress for
the SORN as of July 2020.

PIA - 9:

Identify the sources of PII in the system

Directly from an individual about whom the
information pertains
Hard Copy Mail/Fax
Email
Online
Government Sources
Within the OPDIV
Other Federal Entities
Non-Government Sources
Members of the Public

PIA - 9A:

Identify the OMB information collection approval number or
explain why it is not applicable.

OMB#

Expiration Date

0915-0301

05/31/2021

0915-0150

08/31/2021

0915-0127

03/31/2023

0915-0146

07/31/2020

0915-0140

01/30/2023

0915-0337

04/28/2023

0915-0146

06/15/2023

0915-0388

05/05/2020

PIA - 9B:

Identify the OMB information collection expiration date.

PIA - 10:

Is the PII shared with other organizations outside the system’s
Operating Division?

Yes

PIA - 10A:

Identify with whom the PII is shared or disclosed and for what
purpose

Within HHS

PIA - 10A
(Justification):

Please provide the Justification for PIA - 10A

Unified Financial Management System (UFMS)
- for taxing purposes.

PIA - 10B:

List any agreements in place that authorizes the information
sharing or disclosure (e.g., Computer Matching Agreement,
Memorandum of Understanding (MOU), or Information Sharing
Agreement (ISA)).

BMISS holds a Memorandum of Understanding
(MOU) information Program Management and
System Policy (for Unified Financial
Management System (UFMS)) and Health
Resources and Services Administration (for
BMISS), to ensure the integrity and availability
of the data that is shared between the two
systems.

PIA - 10C:

Describe process and procedures for logging/tracking/accounting
for the sharing and/or disclosing of PII

BMISS tracks every transaction that is sent to
UFMS. This transaction report can be retrieved
upon request.

PIA - 11:

Describe the process in place to notify individuals that their
personal information will be collected. If no prior notice is given,
explain the reason

Awardees and potential awardees are informed
of what PII is collected during the application
process and on the BHW website. It is not
required for user credential PII. User enters PII
as a part of an interactive on-line session.

PIA - 12:

Is the submission of PII by individuals voluntary or mandatory?

Voluntary

PIA - 13:

Describe the method for individuals to opt-out of the collection or
use of their PII. If there is no option to object to the information
collection, provide a reason

Prior to actually registering, individuals are
asked to read the rules of behavior, nondisclosure, and Acceptable Use Policy posted
on the site. They can only proceed into the
system if they choose the "I ACCEPT" button
on-screen which allows them to move forward.
If individuals choose not to accept, then they are
returned to the general information screen.
Since this system is based on cycles, the I
Accept’ data field, stored in the database, is
checked for each new cycle year and forces
them to re-acknowledge/re-accept. If changes
occur to the object to the information collection,
provide a Rules of Behavior, Non-Disclosure,
and Acceptable Use Policy posted on the site
during a new cycle year, then the updated
notifications are posted on the site for the user
to read during logon. For the BHW Connector,
one of the screens, Privacy Settings, gives the
user the option to make her/his profile to be
Public or Private. If the user selects the Private
option, no one is able to look at that user's
profile except the user himself/herself.

PIA - 14:

Describe the process to notify and obtain consent from the
individuals whose PII is in the system when major changes occur
to the system (e.g., disclosure and/or data uses have changed
since the notice at the time of original collection). Alternatively,
describe why they cannot be notified or have their consent
obtained

If any major change to the system, in regards to
information sharing, the system will be used to
notigy participants of the change via email
and/or popup notification upon login.
It is not required for user credential PII.
For the BHW Connector application, a screen is
presented to the user for consent. If the user
clicks "OK" button, then user is presented with
the login screen to proceed further. If the user
selects "X", then the user is taken back to the
previous screen.

PIA - 15:

Describe the process in place to resolve an individual's concerns
when they believe their PII has been inappropriately obtained,
used, or disclosed, or that the PII is inaccurate. If no process
exists, explain why not

Awardees and potential awardees are informed
of what PII is collected during the application
process and on the BHW website.
It is not required for user credential PII.
User enters PII as a part of an interactive online
session.

PIA - 16:

Describe the process in place for periodic reviews of PII contained
in the system to ensure the data's integrity, availability, accuracy
and relevancy. Please address each element in your response. If
no processes are in place, explain why not

Applicants or participants can contact the BHW
Customer Care Center at 1-800-221-9393. Also
available a TTY for hearing impaired: 1-877897-9910 Monday-Friday (except Federal
holidays), 8:00 am to 8:00 pm ET or email at
[email protected] if they have concerns about
the use of their PII. It is not required for user
credentials PII.

PIA - 17:

Identify who will have access to the PII in the system and the
reason why they require access

Users
Administrators
Developers
Contractors
Others

PIA - 17A:

Provide the reason of access for each of the groups identified in
PIA -17

Users: Anyone from the public applying to the
application may see their own information.
Administrators: Internal analysis.
Developers: During design and development
work.
Contractors: NIH; CIT; Sapient: Direct
contractors provide production support for the
system and are required to have access to PII
to resolve data issues such as an incorrect SSN
or contact information, at the request of the PII
owner.
Others: Site Admins to review user profile for
job opportunities

PIA - 17B(1):

Select the type of contractor

HHS/OpDiv Direct Contractor

PIA - 18:

Describe the administrative procedures in place to determine
which system users (administrators, developers, contractors, etc.)
may access PII

A HRSA internal user who needs access to the
system must have a position that requires
access to that data and be approved by the
internal officer's manager to have access to that
data.
The developers working on the system must
obtain an approval from their managers and
BHW.
For the Connector application, the Site POCs
can access and review individual user profile for
open positions at their site. System
administrators also have access to the
individual user profile.

PIA - 19:

Describe the technical methods in place to allow those with
access to PII to only access the minimum amount of information
necessary to perform their job

Access to PII is role based and only specific
roles have access to PII. Only select analysts
have access to SSN and Birth dates.

PIA - 20:

Identify training and awareness provided to personnel (system
owners, managers, operators, contractors and/or program
managers) using the system to make them aware of their
responsibilities for protecting the information being collected and
maintained

All users are required to complete HRSA annual
security awareness training.

Describe training system users receive (above and beyond
general security and privacy awareness training).

There is no additional privacy training beyond
what is provided by HRSA.

PIA - 21:

The annual awareness training is required only
for (internal) HRSA personnel such as admins
and contractors, but not for external (public)
users.

PIA - 23:

Describe the process and guidelines in place with regard to the
retention and destruction of PII. Cite specific NARA records
retention schedule(s) and include the retention period(s)

In order to dispose of the sensitive information
when printed, it must be shredded. Addition
information regarding retention and destruction
of PII will be finalized during development of the
records management portion and the SORN for
this system. The Records Management Officer
has been consulted and we are working with
Records Management Officer to obtain the
appropriate records and retention schedule.
Records are retained and disposed of as
follows:
- Files concerning participants who complete
their obligations or whose obligations are
waived, cancelled, or terminated are transferred
to the Washington National Records Center in
Suitland, Maryland and are destroyed 6 years
after final payment, under disposition schedule
HSA B-351 3. 1.
HRSA has digitized and uploaded paper files
concerning active participants in BHW
scholarship and loan repayment programs into
BMISS. The paper files are stored at the
Washington National Records Center and are
destroyed 15 years after closeout, under
disposition schedule N1-512-92-01, item 25P 1
and 2.
Unfunded or withdrawn applicant records are
destroyed 6 months after the close of each
fiscal year application period, under disposition
schedule N1-512-92-01, item 25P 1.
Currently, all records migrated to BMISS or
created in BMISS are retained indefinitely,
pending NARA’s approval of a revised
schedule.

PIA - 24:

Describe how the PII will be secured in the system using
administrative, technical, and physical controls. Please address
each element in your response

BMISS consists of a multi-tier architecture using
a Windows environment with a custom front-end
developed at HRSA, a second tier of application
servers, and a third tier of databases to encrypt
and store data. All servers are configured to
HHS security guidelines and reside at a secure
data center managed by NIH.
Applicants and vendors access the system via
the Internet, and register for a login and
password to ensure that responsibility for data
can be attributed to an individual.
HRSA employees (and direct contractors) can
only access the internal system via the HHS
Intranet which requires dual factor
authentication.
Communication between components is
controlled through the use of Virtual Lan over
TCP/IP protocol. Applicants and vendors
connect over the internet via secure HTTP
(https) using digital certificates and FIPS
compliant SSL encryption to protect data in
transmission. Internal users connect over the
HHS intranet via secure HTTP (https) using
digital certificates and FIPS compliant SSL
encryption to protect data in transmission.
Physical Controls: Rooms where records are
located are locked when not in use. During
regular business hours, rooms are unlocked but
are controlled by on-site personnel. Security
guards perform random checks on the physical
security of the offices (storage locations) after
duty hours, including weekends and holidays.
Databases are hosted in NIH data centers at
Building 12 and sterling data centers where
physical security are provided.

PIA - 25:

Describe the purpose of the web site, who has access to it, and
how users access the web site (via public URL, log in, etc.).
Please address each element in your response

The Workforce Connector (HWC) allows Health
BHW’s participants to search for open positions
at sites located in areas of need. It is designed
to be a job search platform which allows
participants of BHW’s Loan Repayment
Programs (LRPs) and scholarship programs
(SPs) to search for open positions at sites
located in areas of need. The website is
accessed via public URL for informational and
job search purposes. For individuals applying,
there is an option to create an account with a
username and password as their credentials to
apply to said positions.

PIA - 26:

Does the website have a posted privacy notice?

Yes

PIA - 27:

Does the website use web measurement and customization
technology?

Yes

PIA - 27A:

Select the type of website measurement and customization
technologies is in use and if it is used to collect PII

Session Cookies - Does Not Collect PII

PIA - 28:

Does the website have any information or pages directed at
children under the age of thirteen?

PIA - 29:

Does the website contain links to non-federal government
websites external to HHS?

Review & Comments
Privacy Analyst Review
OpDiv Privacy
Analyst Review
Status:

Approved

Privacy Analyst
Review Date:

7/17/2020

Privacy Analyst
Comments:

The response for 28B is No.

Privacy Analyst
Days Open:

Approved

SOP Signature:

Signature - James Ellis.png

SOP Review
Date:

7/17/2020

SOP Review
SOP Review
Status:

SOP Comments: The response for 28B is No.

SOP Days Open: 0

Agency Privacy Analyst Review
Agency Privacy
Analyst Review
Status:

Approved

Agency Privacy
Analyst Review
Date:

7/20/2020

Agency Privacy
Analyst Review
Comments:

Reviewer: Crystal Bland

Ready for approval and signature.

Agency Privacy
Analyst Days
Open:

Approved

SAOP Signature:

SAOP Review
SAOP Review
Status:
SAOP
Comments:

SAOP Review
Date:

7/20/2020

SAOP Days
Open:

Supporting Document(s)
Name

No Records Found

Size

Type

Upload Date

Downloads

Comments
Question Name

Submitter

Date

Comment

PIA - 4

Ellis, James

7/17/2020

Capitalize department of education

Attachment

Define (NSLDS)
PIA - 9B

Ellis, James

7/17/2020

Paste information from 9A into 9B.

PIA - 25

Ellis, James

7/17/2020

Define HWC.

PIA - 28B

Ellis, James

7/17/2020

Provide response.

PIA - 7

Data Feed Service,
Sync2PIAForm

7/20/2020

N/A

Miscellaneous Fields
Last Updated:

7/21/2020 12:10 AM
Public Burden Statement: The Health Workforce Connector also allows users to create a profile, search
for NHSC and Nurse Corps sites, find job and training opportunities, and search for other clinicians who
are similarly interested in working with underserved populations. An agency may not conduct or
sponsor, and a person is not required to respond to, a collection of information unless it displays a
currently valid OMB control number. The OMB control number for this information collection is
0915-0031 and it is valid until XX/XX/202X. This information collection is voluntary. Public reporting
burden for this collection of information is estimated to average xx hours per response, including the
time for reviewing instructions, searching existing data sources, and completing and reviewing the
collection of information. Send comments regarding this burden estimate or any other aspect of this
collection of information, including suggestions for reducing this burden, to HRSA Reports Clearance
Officer, 5600 Fishers Lane, Room 14N136B, Rockville, Maryland, 20857 or [email protected].

File Type	application/pdf
File Modified	2020-08-24
File Created	2020-08-24