SSN Justification Memo for 0720-0028

DEFENSE HEALTH AGENCY
HEALTHCARE OPERATIONS DIRECTORATE
7700 ARLINGTON BOULEVARD, SUITE 5101
FALLS CHURCH, VIRGINIA 22042-5101

THOMAS.LI
DHA Privacy NDA.SKILES.
Office Review:
1410880209

Digitally signed by
THOMAS.LINDA.SKILES.14108802
09
DN: c=US, o=U.S. Government,
ou=DoD, ou=PKI, ou=DHA,
cn=THOMAS.LINDA.SKILES.14108
80209
Date: 2017.02.07 14:18:19 -05'00'

MEMORANDUM FOR THE DEFENSE PRIVACY CIVIL LIBERTIES AND
TRANSPARENCY DIVISION
SUBJECT:

Justification for the Use of the Social Security Number (SSN) for TRICARE Plus
Enrollment Application (DD Form 2853) and TRICARE Plus Disenrollment
Request (DD Form 2854)

This memorandum is written to satisfy the requirement established by Department of
Defense Instruction (DoDI) 1000.30, "Reduction of Social Security Number (SSN) Use within
DoD," dated August 1, 2012, that requires justification for the collection and use of the SSN on
department Forms. This justification pertains to the updated TRICARE Plus Enrollment
Application (DD Form 2853) and TRICARE Plus Disenrollment Request (DD Form 2854)
forms, which are included as Attachment A and B.
The TRICARE Plus Forms (DD Form 2853 and DD Form 2854) are used to collect
personally identifiable information (PII) into a system of records under the Privacy Act of
1974. The Form is covered by System of Records Notice DMDC 02 DoD, Defense Enrollment
Eligibility Reporting Systems (DEERS) (July 27, 2016, 81 FR 49210). DMDC 02 DoD is
included as Attachment C.
The TRICARE Plus Forms (as referenced above) are DoD forms completed by
beneficiaries to formally enroll in, change, or terminate their coverage in the TRICARE Plus
program. The forms request either the SSN or DoD Benefits Number (DBN) of the sponsor.
DD Form 2853 is used by individuals to apply for TRICARE Plus and DD Form 2854 is used
by individuals to request disenrollment from TRICARE Plus. TRICARE Plus is a program
offered by some military treatment facilities (MTFs) to those already eligible for TRICARE
Standard, TRICARE Extra, TRICARE Standard Overseas, or TRICARE for Life. Dependent
parents and parents-in -law are also eligible for TRICARE Plus. Enrollees are assigned a
primary care provider stationed at a MTF and are expected to utilize that provider for all nonemergency primary care.
Regional Managed Care Support Contractors (MCSCs) are required to enter the
information contained in the Form into the Defense Enrollment Eligibility Reporting System
(DEERS) using the Defense Online Enrollment System (DOES) application, which will reflect
the beneficiary-requested enrollment status. Historically, the SSN has been the primary
identifier to update an enrollment, change or termination using the DOES application and this is
still the current process. The Defense Manpower Data Center Privacy Impact Assessment for
DEERS, dated 12/02/2015, is included as Attachment C. The Defense Information Technology
Portfolio Repository (DITPR) number for DEERS is 1391.
For the continued collection of SSNs under DoDI 1000.30, the Department's use of SSNs

must be justified by one or more of the Acceptable Use Cases set forth in DoDI 1000.30,
Enclosure 2. The Acceptable Use Cases applicable to the TRICARE Plus Forms (as referenced
above) are Paragraph 2.c.(4), Interactions With Financial Institutions, and Paragraph 2.c.(11),
Legacy System Interface.
Acceptable Use Case 2.c(4) permits SSN collection where it may be necessary to have an
individual's SSN "for systems, processes, or forms that interface with or act on behalf of
individuals or organizations in transactions with financial institutions." Financial institutions
with which electronic payment methods are established (Section VI of Attachment A) may
request the applicant's SSN or last four SSN digits to validate the establishment of an electronic
payment method on behalf of the applicant.
Further, MCSCs must input the information on the Form into DOES, which has
historically used the SSN as the primary identifier. Though DOES is able to use both the SSN
and DBN as the primary identifier, eliminating the collection of the SSN altogether would not be
feasible at this time.
Even though DoD has made efforts to inform TRICARE beneficiaries of their DBNs and
encourage use of DBNs in lieu of SSNs on forms and other information collections where SSNs
are not otherwise necessary, some beneficiaries remain unaware of their sponsors’ DBN.
However, TRICARE beneficiaries are aware of their sponsor's SSN, which has historically been
collected by multiple DoD agencies to confirm available benefits. Therefore, the DBN is not
always sufficient as the sole primary identifier permitted on the TRICARE Plus Forms (as
referenced above) or in connection with the DOES application interface with DEERS.
For these reasons, DD Form 2853 and DD Form 2854 continue needing to collect the
SSN for at least some individuals and circumstances under the Acceptable Use Cases found in
Paragraphs 2.c.(4) and 2.c.(11).
If there are questions, my point of contact is Ms. Shane Pham, who may be reached at
[email protected], or by phone at (703) 681-8666.

LARKIN.KATHLEE
N.K.1148043260

Digitally signed by
LARKIN.KATHLEEN.K.1148043260
DN: c=US, o=U.S. Government,
ou=DoD, ou=PKI, ou=DHA,
cn=LARKIN.KATHLEEN.K.1148043260
Date: 2017.02.07 10:52:24 -05'00'

Kathleen K. Larkin
Chief, Health Plan Execution & Operations Division

Attachments:
As stated