SSN Justification Memo DD Form 3201

OFFICE OF THE ASSISTANT SECRETARY OF DEFENSE
1200 DEFENSE PENTAGON
WASHINGTON, DC 20301-1200

HEALTH AFFAIRS

13-Jul-2023

MEMORANDUM FOR OFFICE OF THE ASSISTANT SECRETARY OF DEFENSE FOR
PRIVACY, CIVIL LIBERTIES, AND TRANSPARENCY
SUBJECT: Justification for the Use of Social Security Number in DD Form 3857, Military
Health System Financial Assistance Program/Waiver Program
1. System / Form
DD Form 3857 collects information to assist the Department of Defense (DoD) in determining
the eligibility of an individual for the Military Health System Financial Assistance
Program/Waiver Program (MHS FAP), in accordance with title 10, United States Code (USC),
section 1079b. Per 10 USC § 1079b, DoD is mandated to apply a sliding scale or catastrophic
waiver discount to eligible civilian patients who are not entitled beneficiaries of DoD’s Military
Health System, but who receive healthcare at DoD military medical treatment facilities (MTFs).
The intent of providing a sliding scale/catastrophic waiver is to mitigate financial harm
stemming from MTF medical bills. Section 1079b also grants the Director of the Defense Health
Agency with discretionary authority to waive medical bills in certain instances.
2. Documentation
As documented in title 32 of the Code of Federal Regulations (CFR), part 220, the DD Form
3857 will be completed by civilian patients who desire to apply for the MHS FAP.
3. Authorized Uses
In accordance with DoDI 1000.30, enclosure 2, the SSN meets the following acceptable uses:
• Paragraph 2(c)(4), Interactions With Financial Institutions – Patients may choose to
repay their discounted medical bill in installment payments or by making a full one-time
payment. Patients who agree to make installment payments but subsequently default
will have the balance of their account transferred to the Department of the Treasury’s
Cross-Servicing Next Generation (CSNG) program for collection activity. CSNG relies
primarily on the SSN for collection activities such as Administrative Wage
Garnishment. In cases where the patient is a minor under 18 years of age, the SSN will
be collected from the party (guarantor) responsible for payment of the medical bill.
• Paragraph 2(c)(7), Federal Taxpayer Identification Number – When the Director of
DHA exercises discretionary authority to grant a waiver of medical bills for civilian
non-beneficiary patients, the waiver qualifies as a relevant identifiable event under 26
CFR § 1.6050P-1(b)(2)(G). Accordingly, the DoD must engage in information reporting
to the Internal Revenue Service (IRS) by submitting an IRS Form 1099-C and by
furnishing a copy of the statement to the patient when the Director of DHA exercises the
discretionary authority to waive medical debt. The patient’s SSN is required for
reporting to the IRS. In cases where the patient is a minor under 18 years of age, the

SSN will be collected from the party (guarantor) responsible for payment of the medical
bill.
4. Point of Contact
For questions related to this memorandum, please contact Ms. Merlyn Jenkins, e-mail:
[email protected], phone (703) 681-7346.

SHEDRICK.CH
ARLES.JOSE.1
125538459

Digitally signed by
SHEDRICK.CHARLES.JOS
E.1125538459
Date: 2023.07.14
12:14:38 -05'00'

signed by
LANDREAUX.DARR Digitally
LANDREAUX.DARRELL.W.111925339
6
ELL.W.1119253396 Date: 2023.07.13 17:28:47 -04'00'
Darrell W. Landreaux
Deputy Assistant Secretary of Defense
for Health Resources Management and Policy