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

Administration &
Management
(J-1)

February 21, 2024
MEMORANDUM FOR THE DEFENSE PRIVACY, CIVIL LIBERTIES, AND FREEDOM OF
INFORMATION DIRECTORATE
THROUGH: Defense Health Agency (DHA) Privacy and Civil Liberties Office

signed by
SHEDRICK.CHA Digitally
SHEDRICK.CHARLES.JOSE.
RLES.JOSE.1125 1125538459
Date: 2024.04.02 10:33:16
538459
-05'00'

SUBJECT: Justification for the Use of Social Security Numbers (SSNs) in Department of
Defense (DoD) DD Form 2896-1, Reserve Component Health Coverage Request.
This memorandum is to satisfy the requirements of the Department of Defense
Instruction (DoDI) 1000.30, Reduction of Social Security Numbers (SSN) Use Within DoD,
dated August 1, 2012, requiring justification of the necessity for the collection and use of SSNs,
which includes the DD Forms 2896-1 (Attachments 1).
The forms collect Personally Identifiable Information (PII), including SSN, on
individuals seeking to enroll, change, or terminate their coverage in the TRICARE Reserve
Select and TRICARE Retired Reserve (TRS/TRR) health plans or change their PCM. The
TRS/TRR health plans are premium-based, health plans for Reserve, retired Reserve members,
their families and survivors as indicated within the Defense Enrollment Eligibility Reporting
System (DEERS). Individuals seeking to enroll or change their enrollment status in TRS/TRR
are requested to provide either their SSN or Defense Benefits Number (DBN) of the individual
applicant or their sponsor. Completed forms are sent to the appropriate regional managed care
support contractor (MCSC) to manage the enrolment status of the beneficiaries. Once the
MCSC inputs the information into DEERS, the information is later input into the MCSC’s
database.
As completed forms will be incorporated into a system of records, the applicable system
of records notice is Defense Manpower Data Center (DMDC) 02 DoD, Defense Enrollment
Eligibility Reporting Systems (DEERS) (May 31, 2022; 87 FR 32384). 1 The DMDC
previously approved a privacy impact assessment for DEERS and the DoD Information
Technology Portfolio Repository Identification Number is 1391. 2 Additional information about
how DEERS supports the Military Health System (MHS) is also publicly available on the
DMDC webpage. 3 The forms appear to be subject to the Paperwork Reduction Act (PRA), as
there is an Office of Management and Budget (OMB) Control Number – 0720.RCHC –
associated with the forms and a PRA statement is present on the forms. Further, the PRA
history and related information is publicly available. 4
https://www.federalregister.gov/documents/2022/05/31/2022-11610/privacy-act-of-1974-system-of-records
https://dwp.dmdc.osd.mil/dwp/api/download?fileName=DEERS_PIA.pdf&groupName=websiteDocuments
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https://dwp.dmdc.osd.mil/dwp/api/download?fileName=DEERS_MHS.pdf&groupName=websiteDocuments
4
PRA History of OMB Control No. 0720-0008: https://www.reginfo.gov/public/do/PRASearch
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2

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In accordance with DoDI 1000.30, Enclosure 2, continued use of SSNs within the form
must be justified by one or more of the Acceptable Use Cases. The applicable Acceptable Use
Cases are as follows:
Acceptable Use Case 2.c.(4), Interactions with Financial Institutions. Financial
institutions may require that individuals provide the SSN as part of the process to open
accounts. Therefore, providing the SSN may be required for systems, processes, or forms that
interface with or act on behalf of individuals or organizations in transactions with financial
institutions.
The information, including SSN, collected within the forms may be requested by the
financial institution to establish and validate the electronic payment method. Although the
TRS/TRR program accepts other forms of payment, monthly recurring allotment is mandate
where feasible as per the National Defense Authorization Act for Fiscal Year 2020, Section
702. For example, as monthly recurring allotment is not always feasible, premiums for
TRS/TRR may be paid by either credit card or electronic funds transfer through the applicant’s
financial institution on a monthly recurring basis. As such, the information, including SSN,
collected within the forms may be requested by the financial institution to establish and validate
the electronic payment method.
Acceptable Use Case 2.c.(11), Legacy System Interface. May systems, processes, or
forms that do not meet the criteria in subparagraphs 2.c.(1) through 2.c.(10) within Enclosure
two of the DoDI 1000.30 for the continued use of SSN may not be able to transition away to
another identifier in a timely manner due to an interface with a legacy system still using the
SSN, or due to the excessive cost associated with the change. In these cases, the continued use
of SSN may be acceptable for a specified period of time, provided that formalized, written
plans are in place for the migration away from the SSN in the future. Plans to alter these use
cases must account for interactions with other applications as well as all methods for entry,
processing, or transfer of information from said application. It is critical that transfer away
from the SSN does not cause unacceptably long interruptions to continued operations.
Information collected within the forms is entered into a legacy system, DEERS, using the
Defense Online Enrollment System (DOES) application, which has historically utilized the SSN
as the primary identifier. Although DOES currently uses both SSN and DBN as prime
identifiers, eliminating the collection and use of SSN is not feasible at this time because many
beneficiaries are unaware of their DBN, that the DBN exists, the DBN has not been added to
their DoD Identification (ID) Card yet, and some categories of beneficiaries (e.g., retired
members prior to June 1, 2011; permanently incapacitated dependents eligible for benefits prior
to June 1, 2011, and certain other former members eligible for retired pay and who were
discharged in lieu of transfer prior to June 1, 2011) do not have DBN on their Uniformed
Services ID Card. Although the DoD continues to make efforts to inform TRICARE
beneficiaries of their DBN and encourages the use of the DBN in lieu of SSN, some
beneficiaries are also unaware of the sponsor’s DBN. As such, although DBN is a potential
viable alternative to SSN, DBN is not always sufficient as the sole primary identifier on these
forms or in connection with the DOES application interface with DEERS. The MHS remains
dependent on the Unformed Services to implement the DBN on the Uniformed Services ID
Cards. Lastly, the forms owners are not responsible for DEERS, which is a legacy system that
may not have entirely eliminated the use of SSN.
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However, justification for the use of the SSN does not constitute blanket permission to
use the SSN. The forms may collect the DBN of an individual’s sponsor if known and
available and the forms do not collect SSN if not necessary (e.g., in Section II, Question 12a. –
12f.). The ability to provide the DBN, if available and known by the individuals, reduces the
vulnerability of SSN collection and use. As more fully described above, broader
implementation of the DBN by the Uniformed Services will further reduce the risk associated
with the forms. The owner of the forms will continue to take every reasonable step to reduce
the use of the SSN and protect it where the use is still required. For additional details as to the
elimination of the use of SSN, see the attached plan.
For questions related to this memorandum, please contact Mr. Brain Smith, who may be
contacted at (303) 676-3729 or [email protected].
Attachment:
(1) DD Forms 2896-1
(2) SSN Elimination Plan

HART.RICHARD.
C.1043267180

Digitally signed by
HART.RICHARD.C.1043267180
Date: 2024.02.21 13:32:29 -05'00'

Mr. Richard C. Hart
Chief, Health Plan Design Division
TRICARE Health Plan
Asst. Dir. for Healthcare Administration
Defense Health Agency

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