SSN justification memo

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

July 29, 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.CH Digitally
SHEDRICK.CHARLES.JO
ARLES.JOSE.1 SE.1125538459
Date: 2024.08.16
125538459 11:51:48 -05'00'

SUBJECT: Justification for the Use of Social Security Numbers (SSNs) on DD Form 2947,

TRICARE Young Adult (TYA) Application
This memorandum is to satisfy the requirements of the Department of Defense Instruction
(DoDI) 1000.30, SSN Use Within Department of Defense (DoD), dated August 1, 2012, that
requires justification of the collection and use of SSNs in DoD forms. This justification pertains to
DD From 2947, TRICARE Young Adult (TYA) Application (Enclosure 1).
The DD Form 2947, collects data, including SSN, on individuals seeking to enroll, change,
or terminate their coverage in TYA Prime and Select health plans. Individuals who are losing
regular TRICARE coverage under the Military Health System (MHS) may apply for TYA at the
age of 21 (age 23 if previously enrolled in a full-time course of study at an institution of higher
learning) until reaching age 26, if not married and not eligible for employer-sponsored medical
coverage. Each individual seeking to enroll in or change their enrollment status in TYA is
requested to provide either the SSN or Defense Benefits Number (DBN) of the individual
applicant and the sponsor.
The completed DD Form 2947 is sent to the Private Sector Care Support Contractor
(PSCSC) to manage enrollment status of the beneficiaries. The PSCSC will first put the
information from the DD Form 2947 into the Defense Enrollment Eligibility Reporting System
(DEERS) using the Defense Online Enrollment System (DOES) web-based application. The
information is then manually input into the PSCSC database. The system of records notice
applicable to DD Form 2947 is DMDC 02 “Defense Enrollment Eligibility Reporting Systems
(DEERS).”
In accordance with DoDI 1000.30, continued use of SSNs within DD 2947 must be
justified by one or more of the Acceptable Use Cases set forth in DoDI 1000.30, Enclosure 2. The
Acceptable Use applicable to TYA are as follows:
Acceptable use 2.c.(4) Interactions with Financial Institutions applies because financial
institutions may require that individuals provide the SSN as part of the process to open accounts. It
may therefore be required to provide the SSN for systems, processes, or forms that interface with
or act on behalf of individuals or organizations in transactions with financial institutions.
The premiums for TYA are paid on a monthly recurring basis either through credit card or
electronic funds transfer through the applicant’s financial institution. The TYA program does not
accept any other form of payment. The information collected on the DD Form 2947, including the
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SSN, may be requested by the financial institution to establish and validate the electronic payment
method. As such without the provision of the SSN, TYA premiums cannot be paid upon
enrollment. Of note, though not established through the form, recurring electronic payments may
be set up for premiums thereafter.
Acceptable use 2.c.(11) Legacy System Interface applies because many systems, processes,
or forms that do not meet the criteria in subparagraphs 2.c.(1) through 2.c.(10) of this enclosure for
the continued use of the SSN may not be able to transition 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 the SSN may be acceptable for a specified
time period, 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 consider 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. Also, information collected through DD Form 2947 is input into DEERS
through the DOES application, which has historically used the SSN as the primary identifier.
Though applicants may use their DBN as their primary identifier on the form, removing the SSN
as an option is not feasible at this time. While many beneficiaries are aware of their DBN due to
the phase out of SSNs on DoD identification cards, there are still beneficiaries unfamiliar with
their DBN, or unaware that one exists because it has not been added to their DoD identification
card yet. However, these individuals will know their SSN, or the SSN of the family member being
enrolled. The following beneficiary categories don’t have DBNs on their Uniformed Services ID
Card;
•
•
•
•

Retired Members who retired prior to June 1, 2011 may still be in possession of a DD
Form 2 (Retired) with an INDEF expiration date that displays their SSN.
Permanently incapacitated dependents who became eligible for benefits prior to June 1,
2011 and were issued an ID card with an INDEF expiration date may still be in possession
of an ID card that displays their SSN.
All dependents who turned 75 prior to June 1, 2011 and were issued an ID card with an
INDEF expiration date may still be in possession of an ID Card that displays their SSN.
and
Former members who are eligible for retired pay and elect discharge in lieu of transfer to
the reserve retired list prior to June 1, 2011, and have not yet turned age 60, may still be in
possession of a DD Form 2 (Reserve Retired) with an INDEF expiration date that displays
their SSN.

Until such time as all beneficiaries are informed and aware of their DBN, the SSN will
continue to be needed on DD Form 2947 in order to verify identity. The DBN was created as a
long-term replacement for the SSN, but it has been always understood that until all ID cards have
been updated, we would continue to accept collection of the SSN as an alternative. The MHS
cannot mitigate the lack of the DoD Benefits Number on Uniformed Services ID Cards – only the
military personnel community can.
Even if the ID cards do contain a DBN, DoD Instruction 1000.13, Enclosure 3, paragraph
1.g. states “ID cards shall be retrieved by the sponsor or sponsoring organization when the ID card
has expired, when it is damaged or compromised, or when the card holder is no longer affiliated
with the DoD or no longer meets the eligibility requirements for the card.” Because applicants
have up to the age of 26 after the loss of TRICARE eligibility at the age of 21 or 23 (if a full time
student at an approved institution for higher learning) for military medical benefits to apply for
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TYA coverage, it is possible that the individual’s ID card that contained the DBN was turned in by
the sponsor at the time the family member loss eligibility. Therefore, the applicant may no longer
have access to the DBN if the applicant is no longer in physical possession of an ID card that
would provide evidence of an individual’s DBN.

The DHA Component/Office point of contact for this program is Ms. Debra Fisher, who
may be contacted at (703) 275-6224 or [email protected].

HART.RICHARD
.C.1043267180

Digitally signed by
HART.RICHARD.C.1043267180
Date: 2024.08.08 07:52:58 -04'00'

RICHARD C. HART
Chief, Health Plans Design
DHA, TRICARE Health Plans
[email protected]
Enclosures:
As stated

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