ACTION MEMO

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

April 20, 2026
MEMORANDUM FOR THE DEFENSE PRIVACY, CIVIL LIBERTIES, AND FREEDOM OF
INFORMATION DIRECTORATE
THROUGH: Defense Health Agency Privacy and Civil Liberties Office SHEDRICK.CHARLES
.JOSE.1125538459

Digitally signed by
SHEDRICK.CHARLES.JOSE.11255384
59
Date: 2026.08.04 12:21:23 -05'00'

SUBJECT: Justification for the Use of Social Security Numbers in Department of War DD Form 2837,
Continued Health Care Benefit Program Application
This memorandum is to satisfy the requirements of the Department of War Instruction (DoDI)
1000.30, Reduction of Social Security Numbers (SSN) Use Within Department of War (DoW), dated
August 1, 2012, that requires justification of the necessary collection and use of SSNs in DoW forms,
which includes the DD Form 2837, Continued Health Care Benefit Program (CHCBP) Application
(Attachment 1).
DD Form 2837 collects Personally Identifiable Information (PII), including SSN, on individuals
seeking to enroll, or change their enrollment category in the CHCBP. Individuals who are losing health
care coverage under the Military Health System (MHS) may apply for individual or family coverage for
18 to 36 months. Individuals seeking to enroll or change their enrollment status in CHCBP are requested
to provide either their SSN or Department of Defense Benefits Number (DBN) of the individual
applicant or their sponsor.
The completed form is sent to the CHCBP contractor to manage the enrollment status of the
beneficiaries. The contractor inputs the information from the form into the Defense Enrollment
Eligibility System (DEERS) using the Defense Online Enrollment System (DOES) application, the
information is then manually input into the contractor database.
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
privacy impact assessment (PIA) for DEERS was approved on December 2, 2015. The DoD Information
Technology Portfolio Repository (DITPR) 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
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 to CHCBP
are as follows:
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
3
https://dwp.dmdc.osd.mil/dwp/api/download?fileName=DEERS_MHS.pdf&groupName=websiteDocuments
1
2

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.
Premium Payments for the CHCBP are required and Acceptable Use Case 2.c(4) permits SSN
collection where it may be required to interact with financial institutions. DD Form 2837 only records
the initial premium payment for CHCBP applicants, which is required to be made by check or money
order. Though not established through the form, recurring electronic payments may be set up for
premiums thereafter. The information collected on the form, including the SSN, may be requested by the
financial institution in order to establish the electronic payment.
Acceptable Use Case 2.c.(11), Legacy System Interface. Many 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 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.
Also, information collected through the DD 2837 is entered into a legacy system, DEERS, using
the DOES application, which has historically utilized the SSN as the primary identifier. Although
applicants may use their Defense Benefits Number (DBN) as their primary identifier on the form,
eliminating the collection and 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 DoW identification cards (ID),
there are still beneficiaries unfamiliar with their DBN, or unaware that one exists because it has not been
added to their DoW 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 indefinite (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.

• 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 2837 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 DoW Benefits Number on Uniformed Services ID Cards– only the military personnel community
can.
Even if the ID cards do contain an DBN, DoDI 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 DoW or no longer
meets the eligibility requirements for the card.” Because applicants have up to 60 days after the loss of
all eligibility for military medical benefits to apply for CHCBP coverage, it is possible that the
individual’s ID card that contained the DBN was turned in by the sponsor at the time of separation
processing or for loss of eligibility for a family member, at the time the family member lost eligibility.
So, it could well be the applicant may no longer have access to the DBN if they are no longer in physical
possession of an ID card that would provide evidence of an individual’s DBN.
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.
The Defense Health Agency Component/Office point of contact for this program is Ms. Debra
Fisher, who may be contacted at (703) 275-6224 or [email protected].

Attachment:
(1) DD Forms 2837
(2) SSN Elimination Plan

DANITA F. HUNTER, PhD, PMP
Chief, Policy & Programs Branch
TRICARE Health Plan