SSN Justification

OFFICE OF THE ASSISTANT SECRETARY OF DEFENSE

HEALTH AFFAIRS

SKYLINE FIVE, SUITE 810, 511 1 LEESBURG PIKE

FALLS CHURCH, VIRGINIA 2204 1-3206

March 2, 2011
TR ICARE

MANAGEMENT

ACTIVITY

MEMORANDUM FOR THE RECORD
SUBJECT: Justification for the Use of the Social Security Number (SSN) for
TRICARE Young Adult Application Form
This memorandum is written to satisfy the requirement established in the Office of
Under Secretary of Defense (OUSD) Personnel and Readiness (P&R) Directive-Type
Memorandum 07-0 15-USD (P&R), "DoD Social Security Number (SSN) Reduction
Plan" (DTM 07-015), that requires justification of the collection and use of the SSN on
department forms. This justification pertains to the proposed TRICARE Young Adult
Application is included as Attachment A.
The TRICARE Young Adult Application form used to collect personally
identifiable information (PH) is covered by System of Records Notice DMDC 02 DoD,
Defense Enrollment Eligibility Recording System (DEERS) (August 7,2009, 74 FR
39657), as a Privacy Act of 1974, as amended, system of records pursuant to DoD
5400.11-R, "Department of Defense Privacy Program," May 14,2007. DMDC 02 is
included as Attachment B
The TRICARE Young Adult Application is a proposed DoD beneficiary
completed form to relay their intent to purchase, change or terminate their coverage in the
TRICARE Young Adult (TY A) Program. Regional Managed Care Support Contractors
(MCSCs) are required to use information contained on the form to enter the information
into DEERS (Defense Online Enrollment System [DOES] application) that will reflect
the beneficiary-requested enrollment status. Historically, the SSN has been the primary
identifier to effect an enrollment on the DOES application and this is the current process
in use. The Defense Manpower Data Center (DMDC) Privacy Impact Assessment (PIA)
for DEERS, dated 15 December 2006, and the Paperwork Reduction Act Submission
with respect to the proposed TY A application form are included as Attachments C and D,
respectively.
DTM 07-015, Attachment I, Paragraph 2.c.(11), includes "Legacy System
Interface" as an acceptable use of the SSN so long as there are plans in place for the
migration away from the SSN in the future. The documents and discussion below sets
forth why the SSN still needs to be currently collected on the TRICARE Young Adult
form due to legacy system interface and also details plans that will allow migration away
from collecting SSNs on these forms in the future.

TMA has an SSN Reduction Plan for its Purchased Care Operations dated April
22,2010 (copy included as Attachment E). The TMA Plan is in-line and consistent with
the November 5, 2010 Under Secretary of Defense, Personnel and Readiness
Memorandum titled "Updated Plan for the Removal of Social Security Numbers (SSNs)
from Department of Defense (DoD) Identification (ID) Cards" (Attachment F).
Starting in January 2011, visibly printed SSNs will be removed from DoD ID
Cards. Two new codes (alternative ID numbers) will be printed on the ID Card - the
DoD Benefits Number (DBN) and the Electronic Data Interchange- Personnel Identifier
(EDI-PI). While both of these codes currently exist, they are not known to DoD
beneficiaries. Once they are visibly printed on the ID Card, they will be readily available
to and known by DoD beneficiaries. The ID Card life cycle is such that it will be a 3-4
year process before alternative ID numbers replace the visibly printed SSN on the card.
Because TRICARE Young Adult is a premium-based health plan, young adult
dependents must purchase TRlCARE Young Adult coverage and then can request an ID
card be issued. At the time of initial application, they are only aware of the SSN as the
primary identifier. Upon purchasing TRICARE Young Adult coverage, an ID card can
then be requested by the young adult dependent through the normal ID card processes.
At that point, the DBN will be on the ID card and can be used as a primary identifier.
The regional MCSCs (whose systems and interfaces are part ofTMA's purchased
care operations), were notified in the fall of 20 10 to be prepared to begin using a work­
around process to query DEERS eligibility using the DBN. Future actions include
modification of the TRICARE Systems Manual (TSM) to ultimately require MCSCs to
modify their systems to include free-standing DBN and EDI-PI data fields in addition to
data fields for the SSN. A final timeline for development of the TSM instructions,
coordination, publication, direction to contractors, and contractor implementation time is
not yet definitized, but activities will likely be finalized in the next 24 months.
Based on the above, the SSN still needs to be collected on the TRICARE Young
Adult application form until DoD beneficiaries are cognizant of alternate identifiers and
where to find them in order to input these numbers on an enrollment form instead of the
SSN. This will logically occur when the SSN is visibly replaced on the DoD ID Card
with the alternate identifiers. As indicated above, this process began in January 2011 and
will be a 3-4 year process.
When the required renewal for the TRICARE Young Adult Application form
occurs again in three years, the agency will make a recommendation regarding inclusion
of the DBN as a new field on enrollment forms to be used in lieu of the SSN. At this
time, beneficiaries (who complete the form) will be more knowledgeable about what this

number is and where to find it and contractor's purchased care systems will have been
modified to include free-standing alternate identification numbers.
TRICARE Young Adult Forms are secured to protect PH in accordance with DoD
Regulations.
If there are any questions, my point of contact is Mr. Mark Ellis, (703) 681-0039.

Mr. Michael O'Bar
Deputy Chief
TRICARE Policy & Operations
Attachments

COORDINATION
TMA,OGC

Mr. Paul Bley

TMAlPrivacy and Civil Liberties Office

Ms. Leslie Shaffer