Privacy Impact Assessment

SYSTEM OR APPLICATION NAME: Palmetto GBA/RRB Interface 

DATE: July 14, 2009 

SYSTEM OWNER & TITLE: Ronald Russo, Director of Policy and Systems 

CONTACT POINT: Eileen A. Binkus, Policy and Systems Analyst 

ORGANIZATION: Office of Programs – Policy and Systems 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago, IL 60611-2092 

REVIEWING OFFICIAL NAME & TITLE Patricia Henaghan 

Chief of Information Resources Management 

ORGANIZATION: Bureau of Information Services 

Information Resources Management Center 

U.S. Railroad Retirement Board 

844 North Rush Street 

Chicago, IL 60611-2092 

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SYSTEM OR APPLICATION NAME: Palmetto GBA/RRB Interface 

DATE: JULY 14, 2009 

Overview 

The Railroad Retirement Board (RRB) administers the retirement /survivor benefit program under the 

Railroad Retirement Act (RRA). Under section 7(d) of the RRA, the RRB administers the Medicare 

program, i.e. Title XVIII of the Social Security Act, for persons covered by the railroad retirement system. 

Palmetto GBA, the RRB’s Part B Medicare carrier for individuals with Original Medicare, receives 

inquiries and reports from railroad retirement beneficiaries each day in the course of their regular 

communication with beneficiaries who file Part B Medicare claims. Beneficiaries contact Palmetto to 

report address changes and beneficiary deaths, and to request replacement Medicare cards. In the past, 

Palmetto would refer such callers to their RRB field office. This required the beneficiary to make another 

call. In some cases, the beneficiary would fail to make the call to the RRB to report an address change. 

The Palmetto GBA application was developed to allow Palmetto customer service representatives 

(CSRs) to report the following directly to the RRB: 

• Beneficiary address changes, 

• Beneficiary dates of death, and 

• Requests for replacement Medicare cards 

The Palmetto GBA application is a secure application accessed through the internet by authorized 

Palmetto GBA customer service representatives. Access to the application is controlled by assigned 

user IDs and self-assigned passwords. 

Palmetto CSRs first verify the identity of the caller in accordance with guidelines issued by the Centers 

for Medicare & Medicaid Services (CMS). The guidelines are included in the Disclosure Desk Reference 

for Call Centers, which is in CMS’s Medicare Contractor Beneficiary and Provider Communications 

Manual, Chapter 2 – Beneficiary Customer Services) 

http://www.cms.hhs.gov/manuals/downloads/com109c02.pdf. The CSR then accesses the Palmetto 

application through a secure link on www.rrb.gov to report an address change or a beneficiary death, or 

to request a replacement Medicare card. Palmetto CSRs follow procedures prescribed by the RRB to 

access and complete the appropriate transaction screen. Transactions entered by Palmetto CSRs are 

available for processing the next business day by field offices. 

Section 1.0 – The Nature of the lnformation in the System and Its Source 

We use our Palmetto GBA contractor to provide Medicare customer support services for our 

Beneficiary’s who need to: 

• Change the address 

• Request a new Medicare Card 

• Report the date of death for a beneficiary 

In order for Palmetto GBA to process your request, the CSRs need to obtain identifying information about 

the beneficiary such as: 

Beneficiary change of address transactions involve the collection and use of the following information 

from the railroad retirement beneficiary: 

• Claim number with prefix, 

• First name, initial and last name, 

• Telephone number, and 

PRIVACY IMPACT ANALYSIS - PAGE 2 OF 6 G-514 (7-09) 
• New address, including city, state and ZIP Code. 

Requests for replacement Medicare cards involve the collection and use of the following information from 

the beneficiary: 

• Claim number with prefix, 

• Beneficiary’s social security number, 

• Telephone number, 

• First name, initial and last name, and 

• Zip Code 

To report a beneficiary’s date of death, the following information is collected and used: 

• The beneficiary’s claim number with prefix, 

• The beneficiary’s first name, initial and last name, 

• The beneficiary’s date of death, 

• Contact’s name (who reported the death), 

• Contact’s relationship to the deceased, 

• Contact’s e-mail address, 

• Contact’s address, including city, state and ZIP Code, and 

• Contact’s telephone number 

Section 2.0 -- The Uses of the Information 

We collect this information in order to provide for Medicare support services for you. Our authority to 

collect and use this information comes from the Railroad Retirement Act, section 7(d) (45 U.S.C. § 

231f(d)), Title 18 of the Social Security Act (Medicare) (42 U.S.C. § 1395), RRB’s Privacy regulations (20 

C.F.R. § 200.5) and SSA’s Privacy regulations (20 C.F.R. § 401.) 

Section 3.0 – Retention of Information 

We base our need to retain information on what is required to provide the service for which it is collected. 

The National Records and Archives Administration reviews and approves our retention schedules. When 

the information is no longer required, we securely dispose of it. 

Section 4.0 -- Internal Sharing and Disclosure of Information 

Sensitive information that we store and process to provide Medicare support services is shared internally 

only to those authorized RRB staff members that have a valid business requirement for it. We have 

established security and privacy policies and procedures, awareness training programs and rules that our 

staff must follow when using our systems and accessing sensitive data. Our rules also cover what is 

required to disclose information and the penalties for improper disclosure. 

Section 5.0 -- External Sharing and Disclosure of Information 

We only share information as required to provide for the timely and accurate processing of Medicare 

support requests. Our Privacy Act Systems of Records Notices outline what information we routinely 

share with other agencies or organizations. 

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Section 6.0 – Notice

We publish our Privacy Act Systems of Records Notices both in the Federal Register and on our web site 

(http://www.rrb.gov/bis/privacy_act/SORNList.asp). 

These notices explain: 

• What system collects and uses the information; 

• What information is collected; 

• Under what routine uses we may release that information; 

• How we store, retrieve, retain and safeguard that information; 

• What RRB official is the manager of that system; 

• The procedures to follow if you want to see or request corrections made to any information that 

system may have about you. 

We also publish a Privacy Act Notice and a Paperwork Reduction Act Notice on any form that we use to 

collect personal information from you. 

The Palmetto GBA system uses information that is collected and used as outlined in the Privacy Act 

System of Records Notices (SORN) listed here: 

RRB-3....Medicare, Part B 

RRB-20...Health Insurance and Supplementary Medical Insurance 

 Enrollment and Premium Payment System (Medicare) 

RRB-22...Railroad Retirement, Survivor, and Pensioner Benefit 

 System 

We only share that information needed to provide and manage your benefits with those RRB staff 

members or other organizations that we listed under our routine disclosures in our Privacy Act Systems 

of Records Notice on a strict need-to-know basis. We have management, operational and technical 

control safeguards in place to mitigate risks to information you provide us. 

Section 7.0 -- Individual Access and Redress 

If you wish to review or request a change to the records and benefits that we maintain on you, please 

contact the nearest RRB field office for assistance. 

You may also file a request for information regarding your records in writing, including your full name, 

social security number and railroad retirement claim number (if any). Before information about any 

records will be released, you will be required to provide proof of identity, or authorization from the 

individual you are requesting records for. Send your request to Office of Programs—Director of 

Operations, Railroad Retirement Board, 844 Rush Street, Chicago, Illinois 60611-2092. 

You may also request reconsideration of any adverse determination based on information we used in 

determining your eligibility or payment for claims. We include instructions on how to file a request for 

reconsideration in all of our letters of determination. If you are not satisfied with the results of the review, 

you have the right to pursue a defined appeals process, which we explain in the reconsideration decision 

notice. 

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Section 8.0 -- Technical Access and Security 

Our greatest privacy risk is unauthorized access or modification of records containing sensitive 

information. We mitigate this risk by following Federal security and privacy guidance and directives. An 

independent contractor evaluated the Palmetto GBA system as part of its Certification and Accreditation 

process to ensure we are compliant with the appropriate security standards. 

We provide security and privacy awareness training annually to all agency system users. Before 

granting access to the Benefit Payment Operations system, new users receive training on proper use of 

the system and protecting the confidentiality of the data. We also require our users to receive additional 

training from other Federal Agencies (Social Security Administration and Centers for Medicare and 

Medicaid Services) if they are accessing information that is owned by those agencies. 

Before we grant or modify access to the Benefit Payment Operations system, our management reviews 

the request and approves it if the employee or contractor requires that level of access to perform their 

assigned job duties. Once approved by management, they forward the request to our network access 

control staff, which assigns the appropriate roles and security profile for that authorized user. We use 

established role based access control rules and follow the procedures outlined in our internal agency 

operating manual. 

We use extensive technical measures in order to provide both electronic and physical defense-in-depth 

protection for your information. Some of our safeguards are: 

 Internal policies and training addressing proper handling of sensitive information 

 Limiting access to those staff members who have a business requirement to that information 

 Information systems secured in accordance with Federal Law, National Institute of Standards and 

Technology (NIST) and other Executive Agency guidance and directives. 

 Role based access controls used to control access to electronic data records and applications 

enforcing need to know and least privilege policies 

 Transaction histories are maintained to track any changes to an individuals record 

 Encryption of all data on systems that are located outside of RRB facilities, and on our notebook 

computers 

 Encryption of all data that transits to or from the RRB network 

 Secure disposal of electronic media when it is no longer required 

 Logging of local, network, mainframe and database usage 

 In-Depth electronic security monitoring and incident response technologies and dedicated security 

staff 

 Systematic data backups performed with the backup media securely transported to, and stored at a 

Federal records holding center. 

Section 9.0 – Technology 

We validated that the applications that we use to interface with Palmetto GBA, meets all current Federal 

guidelines and directives via independent evaluation. Additionally, our Privacy and Security staff review 

all information system proposals in accordance with the E-Government Act of 2002 (Public Law 107-347) 

and Office of Management and Budget directives. 

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Conclusion 

We use our contractor, Palmetto GBA, to provide customer services for requests for Medicare address 

changes, duplicate cards and notification of a beneficiary’s death. 

We take our obligation seriously to protect the data that we use to provide benefit services to our railroad 

workers. We do this by complying with Federal information and privacy laws, directives and guidance; by 

providing technical network defenses in depth; and by having established management and operational 

controls in place to manage our information systems. 

Certification of Responsible Officials 

Preparer Signature & Title Eileen Binkus 

Policy and Systems Analyst 

System Owner Signature Ronald Russo 

Director of Policy and Systems 

Approved Signature & Title Patricia Henaghan 

Chief of Information Resources Management Center 

PIA Control Number PIA-20090714-001 

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