No. An MOA and an MOU cannot be used in place of a DSA.  Pursuant to Department of Defense Instruction (DODI) 4000.19, Support Agreements, an MOU and MOA are types of support agreements to be used as explained in DODI 4000.19. A DSA is a Defense Health Agency (DHA) Privacy and Civil Liberties Office (PCLO) administrative control used to document that the request for data managed by DHA (DHA data) complies with federal privacy laws and DOD privacy issuances. Researchers and government contractors as well as public health officials or agents seeking to use DHA data must submit a Data Sharing Agreement Application regardless of whether they have a support agreement that is an MOU or MOA.