FR 2021-02002

The document titled "Privacy Act of 1974; Matching Program," published in the Federal Register, provides a notice of a new Computer Matching Agreement (CMA) between the U.S. Department of Education (ED) and the Department of Defense (DoD). This CMA aims to identify children of military service members who have died in Iraq or Afghanistan after September 11, 2001, to determine their eligibility for increased financial aid under the Higher Education Act. The agreement is set to be effective from March 1, 2021, and will last for 18 months, with a possible extension for an additional 12 months.

Summary of the Document

The CMA serves a crucial purpose by simplifying the process of identifying qualifying students eligible for enhanced educational assistance. By utilizing shared data elements such as Social Security Numbers and birth dates, the ED and DoD can efficiently verify and match records of children who may benefit from the program. The document outlines procedures for submitting public comments before the CMA becomes effective and provides guidelines for accessing related governmental documents online.

Significant Issues and Concerns

While the document outlines the basic framework of the CMA, there are some notable gaps and concerns:

1. Expenditure Transparency: The notice does not detail the specific costs associated with implementing the program. This omission makes it challenging for the public to assess whether it is a prudent use of resources or if there is potential for wasteful spending.

2. Data Privacy and Security: The document lacks a comprehensive explanation of the measures in place to prevent the potential misuse or mismanagement of shared data. As sensitive personal information is involved, the public might have valid concerns over privacy and data protection.

3. Verification Efficiency: The language claims that the matching program provides an efficient method for verification, but it does not elaborate on the mechanisms used to ensure accuracy and efficiency. Greater transparency in describing these processes would be beneficial.

4. Complexity of Comment Submission: The instructions for submitting comments on the proposed CMA are wordy and potentially confusing for individuals unfamiliar with regulatory procedures. Making these instructions more straightforward would help improve public engagement.

5. Privacy Note Instructions: The privacy note advises commenters to be cautious but lacks practical steps on how they can protect their personal information effectively when commenting.

6. CMA Expiration and Recertification: The document briefly mentions the expiration and potential recertification of the CMA but does not provide an in-depth explanation of this process, which could be unclear to laypersons.

Impact on the Public

Overall, the CMA could have a positive impact by enabling eligible students to receive more significant financial aid, thus aiding in their educational pursuits. However, the document's lack of clarity in certain areas may lead to public confusion or skepticism, particularly concerning privacy implications.

Impact on Specific Stakeholders

• Military Families: The agreement is directly beneficial to children of military families who lost a parent in service. It potentially opens up greater educational opportunities by providing increased financial assistance.

• Educational Institutions: Colleges and universities may see an uptick in applications from eligible students seeking financial aid, highlighting the importance of clear and efficient processing by educational bodies.

• Privacy Advocates: Organizations concerned with data privacy may raise issues regarding the protection of sensitive personal information and the adequacy of safeguards in place, owing to the gaps in the document.

In conclusion, while the CMA presents a promising opportunity to assist deserving students, attention needs to be given to how the agreement is communicated and implemented to address financial transparency, data privacy, and public engagement effectively.