Public version of Exhibit C-3 — Brooks v. Thomson Reuters Corporation (Dkt. 153.3)

Record facts

U.S. District Court for the Northern District of California · No. 3:21-cv-01418-EMC · Doc. 153-3 · 2023-01-26 · Docket on CourtListener

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EXHIBIT C-3 
 
 
 
 
Case 3:21-cv-01418-EMC     Document 153-3     Filed 01/26/23     Page 1 of 4

60 million names. 
One CLEAR solution. 
How Thomson Reuters helped the federal 
government verify millions of identities and make 
the nation's healthcare system more secure. 
CONFIDENTIAL 
..... 
the answer companr 
ff:f: THOMSON REUTERS® 
·::::;~;• 
TR-BROOKS002051 
Case 3:21-cv-01418-EMC     Document 153-3     Filed 01/26/23     Page 2 of 4

It was a good system. 
For more than fifty years, federal healthcare recipients have received an identification 
card with their Social Security number printed on it, and that number has been used to 
track and process patient health benefits. 
But the world has changed, and Social Security numbers are no longer the most secure way to ensure the privacy 
of sensitive healthcare information - so the federal government acted. In response to growing concerns that cards 
containing Social Security numbers could make patients vulnerable to identity theft, Congress passed legislation 
requiring the agency responsible for managing those benefits to issue more secure cards no later than April 2019. 
To comply with the law, they developed a new card to replace the beneficiary's Social Security number with a 
randomly generated, 11-digit number unique to each person and unrelated to any of their other personal data. 
But getting those cards into the hands of patients meant mailing new cards to more than 60 million people. With 
such a large mailing, even a small percentage of error could result in benefit cards being sent to incorrect people, 
increasing the possibility of fraud. To ensure that the cards were sent to the correct people, the agency needed 
to verify the recipients' addresses. To accomplish this, the agency undertook what's known as a "data hygiene" 
project - a systemic data review that compares information in a pre-existing database against external data 
sources to certify that the information is correct. 
The agency knew that if it did not double-verify the addresses, several million new cards could end up being sent 
to the wrong address - and potentially into criminal hands - creating a whole new cycle of fraud-related problems. 
Fraudsters might try to abuse the new system as well, by submitting false claims for healthcare services or 
attempting to obtain illicit drug prescriptions. Even more worrisome, patients who did not receive their card in the 
mail might be denied healthcare coverage or vital services. 
The scale of the project was daunting as well because sending even a small percentage of cards to the wrong 
recipients could cost the federal government (i.e., taxpayers) several million dollars in postage alone, and 
potentially billions in fraud. 
Passing the test 
Verifying 60 million addresses is not a trivial undertaking. The agency itself has extensive resources, processes, 
and tools to check their data, but they wanted to add additional safeguards, so they looked to the private sector for 
help. To find a suitable data vendor, the agency set up a pilot test using 5,000 names from the master database. 
Three competing vendors were then asked to conduct data matches to verify each beneficiary's identity and 
address. 
To complete the test, Thomson Reuters used a version of its CLEAR"' investigative software configured to identify 
the recipient's name, date of birth, and last known address. The agency verified the matches by sending certified 
mail to each address and discovered that the Thomson Reuters results were superior to those of its competitors. 
The agency eventually awarded the government's contract to Thomson Reuters. 
Search, verify, repeat 
While winning the contract was undoubtedly good news for Thomson Reuters, it also meant that the team 
responsible had to immediately get to work scaling up the pilot-project system for the real thing: mailing new 
cards to 60 million Americans, many of whom rely exclusively on federal assistance to meet their healthcare 
needs. 
For this project, the agency needed a simple, efficient system to verify the identity and address of every individual 
who would be receiving a new card. They needed to confirm two pieces of information for every name on the list: 
1. Was the listed person the correct beneficiary? 
2. Was the most recent address listed for that person correct? 
If both the recipient's identity and address could be confirmed, a card could be mailed. If not, the card would need 
to be withheld until the recipient's information could be verified some other way. 
CONFIDENTIAL 
CASE STUDY 
The agency knew that if 
it did not double-verify 
the addresses, several 
million new cards could 
end up being sent to 
the wrong address -
and potentially into 
criminal hands ... 
TR-BROOKS002052 
Case 3:21-cv-01418-EMC     Document 153-3     Filed 01/26/23     Page 3 of 4

To accomplish the agency's goals, Thomson Reuters decided to use one of its new products, CLEAR ID Confirm®, 
a streamlined version of its award-winning CLEAR investigative software that enabled the agency to do what it 
wanted right out of the box. Users supply whatever information they have about a person (e.g., name, birth date, 
Social Security number) and CLEAR ID Confirm compares it against information contained in Thomson Reuters 
proprietary public-records databases to determine if there is a match. 
Since millions of names were involved, and time was of the essence, the initial output had to be as simple as 
possible. All the system had to do was answer one fundamental question. Mail the card? Yes or no. 
Unfortunately, the data was not stored in a format that could be easily imported into CLEAR ID Confirm - a 
common issue with legacy systems. To solve that problem, the Thomson Reuters team worked with the agency's IT 
staff to configure a way for the two systems to communicate. The result was an elegant workaround that made the 
data exchange more or less automatic, and was capable of verifying up to three million names a week. 
Working as partners 
Deciding what to do with the positive confirmations was easy: send them a card. The more significant problem 
resided in the "no" results. One way or another those unverified identities and addresses would need to be 
confirmed as well, but that would require some additional sleuthing. To help the agency complete its mission, a 
series of "reason codes" was developed to explain why specific names landed in the "no" results. 
This information turned out to be extremely valuable. As the project unfolded, the agency's data-analytics team 
began examining the reason codes to determine patterns and trends that might help them solve the second piece 
of the puzzle - how to turn more of those "no"s into "yes"s. 
Analysts and Data Scientists at Thomson Reuters also began reviewing the reason-code data, and soon the two 
teams partnered to devise ways to find or correct as much of the missing information as possible. Another benefit 
of this collaboration was the development of several improvements to the automated data-exchange system, 
which in turn led to a higher verification rate and greater efficiency as the project progressed. 
Success, ahead of schedule 
The agency began mailing out its new cards in April of 2018, and completed the mailings in January 2019, months 
ahead of its April 2019 deadline. Mailings were done three to five states at a time, and Thomson Reuters helped 
the agency stay on schedule by turning batch name verifications around in 24 hours in most cases, rather than the 
allotted 48. The new cards look like the old ones but do not contain a Social Security number, signature, gender, 
address, or any other information that an identity thief could use to commit fraud. 
The federal government's intent with these measures is to create a system less susceptible to fraud, waste, and 
abuse. More than $1.2 trillion in taxpayer dollars is paid out to healthcare beneficiaries every year, but not all that 
money ends up in the right hands. In 2017, the Government Accountability Office estimated that Medicare alone 
had recorded $52 billion in so-called "improper payments" (down from $95 billion in 2016), and that same year the 
Department of Justice prosecuted several large fraud cases, recovering more than $3.7 billion in ill-gotten gains. 
Not all improper payments are outright fraud - many are the result of billing errors, but the size and complexity 
of the federal healthcare system make it a favorite target for fraud nonetheless. Use of the new, more secure 
beneficiary cards will be mandatory as of January 1, 2020, after which the federal government will continue to 
monitor its processes for signs of misconduct. In the end, the agency helped ensure that as many of those new 
cards as possible found their way to the correct recipient and that the government itself is better prepared to 
combat fraud in the future. 
It was a good system. Now it is a better one. 
Learn more about Thomson Reuters fraud prevention solutions at tr.com/clear 
CASE STUDY 
Thomson Reuters 
decided to use one of its 
new products, CLEAR ID 
Confirm .. . that 
enabled the agency to 
do what it wanted right 
out of the box. 
The intelligence, technology 
and human expertise you need 
to find trusted answers. 
the answer companr 
THOMSON REUTERS® 
© 2079 Thomson Reuters TR951875/12-19 
CONFIDENTIAL 
TR-BROOKS002053 
Case 3:21-cv-01418-EMC     Document 153-3     Filed 01/26/23     Page 4 of 4

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