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United States Government Accountability Office: 
GAO: 

Report to Congressional Committees: 

February 2015: 

Defense Health Care: 

Better Tracking and Oversight Needed of Servicemember Separations for 
Non-Disability Mental Conditions: 

GAO-15-266: 

GAO Highlights: 

Highlights of GAO-15-266, a report to congressional committees. 

Why GAO Did This Study: 

Non-disability mental conditions, such as personality disorders, can 
render a servicemember unsuitable for military service and can lead to 
an administrative separation. GAO was mandated to report on non-
disability mental condition separations. This report examines the 
extent to which (1) DOD and the military services are able to identify 
the number of enlisted servicemembers separated for non-disability 
mental conditions, and (2) the military services are complying with 
DOD requirements when separating enlisted servicemembers for non-
disability mental conditions, including personality disorders, and how 
DOD and the military services oversee such separations. GAO analyzed 
DOD and the military services’ separation policies, policies related 
to tracking separations, reports the military services submitted to 
DOD regarding compliance with separation requirements, and interviewed 
DOD and military service officials. 

What GAO Found: 

The Department of Defense (DOD) and three of the four military 
services—Army, Navy, and Marine Corps—-cannot identify the number of 
enlisted servicemembers separated for non-disability mental 
conditions—-mental conditions that are not considered service-related 
disabilities. For most non-disability mental condition separations, 
these services use the broad separation code, “condition, not a 
disability,” which mixes non-disability mental conditions with non-
disability physical conditions, such as obesity, making it difficult 
to distinguish one type of condition from the other. In contrast, the 
Air Force is able to identify such servicemembers because it uses all 
five of the separation codes specific to non-disability mental 
conditions. DOD policy requires the military services to use a 
separation code so that DOD can track and analyze separations. 
Moreover, federal standards for internal control state that all 
transactions need to be clearly and accurately documented and readily 
available for examination when needed. The three services had varying 
reasons as to why they use the broad separation code. For example, 
Army officials believed that stating in servicemembers’ discharge 
papers that they were discharged for non-disability mental conditions 
might stigmatize them with future employers. However, DOD stated that 
there are ways to protect servicemembers in this regard by providing 
them with discharge papers that are more general and that do not 
disclose specific reasons for discharge. By not systematically 
identifying or periodically evaluating the number of separations for 
non-disability mental conditions, DOD and the services cannot assess 
how well the separation policy and process are working or inform key 
stakeholders, including the Congress, about separation frequency, 
trends, and other data. 

The military services lack separation policies that address all of 
DOD’s eight requirements for separating servicemembers with non-disability 
mental conditions; both DOD and the services also lack oversight over 
such separations. From fiscal years 2008 through 2012, DOD required 
the services to report on their compliance with DOD requirements for 
personality disorder separations, one of the non-disability mental 
conditions. Most of the services reported by fiscal year 2012 that 
they were not compliant with all eight requirements and many of the 20 
reports contained incomplete and inconsistent information. For 
example, 19 reports were missing information on reserve members. DOD 
discontinued these reports and did not institute any other oversight, 
which is inconsistent with the internal control standard for 
monitoring. GAO also found, based on a review of the services’ 
separation policies, that the services have not updated their policies 
to meet all DOD requirements for non-disability mental condition 
separations. For example, Navy officials stated that they were unaware 
that DOD separation policies had changed since 2008 until GAO’s 
review. DOD officials stated that the military services are 
responsible for conducting oversight of their separation processes; 
however, GAO found that the military services do not have processes to 
oversee non-disability mental condition separations. Without up-to-
date and consistent policies and oversight processes, DOD and the 
military services cannot ensure that servicemembers separated for non-
disability mental conditions have been afforded the protections 
intended by DOD’s separation requirements and that servicemembers have 
been appropriately separated for such conditions. 

What GAO Recommends: 

GAO recommends that DOD and the military services develop a method to 
identify the number of servicemembers separated for non-disability 
mental conditions and take a number of actions to ensure that their 
policies and processes can ensure that servicemembers are 
appropriately separated for non-disability mental conditions in 
accordance with DOD’s separation requirements. DOD generally concurred 
with GAO’s recommendations, but did not provide information on how or 
when it plans to implement the recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-15-266]. For more 
information, contact Randall B. Williamson at (202) 512-7114 or 
williamsonr@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

DOD and Three of the Four Military Services Cannot Identify the Number 
of Enlisted Servicemembers Separated for Non-Disability Mental 
Conditions: 

Military Services' Separation Policies Do Not Address All DOD 
Requirements for Non-Disability Mental Conditions Separations, and DOD 
and the Services Lack Oversight of Such Separations: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Eligibility of Servicemembers Separated for Non-Disability 
Mental Conditions for Veterans' Health Benefits: 

Appendix II: Comments from the Department of Defense: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Changes to Department of Defense (DOD) Separation 
Requirements for Non-Disability Mental Conditions, August 2008 to 
January 2014: 

Table 2: Examples of Inconsistent Data Reported in the Army and the 
Navy Annual Compliance Reports on Separations of Servicemembers for 
Personality Disorders: 

Figure: 

Figure 1: Eligibility of Servicemembers Administratively Separated for 
Non-Disability Mental Conditions to Receive Health Care Benefits from 
the Department of Veterans Affairs (VA): 

Abbreviations: 

DOD: Department of Defense: 

IDP: imminent danger pay: 

JAG: Judge Advocate General: 

PTSD: post-traumatic stress disorder: 

NDAA: National Defense Authorization Act: 

VA: Department of Veterans Affairs: 

[End of section] 

United States Government Accountability Office: 
GAO:
441 G St. N.W. 
Washington, DC 20548: 

February 13, 2015: 

The Honorable John McCain: 
Chairman: 
The Honorable Jack Reed: 
Ranking Member: 
Committee on Armed Services: 
United States Senate: 

The Honorable Mac Thornberry: 
Chairman: 
The Honorable Adam Smith: 
Ranking Member: 
Committee on Armed Services: 
House of Representatives: 

The Department of Defense (DOD) requires that all servicemembers be 
physically and psychologically suitable for military service. DOD 
policy permits an enlisted servicemember to be involuntarily separated 
from the military if the servicemember's mental condition is severe 
enough that it interferes with the servicemember's ability to function 
in the military.[Footnote 1] Servicemembers diagnosed with a mental 
condition may be eligible to receive disability compensation benefits 
from the Department of Veterans Affairs (VA) if the mental condition 
was incurred or aggravated while the servicemember was on active duty, 
such as developing post-traumatic stress disorder (PTSD) related to 
combat. However, if the mental condition is not incurred or aggravated 
while on active duty, it is not considered a service-related 
disability by DOD and VA; in other words, it is considered a non-
disability mental condition. 

Servicemember separations from the military for non-disability mental 
conditions are processed as administrative separations, and DOD has 
requirements that the military services--Army, Air Force, Navy, and 
Marine Corps--must follow when processing these separations.[Footnote 
2] DOD's current processing requirements apply to separations for all 
non-disability mental conditions;[Footnote 3] however, prior to 2011, 
most of the department's requirements only applied to separations for 
one type of non-disability mental condition--personality disorder, 
which is defined as a long-standing, inflexible pattern of behavior 
that deviates markedly from expected behavior, has an onset in 
adolescence or early adulthood, and leads to distress or impairment. 

In 2008, we conducted a review of records of enlisted servicemembers 
who had served in Operation Enduring Freedom or Operation Iraqi 
Freedom and had been separated from the military because of a 
personality disorder.[Footnote 4] We found that DOD and the military 
services did not have adequate oversight to ensure that separation 
requirements were being adhered to when servicemembers were separated 
for personality disorders. We made recommendations to improve DOD's 
and the military services' oversight of such separations. As a result 
of our review, in January 2009, DOD required the military services to 
annually review a sample of personality disorder separations to 
determine whether DOD separation requirements were being followed and 
to report the results to DOD. 

The National Defense Authorization Act (NDAA) for Fiscal Year 2014 
mandated GAO to examine issues regarding separations of servicemembers 
for non-disability mental conditions. For our review, we examined (1) 
the extent to which DOD and the military services are able to identify 
the number of enlisted servicemembers separated for non-disability 
mental conditions, and (2) the extent to which the military services 
are complying with DOD requirements when separating enlisted 
servicemembers for non-disability mental conditions, including 
personality disorders, and how DOD and the military services oversee 
such separations. The NDAA also mandated GAO to report on the ability 
of servicemembers administratively separated for a non-disability 
mental condition to receive VA health benefits, which is addressed in 
appendix I. 

To analyze the extent to which DOD and the military services are able 
to identify the number of enlisted servicemembers that were 
administratively separated because of a non-disability mental 
condition, we reviewed DOD and the military services documents, such 
as DOD's policy on the use of codes to track specific types of 
separations,[Footnote 5] and interviewed DOD and military service 
officials to understand the type of tracking conducted and data 
maintained on separations for non-disability mental conditions, and 
any requirements related to tracking such separations. Our review of 
documents and interviews allowed us to determine the type of 
information that DOD and the military services have available to 
identify servicemembers separated because of non-disability mental 
conditions. We assessed this information against DOD policy--which 
requires separation codes to be used by the military services so that 
DOD can track and analyze separations by their cause, as well as 
against the federal internal control standards. The federal internal 
control standards require agencies to have control activities that 
help ensure management's directives are carried out.[Footnote 6] For 
example, management should have a control that all transactions--such 
as the separations of enlisted servicemembers--are clearly documented 
and the documentation should be available for examination. 

To determine the extent to which the military services are complying 
with DOD requirements when separating enlisted servicemembers for non-
disability mental conditions, including personality disorders, and how 
DOD and the military services oversee such separations, we reviewed 
DOD's and the military services' separation policies to identify 
requirements for separating servicemembers for non-disability mental 
conditions, how these requirements evolved since our last review in 
2008, and whether the requirements have been consistent between DOD 
and each of the military services' policies. We also interviewed DOD 
and military service officials to understand the services' 
administrative separation processes for non-disability mental 
conditions and any oversight conducted by DOD or the military services 
to ensure the processes in place are effective in ensuring DOD 
separation requirements are met. Lastly, we reviewed and analyzed 
annual reports the military services submitted to DOD from fiscal year 
2008 through fiscal year 2012 on their compliance with DOD's 
separation requirements when separating servicemembers for a 
personality disorder. Our interviews and review of policies and 
compliance reports allowed us to determine the practices that DOD and 
the military services use to oversee separations of enlisted 
servicemembers for a personality disorder or other non-disability 
mental conditions. We assessed the information we collected against 
DOD's separation policy. In addition, we assessed the information 
against the federal internal control standard for monitoring, which 
states that there should be reasonable assurance that ongoing 
monitoring occurs in the course of normal operations.[Footnote 7] The 
standard also states that, when deficiencies have been identified, 
there should be a process to resolve them; and that the resolution 
process is not complete until action has been taken to correct 
deficiencies, produce improvements, or demonstrate that findings and 
recommendations do not warrant management action. 

We conducted this performance audit from April 2014 to February 2015 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

Military Services' Separation Process: 

Enlisted servicemembers can be separated from the military when they 
are found to be unsuitable for continued military service. If a 
servicemember is diagnosed with a non-disability mental condition that 
interferes with the servicemember's ability to function in the 
military, a commanding officer may initiate the separation process. 
Separated servicemembers may appeal their separation to a discharge 
review board within 15 years after separation from the military. 
Further, separated servicemembers may appeal the discharge review 
board's decision by applying to a board for the correction of military 
records.[Footnote 8] 

Separation Documentation: 

Once enlisted servicemembers have been separated from military 
service, they receive a certificate of release from the military--
Department of Defense Form 214 (DD Form 214)--that includes dates of 
service, last duty assignment, pay grade and rank, awards received, 
and a characterization of their service--such as honorable or general 
under honorable conditions.[Footnote 9] Copies of the DD Form 214 are 
sent to various entities, such as the applicable military service, VA, 
and the servicemember. Servicemembers receive two copies of the DD 
Form 214--a copy that includes the characterization of their service 
and the reason for the separation and one that does not. The reason 
for the separation is noted by a separation code, as well as a 
narrative that explains the reason for the separation. 

Separation Codes: 

According to DOD policy, separation codes are to be used by the 
military services so that data on the cause of separations can be 
collected and trends in separations analyzed, which may, in turn, 
influence changes in DOD separation policy. DOD established six 
separation codes that the military services may use for non-disability 
mental conditions on the DD Form 214, but the military services have 
discretion as to which codes they choose to use.[Footnote 10] Five of 
these separation codes pertain only to non-disability mental 
conditions. They are (1) acute adjustment disorder, (2) disruptive 
behavior disorder, (3) impulse control disorder, (4) personality 
disorder, and (5) other non-disability mental disorder.[Footnote 11] 
The sixth code available for use by the military services, "condition, 
not a disability," is a broader separation code that includes both non-
disability physical and mental conditions.[Footnote 12] 

DOD's Separation Requirements: 

DOD's separation policy, dated January 27, 2014, contains eight 
separation requirements that the military services must follow when 
separating enlisted servicemembers for non-disability mental 
conditions.[Footnote 13] Of the eight separation requirements, five 
apply to all enlisted servicemembers and three more apply only to 
enlisted servicemembers who served in an imminent danger pay (IDP) 
area, such as Iraq or Afghanistan.[Footnote 14] 

1. The servicemember must be notified in writing that a non-disability 
mental condition is the basis of the proposed separation, 

2. the servicemember must be formally counseled concerning 
deficiencies and afforded an opportunity to overcome those 
deficiencies, 

3. evidence must demonstrate that the servicemember is unable to 
function effectively because of a non-disability mental condition, 

4. the servicemember must receive a non-disability mental condition 
diagnosis by a authorized mental health provider,[Footnote 15] and: 

5. the servicemember must be counseled in writing that the diagnosis 
of a non-disability mental condition does not qualify as a disability. 

For servicemembers who served in an IDP area, the non-disability 
mental condition diagnosis must: 

6. be corroborated by a peer-or higher-level mental health 
professional, 

7. be endorsed by the military service's surgeon general, and: 

8. include an assessment to determine whether the servicemember has 
symptoms of PTSD or other mental illness co-morbidity. 

Over time, DOD has expanded its separation requirements. In 2011 and 
2014 DOD revised its policy by extending its separation requirements 
to apply to servicemembers being separated for any non-disability 
mental condition. See table 1 for an explanation of the policy changes 
since 2008. 

Table 1: Changes to Department of Defense (DOD) Separation 
Requirements for Non-Disability Mental Conditions, August 2008 to 
January 2014: 

DOD requirements as of August 28, 2008: Servicemember must be notified 
in writing of the basis of the proposed separation; 
DOD requirements as of September 30, 2011: No change; 
DOD requirements as of January 27, 2014: No change. 

DOD requirements as of August 28, 2008: Servicemember must be formally 
counseled concerning deficiencies and afforded an opportunity to 
overcome those deficiencies; 
DOD requirements as of September 30, 2011: No change; 
DOD requirements as of January 27, 2014: No change. 

DOD requirements as of August 28, 2008: Evidence must demonstrate that 
the servicemember is unable to function effectively because of a 
personality disorder; 
DOD requirements as of September 30, 2011: No change; 
DOD requirements as of January 27, 2014: Requirement expanded to 
include other non-disability mental conditions. 

DOD requirements as of August 28, 2008: Servicemember must receive a 
personality disorder diagnosis by a psychiatrist or PhD-level 
psychologist who determines that the personality disorder interferes 
with the servicemember's ability to function in the military; 
DOD requirements as of September 30, 2011: No change; 
DOD requirements as of January 27, 2014: Requirement expanded to 
include other non-disability mental conditions, and diagnosis may be 
made by an authorized mental health provider who determines that the 
disorder interferes with the servicemember's ability to function in 
the military[B]. 

DOD requirements as of August 28, 2008: Servicemember must be 
counseled in writing that the diagnosis of a personality disorder does 
not qualify as a disability; 
DOD requirements as of September 30, 2011: No change; 
DOD requirements as of January 27, 2014: Requirement expanded to 
include other non-disability mental conditions. 

Additional requirements that apply to enlisted servicemembers who have 
served or are currently serving in imminent danger pay areas[A]: 

DOD requirements as of August 28, 2008: A personality disorder 
diagnosis must be corroborated by a peer-or higher-level mental health 
professional; 
DOD requirements as of September 30, 2011: Requirement expanded to 
include other non-disability mental conditions; 
DOD requirements as of January 27, 2014: No change. 

DOD requirements as of August 28, 2008: A personality disorder 
diagnosis must be endorsed by the surgeon general of the military 
service concerned; 
DOD requirements as of September 30, 2011: Requirement expanded to 
include other non-disability mental conditions; 
DOD requirements as of January 27, 2014: No change. 

DOD requirements as of August 28, 2008: A personality disorder 
diagnosis must address post-traumatic stress disorder or other mental 
illness co-morbidity; 
DOD requirements as of September 30, 2011: Requirement expanded to 
include other non-disability mental conditions; 
DOD requirements as of January 27, 2014: No change. 

Source: GAO analysis of DOD policy. GAO-15-266. 

Notes: The separation requirements are based on DOD Instruction 
1332.14 Enlisted Administrative Separations. Underlined and bolded 
text indicates the requirement in the August 2008 version of the 
instruction that applies to a personality disorder diagnosis only and 
the text in the subsequent versions of the instruction that expands 
the requirement to apply to all non-disability mental conditions. 

[A] Servicemembers receive imminent danger pay (IDP) when they are on 
duty outside of the United States and are subject to the threat of 
physical harm or imminent danger due to wartime conditions, terrorism, 
civil insurrection, or civil war. In some locations, IDP applies only 
for duty on the ground; and in other locations, ground, airspace, or 
duty aboard a ship at sea qualify. 

[B] Based on DOD policy, an authorized mental health provider is a 
psychiatrist or clinical psychologist, a person with a doctorate in 
clinical social work, or a psychiatric nurse practitioner. In cases of 
outpatient mental health evaluations only, licensed clinical social 
workers who possess a master's degree in clinical social work will 
also be considered authorized mental health providers. 

[End of table] 

DOD and Three of the Four Military Services Cannot Identify the Number 
of Enlisted Servicemembers Separated for Non-Disability Mental 
Conditions: 

DOD and three of the four military services--Army, Navy, and Marine 
Corps--cannot identify the number of enlisted servicemembers separated 
for non-disability mental conditions because, for most separations, 
they do not use available codes to specifically designate the reason 
why servicemembers were separated. Instead, they use the broad 
separation code, "condition, not a disability," that mixes non-
disability mental conditions with non-disability physical conditions, 
making it difficult to distinguish one from the other without a time-
consuming and resource-intensive record review. In contrast, the Air 
Force is able to track the specific reasons for its servicemember 
separations because it uses the full array of separation codes 
available. 

DOD policy requires a separation code to be used by the military 
services so that DOD can track and analyze the reason for separations 
and evaluate DOD's separation policy to determine if changes are 
needed. However, according to DOD officials, the military services can 
choose to use any of the six available codes that DOD provides the 
military services to record non-disability mental conditions, 
including the "condition, not a disability" code. Moreover, under the 
internal control standard for control activities, all transactions--
such as separations of enlisted servicemembers--need to be clearly and 
accurately documented so they can be examined when needed; for 
example, to monitor trends in the reasons for servicemembers' 
separations.[Footnote 16] 

The three military services had varying reasons for using the broad 
separation code, "condition, not a disability." Navy and Marine Corps 
officials stated that they have historically used this code for most 
separations but Navy officials could not explain why they use this 
broad code instead of using one of the separation codes specific to 
non-disability mental conditions. Marine Corps officials cited concerns 
with potential stigma the servicemember may face if a more specific 
code is used. Army officials had a similar concern, stating that they 
use the broad separation code for most non-disability mental condition 
separations to protect enlisted servicemembers after they leave the 
service. Army and Marine Corps officials told us they were concerned 
that employers may request the servicemember's copy of the DD Form 214 
that has the separation code on it, and having a code specific to a 
mental condition might stigmatize the servicemember. Army officials 
stated that this issue has been discussed in media articles for 
several years.[Footnote 17] 

In contrast, both Air Force and DOD officials told us that they do not 
have evidence that including the separation code on the DD Form 214 
has caused problems for servicemembers, as suggested by the Army. An 
Air Force official said that, unlike the Army, the Air Force does not 
have information that using these codes has caused problems for 
separated Air Force servicemembers. Likewise, DOD officials told us 
that they have not heard that this is a problem. According to DOD 
officials, characterization of service, such as honorable or 
dishonorable, is usually the piece of information that employers want 
from the form. By including the characterization of service on both of 
the servicemember's copies of the DD Form 214, DOD believes that the 
servicemember could provide an employer with the copy that does not 
contain the reason for the separation and the employer will be 
satisfied because the characterization of service is indicated. 
[Footnote 18] 

Because the three military services are using the broad separation 
code "condition, not a disability" for most separations, the resulting 
data cannot be used to identify the number of servicemembers separated 
for non-disability mental conditions. There is no other systematic way 
to track these separations; that is, without a tedious and time-
consuming manual review. In one instance for example, in response to a 
request from DOD for information on the number of separations for non-
disability mental conditions, the Army undertook a 6-month manual 
review of over 2,000 servicemember files--all because it does not 
delineate separations for non-disability mental versus non-disability 
physical conditions in any data system. If DOD and the military 
services cannot systematically identify or periodically evaluate the 
number of enlisted servicemembers separated for non-disability mental 
conditions, they cannot assess how well the separation policy and 
process is working or respond specifically to key stakeholders, 
including the Congress, about trends in or concerns about separations 
for non-disability mental conditions. 

Military Services' Separation Policies Do Not Address All DOD 
Requirements for Non-Disability Mental Conditions Separations, and DOD 
and the Services Lack Oversight of Such Separations: 

From fiscal years 2008 through 2012, when the services were filing 
compliance reports, most services did not report full compliance with 
DOD separation requirements for separations for personality disorder. 
We also found that the reports contained incomplete and inconsistent 
data, and DOD conducted limited review of these reports. Further, 
based on a review of separation policies, we found that none of the 
services' policies address all DOD requirements for non-disability 
mental condition separations. Additionally, DOD and the military 
services do not have oversight processes in place to ensure compliance 
with DOD requirements in this regard. 

Most Services Did Not Report Full Compliance with Requirements for 
Personality Disorder Separations, the Reports Contained Incomplete and 
Inconsistent Data, and DOD Conducted Limited Review: 

Most of the Military Services Had Not Reported Full Compliance When 
DOD Discontinued the Compliance Reports: 

From fiscal years 2008 through 2012, DOD required the military 
services to monitor and report to DOD on their compliance with DOD 
requirements for separating servicemembers for personality disorders; 
however, while the services generally reported improved compliance 
over the 5 years of reporting, we found in the 2012 compliance reports 
that three of the services had not yet achieved full compliance with 
all of DOD's 2008 separation requirements. For each of the 20 
compliance reports the services submitted for fiscal years 2008 
through 2012, the military services were required to review a sample 
of at least 10 percent of their personality disorder separations for 
the fiscal year and assess the service's compliance with DOD's 2008 
separation requirements. Compliance, according to DOD, was achieved if 
the sample reviewed met a 90 percent compliance threshold for each 
requirement. According to DOD officials, the annual compliance reports 
were discontinued in 2013 because the military services' 2012 
compliance reports indicated that the services were compliant with all 
of DOD's 2008 requirements. However, it is unclear how DOD came to 
this conclusion when our review of the 2012 compliance reports found 
that the Air Force, Marine Corps, and Navy did not report compliance 
with all DOD requirements. Specifically, the Marine Corps reported 
compliance below 90 percent with one requirement and the Air Force was 
below this compliance rate for two requirements.[Footnote 19] Further, 
the Navy did not report on its compliance with three of the eight 
separation requirements, so DOD could not have known the Navy's level 
of compliance in those areas.[Footnote 20] 

Among the 20 compliance reports submitted during fiscal years 2008 
through 2012, the services reported the most difficulty meeting the 
requirement to notify all servicemembers that a personality disorder 
diagnosis does not constitute a disability. For example, the Marine 
Corps reported 78 percent or less compliance with this requirement in 
3 of its 5 reports.[Footnote 21] In the Air Force's fiscal year 2009 
compliance report, after finding itself noncompliant with this DOD 
requirement, the Air Force acknowledged that its policy incorrectly 
stated that servicemember notification was only required for 
servicemembers who served in an IDP area. However, even after the Air 
Force updated its policy in September 2010 and made a correction in 
this regard, the Air Force's compliance with this requirement was 81 
percent in fiscal year 2011 and 89 percent in fiscal year 2012. 
Because three of the four services were noncompliant with at least one 
requirement in their 2012 reports, DOD's discontinuation of these 
reports was premature. The federal internal control standard for 
monitoring states that there should be reasonable assurance that 
ongoing monitoring occurs in the course of normal operations. Further, 
it requires reasonable assurance that deficiencies are identified and 
corrected or otherwise resolved.[Footnote 22] 

Many Compliance Reports Were Incomplete or Contained Inconsistent 
Information: 

Our review of the services' compliance reports found examples of 
incomplete and inconsistent information in many of the 20 compliance 
reports submitted by the military services to DOD between fiscal years 
2008 and 2012. 

Regarding incomplete information in the compliance reports, we found 
three areas of concern: 

* Compliance information for reservists and National Guard members was 
missing. Nineteen of the 20 compliance reports did not assess 
compliance with separation requirements for reservists and National 
Guard members who were separated while not on active duty.[Footnote 
23] Some military service officials stated that they did not provide 
information on these reservists and National Guard members because DOD 
did not specifically ask for them to be included in the reports. 
However, DOD instructed the Secretaries of the Army, the Air Force, 
and the Navy and the Commandant of the Marine Corps to include a 
random sampling of all personality disorder separations for each 
military department, in which reservists and National Guard members 
are included as part of their respective departments. 

* Compliance information for servicemembers who served in an IDP area 
was missing. Eight of the 20 compliance reports did not indicate how 
many of the servicemembers in their review sample had served in an IDP 
area, if any.[Footnote 24] As a result, it is not clear the extent to 
which compliance was assessed in these reports for the three 
separation requirements that apply only to servicemembers who served 
in an IDP area. Further, in its fiscal year 2011 report, Navy reported 
that its review sample did not include any servicemembers who served 
in an IDP area. Therefore, Navy could not have assessed compliance 
with the three separation requirements that apply to these 
servicemembers, even though Navy reported 100 percent compliance with 
them. While DOD did not explicitly state that servicemembers that 
served in an IDP area should be included in the sample reviewed by the 
military services, three of the eight separation requirements only 
apply to such servicemembers, so the need to include these types of 
servicemembers in the review sample in order for DOD to gauge 
compliance should have been clear. 

* The Navy had incomplete information in its fiscal year 2010 
compliance report. The Navy failed to complete the reporting 
requirement for its fiscal year 2010 compliance report because its 
findings were based on a 4 percent sample of the total number of 
servicemembers separated for a personality disorder in that fiscal 
year--not the 10 percent required by DOD. In its compliance report, 
Navy stated that additional separations would be reviewed to fulfill 
DOD's sample size requirement, but according to DOD and Navy 
officials, the results of this review were never reported to DOD. When 
asked about these additional reviews, Navy officials could not offer 
an explanation regarding whether the reviews were conducted. 

In addition to incomplete information in the compliance reports, we 
found that two of the four services--Army and Navy--reported 
inconsistent numbers in several of their compliance reports. 
Specifically, DOD required the services to include in each annual 
compliance report the total number of personality disorder 
separations. However, the Army's and the Navy's reports of these 
numbers were not consistent across the 5 years, as demonstrated in 
table 2. According to DOD officials, DOD could not find documentation 
of follow-up with the services regarding these inconsistencies. 
[Footnote 25] 

Table 2: Examples of Inconsistent Data Reported in the Army and the 
Navy Annual Compliance Reports on Separations of Servicemembers for 
Personality Disorders: 

Army: 

Example 1: 
The Army reported in its fiscal year 2008 report that there were 567 
separations in that year; 
* In its fiscal year 2010 report, the Army stated there were 641 
separations in fiscal year 2008. 

Example 2: 
The Army reported in its fiscal year 2009 report that there were 255 
separations in that year; 
* In its fiscal year 2010 report, the Army stated there were 575 
separations in fiscal year 2009. 

Navy: 

Example 1: 
The Navy reported in its fiscal year 2008 report that there were 946 
separations in that year; 
* In its fiscal year 2010 report, the Navy stated there were 1086 
separations in fiscal year 2008; 
* In its fiscal year 2012 report, the Navy stated there were 975 
separations in fiscal year 2008. 

Example 2: 
The Navy reported in its fiscal year 2011 report that there were 189 
separations in that year; 
* In its fiscal year 2012 report, the Navy stated there were 173 
separations in fiscal year 2011. 

Source: GAO analysis of Department of Defense data. GAO-15-266. 

[End of table] 

DOD's Review of the Military Services' Compliance Reports for 
Personality Disorder Separations Was Limited: 

Based on interviews with officials from DOD and the military services, 
we found that almost no follow-up was conducted by DOD with the 
military services regarding the compliance reports even though the 
services reported noncompliance with separation requirements across 
the 5 years of reports. DOD officials stated that they received the 
annual compliance reports from the military services and assumed that 
the information provided in these reports was accurate, given that 
they were signed by each of the three military service secretaries and 
a representative of the Commandant of the Marine Corps. 

By not reviewing the information provided, DOD did not know that the 
reports contained inconsistent and incomplete information, and the 
agency made the decision to end the compliance reports based on what 
we found to be faulty assurances of compliance. To discontinue 
compliance reporting and not institute any other type of oversight is 
inconsistent with the standards for internal control in the federal 
government, which states that there should generally be assurance that 
ongoing monitoring occurs in the course of normal operations.[Footnote 
26] 

The Military Services' Policies Have Not Been Updated to Fully Address 
DOD Requirements for Separating Servicemembers for All Non-Disability 
Mental Conditions: 

In addition to problems we identified with compliance reports focusing 
on personality disorder separations, we also found that the Army, the 
Navy, the Marine Corps, and components of the Air Force--namely, the 
Reserves and National Guard--have been separating servicemembers for 
non-disability mental conditions according to policies that are not 
consistent with all DOD requirements.[Footnote 27] Each of the 
services has policies for separating servicemembers for non-disability 
mental conditions; however, we found these policies to be inconsistent 
with DOD policy because they have not been updated to include all of 
the changes in DOD requirements over time. Specifically, we found the 
following. 

* The Army active duty separation policy is not consistent with one of 
DOD's separation requirements.[Footnote 28] Specifically, one 
requirement has not been expanded to apply to servicemembers separated 
for all non-disability mental conditions.[Footnote 29] In addition, 
the Army Reserves and National Guard separation policy was updated in 
March 2014 yet does not contain all of DOD's separation requirements, 
such as the requirement that servicemembers be counseled in writing 
that their diagnosis does not qualify as a disability.[Footnote 30] 

* The Navy's separation policy has not been updated to be fully 
consistent with DOD policy.[Footnote 31] The Navy officials stated 
they were unaware that DOD had revised its separation policy in 2011, 
and again in 2014, until we discussed this with them in May 2014 
during the course of our review. 

* The Marine Corps' separation policy has not been updated to be fully 
consistent with DOD policy, since the Navy is responsible for revising 
and implementing such policies for the Marine Corps.[Footnote 32] 

* The Air Force Reserves and National Guard separation policy was 
created in 2005 and has not been updated over time as DOD has updated 
its separation requirements for non-disability mental conditions. 
[Footnote 33] For example, the policy does not contain the 
separation requirements applicable to servicemembers who served in an 
IDP area. 

Because the services have been separating servicemembers based on 
outdated DOD policy, some servicemembers may not have been afforded 
the protections intended by DOD's updated separation requirements. For 
example, servicemembers who served in an IDP area may not have had 
their diagnosis endorsed by the military services' Office of the 
Surgeon General as required by DOD and have been separated without the 
benefit of a confirmation of their diagnosis by this senior medical 
entity. 

During the course of our review, we also found that the Air Force 
National Guard does not have a process to separate National Guard 
members for non-disability mental conditions. In 2013, Air Force 
National Guard reported that it had not been separating Guard members 
for non-disability mental conditions because it did not have a process 
to get a mental health assessment or diagnosis for National Guard 
members. National Guard members believed to have non-disability mental 
conditions were either returned to duty or separated for another 
reason such as misconduct or unsatisfactory performance of duty. 
According to DOD policy, when separation for unsatisfactory 
performance or misconduct is warranted, separating a servicemember for 
a non-disability mental condition is not appropriate.[Footnote 34] 
Under federal internal control standards, control activities should be 
established to help ensure that performance is correctly assessed and 
transactions are accurately recorded.[Footnote 35] Accordingly, there 
should be processes in place so that, if a servicemember is identified 
as potentially having a non-disability mental condition that affects 
the member's ability to perform military duties, that servicemember 
can be separated for such a condition in accordance with DOD 
requirements, if appropriate. 

The Air Force developed a corrective action plan to address the 
National Guard's inability to separate National Guard members for non-
disability mental conditions; however, this plan was never 
implemented. According to officials, the biggest challenge in 
implementing the plan was that the Air Force National Guard does not 
have authorized mental health providers who can diagnose non-
disability mental conditions. Without a mental condition diagnosis by 
an authorized mental health provider, a servicemember cannot be 
separated for a non-disability mental condition, according to Air 
Force policy.[Footnote 36] According to officials, the Air Force 
National Guard would need to be tasked and provided related funding to 
have these providers available. The officials could not provide any 
further information on why no further action was taken to correct this 
identified problem. Further, Air Force officials stated that they 
could not identify the number of servicemembers potentially affected 
by this problem without conducting a comprehensive file review. Air 
Force National Guard members that are thought to have a non-disability 
mental condition but are separated for another reason, such as 
misconduct, risk not receiving the protections of DOD's separation 
requirements. 

DOD and the Military Services Do Not Conduct Oversight for 
Servicemember Separations for Non-Disability Mental Conditions: 

Beyond the limited review DOD conducted of the military services' 
compliance reports conducted for personality disorder separations, 
which was discontinued after fiscal year 2012, DOD and military 
service officials stated they do not conduct any oversight of all non-
disability mental condition separations. In September 2011, DOD 
revised its separation policy by expanding the three requirements that 
apply to servicemembers who served in an IDP area to include 
servicemembers separated for any non-disability mental conditions, not 
just for personality disorders.[Footnote 37] In January 2014, DOD 
again revised this policy and expanded the separations requirements so 
that all eight requirements apply to servicemembers separated for any 
non-disability mental condition. However, DOD officials stated that 
they have not required the military services to conduct any review of 
their compliance with DOD's separation requirements for all non-
disability mental conditions to determine whether they are being 
followed. As noted previously, the internal control standard for 
monitoring states that controls should be designed to assure that 
ongoing monitoring occurs in the course of normal operations.[Footnote 
38] 

According to DOD officials, the military services are responsible for 
conducting oversight of their separation processes, not DOD. However, 
while some of the military services have review steps within their 
process for separating servicemembers for non-disability mental 
conditions, none of the services have an entity-wide oversight 
process, such as conducting an annual review, to oversee separations 
and provide reasonable assurance that the review steps they have in 
place are effective at ensuring DOD separation requirements are met. 
Specifically, we found their review processes are the following: 

* The Air Force separation process includes reviews of separation 
packages--which is prepared by a commanding officer--by the Air Force 
central personnel office and a Judge Advocate General (JAG) Corps 
attorney prior to separation.[Footnote 39] Officials from these 
offices told us that the purpose of the reviews is to ensure that the 
appropriate documentation is present to support the separation. 
[Footnote 40] 

* The Army's JAG Corps also reviews all separation packages prior to 
separation to ensure documentation is present and is consistent with 
law and policy, according to Army officials.[Footnote 41] While this 
is the current practice, Army officials also told us that they have 
plans in place to start conducting oversight of separations for non-
disability mental conditions. Specifically, Army officials stated that 
separations for non-disability mental conditions will be included as 
part of the Army Organizational Inspection Program, which will review 
a sample of active duty servicemember separations at local commands to 
see if documentation is present that indicates that DOD separation 
requirements have been met. These inspections will not include reserve 
and National Guard member separations. Army officials stated they plan 
to conduct the first inspection in January 2015.[Footnote 42] 

* The Marine Corps Judge Advocates review the separation packages for 
personality disorder separations--but not for other non-disability 
mental conditions separations--to ensure documentation is present and 
is consistent with law and policy, according to Marine Corps officials. 

* The Navy does not conduct any review of the separation package 
prepared by a commanding officer prior to the servicemember's 
separation. 

The absence of a routine and comprehensive entity-wide oversight 
mechanism--such as an annual compliance review--prevents the military 
services from knowing if they are complying with all of DOD 
requirements and appropriately separating servicemembers with non-
disability mental conditions. 

Conclusions: 

The inability to easily identify the number of enlisted servicemembers 
separated for non-disability mental conditions hinders oversight by 
DOD and the military services to ensure that servicemembers are being 
separated appropriately. For example, without such data, DOD cannot 
determine how many separated servicemembers have served in IDP areas--
who may be at greater risk of having a service-related mental 
condition, such as PTSD--or determine if these servicemembers have 
been afforded the protections intended by the separation requirements, 
such as ensuring they are assessed for service-related mental 
conditions prior to being separated for a non-disability mental 
condition. Further, lack of such data prevents DOD from being able to 
conduct analyses--such as trends in non-disability mental condition 
separations over time--that are important for determining whether the 
separation policy is working, and if not, how it should be changed. 

Absent an effective process for monitoring and reporting compliance, 
DOD and the military services cannot assure that the military services 
are complying with DOD requirements for separating servicemembers with 
non-disability mental conditions. The fact that some military services 
were not aware of or had not yet aligned their policies or processes 
with updated DOD requirements for separating servicemembers with non-
disability mental conditions is of particular concern. Because the 
services have been separating servicemembers based on outdated DOD 
policy, the military services may not have been affording all 
servicemembers with the protections that DOD intended through its 
recent updates of separation requirements for non-disability mental 
conditions. As a result, some servicemembers may have been separated 
for non-disability mental conditions inappropriately. It is also of 
concern that, although the Air Force reported its inability to 
separate National Guard members for non-disability mental conditions 
in 2013, it has made no progress in correcting this issue. Meanwhile, 
these members risk not receiving the protections intended by DOD's 
separation requirements. 

Recommendations for Executive Action: 

To improve identification of enlisted servicemembers separated for non-
disability mental conditions, and to provide reasonable assurance that 
enlisted servicemembers, including Air Force National Guard members, 
are separated for non-disability mental conditions as appropriate and 
in accordance with DOD requirements, we recommend that the Secretary 
of Defense take the following six actions: 

* Direct the Under Secretary of Defense for Personnel and Readiness 
and the Secretaries of the Army and the Navy and the Commandant of the 
Marine Corps to use the separation codes specific to a non-disability 
mental condition or develop another uniform method to track 
servicemembers who have been separated for specific non-disability 
mental conditions so that this information can be easily retrieved. 

* Direct the Under Secretary of Defense for Personnel and Readiness 
and the Secretary of the Air Force to take steps to ensure there is an 
appropriately staffed process to identify and administratively 
separate enlisted National Guard members who are unable to function 
effectively in the National Guard because of a non-disability mental 
condition. 

* Direct the Secretaries of the Army, the Air Force, and the Navy and 
the Commandant of the Marine Corps to update their services' 
administrative separation policies to be consistent with DOD 
regulations for those servicemembers separated for all non-disability 
mental conditions. 

* Direct the Secretaries of the Air Force and the Navy and the 
Commandant of the Marine Corps to implement processes to oversee 
separations for non-disability mental conditions, such as 
reinstituting the requirement of annual compliance reporting of a 
sample of administrative separations, using current DOD policy 
requirements as review criteria for servicemembers of all military 
services and their Reserve components. 

* Direct the Secretary of the Army to ensure that Army's planned 
oversight of separations for non-disability mental conditions is 
implemented and incorporates reservists and National Guard members 
separated for such conditions, or that Army implement another process 
to oversee such administrative separations using current DOD policy 
requirements as review criteria for all servicemembers, including 
reservists and National Guard members. 

* Direct the Under Secretary of Defense for Personnel and Readiness to 
review any processes used by the military services to oversee such 
administrative separations to ensure compliance with DOD requirements. 

Agency Comments and Our Evaluation: 

We provided DOD and VA a draft of this report for advance review and
comment. DOD provided written comments, which we have reprinted in
appendix II. DOD generally concurred with our six recommendations.
Regarding our recommendation that DOD direct the Secretaries and
Commandant to use the existing separation codes specific to a nondisability
mental condition or develop another uniform method to track
such servicemember separations, DOD provided several reasons why it
would not use the existing separation codes specific to non-disability
mental conditions, including the possible stigmatization of the
servicemember, but DOD agreed with the need to develop a method to
uniformly track such separations. In its comments, DOD did not outline
how it would develop a method to track these servicemember
separations, nor when it would implement this or other of our
recommendations. DOD and VA also provided technical comments,
which we incorporated as appropriate. 

We are sending copies of this report to the appropriate congressional
committees; the Secretary of Defense; the Secretaries of the Army, the
Air Force, and the Navy; the Commandant of the Marine Corps; the
Under Secretary of Defense for Personnel and Readiness; the Secretary
of Veterans Affairs; and other interested parties. In addition, this 
report is available at no charge on the GAO Web site at 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-7114 or williamsonr@gao.gov. Contact points 
for our Offices of Congressional Relations and Public Affairs may be 
found on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix III. 

Signed by: 

Randall B. Williamson: 
Director, Health Care: 

[End of section] 

Appendix I: Eligibility of Servicemembers Separated for Non-Disability 
Mental Conditions for Veterans' Health Benefits: 

Like any veteran separated from military service under other than 
dishonorable conditions, veterans separated for non-disability mental 
conditions are eligible to receive Department of Veterans Affairs (VA) 
health care benefits, if they meet certain service requirements. 
[Footnote 43] Generally, servicemembers must have served 24 continuous 
months, or the full period for which they were called or ordered to 
active duty, in order to be eligible to receive VA health care 
benefits.[Footnote 44] 

Once VA determines the eligibility of veterans who have applied for VA 
health care, it assigns them to an enrollment priority group.[Footnote 
45] Generally, VA assigns veterans separated for non-disability mental 
conditions to priority groups 5 through 8.[Footnote 46] VA assigns the 
veterans as follows: 

* If the veteran has served in an imminent danger pay (IDP) area: 
[Footnote 47] the veteran is afforded what is known as enhanced 
enrollment status and is generally assigned to priority group 6. 
[Footnote 48] The veteran is not subject to copayments for visits or 
medications for conditions potentially related to their service in an 
IDP area, such as physical injuries incurred while in 
service.[Footnote 49] The veteran remains enrolled as priority group 6 
for 5 years after discharge from the military. If during this 5-year, 
post-discharge period an eligibility status is gained that affords 
enrollment in a higher priority group, such as the finding of a 
compensable service-related medical condition, the veteran is 
immediately moved to the higher priority group. Once the 5-year term 
has ended, the veteran remains enrolled in the VA health care system 
but his priority for enrollment is reassessed and the veteran may be 
shifted to priority group 5, 7, or 8 depending on his household income. 

* If the veteran has not served in an IDP area: the veteran is 
assigned to priority group 5, 7, or 8 based on income level. Veterans 
enrolled in these priority groups must agree to pay applicable 
copayments. Veterans remain enrolled in the VA health care system but 
are reassessed annually, and placed in a priority group based on the 
veteran's household income. (See figure 1) 

Figure 1: Eligibility of Servicemembers Administratively Separated for 
Non-Disability Mental Conditions to Receive Health Care Benefits from 
the Department of Veterans Affairs (VA): 

[Refer to PDF for image: flow chart] 

Veteran separated for Department of Defense for a non-disability 
mental condition: 

Served 24 months continuous active duty or the full period called or 
ordered to active duty? 
If No: Not generally eligible to receive VA health care benefits; 
If Yes: Continue. 

Served in an imminent danger pay area? 
If No: Assigned to a priority group based on income and agrees to pay 
any applicable copayments for medical care or medications based on the 
priority group assigned; 
If Yes: Assigned to priority group 6 and receives cost-free care and 
medications for conditions potentially related to service for 5 years 
after discharge from the military. 

Source: GAO summary of VA information. GAO-16-266. 

Note: The figure contains a general description of the eligibility of 
servicemembers separated from the military for non-disability mental 
conditions to receive health care from VA as veterans. There are 
specific circumstances that are not depicted in this figure that may 
apply to some veterans. For example, there are a number of exclusions 
to the minimum duty requirement of 24 months. Veterans must apply for 
VA health care benefits so that individual eligibility may be 
determined. Further, if a veteran separated for a non-disability 
mental condition has another medical condition related to their 
service--such as a back problem--they may be placed in a higher 
priority group due to that condition. 

[End of figure] 

Once assigned a priority group and enrolled in VA's health care 
system, the veteran is eligible to receive VA's medical benefits 
package, which covers most of VA's medical services such as preventive 
care, and outpatient and inpatient diagnostic and treatment services, 
and includes services for mental health conditions. 

[End of section] 

Appendix II: Comments from the Department of Defense: 

Office of The Assistant Secretary Of Defense: 
Readiness and Force Management: 
4000 Defense Pentagon: 
Washington, D.C. 20301-4000: 

January 16, 2015: 
	
Mr. Randy Williamson: 
Director, Health Care: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington DC 20548: 

Dear Mr. Williamson: 

This is the Department of Defense (DoD) response to the GAO Draft 
Report, GAO-15-266, 'Defense Health Care: Better Tracking and 
Oversight Needed of Servicemember Separations for Non-Disability 
Mental Conditions' dated December 18, 2014 (GAO Code 100021). 

Thank you for the opportunity to review and comment on the draft 
report. We recognize the immense importance of executing procedures to 
get these separations right and to not inadvertently stigmatize or 
disclose sensitive medical information pertaining to our servicemembers.
The Department is providing official written comments for inclusion in 
the report. 

Sincerely, 

Signed by: 

Juliet M. Beyler: 
Director, Officer and Enlisted Personnel Management (Military 
Personnel Policy): 

Attachment: As stated: 

cc: 
Deputy Assistant Secretary of the Army for Military Personnel and 
Quality of Life; 
Deputy Assistant Secretary of the Navy for Military Personnel Policy; 
Deputy Assistant Secretary of the Air Force for Force Management 
Integration. 

GAO Draft Report Dated December 18, 2014: 
GAO-15-266 (GAO Code 100021): 

"Defense Health Care: Better Tracking And Oversight Needed Of
Servicemember Separations For Non-Disability Mental Conditions" 

Department Of Defense Comments To The GAO Recommendations: 

Recommendation 1: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness and 
the Secretaries of the Army and the Navy and the Commandant of the 
Marine Corps to use the separation codes specific to a non-disability 
mental condition or develop another uniform method to track 
servicemembers who have been separated for specific non-disability 
mental conditions so that this information can be easily retrieved. 

DoD Response: Partially Concur. 

DoD nonconcurs with the recommendation to direct the Military 
Department Secretaries to use the separation codes specific to non-
disability mental conditions. Use of specific Separation Program 
Designator (SPD) codes as a tracking mechanism for discharges related 
to specific non-disability mental conditions would capture only those 
servicemembers separating from active duty and would not encompass 
those members separating from the Reserves or National Guard who were 
not on active duty. Additionally, the Army has raised concerns that 
mandating disclosure of specific non-disability mental conditions has 
potential to stigmatize those veterans by disclosing sensitive medical 
information. However, DoD agrees there is a need to develop alternate 
methods to uniformly track this information in an easily retrievable 
manner, and as well to conduct a comprehensive review of SPD codes and 
the information portrayed on various copies of the DD Form 214. 

Recommendation 2: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness and 
the Secretary of the Air Force to take steps to ensure there is an 
appropriately staffed process to identify and administratively 
separate National Guard members who are unable to function effectively 
in the National Guard because of a non-disability condition. 

DoD Response: Concur. 

Recommendation 3: The GAO recommends that the Secretary of Defense 
direct the Secretaries of the Army, the Air Force, and the Navy and 
the Commandant of the Marine Corps to update their administrative 
separation policies to be consistent with DOD regulations for those 
servicemembers separated for all non-disability mental conditions. 

DoD Response: Concur. 

Recommendation 4: The GAO recommends that the Secretary of Defense 
direct the Secretaries of the Air Force and the Navy and the 
Commandant of the Marine Corps to implement processes to oversee such 
administrative separations, such as reinstituting the requirement of 
annual compliance reporting of a sample of administrative separations, 
using current DOD policy requirements as review criteria for 
servicemembers of all military services and their Reserve component. 

DoD Response: Concur. 

Recommendation 5: The GAO recommends that the Secretary of Defense 
direct the Secretary of the Army to ensure that Army's planned 
oversight of separations for non-disability mental conditions is 
implemented and incorporates reservists and National Guard members 
separated for such conditions, or that Army implement another process 
to oversee such administrative separations using current DOD policy 
requirements as review criteria for all serviecmembers, including 
reservist and National Guard members. 

DoD Response: Concur. 

Recommendation 6: The GAO recommends that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness to 
review any processes used by the military services to oversee such 
administrative separations to ensure compliance with DOD requirements. 

DoD Response: Concur. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Randall B. Williamson, (202) 512-7114 or williamsonr@gao.gov: 

Staff Acknowledgments: 

In addition to the contact named above, Marcia A. Mann (Assistant 
Director), Zhi Boon, Deirdre Brown, Cathleen J. Hamann, Lisa Opdycke, 
Vikki Porter, and Laurie F. Thurber were major contributors to this 
report. Jacquelyn Hamilton provided legal support. 

[End of section] 

Footnotes: 

[1] Enlisted servicemembers are those in the active duty component and 
Reserve component--reservists and National Guard members. Officers may 
also be separated from the military; however, the separation process 
for officers is different from that of enlisted servicemembers and was 
not the focus of this review. 

[2] We use "separation" to refer to administrative separations for non-
disability mental conditions. DOD's requirements for these separations 
are in Department of Defense Instruction 1332.14 Enlisted 
Administrative Separations. 

[3] These include mental conditions such as acute adjustment disorder, 
disruptive behavior disorder, impulse control disorder, personality 
disorder, and other mental conditions, such as attention-deficit 
hyperactivity disorder. 

[4] GAO, Defense Health Care: Additional Efforts Needed to Ensure 
Compliance with Personality Disorder Separation Requirements, 
[hyperlink, http://www.gao.gov/products/GAO-09-31] (Washington, D.C.: 
Oct. 31, 2008). 

[5] Department of Defense Instruction 1336.01 Certificate of Release 
or Discharge from Active Duty (DD Form 214/5 Series) (Aug. 20, 2009). 

[6] See GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[7] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[8] Servicemembers who choose to challenge the reason for their 
separations beyond 15 years after separation apply directly to the 
board for the correction of military records. 

[9] According to DOD policy, servicemembers separated from the 
military for non-disability mental conditions receive a service 
characterization of honorable or general under honorable conditions. 

[10] A separation code is a three letter code, with the last two 
letters indicating the condition for which the servicemember was 
separated, and the first letter indicating other information regarding 
the separation. In this report, when we refer to the separation code, 
we are referring to the information in the last two letters 
specifically. 

[11] The other non-disability mental disorder category allows military 
services to group the four mental conditions listed above along with 
other conditions not assigned a specific code under one broad 
separation code. 

[12] Examples of non-disability physical conditions for which 
servicemembers can be administratively separated include obesity and 
travel sickness. 

[13] Department of Defense Instruction 1332.14 Enlisted Administrative 
Separations (Jan. 27, 2014). This DOD separation policy was the most 
current policy available at the time of our review. On December 4, 
2014, DOD released an updated separation policy but this update did 
not affect the separation requirements discussed in this report. 

[14] Servicemembers receive imminent danger pay (IDP) when they are on 
duty outside of the United States and are subject to the threat of 
physical harm or imminent danger due to wartime conditions, terrorism, 
civil insurrection, or civil war. In some locations, IDP applies only 
for duty on the ground; and in other locations, ground, airspace, or 
duty aboard a ship at sea qualify. 

[15] Based on DOD policy, an authorized mental health provider is a 
psychiatrist or clinical psychologist, a person with a doctorate in 
clinical social work, or a psychiatric nurse practitioner. In cases of 
outpatient mental health evaluations only, licensed clinical social 
workers who possess a master's degree in clinical social work will 
also be considered authorized mental health providers. 

[16] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[17] While the Army, Navy, and Marine Corps use the broad code for 
most non-disability mental condition separations, these services also 
use the separation code specific to personality disorder. Army and 
Marine Corps officials stated that they use the personality disorder 
separation code because of DOD's interest in analyzing these types of 
separations. Navy officials could not explain why the Navy uses this 
code. The Navy and the Marine Corps use the personality disorder 
separation code for all personality disorder separations. The Army 
uses the personality disorder separation code for servicemembers that 
served less than 24 months; all other separations for personality 
disorder fall under the broad separation code "condition, not a 
disability." Army officials told us that they tried to discontinue 
using the personality disorder separation code in an effort to protect 
servicemembers from possible stigmatization of having a specific code 
that indicates a mental condition on the DD Form 214. However, 
according to Army officials, DOD officials told Army that it must use 
the specific code for personality disorder. In 2009, in response to 
DOD, Army continued using the personality disorder separation code for 
servicemembers that served less than 24 months, but began using the 
broader code of "condition, not a disability" for other servicemembers 
in an effort to protect those servicemembers who had served longer, 
according to Army officials. 

[18] DOD officials stated that they have discussed adding the 
characterization of service to both copies of the DD Form 214 that the 
servicemember receives; however, no action has been taken. 

[19] The Marine Corps was out of compliance with the requirement to 
notify the servicemember that the diagnosis of a personality disorder 
does not qualify as a disability (78 percent). Air Force was also out 
of compliance with this requirement (89 percent), as well as the 
requirement that the diagnosis be endorsed by the Air Force's Surgeon 
General (75 percent). 

[20] The three requirements were (1) servicemember received formal 
counseling and was afforded the opportunity to improve behavior prior 
to being separated; (2) servicemember received written notification of 
impending separation based on personality disorder diagnosis; and (3) 
servicemember was advised that the diagnosis of a personality disorder 
does not qualify as a disability. 

[21] The Marine Corps reported 90 percent compliance in its fiscal 
year 2008 report and 100 percent compliance in its fiscal year 2011 
report. 

[22] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[23] The Air Force provided Reserve and National Guard data in its 
fiscal year 2011 compliance report. The Air Force attempted to provide 
this information in its fiscal year 2012 report but noted problems 
identifying and assessing these two groups, and therefore, they were 
not included in that year's report. Otherwise, the services stated 
that they only included reservists or National Guard members in their 
reports if they were on active duty orders when they were separated 
for a personality disorder. 

[24] Of the five reports submitted by each military service between 
fiscal years 2008 and 2012, the Army did not include this information 
in three reports, the Air Force did not include this information in 
one report, the Navy did not include this information in two reports, 
and the Marine Corps did not include this information in two reports. 

[25] Navy officials could not explain to us why their reported numbers 
for a given fiscal year changed in subsequent reports and which 
numbers were correct. Army officials provided us with explanations as 
to why their reported numbers for a given fiscal year changed in 
subsequent reports. Army officials stated that the correct numbers are 
as follows: in fiscal year 2008 there were 641 personality disorder 
separations and in fiscal year 2009 there were 575 personality 
disorder separations. 

[26] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[27] During our review, we found that the Air Force active duty 
separation policy [Air Force Instruction 36-3208 Administrative 
Separation of Airmen (July 2, 2013)] is not consistent with two of 
DOD's separation requirements. The Air Force policy does not require 
that servicemembers be assessed for PTSD or other mental illness co-
morbidity prior to being separated for a non-disability mental 
condition, nor does it require servicemembers to be counseled in 
writing that such a diagnosis does not qualify as a disability. 
However, we found that these requirements are included in a checklist 
that is used by commanders and reviewed by a central personnel office 
during the separation process. 

[28] Army Regulation 635-200 Personnel Separations Active Duty 
Enlisted Administrative Separations (Washington, D.C.: Sept. 6, 2011) 
and Army OTSG/MEDCOM Policy Memo 14-049 Administrative Separation of 
Soldiers for Personality Disorder (PD) under Chapters 5-13 and 5-17, 
or Other Designated Physical or Mental Conditions under Chapter 5-17 
(Fort Sam Houston, T.X.: Jun. 23, 2014). 

[29] The DOD requirement that the Army has not updated in its 
separation policy is that the servicemember must be counseled in 
writing that the diagnosis of a non-disability mental condition does 
not qualify as a disability. 

[30] Army Regulation 135-178 Army National Guard and Army Reserve 
Enlisted Administrative Separations (Washington D.C.: Mar. 18, 2014). 

[31] MILPERSMAN 1910-120 Separation by Reason of Convenience of the 
Government - Physical or Mental Conditions (Mar. 15, 2012). This 
policy applies to both active-duty and reserve servicemembers. 

[32] Marine Corps Order 1900.16 Separation and Retirement Manual 
(Washington, D.C.: Nov. 26, 2013). According to Marine Corps 
officials, this policy applies to both active-duty and reserve 
servicemembers. 

[33] Air Force Instruction 36-3209 Separation and Retirement 
Procedures for Air National Guard and Air Force Reserve Members 
(Washington D.C.: Apr. 14, 2005). 

[34] Air Force officials told us that in order to separate a National 
Guard member for a non-disability mental condition, the commander 
would first have to notice that the National Guard member may have a 
non-disability mental condition and take action to get the member 
medically evaluated, before moving forward with that type of 
separation. The officials added that if a commander only sees a 
National Guard member once a month at drills, for example, they may 
not notice that the member may potentially have a non-disability 
mental condition; or if the National Guard member does not show up to 
drill, the commander would not notice such a condition and instead 
would likely separate the member for unsatisfactory duty performance. 

[35] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[36] Air Force officials told us that National Guard members in 
initial active-duty training and those that have just returned from 
active-duty service in an IDP area may be separated for a non-
disability mental condition. The officials stated that in these cases, 
the servicemembers would be on active-duty orders, and therefore, able 
to receive a medical evaluation from an Air Force medical provider. 
The officials added that if the provider diagnosed the servicemember 
with a non-disability mental condition that interfered with the 
performance of the servicemembers' military duties, the servicemember 
would be separated for a non-disability mental condition. 

[37] The three requirements expanded were that non-disability mental 
condition diagnosis must (1) be corroborated by a peer-or higher-level 
mental health professional, (2) be endorsed by the military service's 
surgeon general; and (3) include an assessment to determine whether 
the servicemember has symptoms of PTSD or other mental illness co-
morbidity. 

[38] See [hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1]. 

[39] The Air Force, the Army, and the Navy each have a Judge Advocate 
General's (JAG) Corps that is composed of uniformed and civilian 
licensed attorneys. These attorneys provide legal advice to the 
command and staff, and represent servicemembers on military legal 
issues. The Marine Corps have a Judge Advocate Division where licensed 
attorneys provide advice on legal matters and oversee the Marine Corps 
legal community. 

[40] For servicemembers that served in an IDP area, DOD requires that 
the servicemember's diagnosis be endorsed by the military service's 
surgeon general. According to officials, in order to fulfill this 
requirement, the Air Force central medical office, on behalf of the 
Air Force Surgeon General, reviews the separation packages of these 
servicemembers to see if all DOD separation requirements are met; 
whereas, the comparable medical offices in the Army and the Navy--
which reviews medical information on behalf of the Marine Corps--
review the separation packages of these servicemembers, but only to 
see if the DOD separation requirements that are medical in nature, 
such as the diagnosis addressing PTSD, have been met. 

[41] According to Army officials, the National Guard JAG Corps does 
not generally review separation packages of National Guard members 
prior to their separation. 

[42] Army officials also stated that they completed a review of the 
medical records of those servicemembers separated for all non-
disability mental conditions from September 11, 2001, to August 31, 
2012, to see if separation requirements that are medical in nature 
were met. However, officials could not provide the results of the 
review, or any related documentation, as the review has not yet been 
finalized and approved by the Army. 

[43] According to Department of Defense (DOD) policy, veterans 
separated from DOD for non-disability mental conditions receive a 
service characterization of honorable or general under honorable 
conditions. 

[44] There are a number of exceptions to the minimum duty requirements 
that VA will determine once the veteran applies for VA health care 
benefits. 38 U.S.C. § 5303A.  

[45] The number of veterans who can be enrolled in the health care 
program is dependent upon the amount of money VA receives in advance 
appropriations each year, 38 U.S.C. § 1710(a)(4). Since funds are 
limited, VA sets up priority groups to ensure that certain groups of 
veterans are able to be enrolled before others. The priority groups 
range from 1-8 with 1 being the highest priority. Priority is 
generally based on service-connected disability, low income, and other 
recognized statuses such as former prisoners of war. 38 U.S.C. § 1705; 
38 C.F.R. § 17.36. 

[46] Veterans separated for non-disability mental conditions may be 
assigned to a higher priority group if, for example, they have other 
illnesses or injuries possibly related to their military service. 

[47] Servicemembers receive imminent danger pay (IDP) when they are on 
duty outside of the United States and are subject to the threat of 
physical harm or imminent danger due to wartime conditions, terrorism, 
civil insurrection, or civil war. In some locations, IDP applies only 
for duty on the ground; and in other locations, ground, airspace, or 
duty aboard a ship at sea qualify. 

[48] Currently enrolled veterans and new enrollees, who were 
discharged from active duty on or after January 28, 2003, are eligible 
for the enhanced benefits for 5 years post discharge. Veterans 
discharged from active duty before January 28, 2003, who applied for 
enrollment on or after January 28, 2008, were eligible for the 
enhanced benefit until January 28, 2011. 38 U.S.C. § 1710(e)(3). 

[49] Unless otherwise exempted, veterans that served in an IDP area 
must either disclose their prior year gross household income or 
decline to provide their financial information and agree to make 
applicable copayments for care or services VA determines are clearly 
unrelated to their military service. This could include care or 
services for the non-disability mental condition for which the veteran 
was separated from the military since DOD and VA do not consider the 
condition to be service-related. 

[End of section] 

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