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entitled 'Military Personnel: DOD Comments on GAO's Report on More DOD 
Actions Needed to Address Servicemembers' Personal Financial Management 
Issues' which was released on May 26, 2005.

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May 11, 2005:

The Honorable Richard J. Durbin: 
United States Senate:

Subject: Military Personnel: DOD Comments on GAO's Report on More DOD 
Actions Needed to Address Servicemembers' Personal Financial Management 
Issues:

Dear Senator Durbin:

In response to your request, we issued a report in April 2005 on the 
Department of Defense's (DOD) efforts to address personal financial 
management (PFM) issues encountered by its servicemembers and their 
families.[Footnote 1] In that report, we made recommendations to the 
Secretary of Defense to enhance servicemembers' financial conditions 
and the effectiveness of DOD's PFM programs and training. On March 17, 
2005, we provided a draft of that report to DOD for review and comment. 
DOD did not provide comments in time to incorporate them in the final 
GAO report that went to printing on April 22, 2005. To present DOD's 
comments and provide our perspective on them, this report briefly 
summarizes our April 2005 report's objectives, results, and 
recommendations, along with DOD's comments and our evaluation of the 
comments. DOD's comments, which were provided by the Under Secretary of 
Defense for Personnel and Readiness, are included as an enclosure to 
this report.

Summary of Objectives, Results, and Recommendations:

We answered three questions in our April 2005 report: (1) To what 
extent does deployment impact the financial conditions of active duty 
servicemembers and their families? (2) Does DOD have an oversight 
framework for evaluating military programs that assist both deployed 
and non-deployed servicemembers in managing their personal finances? 
And (3) To what extent are junior enlisted servicemembers receiving 
required personal financial management training?

We found that the financial conditions of deployed and non-deployed 
servicemembers and their families are similar, but deployed 
servicemembers and their families may face additional financial 
problems related to pay. In both a 2003 DOD-wide survey and non- 
generalizable focus groups that GAO conducted on 13 military 
installations in the United States and Germany, servicemembers who were 
deployed reported similar financial conditions as those who were not 
deployed. Some of GAO's focus group participants also noted that they-
-like Army reservists in GAO's 2004 report[Footnote 2]--had not 
received their $250 family separation allowance each month during their 
deployment. Pay record data showed that almost 6,000 deployed 
servicemembers had received more than the prescribed $250 for January 
2005, and 11 of them received a $3,000 catch-up, lump sum payment--the 
equivalent of 12 months of the allowance. This pay problem was due, in 
part, to service procedures being confusing and not always followed. 
Families who do not receive this allowance each month may experience 
financial strain caused by additional expenses, such as extra 
childcare. In addition, DOD and installation officials as well as 
servicemembers told us that problems communicating with creditors 
during deployment can cause other financial difficulties. 
Servicemembers told us that limited Internet access, the high cost of 
calling from overseas, and delays in the delivery of mail often 
prevented them from promptly contacting creditors. Failure to avoid or 
promptly correct serious financial problems can result in negative 
consequences, such as bad credit ratings for these servicemembers and 
decreased morale and readiness for the servicemembers' units.

We also found that DOD lacks an oversight framework--one with results- 
oriented performance measures and reporting requirements--for 
evaluating the effectiveness of PFM programs across the services. 
Although DOD's 2002 human capital strategic plan stated that a 
standardized evaluation system for PFM programs is a desired goal, DOD 
does not currently have such a system. In 2003, GAO reported that DOD 
had included evaluative reporting measures in a draft of its PFM 
instruction to the services. However, the final PFM instruction, issued 
by DOD in 2004, did not address outcome measures or contain a 
requirement that the services report program results to DOD. When asked 
why the evaluation and reporting requirements had been dropped, DOD 
officials indicated that the services objected to these additional 
requirements. Without a policy requiring evaluation and a reporting 
relationship between DOD and the services, DOD and Congress do not have 
the visibility or oversight needed to address issues related to the PFM 
programs.

Some junior enlisted servicemembers are not receiving PFM training that 
is required by service regulations. While each of the services 
implements PFM training differently to take into account service- 
specific constraints, all of the services have policies requiring that 
PFM training be provided to junior enlisted servicemembers. The extent 
to which the PFM training is received is unknown because most of the 
services do not track the completion of PFM training at the service 
level. Only the Army collected installation-level data and could 
provide a service-wide estimate of PFM training completed by junior 
enlisted servicemembers. Senior Army officers at most of the Army 
installations we visited acknowledged the need for PFM training but 
noted that current deployment schedules limit the time available to 
prepare soldiers for their warfighting mission. Top-level DOD officials 
have repeatedly stated that financial issues directly affect 
servicemembers' mission readiness and should be addressed. Therefore, 
units whose servicemembers do not receive required PFM training risk 
jeopardizing their ability to meet mission requirements.

To address issues related to servicemembers' financial management, we 
recommended in our April 2005 report that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness to 
take the following four actions:

* Take the necessary steps, in conjunction with the Defense Finance and 
Accounting Service and the services, to ensure servicemembers receive 
family separation allowances on a monthly basis during deployments. 
These steps might include those recommended in our prior review of Army 
Reserve pay,[Footnote 3] such as clarifying and simplifying procedures 
and forms implementing family separation allowance entitlements or 
having DOD and the operational components of the services to work 
together to ensure the family separation allowance entitlement 
eligibility form is received by the Defense Finance and Accounting 
Service to start the allowance when the servicemember is entitled to it.

* Identify and implement, with the services, steps that can be taken to 
allow deployed servicemembers better communications with creditors. 
These steps may include increasing Internet access and providing toll- 
free telephone access for deployed servicemembers when they need to 
address personal financial issues.

* Develop and implement, in conjunction with the services, a DOD-wide 
oversight framework with a results-oriented evaluation plan for the PFM 
programs and formalize DOD's oversight role by including evaluation and 
reporting requirements in the PFM instruction.

* Require the services to develop and implement a tactical plan with 
time-based milestones to show how the appropriate service policy office 
will monitor financial management training and thereby ensure that 
junior enlisted servicemembers receive the required training.

Agency Comments and Our Evaluation:

DOD's comments on a draft of our April 2005 report are summarized below 
and reproduced in the enclosure. Regarding our four recommendations, 
DOD concurred with one and partially concurred with the remaining 
three. 

DOD concurred with our recommendation to take the necessary steps, in 
conjunction with the Defense Finance and Accounting Service and the 
services, to ensure servicemembers receive family separation allowances 
on a monthly basis during deployments.

DOD partially concurred with our recommendation to identify and 
implement, with the services, steps (such as increasing Internet access 
and providing toll-free telephone access) to allow deployed 
servicemembers better communications with creditors. DOD stated that 
servicemembers are to establish extended absence plans for their 
personal finances to ensure that their obligations are covered. It also 
noted that the Servicemembers Civil Relief Act was established to allow 
servicemembers in training and on a deployment, the opportunity to set 
aside certain personal financial concerns and focus on the mission at 
hand. It further noted that, in all situations, additional capability 
to communicate, particularly with creditors, may not be appropriate due 
to operational requirements and that deployed units maintain a rear 
echelon to assist servicemembers in working out unforeseen financial 
issues that may arise during deployment. We agree that operational 
constraints need to be considered in any effort to enhance 
servicemembers' abilities to communicate with creditors and that 
servicemembers should be responsible for maintaining their financial 
affairs by developing extended absence plans and using appropriate 
laws. Those points notwithstanding, we reported that some 
servicemembers nevertheless encountered financial problems because of 
emergencies and possibly lack of planning. Additionally, we recognize 
that the rear echelon may be able to provide assistance when such 
emergencies arise, but we also noted in our report that some 
servicemembers are reluctant to let their chain of command know of 
their financial troubles and therefore may not use military-provided 
support for private matters, such as financial problems. Our 
recommendation seeks a way to proactively address financial issues 
before the issues resulted in the negative consequences for 
servicemembers and we continue to believe it should be implemented by 
DOD.

DOD also partially concurred with our recommendation to develop and 
implement, with the services, a DOD-wide oversight framework with a 
results-oriented evaluation plan for PFM programs and to formalize 
DOD's oversight role by including evaluation and reporting requirements 
in the PFM instruction. DOD noted that the department is pursuing 
management information that includes personal finance and has developed 
an information model that supports mission accomplishment and includes 
monitoring force management risk. It further stated that personal 
finance is seen as an important part of this model and that a key 
aspect of assessing personal finances will be the policies established 
in the November 2004 DOD Instruction 1342.17, Personal Financial 
Management Programs for Servicemembers. We agree with DOD's response 
that personal finance is an important part of any information model to 
support mission accomplishment. However, as we stated in our report, 
the current DOD PFM instruction does not contain program evaluation 
requirements or reports that the services should routinely provide to 
DOD for its PFM oversight role. The total absence of evaluative and 
reporting requirements in the PFM instruction is particularly notable 
given that DOD acknowledged the importance of the requirements in two 
earlier documents: (1) the 2002 human capital strategic plan, which 
stated that a standardized evaluation system for PFM programs is a 
desirable goal, and (2) an earlier draft of the instruction that 
contained evaluative and reporting requirements. Moreover, DOD did not 
provide us with documentation for how the information model would be 
used to address deficiencies in the current PFM instruction. We 
continue to believe, as we have recommended, that this instruction 
should make explicit DOD's requirements for (1) results-oriented 
evaluation of the PFM programs and (2) the services to provide reports 
to DOD on their PFM programs.

Additionally, DOD partially concurred with our recommendation to 
require the services to develop and implement a tactical plan with time-
based milestones to show how the appropriate service policy office will 
monitor whether servicemembers receive required financial management 
training. DOD noted that it had established sufficient procedures 
within its November 2004 PFM instruction to allow the military 
departments flexibility in their approach to having servicemembers 
"demonstrate a basic understanding" of important personal financial 
topics. We agree that the services may need some flexibility in the 
delivery of required PFM training. However, DOD's response does not 
address the services' lack of monitoring to determine whether required 
PFM training is actually received by the servicemembers. While DOD 
notes that the military services are delegated responsibility for 
achieving the requirements listed in the November 2004 instruction and 
that the services are responsible for monitoring fulfillment of the 
policy, we still believe, as we have recommended, that a service-level 
tactical plan with time-based milestones is needed to show how the 
appropriate service policy office will ensure that junior enlisted 
servicemembers receive required PFM training. DOD also stated that it 
would continue to monitor the behavior of servicemembers as the outcome 
of the training and evaluation accomplished by the services. At this 
point, DOD and the services do not monitor training completion--an 
output. Therefore, it will be impossible to determine whether the 
desired outcome of training--improved financial behavior--is being 
achieved.

We continue to believe that our recommendations have merit and will 
strengthen the department's oversight and the effectiveness of the PFM 
programs and training; consequently, we are not revising them. DOD also 
provided two technical comments on our draft report. We corrected one 
before receiving the DOD comments, and the other was an editorial 
change we did not believe was needed.

As agreed with your office, unless you publicly announce its contents 
earlier, we plan no further distribution of this report until 30 days 
after its issue date. At that time, we will provide copies of this 
report to interested congressional committees and the Secretary of 
Defense. We will also make copies available to others upon request. 
This report will be available at no charge on GAO's Web site at 
[Hyperlink, http://www.gao.gov].

If you or your staff have any questions regarding this report, please 
contact me at (202) 512-5559 ([Hyperlink, stewartd@gao.gov]) or Jack E. 
Edwards at (202) 512-8246 ([Hyperlink, edwardsj@gao.gov]). Other key 
contributors to this report were Marion A. Gatling, David A. Mayfield, 
and Terry L. Richardson.

Sincerely yours,

Signed by: 

Derek B. Stewart: 
Director, Defense Capabilities and Management:

Enclosure:

Enclosure I: Comments from the Department of Defense:

UNDER SECRETARY OF DEFENSE: 
PERSONNEL AND READINESS:

4000 DEFENSE PENTAGON: 
WASHINGTON, D.C. 20301-4000:

APR 22, 2005: 

Mr. Derek B. Stewart: 
Director:
Defense Capabilities and Management: 
U.S. Government Accountability Office: 
Washington, DC 20548:

Dear Mr. Stewart:

The enclosed documents provide comments to recommendations and 
technical corrections to proposed GAO Report, GAO-05-348, MILITARY 
PERSONNEL: DoD Actions Needed to Address Servicemembers' Personal 
Financial Management Issues.

Thank you for the opportunity to provide comment on the final report.

Signed by: 

David S.C. Chu:

Enclosure: As stated:

GAO-05-348/GAO CODE 350491:

"MILITARY PERSONNEL: MORE DOD ACTIONS NEEDED TO ADDRESS SERVICEMEMBERS' 
PERSONAL FINANCIAL MANAGEMENT ISSUES:"

DEPARTMENT OF DEFENSE COMMENTS TO THE RECOMMENDATIONS:

RECOMMENDATION 1: The GAO recommended that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness to 
take the necessary steps, in conjunction with the Defense Finance and 
Accounting Service and the Services, to ensure Servicemembers' receive 
family separation allowances on a monthly basis during deployments. 
These steps might include those recommended in GAO's prior review of 
Army Reserve pay (GAO-04-911) such as clarifying and simplifying 
procedures and forms implementing family separation allowance 
entitlements or having DoD and the operational components of the 
Services to work together to ensure family separation allowance 
entitlement eligibility form is received by the Defense Finance and 
Accounting Service to start the allowance when the Servicemember is 
entitled to it. (Page 20/Draft Report):

DoD RESPONSE: Concur.

RECOMMENDATION 2: The GAO recommended that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness to 
identify and implement, with the Services, steps that can be taken to 
allow deployed Servicemembers better communications with creditors. 
These steps may include increasing Internet access and providing toll- 
free telephone access for deployed Servicemembers when they need to 
address personal financial issues. (Page 20/Draft Report):

DoD RESPONSE: Partially Concur. Although the report cites that Service 
members would like additional opportunities to communicate with 
creditors through increased Internet access and toll-free telephone 
access, the decision to provide additional communication capability 
must be retained by the field commander. In all situations additional 
capability to communicate, particularly with creditors, may not be 
appropriate due to operational requirements.

By policy, Service members are to establish an extended absence plan 
for their personal finances to ensure their obligations will be 
adequately covered. Additionally, the Service member Civilian Relief 
Act (SCRA) was established to allow Service members in training and on 
a deployment, the opportunity to set aside personal financial concerns 
to focus on the mission at hand. And finally, in situations where 
unforeseen issues arise that were not covered in the Service member's 
plan, or covered by the SCRA, deployed units maintain a rear echelon to 
work these types of issues for deployed Service members.

Communication is an important morale factor for troops in the field, 
but should not be considered as an essential for Service members to 
maintain their financial wellbeing while in deployed locations.

RECOMMENDATION 3: The GAO recommended that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness to 
develop and implement, in conjunction with the Services, a DoD-wide 
oversight framework with a results-oriented evaluation plan for the 
personal financial management programs and formalize DoD's oversight 
role by including evaluation and reporting requirements in the personal 
financial management instruction.

(Page 20/Draft Report):

DoD RESPONSE: Partially Concur. The Department is pursuing management 
information that includes personal finance to support the Department's 
implementation of the President's Management Agenda and to comply with 
the Government Performance Results Act. The Department has developed an 
information model that supports mission accomplishment that includes 
monitoring force management risk. Personal finance is seen as an 
important part of this model and is evaluated to ensure the needs of 
Service members and their families are met in order to sustain the 
readiness of the force. The key aspect of this assessment will be the 
policies recently established in the DoD Instruction 1342.17, Personal 
Financial Management Programs for Service Members, November 12, 2004.

RECOMMENDATION 4: The GAO recommended that the Secretary of Defense 
direct the Under Secretary of Defense for Personnel and Readiness to 
require the Services to develop and implement a tactical plan with time-
based milestones to show how the appropriate Service policy office will 
monitor financial management training and thereby ensure that junior 
enlisted Servicemember receive the required training. (Page 20/ Draft 
Report):

DoD RESPONSE: Partially Concur. The Office of the Under Secretary of 
Defense for Personnel and Readiness has established policy and 
sufficient procedures within DoDI 1342.17 to allow the Military 
Departments to accomplish their responsibilities. The policy and 
procedures have been written to provide the Military Services 
flexibility in their approach to having Service members "demonstrate a 
basic understanding" of important personal financial topics. The 
Military Departments are delegated responsibility for achieving the 
requirements listed in the Instruction and it is their responsibility 
to monitor fulfillment of the policy. The Department will continue to 
monitor the behavior of Service members as the outcome of the training 
and evaluation accomplished by the Military Services. 

[End of section]

(350705):

FOOTNOTES

[1] See GAO, Military Personnel: More DOD Actions Needed to Address 
Servicemembers' Personal Financial Management Issues, GAO-05-348 
(Washington, D.C.: Apr. 26, 2005).

[2] See GAO, Military Pay: Army Reserve Soldiers Mobilized to Active 
Duty Experienced Significant Pay Problems, GAO-04-911 (Washington, 
D.C.: Aug. 20, 2004). We found that the procedures to determine 
entitlement and to process family separation allowance were not well 
understood by either pay technicians or soldiers themselves. We 
recommended that the Secretary of the Army, in conjunction with the 
Under Secretary of Defense (Comptroller), clarify and simplify 
procedures and forms implementing family separation allowance 
entitlement policy.

[3] See GAO-04-911.