Department of Defense: Actions Needed to Improve Management and Oversight of Dependency Determinations for Incapacitated Adult Children
Fast Facts
Military families with incapacitated adult children must provide medical and financial information to DOD to prove the child’s dependency. These families may lose healthcare benefits if their dependency applications are denied.
We found that DOD’s policy doesn’t give the military services enough information to make consistent decisions. For example, there isn’t much guidance on financial determinations, so each military service uses its own formula to calculate eligible expenses in dependency applications.
We recommended that DOD provide detailed guidance for financial determinations to ensure that all military families are treated equitably.
Stethoscope, calculator, medical bill
Highlights
What GAO Found
The military services have jointly established policy for determining the dependency status of incapacitated adult children of servicemembers. However, the policy provides limited guidance and inconsistent standards, resulting in the military services developing fragmented approaches for processing applications. For example, the policy provides limited information for making financial determinations. As a result, the Defense Finance and Accounting Service (DFAS) (which processes applications for the Army and the Air Force), the Navy, and the Marine Corps use different formulas to calculate eligible expenses, resulting in outcomes that vary among the military services (see figure). These outcomes may result in increased hardships for military families, including the loss of healthcare coverage and military base access. Providing detailed, specific guidance for financial determinations would enhance the equitable treatment of all military families.
Examples of Calculations of Incapacitated Adult Child Eligible Expenses
Note: Total eligible expenses are divided by two to determine whether the child's income exceeds 50 percent of their expenses. Monthly expenses and income are held constant for both families.
Department of Defense (DOD) oversight of the dependency determination process is limited, in part because policy does not clearly define oversight roles and responsibilities. Without clarifying oversight roles responsibilities, to include ensuring the consistent tracking, monitoring, and reporting of reliable applications and determinations data across the military services, DOD lacks visibility and relevant information to inform decision-making about the process. Without exercising oversight, DOD may be unaware of inconsistencies in the process and related outcomes.
Why GAO Did This Study
Military families with adult children who are incapable of self-support due to impairment face unique challenges, including the loss of healthcare and other benefits if these incapacitated adult children lose their dependency status.
Senate Report 115-262 included a provision for GAO to review DOD's dependency determination process for incapacitated adult children. This report assesses, among other things, the extent to which the military services have established policy for determining the dependency status of incapacitated adult children, and the extent to which DOD oversees dependency determinations, including tracking, monitoring, and reporting on applications and determinations. GAO reviewed relevant policies and guidance; interviewed DOD and military service officials and families involved in the dependency determination process; and analyzed program data.
Recommendations
GAO is making six recommendations, including that DOD provide detailed, specific guidance for financial determinations, and clearly define and exercise oversight roles and responsibilities. DOD concurred with two of GAO's recommendations and identified actions it plans to take to implement them. DOD partially concurred with four of GAO's recommendations. GAO continues to believe the recommendations are valid, as discussed in the report.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Defense | The Secretary of Defense should ensure that the Secretaries of the Military Departments revise AFI 36-3026, Volume 1, to provide detailed guidance for financial determinations and to establish consistent medical standards for all of the military services to use in determining the dependency status of incapacitated adult children, including what household and personal expenses and income are allowable, how these are to be calculated, and what medical documentation is required. (Recommendation 1) |
DOD concurred with this recommendation. In May 2021, DOD officials stated that a Secondary Dependency Claims Working Group has been established with the goal of proposing standards for secondary dependent financial dependency determinations, to include permanently incapacitated dependents, across the DOD. Officials stated that the Under Secretary of Defense for Personnel and Readiness (USD P&R) will evaluate the working group's recommendations and publish a USD P&R policy memorandum to establish detailed guidance for financial determinations and consistent medical documentation for all of the services to use in determining the dependency status of incapacitated adult children. In September 2023, DOD officials stated that the Working Group was coordinating a new instruction that will provide clear direction for the financial and medical determinations of incapacitated adult children. Officials also stated that AFI 36-3026, Volume 1 was being updated in conjunction with the new instruction with an expected completion date of October 2024. As of November 2024, the department was still working on these efforts and estimates completion in April 2025. We will follow-up to determine if DOD has implemented its planned actions after the expected April 2025 completion date.
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| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Secretaries of the Military Departments and the Director of the Defense Finance and Accounting Service, identifies and implements the most effective means to provide information to families of incapacitated adult children to assist them in completing the dependency determination process. Such methods could include providing additional application instructions to families, making improvements to the DD Form 137-5, Dependency Statement – Incapacitated Child Over Age 21, such as providing detailed explanations of allowable expenses and how they should be calculated, providing detailed information about available support services, and providing additional and more advance notice to families. (Recommendation 2) |
DOD partially concurred with this recommendation and noted that existing instructional tools exist to help families navigate the dependency determination process. However, DOD stated that a Under Secretary of Defense for Personnel and Readiness user group will identify additional means to improve the information available to military families. In November 2024, DOD stated that it is pursuing a web portal to establish a uniform method for submitting, tracking, and approving incapacitated adult child dependency applications. According to DOD the web portal will include information on the incapacitated adult child program and application. The web portal is expected to be completed by October 2025. Further, DOD stated that it is exploring options to provide information to ensure servicemembers are aware of the incapacitated adult child program. We will follow-up to determine if DOD has implemented its planned actions.
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| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness clearly defines oversight responsibilities of the Department of Defense Human Resources Activity and the military services for the incapacitated adult child dependency process, including the consistent tracking, monitoring, and reporting of reliable data on incapacitated adult child dependency applications and determinations across the military services for use in data-driven decision-making. (Recommendation 3) |
DOD partially concurred with this recommendation and stated that while current DOD guidance does not include specific oversight responsibilities for the incapacitated adult child program DOD concurred with the need for a single office to provide oversight of the program. DOD noted that the Under Secretary of Defense for Personnel and Readiness would identify the office and assign responsibility within 60 days of our report. In March 2021, the Under Secretary of Defense for Personnel and Readiness assigned oversight responsibility for the Department's permanently incapacitated dependent child program to the Office of the Assistant Secretary of Defense for Manpower and Reserve Affairs. In September 2023, DOD stated that the office of Military Personnel Policy has been identified as the lead office responsible for the incapacitated adult child dependency determination program and that it is preparing an instruction to establish responsibilities for other offices. In November 2024, DOD stated its updated instruction "Dependency Determinations for Incapacitated Adult Children" is under review. DOD expects the instruction to be signed in April 2025. We will follow-up to determine if DOD has implemented its planned actions.
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| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the Department of Defense Human Resources Activity to exercise its oversight responsibilities for the incapacitated adult child dependency process, as clarified, including the use of consistent and reliable data on applications and determinations for data-driven decision-making to identify and address deficiencies and to inform program efforts. (Recommendation 4) |
DOD partially concurred with this recommendation, however DOD noted that it would address the recommendation after it takes action on our recommendation related to defining oversight responsibilities for the incapacitated adult child dependency determination process. In March 2021, the Under Secretary of Defense for Personnel and Readiness assigned oversight responsibility for the Department's permanently incapacitated dependent child program to the Office of the Assistant Secretary of Defense for Manpower and Reserve Affairs. As of August 2021, DOD has not provided us with any additional actions taken. When we confirm what actions the Office of the Assistant Secretary of Defense for Manpower and Reserve Affairs has taken in response to this recommendation, we will provide updated information. In September 2023, DOD stated that the office of Military Personnel Policy has been identified as the lead office responsible for the incapacitated adult child dependency determination program and that it is preparing an instruction to establish responsibilities for other offices. In November 2024, DOD stated that its updated instruction "Dependency Determination for Incapacitated Adult Children" is under review. DOD expected the instruction to be signed in April 2025. We will follow-up to determine if DOD has implemented its planned actions.
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| Department of Defense | The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness clarifies the definition of a nondependent family member in DOD Instruction 1315.19 and the circumstances under which nondependent family members should be considered for services provided by the Exceptional Family Member Program. (Recommendation 5) |
DOD concurred with this recommendation and stated that it will review its policy to determine if the definition of a nondependent family member continues to be current and appropriate. In September 2023, DOD stated that it was updating DOD Instruction 1315.19. DOD expects to complete the update by May 2025. As of August 2024, the department was still working on updating the DOD instruction. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
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| Department of Defense | The Secretary of Defense should ensure that the Secretaries of the Military Departments revise military service-level policy to ensure consistency with the DOD Instruction 1315.19 definition of nondependent family members and the circumstance under which a nondependent family member should be considered for services provided by the Exceptional Family Member Program. (Recommendation 6) |
DOD partially concurred with this recommendation and stated that if DOD determines the current definition of a nondependent family member is no longer appropriate, it will ensure that Service-level policies will be revised to be consistent with the definition. As of September 2023, DOD stated that it was updating DOD Instruction 1315.19. DOD expects to complete these updates by May 2025. As of August 2024, the department was still working on updating the DOD instruction. When we confirm what actions the agency has taken, we will update this information.
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