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

GAO-15-266 Published: Feb 13, 2015. Publicly Released: Feb 13, 2015.
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Highlights

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.

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.

Recommendations

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.

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Defense 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, the Secretary of Defense should 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.
Closed – Implemented
DOD partially concurred with our recommendation. In July 2015, the Department chartered a Military Service Member Separation Standardization Workgroup comprised of representatives from each Military Department, the Military Services (including the Coast Guard), the National Guard Bureau, and the Defense Data Management Center, among others. The Workgroup was charged with making recommendations to ensure reasons for separation, characterization of service, and the associated codes, particularly separation codes, were consistently applied across the military services. One of the Workgroup's tasks was to provide a comprehensive review of those codes, categorizing active and inactive codes, and clarifying linkage to benefits. The Workgroup completed this task, and as of July 1, 2018, the military services must use the "condition, not a disability" separation code family for separations based on such conditions. Further, the services must properly code and track the underlying condition used as the basis for separation within appropriate medical data systems.
Department of Defense 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, the Secretary of Defense should 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.
Closed – Implemented
DOD concurred with our recommendation. In May 2019, the Air Force National Guard Bureau released a policy memo regarding compliance reporting for non-disability mental condition separations. This memo included process steps for separating National Guard members with a non-disability mental condition, as well as a required separation checklist to ensure National Guard members are separated in accordance with DOD policy and separations are appropriately documented. Further, the memo stated that a random sampling of at least ten percent of all Air National Guard separations on the basis of non-disability mental conditions will be completed, and if non-compliance is detected, a corrective action plan must be completed on the deficiency.
Department of Defense 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, the Secretary of Defense should 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.
Closed – Implemented
DOD concurred with our recommendation. As of November 2019, the four military services--Army, Air Force, Navy and Marine Corps--have updated their administrative separation policies to be consistent with DOD regulations for those service members separated for all non-disability mental conditions.
Department of Defense 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, the Secretary of Defense should 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.
Closed – Implemented
DOD concurred with our recommendation. In August 2016, the Department reinstated the requirement of annual compliance reporting of a sample of administrative separations. Military services were required to submit compliance reports for fiscal years 2016 and 2017. Further, in August 2018, the Department issued a policy memo stating that while incremental progress across the military services had been made, full compliance had not been achieved. The memo further stated that because of uneven compliance and recent changes to policy, the military services are to continue compliance reporting for another 2 years-fiscal years 2018 and 2019.
Department of Defense 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, the Secretary of Defense should 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.
Closed – Implemented
DOD concurred with our recommendation. In June 2016, Army stated that, through the Office of the Surgeon General, it had begun conducting quarterly reviews in fiscal year 2016 of all administrative separations coded as "condition, not a disability" for behavioral health conditions in previously deployed servicemembers on active duty. Further, Army stated that the Office of the Surgeon General has developed an automated system to track administrative separations of all servicemembers on active duty. In June 2019, Army provided GAO with the results of the most recent quarterly reviews conducted by the Office of the Surgeon General in fiscal year 2018. Additionally, Army provided a workflow guide and related checklist for processing non-disability mental conditions separations that, according to officials, applies to all active duty, National Guard and reserve servicemembers. However, according to Army, as of July 2019, there have been no administrative separations for non-disability mental conditions for reservists or National Guard members so the workflow guide and checklist have not yet been used for these servicemembers. Army's intent to use these documents, as well as the inclusion of reservists and National Guard members in Army's annual compliance reporting required by DOD (see recommendation 4), should help ensure such separations are compliant with DOD requirements.
Department of Defense 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, the Secretary of Defense should 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.
Closed – Implemented
DOD concurred with our recommendation. In July 2015, the Department chartered a Military Service Member Separation Standardization Workgroup comprised of representatives from each Military Department, the military services (including the Coast Guard), the National Guard Bureau, and the Defense Data Management Center, among others, and since August 2015, the Workgroup has been meeting. The Workgroup was charged with making recommendations to ensure reasons for separation, characterization of service, and the associated codes, particularly separation program designator (SPD) codes, were consistently applied across the military services. One of Workgroup's tasks was to provide a comprehensive review of those codes, categorizing active and inactive codes, and clarifying linkage to benefits. The Workgroup completed this task, and as of July 1, 2018, the military services must use the "condition, not a disability" SPD code family for separations based on such conditions. Further, the services must properly code and track the underlying condition used as the basis for separation within appropriate medical data systems in accordance with DOD Instruction 6040.42, "Management Standards for Medical Coding of DOD Health Records." Additionally, in September 2018, DOD stated that given the success of the Workgroup, it will be codified as a standing workgroup in the next major update to appropriate Department policy instructions.

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Topics

Aid for the disabledDisease detection or diagnosisHealth care servicesIdentification codesInternal controlsMental health care servicesMilitary forcesMilitary medical dischargesMilitary personnelPeople with disabilitiesReporting requirementsVeterans benefitsPolicies and procedures