Defense Health Care: DOD Needs to Clarify Policies Related to Occupational and Environmental Health Surveillance and Monitor Risk Mitigation Activities
Highlights
What GAO Found
Inconsistencies between Department of Defense (DOD) and military service-specific policies regarding occupational and environmental health surveillance (OEHS) data storage have contributed to fragmentation and duplication of OEHS data between two information technology systems—the Military Exposure Surveillance Library (MESL) and the Defense Occupational and Environmental Health Readiness System (DOEHRS). Not having consistent policies for which system should be used to store OEHS data is contrary to federal standards for internal control. As a result, officials' efforts to store these data have resulted in both fragmentation and duplication, which GAO's prior work has shown may result in inefficiencies. Correspondingly, in some cases, similar types of unclassified OEHS data are being submitted to both MESL and DOEHRS, and in other cases, identical OEHS data are being submitted to both systems. However, neither system serves as a central repository for these data, and as a result, it is difficult to identify complete and comprehensive OEHS data sets, which may lead to problems when officials attempt to use these data in the future. Additionally, DOD's policy for OEHS data does not specifically address quality assurance. Consequently, some of the military services have developed their own guidance, resulting in inconsistent approaches and levels of effort, which has reduced DOD's ability to be confident that the data are sufficiently reliable. Federal standards for internal control state that management should continually monitor information captured and maintained for several factors, including reliability.
The military services use site assessments to identify and address potential occupational and environmental health risks at a deployment site. These assessments may include recommended countermeasures, such as the use of personal protective equipment. However, the extent to which these recommendations are being implemented is unclear because U.S. Central Command (CENTCOM)—the combatant command responsible for military operations in the geographic area that includes Iraq and Afghanistan—does not require base commanders to document their decisions on implementing them. Officials also said they are not monitoring these recommendations, and instead rely on others to elevate concerns, as necessary. In contrast, DOD's policy for its safety and occupational health program requires the department's components, including the combatant commands, to ensure that risk management decisions are documented and reevaluated. Federal standards for internal control also note that appropriate documentation is a key internal control activity and that agencies should monitor their activities for managing identified risks.
Both DOD and the Department of Veterans Affairs (VA) have used OEHS data to a limited extent to address post-deployment health conditions. For example, DOD officials said that the primary limitation with OEHS data collected during deployments continues to be the inability to capture exposure data at the individual servicemember level, although a method to do so is currently being explored. Additionally, DOD and VA use OEHS data to conduct research that may help determine service connections for post-deployment health conditions, but it has been difficult for researchers to establish a causal link between exposures and specific health conditions.
Why GAO Did This Study
OEHS is the regular collection and reporting of occupational and environmental health hazard data that can be used to help prevent, treat, or control disease or injury. In 2005, GAO reported that DOD needed to make improvements with OEHS during deployments to address immediate and long-term health issues.
GAO was asked to assess DOD's current OEHS efforts. This report examines (1) the extent to which the military services centrally store OEHS data and verify its reliability; (2) how, if at all, DOD identifies potential occupational and environmental health risks for sites in Iraq and Afghanistan, and to what extent these risks are mitigated; and (3) the extent to which DOD and VA use OEHS data to address post-deployment health conditions. GAO reviewed and analyzed DOD and military service policies on OEHS data storage and quality assurance, as well as policies related to conducting and monitoring assessments for deployment sites. GAO also interviewed DOD, military service, and VA officials, as well as groups representing servicemembers and veterans.
Recommendations
GAO recommends that DOD clarify its policies for the storage and quality assurance of OEHS data, and require other related policies to be amended accordingly. GAO also recommends that CENTCOM revise its policy to require adequate documentation and consistent monitoring of deployment risk mitigation activities. In commenting on the report, DOD concurred with GAO's recommendations, and VA generally agreed with the conclusions.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Defense | To eliminate the fragmentation and duplication in the storage of unclassified OEHS data, the Secretary of Defense should determine which IT system--DOEHRS or MESL--should be used to store specific types of unclassified OEHS data, clarify the department's policy accordingly, and require all other departmental and military-service-specific policies to be likewise amended and implemented to ensure consistency. |
In February 2018, the Department of Defense (DOD) informed GAO that it determined that all unclassified OEHS data would be stored in DOEHRS because the MESL system was terminated following the transfer of all unclassified OEHS data from MESL to DOEHRS in September 2017. In 2019, DOD updated its department's policies (DOD Instruction 6490.03 in June 2019, and Defense Health Agency Procedural Instruction 6490.03 in December 2019) to clarify the department's decision. These policies also required other military-service-specific policies to be likewise amended and implemented to ensure consistency, which was completed in February 2020.
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| Department of Defense | To ensure the reliability of OEHS data, the Secretary of Defense should establish clear policies and procedures for performing quality assurance reviews of the OEHS data collected during deployment, to include verifying the completeness and the reasonableness of these data, and require that all other related military-service-specific policies be amended and implemented to ensure consistency. |
DOD concurred with our recommendation and has made several corresponding updates to its policies related to quality assurance for occupational and environmental health surveillance (OEHS) data. Specifically, DOD Instruction 6490.03 (Deployment Health) was updated in June 2019 and directed the military services to establish clear procedures for quality assurance reviews of deployment OEHS data, to include verifying the completeness and reasonableness of these data, and to ensure consistency. In addition, in January 2023 a joint publication for all of the military services-"Occupational and Environmental Health Site Surveillance at Deployment Locations"-was revised to include steps on data verification, data validation (completeness and reasonableness), and data assessment. As such, we are closing this recommendation as implemented.
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| Department of Defense | To ensure that potential occupational and environmental health risks are mitigated for servicemembers deployed to Iraq and Afghanistan, the Secretary of Defense should require CENTCOM to revise its policy to ensure that base commanders' decisions on whether to implement risk mitigation recommendations identified in OEHSAs are adequately documented and consistently monitored by the appropriate command. |
In June 2019, DOD revised DOD Instruction 6490.03, which directs the Combatant Commanders to ensure that commanders' decisions on whether to implement risk recommendations are adequately documented and consistently monitored by the appropriate command. In May 2020, CENTCOM revised its Central Command Regulation 40-2, which likewise required that these decisions be documented and also consistently monitored on at least an annual basis by the CENTCOM or appropriate Joint Task Force Commander.
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