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entitled 'Defense Health Care: Additional Efforts Needed to Ensure
Compliance with Personality Disorder Separation Requirements' which was
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Report to Congressional Addressees:
United States Government Accountability Office:
GAO:
October 2008:
Defense Health Care:
Additional Efforts Needed to Ensure Compliance with Personality
Disorder Separation Requirements:
GAO-09-31:
GAO Highlights:
Highlights of GAO-09-31, a report to congressional addressees.
Why GAO Did This Study:
At DOD, a personality disorder can render a servicemember unsuitable
for service. GAO was required to report on personality disorder
separations and examined (1) the extent that selected military
installations complied with DOD’s separation requirements and (2) how
DOD ensures compliance with these requirements. GAO reviewed a sample
of 312 servicemembers’ records from four installations, representing
the Army, Air Force, and Marine Corps, that had the highest or second
highest number of Operation Enduring Freedom or Operation Iraqi Freedom
servicemembers separated because of a personality disorder. The review
is generalizable to the installations, but not to the services. GAO
also reviewed 59 Navy servicemembers’ records, but this review is not
generalizable to the installation or the Navy because parts of the
separation process could have been completed at multiple locations.
What GAO Found:
GAO’s review of enlisted servicemembers’ records found that the
selected military installations GAO visited varied in their documented
compliance with DOD’s requirements for personality disorder
separations. DOD has requirements for separations because of a
personality disorder, which is defined as an enduring pattern of
behavior that deviates markedly from expected behavior and has an onset
in adolescence or early adulthood. The three key requirements
established by DOD are that enlisted servicemembers (1) must be
notified of their impending separation because of a personality
disorder, (2) must be diagnosed with a personality disorder by a
psychiatrist or psychologist who determines that servicemembers’
personality disorder interferes with their ability to function in the
military, and (3) must receive formal counseling about their problem
with functioning in the military. For the four installations,
compliance with the notification requirement was at or above 98
percent. The compliance rates for the requirement related to the
personality disorder diagnosis ranged from 40 to 78 percent. For the
requirement for formal counseling, compliance ranged from 40 to 99
percent. GAO’s review of the documentation in the enlisted Navy
servicemembers’ records found that compliance varied by requirement.
Ninety-five percent of enlisted Navy servicemembers’ records had
documentation indicating that enlisted servicemembers had been notified
of their impending separation because of a personality disorder. Eighty-
two percent had documentation that indicated compliance with the
requirement that enlisted servicemembers must be diagnosed with a
personality disorder by a psychiatrist or psychologist who determines
that the personality disorder interferes with servicemembers’ ability
to function in the military. Seventy-seven percent had documentation
indicating compliance with the requirement for formal counseling.
DOD does not have reasonable assurance that its key personality
disorder separation requirements have been followed. DOD policy directs
the military services to implement and ensure consistent administration
of DOD’s requirements for separating enlisted servicemembers because of
a personality disorder. According to military service officials, the
military services delegate to commanders with separation authority at
military installations sole responsibility for ensuring that the
separation requirements are followed for enlisted servicemembers under
their command. When asked about the low rates of compliance for some of
the separation requirements that GAO found, military officials
responsible for reviewing the servicemembers’ records with whom GAO
spoke could not explain why these separations were approved if
compliance with the separation requirements was not documented in the
servicemembers’ records. The military services have not established a
way to determine whether the commanders with separation authority are
ensuring that DOD’s key separation requirements are met, and DOD does
not have reasonable assurance that its requirements have been followed.
What GAO Recommends:
GAO recommends that DOD (1) ensure that the services’ personality
disorder separations comply with DOD’s requirements and (2) monitor the
services’ compliance. DOD concurred with GAO’s first recommendation and
partially concurred with the other. DOD stated that it will strengthen
policy guidance for the services’ compliance reporting, but stated that
it is the responsibility of the services to ensure compliance. However,
GAO’s review indicates that reliance on the services is insufficient to
ensure compliance.
To view the full product, including the scope and methodology, click on
[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-09-31]. For more
information, contact Randall B. Williamson at (202) 512-7114 or
williamsonr@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Selected Military Installations' Compliance with Three Key Personality
Disorder Separation Requirements Varied:
DOD Does Not Have Reasonable Assurance That Its Separation Requirements
Have Been Followed:
Enlisted Servicemembers' Selection of Protections Available During and
After Separation Varied:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Comments from the Department of Defense:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Criteria to Determine Compliance from Review of Separation
Packets in Enlisted Servicemembers' Personnel Records:
Table 2: Criteria to Determine Compliance from Review of Separation
Packets in Enlisted Servicemembers' Personnel Records:
Figures:
Figure 1: Rate of Documented Compliance at Selected Military
Installations with Requirement That Enlisted Servicemembers Be
Diagnosed with a Personality Disorder by a Psychiatrist or Psychologist
Who Determines That the Personality Disorder Interferes with
Servicemembers' Ability to Function in the Military, for Separations
Completed from November 1, 2001, through June 30, 2007:
Figure 2: Rate of Documented Compliance at Selected Military
Installations with Requirement That Enlisted Servicemembers Receive
Formal Counseling about Their Problem with Functioning in the Military,
for Separations Completed from November 1, 2001, through June 30, 2007:
Abbreviations:
DMDC: Defense Manpower Data Center:
DOD: Department of Defense:
DSM: Diagnostic and Statistical Manual of Mental Disorders:
OEF: Operation Enduring Freedom:
OIF: Operation Iraqi Freedom:
PTSD: post-traumatic stress disorder:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
October 31, 2008:
Congressional Addressees:
The Department of Defense (DOD) requires that all servicemembers,
including those who serve in Operation Enduring Freedom (OEF) and
Operation Iraqi Freedom (OIF), be physically and psychologically
suitable for military service.[Footnote 1] Enlisted servicemembers who
fail to meet this standard may be separated from the military.[Footnote
2] One psychological condition that can render a servicemember
unsuitable for military service is a 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.[Footnote 3]
Such a condition may make one unable to work within a military
environment. DOD data show that from November 1, 2001, through June 30,
2007, about 26,000 enlisted servicemembers were separated from the
military because of a personality disorder.[Footnote 4] Of these
26,000, about 2,800 had deployed at least once in support of OEF/OIF.
Accurately diagnosing OEF/OIF servicemembers with a personality
disorder can be challenging. Specifically, some of the symptoms of a
personality disorder--irritability, feelings of detachment or
estrangement from others, and aggressiveness--are similar to the
symptoms of post-traumatic stress disorder (PTSD), a condition for
which some OEF/OIF servicemembers may also be at risk. However,
according to mental health experts and military mental health
providers, one important difference between a personality disorder and
PTSD is that a personality disorder is a long-standing condition,
whereas PTSD is a condition that follows exposure to a traumatic event.
Although servicemembers with personality disorders may have symptoms
that first appear during their military duty, DOD does not consider
this to be a condition caused by military service. A separation from
the military because of a personality disorder can be stigmatizing and
can have adverse consequences for servicemembers, such as limiting
employment opportunities after servicemembers leave the military.
DOD has established three key requirements that the military services-
-Army, Air Force, Navy, and Marine Corps--must follow when separating
enlisted servicemembers because of a personality disorder.[Footnote 5]
Specifically, before they are separated because of a personality
disorder, enlisted servicemembers:
* must receive notification of their impending separation because of a
personality disorder;
* must receive, prior to the notification, a diagnosis of personality
disorder by a psychiatrist or psychologist[Footnote 6] who determines
that the personality disorder interferes with servicemembers' ability
to function in the military; and:
* must receive formal counseling about their problem with functioning
in the military.[Footnote 7]
Typically, an enlisted servicemember's commander initiates the
separation process. This commander, as well as a psychiatrist or
psychologist, must follow the requirements established by DOD when
separating a servicemember because of a personality disorder.
Additionally, servicemembers undergoing the separation process have
various protections available to them. For example, servicemembers may
meet with a military attorney to discuss their rights during the
separation process.
Congress included provisions in the National Defense Authorization Act
for Fiscal Year 2008 that require us to review and report on OEF/OIF
servicemembers' separations from military service because of a
personality disorder,[Footnote 8] and 11 senators also expressed
interest in this work. For our review, we examined (1) the extent to
which selected military installations complied with DOD requirements
for separating enlisted servicemembers because of a personality
disorder, (2) how DOD ensures compliance by the military services with
personality disorder separation requirements, and (3) the extent to
which enlisted servicemembers selected the protections available to
them.
To determine the extent to which selected military installations
[Footnote 9] complied with DOD's personality disorder separation
requirements, we reviewed DOD and the military services' separation
regulations and instructions to identify the key requirements for
separating enlisted servicemembers because of a personality disorder.
We included only enlisted servicemembers because officers generally are
able to resign at any time rather than be involuntarily separated. We
obtained DOD data for enlisted OEF/OIF servicemembers separated because
of a personality disorder from November 1, 2001, through June 30, 2007,
which we determined to be sufficiently reliable for our purposes by
corroborating these data with information in the servicemembers'
personnel records. We analyzed these data to determine which
installations across the military services had the highest number of
enlisted OEF/OIF servicemembers separated because of a personality
disorder. We selected four installations to visit-- Fort Carson (Army),
Fort Hood (Army), Davis-Monthan Air Force Base (Air Force), and Camp
Pendleton (Marine Corps)--because these installations accounted for the
highest or second highest number of enlisted OEF/OIF servicemembers
separated because of a personality disorder from November 1, 2001,
through June 30, 2007, among their military service's installations.
[Footnote 10],[Footnote 11] For three of the installations we visited,
we obtained and reviewed personnel records for a random sample of
enlisted servicemembers whose certificates of release[Footnote 12]
indicated that they were separated from these installations because of
a personality disorder. For the fourth installation, we obtained and
reviewed personnel records for all of the enlisted servicemembers whose
certificates of release indicated that they were separated from that
installation because of a personality disorder. We reviewed all of
these enlisted servicemembers' records because the total number of
servicemembers separated from this installation was too small to draw a
random, generalizable sample. Our findings based on our compliance
review can be generalized to each of the four installations but cannot
be generalized to the military services.
In addition to the four military installations from the Army, Air
Force, and Marine Corps, we visited Naval Base San Diego. We obtained
and reviewed personnel records for enlisted Navy servicemembers whose
certificates of release indicated that they were separated because of a
personality disorder. During the course of our review, Navy officials
at this base told us that enlisted Navy servicemembers selected for our
review were transferred to the transient personnel unit at Naval Base
San Diego from a Navy ship at various points in the separation process.
[Footnote 13] According to a Navy official, most enlisted Navy
servicemembers were diagnosed, formally counseled, and notified of
their impending separation while on board a Navy ship and were
transferred to the transient personnel unit at Naval Base San Diego to
receive their certificates of release. Other enlisted Navy
servicemembers were diagnosed, formally counseled, and notified of
their impending separation while at Naval Base San Diego. We could not
generalize our findings to Naval Base San Diego because some of the
elements of the separation process could have been completed while
these servicemembers were on board a Navy ship. We also could not
generalize to the Navy. Therefore, we have reported the results of our
review of enlisted Navy servicemembers' records separately from our
presentation of findings based on our review of the other four military
installations.
For our compliance review, we examined 312 personnel records for
enlisted servicemembers from the Army, Air Force, and Marine Corps
installations and 59 records for enlisted servicemembers from the Navy-
-371 records in total. We obtained these records from each military
service's central repository, where the personnel records of
servicemembers who have been separated from the military are stored. In
each of these records, we reviewed what is known as a separation
packet, which is required to contain documents related to a
servicemember's separation.[Footnote 14] According to military service
officials responsible for the separation policy, the separation packet
is required to include documentation demonstrating that DOD's three key
requirements for a personality disorder separation have been met.
To complete our compliance review, we reviewed servicemembers'
separation packets first to see if the packets contained documentation
that servicemembers had been notified of their impending separation
because of a personality disorder. If the servicemembers' separation
packets lacked such documentation, we did not assess compliance for the
other two key separation requirements. If the packets did include such
documentation, we reviewed the packets to determine whether they
contained documentation required by the military services demonstrating
that the other two key requirements had been met. Table 1 describes the
criteria we used to determine compliance.
Table 1: Criteria to Determine Compliance from Review of Separation
Packets in Enlisted Servicemembers' Personnel Records:
Requirement: Servicemembers must be notified of the separation because
of a personality disorder;
Compliance: Separation packet contained a notification letter of the
separation because of a personality disorder;
Noncompliance: Separation packet did not contain a notification letter
of the separation because of a personality disorder.
Requirement: Servicemembers must receive a personality disorder
diagnosis by a psychiatrist or psychologist who determines that the
personality disorder interferes with servicemembers' ability to
function in the military;
Compliance: Separation packet contained what is known as a medical form
that documents the following three parts of this requirement: (a) A
diagnosis of personality disorder; (b) Made by psychiatrist or
psychologist; (c) Who determines that the personality disorder
interferes with servicemembers' ability to function in the military;
Noncompliance: Separation packet did not contain a medical form; or;
Separation packet included a medical form, but documentation supporting
one or more of the following parts of this requirement was missing or
was incorrect: (a) A diagnosis of personality disorder; (b) Made by
psychiatrist or psychologist; (c) Who determines that the personality
disorder interferes with servicemembers' ability to function in the
military.
Requirement: Servicemembers must be formally counseled about their
problem with functioning in the military;
Compliance: Separation packet contained a counseling form;
Noncompliance: Separation packet did not include a counseling form.
Source: GAO analysis of DOD's and military services' separation
regulations and instructions.
[End of table]
To determine how DOD ensures compliance with its personality disorder
separation requirements by the military services, we reviewed DOD
regulations and interviewed officials from DOD and the military
services. To determine the extent to which enlisted servicemembers
selected the protections available to them, such as consulting legal
counsel prior to being separated, we reviewed the same 371 enlisted
servicemembers' separation packets as we reviewed to determine
compliance with DOD's personality disorder separation requirements--
312 separation packets for enlisted servicemembers from the Army, Air
Force, and Marine Corps installations and 59 separation packets for
enlisted servicemembers from the Navy.[Footnote 15] For the 371
enlisted servicemembers whose separation packets we reviewed, we also
obtained information from the military services to determine whether
any of these servicemembers appealed the reason for their separation.
Appendix I provides more detailed information on our methodology. We
conducted this performance audit from May 2007 through August 2008 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.
Results in Brief:
The four military installations we visited varied in their compliance
with DOD's three key requirements for personality disorder separations.
For the four installations, compliance with the requirement to notify
enlisted servicemembers of their impending separation because of a
personality disorder was at or above 98 percent. The compliance rates
for the requirement that enlisted servicemembers must be diagnosed with
a personality disorder by a psychiatrist or psychologist who determines
that the personality disorder interferes with servicemembers' ability
to function in the military ranged from 40 to 78 percent. For the
requirement that enlisted servicemembers be formally counseled about
their problem with functioning in the military, compliance ranged from
40 to 99 percent. Our review of the documentation in the enlisted Navy
servicemembers' separation packets found that compliance varied by
requirement. Ninety-five percent of enlisted Navy servicemembers'
separation packets had documentation indicating that they had been
notified of their impending separation because of a personality
disorder. Eighty-two percent had documentation that indicated
compliance with the requirement that enlisted servicemembers must be
diagnosed with a personality disorder by a psychiatrist or psychologist
who determines that the personality disorder interferes with
servicemembers' ability to function in the military. Seventy-seven
percent had documentation indicating compliance with the requirement
for formal counseling.
DOD does not have reasonable assurance that its key personality
disorder separation requirements have been followed. DOD policy directs
the military services to implement and ensure consistent administration
of DOD's requirements for separating enlisted servicemembers because of
a personality disorder. In turn, according to officials in each of the
military services, the military services delegate to commanders with
separation authority at military installations sole responsibility for
ensuring that the key separation requirements are followed for enlisted
servicemembers under their command. When asked about the low rates of
compliance for some of the separation requirements that we found, the
military officials responsible for reviewing the separation packets
with whom we spoke could not explain why these separations were
approved if compliance with the separation requirements was not
documented in the servicemembers' separation packets. The military
services have given commanders with separation authority sole
responsibility for ensuring compliance with DOD's requirements, but the
military services have not established a way to determine whether these
commanders are ensuring that DOD's key separation requirements are met.
Furthermore, DOD does not have reasonable assurance that its
requirements for separating enlisted servicemembers because of a
personality disorder have been followed.
The extent to which enlisted servicemembers from the four installations
selected the protections available to them varied. For example, the
majority of enlisted servicemembers--about 93 percent--requested copies
of the separation documents, while few enlisted servicemembers-
-12 percent--indicated that they wanted to submit statements on their
own behalf to the commander with separation authority. Among enlisted
Navy servicemembers, 66 percent requested copies of their separation
documents, while 5 percent stated that they wanted to submit statements
on their own behalf to the commander with separation authority. After
separation had occurred, three enlisted servicemembers from the four
installations we visited and among enlisted Navy servicemembers whose
separation packets we reviewed chose to challenge the reason for their
separation.
To help ensure that DOD's requirements for personality disorder
separations are met and to help increase assurance that these
separations are appropriate, we recommend that the Secretary of Defense
direct the Under Secretary of Defense for Personnel and Readiness to
(1) direct the Secretaries of the Army, the Air Force, and the Navy and
the Commandant of the Marine Corps to develop a system to ensure that
personality disorder separations are conducted in accordance with DOD's
requirements and (2) ensure that DOD monitors the military services'
compliance with DOD's personality disorder separation requirements. In
written comments on a draft of this report, DOD concurred with our
recommendation that the military services develop a system to ensure
that personality disorder separations be conducted in accordance with
DOD's requirements. DOD partially concurred with our recommendation
that DOD monitor the military services' compliance with DOD's
personality disorder separation requirements. DOD stated that it will
strengthen policy guidance related to the military services'
standardized compliance reporting, but that it is the responsibility of
the military services to ensure compliance with DOD policy. However, as
we stated in our draft report, DOD's reliance on the military services
to ensure compliance with its separation requirements does not provide
reasonable assurance that these requirements will be followed. The low
rates of compliance we found for some of DOD's key personality disorder
separation requirements suggest the need for another system to ensure
compliance with these requirements, as well as the need for DOD to
monitor the military services' compliance. DOD also provided technical
comments, which we incorporated as appropriate.
Background:
Enlisted servicemembers can be separated from the military when they
are found to be unsuitable for continued military service. According to
DOD regulations, enlisted servicemembers can be separated for reasons
such as misconduct, failure to overcome substance abuse, and certain
mental health conditions, including a personality disorder. A
personality disorder by itself does not make enlisted servicemembers
unsuitable for military service. DOD requires that the disorder be
severe enough that it interferes with an enlisted servicemember's
ability to function in the military.[Footnote 16]
DOD and the military services require that to diagnose a personality
disorder a psychiatrist or psychologist use criteria established in the
Diagnostic and Statistical Manual of Mental Disorders (DSM), which was
developed by the American Psychiatric Association.[Footnote 17]
Similarly, in the private sector, clinicians use criteria in the DSM to
diagnose a personality disorder, but in some instances, clinicians
other than psychiatrists or psychologists, such as licensed clinical
social workers, may make this diagnosis.
Diagnosing a personality disorder in a servicemember who has served in
combat can be complicated by the fact that some symptoms of a
personality disorder may be similar to symptoms of combat-related
mental health conditions. For example, both personality disorder and
PTSD have similar symptoms of feelings of detachment or estrangement
from others, and irritability. According to the American Psychiatric
Association and the American Psychological Association, the only way to
distinguish a personality disorder from a combat-related mental health
condition, such as PTSD, is by getting an in-depth medical and personal
history from the servicemember that is corroborated, if possible, by
family and friends.
According to DOD officials, the three key requirements that the
military services must follow when separating an enlisted servicemember
are designed to help ensure that enlisted servicemembers are separated
for the appropriate reason.[Footnote 18],[Footnote 19] Documentation of
compliance with these requirements is to be included in the separation
packet found in the enlisted servicemember's personnel record, as
required by the military services. The separation packet is required to
contain other documents related to the enlisted servicemember's
separation. According to officials from the military services, the
servicemember's immediate commander gives the separation packet to an
installation official who is to review the packet to verify that the
requirements for the personality disorder separation have been met. If
this review verifies that the requirements have been met, the
separation packet is then sent to a commander at the installation who
has authority for approving a personality disorder separation for that
enlisted servicemember. This commander is a higher-level officer than
the enlisted servicemember's immediate commander. A military
installation may have more than one commander who has the authority to
approve separations because of a personality disorder. However, each
commander with separation authority approves separations only for
enlisted servicemembers under his or her command.
Once enlisted servicemembers have been separated from military service,
they receive certificates of release from the military, which include
information on the reason for separation and an official
characterization of their time in the service.[Footnote 20] For
enlisted servicemembers separated because of a personality disorder,
their certificates of release would state that the reason for their
separation was a personality disorder. Employers may request to see
separated servicemembers' certificates of release to verify their
military service, and employers may make employment decisions based on
the information they see on servicemembers' certificates of release.
Enlisted servicemembers have protections available to them when going
through the separation process. All enlisted servicemembers can submit
statements on their own behalf to the commander with separation
authority, consult with legal counsel prior to separation, and obtain
copies of the separation packet that is sent to the commander with
separation authority. In addition, enlisted servicemembers with 6 or
more years of military service are eligible to request a hearing before
an administrative board.[Footnote 21] An administrative board hearing
allows enlisted servicemembers to have legal representation, call
witnesses, and speak on their own behalf in defending against the
recommended separation. The board includes at least three members who,
following a hearing, make a recommendation to the commander with
separation authority as to whether the enlisted servicemember should be
separated.
Enlisted servicemembers also have protections available to them after
they have been separated. They may challenge the reasons given for
their separations after they have been separated from the military.
Within 15 years after separation from the military, enlisted
servicemembers may appeal their separation to a discharge review board.
Further, enlisted servicemembers may appeal the discharge review
board's decision by applying to a board for the correction of military
records.[Footnote 22]
Selected Military Installations' Compliance with Three Key Personality
Disorder Separation Requirements Varied:
The four military installations we visited varied in their compliance
with DOD's three key requirements for personality disorder separations.
For the four installations, compliance with the first requirement--to
notify enlisted servicemembers of their impending separation because of
a personality disorder--was at or above 98 percent. For the second
requirement, that enlisted servicemembers must be diagnosed with a
personality disorder by a psychiatrist or psychologist who determines
that the personality disorder interferes with servicemembers' ability
to function in the military, the compliance rates ranged from 40 to 78
percent. Compliance ranged from 40 to 99 percent for the third
requirement, that enlisted servicemembers receive formal counseling
about their problem with functioning in the military. Our review of the
documentation in the enlisted Navy servicemembers' separation packets
found that compliance varied by requirement.
Compliance with the Notification Requirement Ranged from 98 to 100
Percent:
Across the four installations, the percentage of enlisted
servicemembers' separation packets that documented compliance with the
notification requirement ranged from 98 to 100 percent. Of the 312
enlisted servicemembers' separation packets included in our review,
only 4 did not contain documentation that the servicemembers received
notification that they were being separated because of a personality
disorder. We did not assess whether the separation packets for these 4
servicemembers had documentation that indicated compliance for the
remaining two key separation requirements.
Compliance with the Requirement Related to the Personality Disorder
Diagnosis Ranged from 40 to 78 Percent:
Across the four installations, the percentage of enlisted
servicemembers' separation packets that had documentation indicating
compliance with all three parts of the second requirement--that
enlisted servicemembers separated because of a personality disorder (1)
be diagnosed with a personality disorder (2) by a psychiatrist or
psychologist who (3) determines that the personality disorder
interferes with servicemembers' ability to function in the military--
ranged from 40 to 78 percent. Noncompliance with this requirement
occurred in two ways: enlisted servicemembers' separation packets did
not contain the medical form used to document the three parts of this
requirement or servicemembers' separation packets contained the medical
form but documentation on the form for one or more of the three parts
of this requirement was missing or incorrect. Figure 1 summarizes the
four installations' compliance rates for this requirement.
Figure 1: Rate of Documented Compliance at Selected Military
Installations with Requirement That Enlisted Servicemembers Be
Diagnosed with a Personality Disorder by a Psychiatrist or Psychologist
Who Determines That the Personality Disorder Interferes with
Servicemembers' Ability to Function in the Military, for Separations
Completed from November 1, 2001, through June 30, 2007:
[See PDF for image]
This figure is a stacked vertical bar graph depicting the following
data:
Installation: A;
Compliance–Medical form was present and documentation on the form
supported all|three parts of this requirement: 40%;
Noncompliance–Medical form was present but documentation on the form
supporting|one or more of the three parts of this requirement was
missing or incorrect: 60%;
Noncompliance–Medical form was missing: 0.
Installation: B;
Compliance–Medical form was present and documentation on the form
supported all|three parts of this requirement: 72.7%;
Noncompliance–Medical form was present but documentation on the form
supporting|one or more of the three parts of this requirement was
missing or incorrect: 24.2%;
Noncompliance–Medical form was missing: 3%.
Installation: C;
Compliance–Medical form was present and documentation on the form
supported all|three parts of this requirement: 57.1%;
Noncompliance–Medical form was present but documentation on the form
supporting|one or more of the three parts of this requirement was
missing or incorrect: 24.1%;
Noncompliance–Medical form was missing: 18.8%.
Installation: D;
Compliance–Medical form was present and documentation on the form
supported all|three parts of this requirement: 78.2%;
Noncompliance–Medical form was present but documentation on the form
supporting|one or more of the three parts of this requirement was
missing or incorrect: 10.3%;
Noncompliance–Medical form was missing: 11.5%.
Notes: We determined compliance with this requirement by reviewing 308
personnel records of enlisted servicemembers whose separation packets
had documentation that they had been notified of their impending
separation because of a personality disorder.
Air Force officials acknowledged that prior to October 2006 some
enlisted servicemembers with a mental health diagnosis other than a
personality disorder, such as adjustment disorder, were erroneously
separated under the reason of a personality disorder. However in
October 2006, Air Force officials stated that they took steps to
correct this error. Some of the servicemembers separated from the Air
Force installation we visited may have been affected by this error.
[End of figure]
We found that 34 enlisted servicemembers' separation packets did not
contain a medical form, which is used to document compliance with the
three parts of this requirement. We also found that of the enlisted
servicemembers' separation packets that contained a medical form, the
medical form in 66 of these packets did not contain information needed
to fulfill all three parts of the requirement. For example, 27 of these
66 enlisted servicemembers' medical forms had documentation indicating
that the servicemember had been diagnosed with a personality disorder,
but there was also information in the medical form indicating that the
diagnosis was not made by a psychiatrist or psychologist. In some of
these cases, we found that the diagnosis of a personality disorder was
made by a licensed clinical social worker or other type of provider,
such as a battalion surgeon.
Compliance with the Requirement for Formal Counseling Ranged from 40 to
99 Percent:
We found that compliance with the requirement that enlisted
servicemembers receive formal counseling about their problem with
functioning in the military ranged from 40 to 99 percent.[Footnote 23]
Across the four installations, we found that 42 enlisted
servicemembers' separation packets did not contain a counseling form
documenting that servicemembers received formal counseling as required.
As a result, these 42 servicemembers' separation packets were
noncompliant with this requirement. Figure 2 summarizes the four
installations' compliance rates for this requirement.
Figure 2: Rate of Documented Compliance at Selected Military
Installations with Requirement That Enlisted Servicemembers Receive
Formal Counseling about Their Problem with Functioning in the Military,
for Separations Completed from November 1, 2001, through June 30, 2007:
[See PDF for image]
This figure is a stacked vertical bar graph depicting the following
data:
Installation: A;
Compliance–Counseling form was present: 40%;
Noncompliance–Counseling form was missing: 60%.
Installation: B;
Compliance–Counseling form was present: 91.9%;
Noncompliance–Counseling form was missing: 8.1%.
Installation: C;
Compliance–Counseling form was present: 75.9%;
Noncompliance–Counseling form was missing: 24.1%.
Installation: D;
Compliance–Counseling form was present: 98.9%;
Noncompliance–Counseling form was missing: 1.1%.
Note: We determined compliance with this requirement by reviewing 308
personnel records of enlisted servicemembers whose separation packets
had documentation that they had been notified of their impending
separation because of a personality disorder.
[End of figure]
Documented Compliance with the Three Key Personality Disorder
Separation Requirements Varied for Enlisted Navy Servicemembers'
Separation Packets That We Reviewed:
Our review of the documentation in 59 enlisted Navy servicemembers'
separation packets found that compliance varied by requirement. Of the
separation packets that we reviewed, 95 percent had documentation
indicating that enlisted servicemembers had been notified of their
impending separation because of a personality disorder. (Three enlisted
servicemembers' separation packets did not contain documentation of
this requirement, and as a result, we did not assess compliance with
the remaining two requirements for these three servicemembers'
separation packets.) The requirement that enlisted servicemembers be
diagnosed with a personality disorder by a psychiatrist or psychologist
who determines that the personality disorder interferes with
servicemembers' ability to function in the military had a compliance
rate of 82 percent for the 56 remaining enlisted Navy servicemembers'
separation packets that we reviewed. Of the 56, we found that 1
enlisted Navy servicemember's separation packet did not contain a
medical form, which is used to document compliance with the three parts
of this requirement. We also found that 9 of the 56 enlisted Navy
servicemembers' separation packets contained a medical form, but did
not have documentation indicating compliance with all three parts of
this requirement. Most of these--6--did not have documentation
indicating that the diagnosis of a personality disorder was made by a
psychiatrist or psychologist. For the requirement for formal
counseling, 77 percent of the 56 enlisted Navy servicemembers'
separation packets contained documentation that enlisted servicemembers
received formal counseling about their problem with functioning in the
military.[Footnote 24]
DOD Does Not Have Reasonable Assurance That Its Separation Requirements
Have Been Followed:
DOD does not have reasonable assurance that its key personality
disorder separation requirements have been followed. DOD policy directs
the military services to implement and ensure consistent administration
of DOD's requirements for separating enlisted servicemembers because of
a personality disorder. In turn, according to officials in each of the
military services, the military services delegate to commanders with
separation authority at the military installations sole responsibility
for ensuring that the requirements are followed for enlisted
servicemembers under their command.
According to military officials at the installations we visited, to
ensure compliance with DOD's key separation requirements, the commander
with separation authority has an official at the installation examine
the enlisted servicemember's separation packet prior to the separation
to determine that all requirements have been met. Military officials
responsible for reviewing the separation packets at the installations
we visited explained that when the official who is reviewing the
separation packet discovers that a requirement for separation has not
been documented, the reviewing official is supposed to take steps to
resolve the situation. For example, if the official reviewing the
separation packets does not find documentation that enlisted
servicemembers have been formally counseled about their problem with
functioning in the military, the reviewing official would verify that
the formal counseling had occurred and then obtain documentation of
that counseling session. Similarly, a Navy legal official told us that
enlisted servicemembers' separation packets should be reviewed to make
sure that DOD's key separation requirements have been met before the
separations are approved. When we asked about the low rates of
compliance for some of the separation requirements that we found at the
Army, Air Force, and Marine Corps installations we visited and for the
enlisted Navy servicemembers' records that we reviewed, the military
officials responsible for reviewing the separation packets with whom we
spoke could not explain why these separations were approved if
compliance with the separation requirements was not documented in the
separation packet.
Having given sole responsibility to the commanders with separation
authority to ensure compliance, the military services have not
established a way to determine whether these commanders are ensuring
that DOD's key requirements are met. Furthermore, DOD does not have
reasonable assurance that its requirements for separating enlisted
servicemembers because of a personality disorder have been followed.
Enlisted Servicemembers' Selection of Protections Available During and
After Separation Varied:
At the four installations we visited, enlisted servicemembers who were
separated because of a personality disorder varied in the extent to
which they selected the protections available to them during the
separation process, depending on the specific protection. Based on our
review of separation packets in the enlisted servicemembers' personnel
records, we found that a small proportion of enlisted servicemembers--
12 percent--stated that they wanted to submit statements on their own
behalf to the commander with separation authority. Of these
servicemembers who submitted a statement, 18 percent submitted a
statement that either questioned whether the diagnosis of a personality
disorder was an accurate diagnosis or requested not to be separated.
All of these servicemembers were separated. We also found that 38
percent of enlisted servicemembers at the installations we visited
stated that they wanted to consult with legal counsel prior to their
separation. According to legal officials at the installations we
visited, enlisted servicemembers may seek legal counsel to discuss the
implications of a personality disorder separation, seek advice on how
to stay in the military, or obtain information on their eligibility for
Department of Veterans Affairs' benefits, such as health and
educational benefits, after separation. For enlisted Navy
servicemembers whose separation packets we reviewed, 5 percent selected
to submit statements and 5 percent selected to consult with counsel
prior to separation.
Based on our review of enlisted servicemembers' separation packets for
the installations we visited, we found that the majority of
servicemembers requested copies of their separation packets, which are
sent to the commander with separation authority. Specifically, 289 of
312 enlisted servicemembers in our review at the four installations--93
percent--requested copies of their separation packets, while 66 percent
of enlisted Navy servicemembers in our review requested copies of their
separation packets. We also found that no enlisted servicemembers--
either at the installations we visited or among the enlisted Navy
servicemembers whose separation packets we reviewed--requested a
hearing before an administrative board prior to their separation.
[Footnote 25]
Enlisted servicemembers may challenge the reason given for their
separation to a discharge review board after the separation has been
completed. For the four installations we visited and for enlisted Navy
servicemembers, we found that three enlisted servicemembers applied to
their military service's discharge review board to challenge the reason
for their separation. Of these three, one servicemember received a
change to the reason for separation because the discharge review board
found that the separation because of a personality disorder was unjust.
For this servicemember, the reason for separation was changed from
personality disorder to the reason of secretarial authority of that
military service.[Footnote 26] The other two servicemembers who applied
for a change to their reason for separation did not receive a change
because the discharge review board found that the documentation present
in the personnel record supported the personality disorder separation.
The two servicemembers who were unsuccessful in their appeal to the
discharge review board did not choose to appeal the discharge review
board's decision to the board for the correction of military records.
Conclusions:
DOD has established requirements that are intended to help ensure that
enlisted servicemembers separated because of a personality disorder are
separated appropriately. Failure to comply with these requirements
increases the risk of enlisted servicemembers being inappropriately
separated because of a personality disorder. For enlisted
servicemembers, the stakes are high because a personality disorder
separation can carry a long-term stigma in the civilian world. Because
DOD relies on the military services to ensure compliance with its key
personality disorder separation requirements, and because the military
services rely solely on commanders with separation authority to ensure
compliance with these requirements, there is a lack of reasonable
assurance that the requirements have been met. During our review of
enlisted servicemembers' separation packets at the four military
installations and for enlisted Navy servicemembers' separation packets
we reviewed, the low rates of compliance we found for some of the key
personality disorder separation requirements indicate that the military
services need a system, beyond relying on the commanders who are making
separation decisions, to ensure compliance with DOD's personality
disorder separation requirements. Additionally, DOD needs to monitor
the military services' compliance with these requirements. Until this
happens, DOD does not have reasonable assurance that personality
disorder separations of enlisted servicemembers have been appropriate.
Recommendations for Executive Action:
To help ensure that DOD's requirements for personality disorder
separations are met and to help increase assurance that these
separations are appropriate, we recommend that the Secretary of Defense
direct the Under Secretary of Defense for Personnel and Readiness to:
1. direct the Secretaries of the Army, the Air Force, and the Navy and
the Commandant of the Marine Corps to develop a system to ensure that
personality disorder separations are conducted in accordance with DOD's
requirements and:
2. ensure that DOD monitors the military services' compliance with
DOD's personality disorder separation requirements.
Agency Comments and Our Evaluation:
In written comments on a draft of this report, DOD concurred with our
recommendation that the military services develop a system to ensure
that personality disorder separations are conducted in accordance with
DOD's requirements. DOD partially concurred with our recommendation
that DOD monitor the military services' compliance with DOD's
personality disorder separation requirements. DOD stated that it will
strengthen policy guidance related to the military services'
standardized compliance reporting, but that it is the responsibility of
the military services to ensure compliance with DOD policy. However, as
we stated in our draft report, DOD's reliance on the military services
to ensure compliance with its separation requirements has not provided
reasonable assurance that these requirements will be followed. We
believe that the low rates of compliance we found for some of DOD's key
personality disorder separation requirements suggest the need for
another system to ensure compliance with these requirements, as well as
the need for DOD to monitor the military services' compliance.
DOD suggested that we change the title of our draft report to indicate
that our subject area was personnel management and not defense health
care. We have not changed the title. For an enlisted servicemember to
be separated because of a personality disorder, the servicemember must
first be diagnosed as having a personality disorder. Therefore, we
consider our review of DOD's separation process for servicemembers with
personality disorders a review of a health care issue.
In its comments, DOD also identified two inaccuracies in our
description of DOD's separation requirements. DOD pointed out that its
policy does not state that a servicemember's written notification of
the impending separation has to come from a servicemember's commander,
as we indicated in our draft report. According to DOD, the policy does
not specify who must provide this written notification. We revised our
draft report to clarify our discussion of this requirement. However,
this change did not affect the results of our compliance review because
we determined compliance based on whether servicemembers' separation
packets contained a notification letter and not on who notified the
servicemember. DOD also pointed out that its policy does not state that
servicemembers must receive formal counseling from their supervisors
about their problem with functioning in the military, as we stated in
our draft report. According to DOD, the policy does not state who
should provide the formal counseling to the servicemember; however, we
were told by a DOD separation policy official that the counseling
should be done by the servicemember's supervisor. We revised our draft
report to clarify our discussion of this requirement. This also did not
change the results of our compliance review because we assessed
compliance based on whether servicemembers' separation packets
contained a counseling form and not on who counseled the servicemember.
DOD also provided technical comments, which we incorporated as
appropriate. DOD's written comments are reprinted in appendix II.
We are sending copies of this report to the Secretary of Defense; the
Secretaries of the Army, the Air Force, and the Navy; the Commandant of
the Marine Corps; and appropriate congressional committees and
addressees. We will also provide copies to others upon request. In
addition, this report is available at no charge on the GAO Web site at
[hyperlink, 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:
List of Congressional Addressees:
The Honorable Carl Levin:
Chairman:
The Honorable John McCain:
Ranking Member:
Committee on Armed Services:
United States Senate:
The Honorable Ike Skelton:
Chairman:
The Honorable Duncan L. Hunter:
Ranking Member:
Committee on Armed Services:
House of Representatives:
The Honorable Daniel K. Akaka:
United States Senate:
The Honorable Wayne Allard:
United States Senate:
The Honorable Christopher S. Bond:
United States Senate:
The Honorable Barbara Boxer:
United States Senate:
The Honorable Tom Harkin:
United States Senate:
The Honorable Joseph I. Lieberman:
United States Senate:
The Honorable Claire C. McCaskill:
United States Senate:
The Honorable Patty Murray:
United States Senate:
The Honorable Barack Obama:
United States Senate:
The Honorable Ken Salazar:
United States Senate:
The Honorable Bernard Sanders:
United States Senate:
[End of section]
Appendix I: Scope and Methodology:
To meet our objectives, we examined Department of Defense (DOD)
separation regulations that the military services are required to
follow to help ensure that enlisted servicemembers are separated for
the appropriate reasons. For our review, we examined (1) the extent to
which selected military installations complied with DOD requirements
for separating enlisted servicemembers because of a personality
disorder, (2) how DOD ensures compliance with personality disorder
separation requirements by the military services, and (3) the extent to
which enlisted servicemembers who are separated because of a
personality disorder selected protections available to them.
For this review, we included enlisted servicemembers from the Army, Air
Force, Navy, and Marine Corps. We included only enlisted servicemembers
because officers are able to resign at any time rather than be
involuntarily separated. We included enlisted servicemembers who
deployed at least once in support of Operation Enduring Freedom (OEF)
or Operation Iraqi Freedom (OIF). The Coast Guard was excluded because
it is under the direction of the Department of Homeland Security and
represents a very small portion of servicemembers deployed in support
of OEF and OIF. For this review, enlisted servicemembers are those in
the active duty component and Reserve component--reservists and
National Guard members--who were discharged or released from active
duty from November 1, 2001--the first full month of combat operations
for OEF--through June 30, 2007--the latest date for which data were
available from DOD at the time of our review.
We obtained data from DOD's Defense Manpower Data Center (DMDC) on the
number of enlisted servicemembers who had been separated from the
military because of a personality disorder from November 1, 2001,
through June 30, 2007. These data came from DMDC's Active Duty Military
Personnel Transaction File and DMDC's Reserve Components Common
Personnel Data Transaction File, which are databases that contain
servicemember-level data, such as Social Security number, education
level, date of birth, pay grade, separation program designator code,
and reenlistment eligibility. The Active Duty Military Personnel
Transaction File contains a transaction record for every individual
entrance, separation, or reenlistment in the Army, Air Force, Navy, and
Marine Corps within a specific time frame. The Reserve Components
Common Personnel Data Transaction File contains this information for
every individual entrance, separation, or reenlistment in the Army
National Guard, Army Reserve, Air National Guard, Air Force Reserve,
Navy Reserve, and Marine Corps Reserve within a specific time frame. We
also asked that DMDC indicate, from its Contingency Tracking System
Deployment File, if any enlisted servicemembers who were separated
because of a personality disorder were also deployed, for at least one
tour of duty, in support of OEF or OIF. The Contingency Tracking System
Deployment File is a database that includes data elements for all
servicemembers deployed in support of OEF/OIF. A contingency tracking
system deployment is defined as a servicemember being physically
located within the OEF or OIF combat zones/areas of operation, or
specifically identified by the military service as directly supporting
the OEF/OIF mission outside of the designated combat zone. We
determined that the DMDC data were sufficiently reliable because we
corroborated these data with information in the enlisted
servicemembers' personnel records.
Based on our analysis of the data provided by DMDC, we selected four
military installations across the Army, Air Force, and Marine Corps to
visit based on whether the installation had the highest or second
highest number of enlisted OEF/OIF servicemembers separated because of
a personality disorder for that service. We selected one installation
each from the Air Force and the Marine Corps. We selected two Army
installations because at the time of our review, the Army had the
majority of servicemembers deployed in support of OEF/OIF when compared
with the Air Force and the Marine Corps. Among Marine Corps
installations, we selected Camp Pendleton, in California, which had the
second highest number of enlisted servicemembers separated because of a
personality disorder during this time period. This installation was
selected because the Marine Corps installation with the highest number
of enlisted servicemembers separated because of a personality disorder
was in the midst of a deployment cycle and requested that we not visit.
The other military installations we selected were Fort Carson (Army),
Colorado; Fort Hood (Army), Texas; and Davis-Monthan Air Force Base
(Air Force), Arizona.
In addition to the four military installations we visited, we visited
Naval Base San Diego. We selected Naval Base San Diego based on DMDC's
data, which identified this naval base as having the second highest
number of enlisted OEF/OIF Navy servicemembers separated because of a
personality disorder from November 1, 2001, through June 30, 2007.
[Footnote 27] During the course of our review, Navy officials at this
base told us that enlisted Navy servicemembers selected for our review
were transferred to the transient personnel unit at Naval Base San
Diego from a Navy ship at various points in the separation process.
[Footnote 28] According to a Navy official, most enlisted Navy
servicemembers were diagnosed, formally counseled, and notified of
their impending separation while on board a Navy ship and were
transferred to the transient personnel unit at Naval Base San Diego to
receive their certificates of release. Other enlisted Navy
servicemembers were diagnosed, formally counseled, and notified of
their impending separation while at Naval Base San Diego. We could not
generalize our findings to Naval Base San Diego because some of the
elements of the separation process could have been completed while
these servicemembers were on board a Navy ship. Therefore, we have
reported the results of our review of enlisted Navy servicemembers'
records separately from our presentation of findings based on our
review of the other four military installations.
To determine the extent to which the four military installations and
enlisted Navy servicemembers' records that we reviewed complied with
DOD personality disorder separation requirements, we reviewed DOD's and
the military services' enlisted administrative separation regulations
and instructions to identify the key requirements for separating
enlisted servicemembers because of a personality disorder. We also
interviewed officials at each of the military services' headquarters
who are responsible for overseeing separation policy. We interviewed
additional officials at each of the four selected installations and at
Naval Base San Diego, including mental health providers, staff judge
advocates, legal counsel with defense services, unit commanders,
administrators of the Medical Evaluation Board, and officials in the
transition/separation offices, to understand the administrative
separation process.
Additionally, to determine whether the selected installations and
enlisted Navy servicemembers' records that we reviewed complied with
DOD's requirements for separating servicemembers because of a
personality disorder, we obtained and reviewed the personnel records of
selected servicemembers to verify that their certificates of release
indicated that they were separated because of a personality disorder.
We obtained these records from each military service's central
repository, where the personnel records of servicemembers who have been
separated from the military are stored. According to military service
officials responsible for separation policy, the separation packet,
which is found in the enlisted servicemember's personnel record, is
required to contain documents related to the separation, including
documents indicating that DOD's three key requirements have been met.
[Footnote 29]
For three of the installations we selected, we reviewed the personnel
records of a random, generalizable sample of enlisted servicemembers
who deployed at least once in support of OEF/OIF and who were separated
from that installation because of a personality disorder from November
1, 2001, through June 30, 2007. For the other installation we selected,
we reviewed the personnel records of all enlisted servicemembers who
deployed at least once in support of OEF/OIF and who were separated
from that installation because of a personality disorder from November
1, 2001, through June 30, 2007, because the number of servicemembers
separated from that installation was too small to draw a random,
generalizable sample. In total, we included 343 enlisted
servicemembers' personnel records across the four installations. Of
these 343 records, 312 enlisted servicemembers' personnel records were
included in our documentation review because their personnel records
contained separation packets, which we needed to review to determine
compliance. Of the 31 servicemembers' personnel records that were
excluded from our review, 3 had separation packets that were illegible.
The remaining 28 servicemembers' personnel records did not have
separation packets available for our review.
We also obtained 94 enlisted Navy servicemembers' personnel records
from the Navy's central repository, where the personnel records of
servicemembers who have been separated are stored after they leave the
Navy. We reviewed the personnel records of all enlisted Navy
servicemembers who deployed at least once in support of OEF/OIF and who
were separated from Naval Base San Diego because of a personality
disorder from November 1, 2001, through June 30, 2007, because the
number of enlisted servicemembers separated from Naval Base San Diego
was too small to draw a random, generalizable sample. We reviewed these
personnel records to determine if they contained separation packets,
which are required by the Navy. Of the 94 enlisted Navy servicemembers,
59 servicemembers' personnel records were included in our review
because their records contained separation packets, which were needed
for us to determine compliance. We excluded 35 enlisted Navy
servicemembers' personnel records from our evaluation of compliance.
One enlisted servicemember's separation packet was illegible and 34
enlisted servicemembers' separation packets were not available for
review.
In our review, we determined compliance for each of the three key
personality disorder separation requirements by reviewing the
documentation in the enlisted servicemembers' separation packets to see
if it indicated compliance with that requirement. If the enlisted
servicemember's separation packet did not include documentation that
the servicemember had been notified of the impending separation because
of a personality disorder--one of the key requirements for a
personality disorder separation--we did not assess compliance with the
other two key requirements. Table 2 describes the criteria we used to
determine compliance.
Table 2: Criteria to Determine Compliance from Review of Separation
Packets in Enlisted Servicemembers' Personnel Records:
Requirement: Servicemembers must be notified of the separation because
of a personality disorder;
Compliance: Separation packet contained a notification letter of the
separation because of a personality disorder;
Noncompliance: Separation packet did not contain a notification letter
of the separation because of a personality disorder.
Requirement: Servicemembers must receive a personality disorder
diagnosis by a psychiatrist or psychologist who determines that the
personality disorder interferes with servicemembers' ability to
function in the military;
Compliance: Separation packet contained what is known as a medical form
that documents the following three parts of this requirement: (a) A
diagnosis of personality disorder; (b) Made by psychiatrist or
psychologist; (c) Who determines that the personality disorder
interferes with servicemembers' ability to function in the military;
Noncompliance: Separation packet did not contain a medical form; or;
Separation packet included a medical form, but documentation supporting
one or more of the following parts of this requirement was missing or
was incorrect: (a) A diagnosis of personality disorder; (b) Made by
psychiatrist or psychologist; (c) Who determines that the personality
disorder interferes with servicemembers' ability to function in the
military.
Requirement: Servicemembers must be formally counseled about their
problem with functioning in the military;
Compliance: Separation packet contained a counseling form;
Noncompliance: Separation packet did not include a counseling form.
Source: GAO analysis of DOD's and military services' separation
regulations and instructions.
[End of table]
Our review of compliance can be generalized to each of the four
installations we visited, but not to the military services. For
enlisted Navy servicemembers whose separation packets we reviewed, we
cannot generalize to Naval Base San Diego or to the Navy.
To determine how DOD ensures compliance by the military services with
requirements for separating enlisted servicemembers because of a
personality disorder, we reviewed DOD regulations and interviewed DOD
and the military services' officials responsible for separation policy.
Additionally, we interviewed military officials responsible for legal
services at the installations we visited and at Naval Base San Diego
about how they ensure compliance with DOD's key requirements for
personality disorder separations.
To determine the extent to which enlisted servicemembers at the four
installations we visited and enlisted Navy servicemembers selected the
protections available to them during the separation process, we
reviewed the same 371 enlisted servicemembers' separation packets as we
reviewed to determine compliance with DOD's personality disorder
separation requirements--312 separation packets for enlisted
servicemembers from the Army, Air Force, and Marine Corps installations
and 59 separation packets for enlisted servicemembers from the Navy.
Enlisted servicemembers are given a list of the protections available
to them and select protections from this list, which are included in
servicemembers' separation packets. From our review of the separation
packets, we determined whether enlisted servicemembers selected the
protections available, but did not determine whether servicemembers
received the protections that they selected. To determine the extent to
which enlisted servicemembers selected protections available after
being separated, we obtained information from each military service's
discharge review board and board for the correction of military
records. Using this information, we determined whether the same 371
enlisted servicemembers, whose separation packets we reviewed to
determine compliance with DOD's personality disorder separation
requirements, challenged the reason for their separation.
We conducted this performance audit from May 2007 through August 2008
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.
[End of section]
Appendix II: Comments from the Department of Defense:
Under Secretary Of Defense:
Personnel and Readiness:
4000 Defense Pentagon:
Washington, DC 2030-4000:
October 8, 2008:
Mr. Randall B. Williamson:
Director, Health Care:
U.S. Government Accountability Office:
441 G. Street, N.W.
Washington, DC 20548:
Dear Mr. Williamson:
This is the Department of Defense response to the GAO Draft Report, GAO-
08-1008, "Defense Health Care: Additional Efforts Needed to Ensure
Compliance with Personality Disorder Separation Requirements," dated
August 26, 2008 (GAO Code 290722).
Thank you for the opportunity to review and comment on this draft. We
appreciate the critical review your team has undertaken with this
important issue. It is imperative we follow prescribed procedures when
separating Service members as well as honor their rights to appeal.
Please refer to our enclosed critical and technical comments on this
report and GAO recommendations.
Again, we thank you for the opportunity to provide these comments. My
points of contact for additional information are Col Bob Ireland
(Functional) at (703) 681-3611 and Mr. Gunther Zimmerman (Audit
Liaison) at (703) 681-4360.
Sincerely,
Signed by:
David S. C. Chu:
Enclosure: As slated:
GAO Draft Report - Dated August 26, 2008:
GAO Code 290722/GAO-08-1008:
"Defense Health Care: Additional Efforts Needed to Ensure Compliance
with Personality Disorder Separation Requirements"
Department Of Defense Comments:
Report Title: The current title is, "Defense Health Care: Additional
Efforts Needed to Ensure Compliance with Personality Disorder
Separation Requirements"
Recommended Chang: "Personnel Management: Report to Congress on the
Execution of Policies and Procedures to Administratively Separate
Members of the Armed Forces on the Basis of Personality Disorder"
Rationale for change: Defense Health Care programs do not manage
personnel separation policies and practices--the primary focus of this
study. "Personnel management" is inclusive of and accounts for both
medical and administrative discharge requirements. This report does not
address clinical practice ("health care") efficacy or judgment, but
rather whether a doctoral psychologist's or psychiatrist's statement
recommending separation for a personality disorder was included in
separation packages. In addition, the subtitle describes a finding,
rather than the subject of the report.
Page 3, Lines 12-13 (Table 1, Table 2, etc.): The bullet reads, "must
receive notification by their commander of the impending separation
because of a personality disorder."
Recommended change: "must receive written notification of their
impending separation because of personality disorder."
Rationale for change: DoDD 1332.14, Enlisted Administrative
Separations, Enclosure 6, paragraph 2.a. requires that the "respondent
shall he notified in writing of:" It makes no mention that the
notification must come from the commander. The old version of DoDD
1332.14 also made no mention of the written notification having to come
from the commander.
Page 3, Lines 18-19 (p. 8 last sentence, Table 1, Table 2, etc.): The
bullet reads, "must receive counseling by their supervisors about their
problem with functioning in the military."
Recommended change: "must receive formal counseling concerning their
deficiencies which interfere with assignment to, or performance of,
duty."
Rationale for change: DoDD 1 332.14, Enlisted Administrative
Separations, Paragraphs 3.a.(8)(a) and (b) do not stipulate who must
provide the counseling, only that the formal counseling must be
provided. This change should be incorporated throughout the report
(e.g., Table I, last line of Pg 8, Table 2, etc.)
GAO Draft Report - Dated August 26, 2008:
GAO Code 290722/GAO-08-1008:
"Defense Health Care: Additional Efforts Needed to Ensure Compliance
with Personality Disorder Separation Requirements"
Department Of Defense Comments To The Recommendations:
Recommendation 1: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense for Personnel and Readiness to
direct the Secretaries of the Army, the Air Force, and the Navy and the
Commandant of the Marine Corps to develop a system to ensure that
personality disorder separations are conducted in accordance with DoD's
requirements.
DOD Response: Concur.
Recommendation 2: The GAO recommends that the Secretary of Defense
direct the Under Secretary of Defense for Personnel and Readiness to
ensure that DoD monitors the military Services' compliance with DoD's
personality disorder separation requirements.
DOD Response: Partial Concurrence.
It is the responsibility of the Military Departments to ensure
compliance with DoD policies. However, the USD(P&R) will strengthen
policy guidance regarding Service standardized compliance reporting.
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Randall B. Williamson, (202) 512-7114 or williamsonr@gao.gov:
Acknowledgments:
In addition to the contact named above, Mary Ann Curran, Assistant
Director; Sarah Burton; Christie Enders; Krister Friday; Becky
Hendrickson; Martha R.W. Kelly; Lisa Motley; Jason Vassilicos; and
Suzanne Worth made key contributions to this report.
[End of section]
Footnotes:
[1] Department of Defense Directive 6200.04, Section 4.1, Force Health
Protection (Apr. 23, 2007).
[2] We included only enlisted servicemembers because officers generally
are able to resign at any time rather than be involuntarily separated.
[3] Diagnostic and Statistical Manual of Mental Disorders, 4th ed.,
Text revision (Washington, D.C.: American Psychiatric Association,
2000).
[4] At the time of our review, the most recent DOD data on separations
were through June 30, 2007.
[5] In the military, personality disorder separations are processed as
administrative separations. We use "separation" to refer to these
administrative separations.
[6] According to a DOD official, DOD does not hire psychologists who
are not doctoral-level psychologists. We use psychologists to refer to
doctoral-level psychologists.
[7] Although DOD separation policy does not specify who needs to
conduct the formal counseling session, according to a DOD separation
policy official, the counseling should be done by the servicemember's
supervisor.
[8] Pub. L. No. 110-181, § 597(b), 122 Stat. 3, 140.
[9] For the purposes of this report, we use "installation" to refer to
Army, Marine Corps, and Air Force locations that we visited.
[10] We selected two Army installations because at the time of our
review the Army had the majority of servicemembers deployed in support
of OEF/OIF when compared with the Air Force and Marine Corps.
[11] Among Marine Corps installations, Camp Pendleton had the second
highest number of enlisted OEF/OIF servicemembers separated because of
a personality disorder during this time period. The Marine Corps
installation with the highest number of enlisted OEF/OIF servicemembers
separated because of a personality disorder was in the midst of a
deployment cycle and requested that we not visit this installation.
[12] When servicemembers are separated from military service, they each
receive a certificate of release from the military, known as a DD-214,
which includes information on the reason for separation.
[13] The transient personnel unit serves as a transition center for
Navy servicemembers who are being separated from military service.
[14] DOD policy does not specify which documents should be included in
the separation packet. However, each military service specifies which
documents or documentation is required to be included in the separation
packet.
[15] Enlisted servicemembers are given a list of the protections
available to them and select protections from this list. This list is
included in servicemembers' separation packets. Our review of the
separation packets in enlisted servicemembers' personnel records was
for the purpose of determining whether the servicemembers selected the
protections available to them. We did not determine if a protection was
exercised.
[16] Department of Defense Directive 1332.14, Enlisted Administrative
Separations (Nov. 21, 2003).
[17] Psychiatrists and psychologists may use multiple diagnostic
approaches, including a variety of psychological tests that aid in
establishing a diagnosis. However, as with other mental health
conditions, no single test can definitively determine if an individual
has a personality disorder, according to mental health experts.
[18] The military services have established policies governing
separating enlisted servicemembers with personality disorders. These
policies reaffirm the three key requirements established by DOD.
[19] After our review was completed, DOD updated its enlisted
administrative separation policy and included additional requirements
for enlisted servicemembers who are separated because of a personality
disorder and have served in designated combat zones, such as OEF/OIF.
Among its requirements, the updated policy requires that a
servicemember's diagnosis of a personality disorder be corroborated by
a peer or higher-level mental health professional and be endorsed by
the military service's surgeon general.
[20] Specifically, enlisted servicemembers who are separated because of
a personality disorder receive either an "honorable" or "general under
honorable" characterization of service that is given at the time of
separation. This is in contrast to another separation due to
misconduct, for which an enlisted servicemember may receive an "other
than honorable" characterization of service.
[21] The Navy allows enlisted servicemembers with less than 6 years of
service to request that their separations be reviewed and approved by a
commander with a higher-level authority than the commander who
regularly approves personality disorder separations.
[22] 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.
[23] If the psychiatrist or psychologist determines that enlisted
servicemembers are a threat to themselves or others, the Marine Corps
waives the requirement that servicemembers must receive formal
counseling. We considered enlisted servicemembers' separation packets
that included documentation of this waiver to indicate compliance with
DOD's counseling requirement.
[24] If the psychiatrist or psychologist determines that servicemembers
are a threat to themselves or others, the Navy waives the requirement
that servicemembers must receive formal counseling. We considered
enlisted servicemembers' separation packets that included documentation
of this waiver to indicate compliance with DOD's counseling
requirement.
[25] For the four installations we visited and the enlisted Navy
servicemembers' separation packets that we reviewed, 36 enlisted
servicemembers had 6 or more years of military service and, as such,
were eligible to request a hearing before an administrative board.
[26] According to DOD Directive 1332.14, Enlisted Administrative
Separations, the secretary of a military service can separate an
enlisted servicemember if he/she determines that it is in the best
interest of the service.
[27] Naval Base San Diego was also selected to coordinate with our
visit to another installation.
[28] The transient personnel unit serves as a transition center for
Navy servicemembers who are being separated from military service.
[29] DOD policy does not state the documents that should be included in
the separation packet, which is found in the servicemember's personnel
record. However, each military service specifies what documents or
documentation is required to be included in the separation packet.
[End of section]
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