GAO 

United States Government Accountability Office

Report to the Chairman, Subcommittee 

on National Security and Foreign 

Affairs, Committee on Oversight and 

Government Reform, House of 

Representatives 

MILITARY 

PERSONNEL 

Additional Actions Are 

Needed to Strengthen 

DOD’s and the Coast 

Guard’s Sexual 

Assault Prevention 

and Response 

Programs 

February 2010 

GAO-10-215 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

February 2010

MILITARY PERSONNEL

Additional Actions Are Needed to Strengthen DOD's

and the Coast Guard's Sexual Assault Prevention and 

Highlights of GAO-10-215, a report to the Response Programs

Chairman, Subcommittee on National 

Security and Foreign Affairs, Committee 

on Oversight and Government Reform, 

House of Representatives 

Sexual assault is a crime with 

negative implications to military 

readiness and esprit de corps. In 

response to a congressional 

request, GAO, in 2008, reviewed 

Department of Defense (DOD) and 

U.S. Coast Guard sexual assault 

prevention and response programs 

and recommended a number of 

improvements. GAO was 

subsequently asked to evaluate the 

extent to which (1) DOD has 

addressed GAO’s 2008 

recommendations and further 

developed its programs, (2) DOD 

has established a sexual assault 

database, and (3) the Coast Guard 

has addressed GAO’s 2008 

recommendations and further 

developed its programs. To do so, 

GAO analyzed legislative 

requirements and program 

guidance, interviewed officials, and 

compared database 

implementation efforts to key 

information technology best 

practices. 

What GAO Recommends

To strengthen program 

implementation, GAO recommends 

that DOD take steps, including 

incorporating all key elements into 

its draft oversight framework and 

adhering to key system acquisition 

best practices, as it develops its 

database. GAO also recommends 

that the Coast Guard take steps, 

including establishing a systematic 

process to track program data and 

establishing quality control 

procedures. DOD and the Coast 

Guard concurred with the 

recommendations. 

DOD has addressed four of GAO’s nine recommendations from 2008 regarding 

the oversight and implementation of its sexual assault prevention and 

response programs. For example, the Office of the Secretary of Defense 

(OSD) evaluated department program guidance for joint and deployed 

environments, and it evaluated factors that may hinder access to health care 

following a sexual assault. But DOD’s efforts to address the other 

recommendations reflect less progress. For example, GAO recommended that 

DOD develop an oversight framework, to include long-term goals and 

milestones, performance goals and strategies, and criteria for measuring 

progress. However, GAO found that the draft framework lacks key elements 

needed for comprehensive oversight of DOD’s programs, such as criteria for 

measuring progress and an indication of how it will use the information 

derived from such measurement to improve its programs. Until OSD 

incorporates all key elements into its draft oversight framework, it will remain 

limited in its ability to effectively manage program development to help 

prevent and respond to sexual assault incidents. DOD acknowledges that 

more work remains in order to fully develop its oversight framework. 

DOD has taken steps to begin acquiring a centralized sexual assault database. 

However, it did not meet a legislative requirement to establish the database by 

January 2010, and it is unclear when the database will be established because 

DOD does not yet have a reliable schedule to guide its efforts. Also, key 

system acquisition best practices associated with successfully acquiring and 

deploying information technology systems, such as economically justifying 

the proposed system solution and effectively developing and managing 

requirements, have largely not been performed. OSD officials said they intend 

to employ these acquisition best practices. Until this is accomplished the 

program will be at increased risk of not delivering promised mission 

capabilities and benefits on time and within budget. 

While the Coast Guard has partially implemented one of GAO’s two 

recommendations for further developing its sexual assault prevention and 

response program, it has not implemented the other. In June 2009, the Coast 

Guard began assessing its program staff’s workload, which represents 

progress in addressing GAO’s recommendation to evaluate its processes for 

staffing key installation-level positions in its program. However, it has not 

addressed GAO’s recommendation to develop an oversight framework. 

Further, the Coast Guard lacks a systematic process for assembling, 

documenting, and maintaining sexual assault incident data, and lacks quality 

control procedures to ensure that the program data being collected are 

reliable. In fiscal year 2008, for example, different Coast Guard offices 

documented conflicting numbers of sexual assault reports: the Coast Guard 

Program Office documented 30, while the Investigative Office documented 78. 

The Coast Guard had to resolve this significant discrepancy before it could 

provide its data to DOD. Without a systematic process for tracking its data, 

the Coast Guard lacks reliable knowledge on the occurrence of sexual 

assaults. 

View GAO-10-215 or key components. 

For more information, contact Brenda S. 

Farrell at (202) 512-3604 or farrellb@gao.gov 

or Randolph C. Hite at (202) 512-3439 or 

hiter@gao.gov. 
Page i GAO-10-215 

Contents 

Letter 1

Results in Brief 4 

Background 6 

DOD’s Efforts to Address GAO’s Recommendations from 2008 

Reflect Varying Levels of Progress 12 

DOD Has Yet to Establish a Centralized Sexual Assault Database 22 

Coast Guard Has Partially Implemented One of Our Two 

Recommendations from 2008 31 

Conclusions 36 

Recommendations for Executive Action 37 

Agency Comments and Our Evaluation 38 

Appendix I Scope and Methodology 44 

Appendix II Comments from the Department of Defense 47 

Appendix III Comments from the U.S. Coast Guard 58 

Appendix IV GAO Contacts and Staff Acknowledgments 60 

Tables 

Table 1: Nine Improvement Opportunities and Selected 

Corresponding Target Improvement Initiatives Contained 

in OSD’s Draft Oversight Framework 16 

Table 2: Summary of Increments and Phases for Acquiring DOD’s 

Defense Sexual Assault Incident Database 24 

 Sexual Assault Prevention Programs 
Abbreviations 

DOD Department of Defense 

MDA Milestone Decision Authority 

OMB Office of Management and Budget 

OSD Office of the Secretary of Defense 

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Page ii GAO-10-215 Sexual Assault Prevention Programs
Page 1 GAO-10-215 

 

United States Government Accountability Office

Washington, DC 20548 

 

February 3, 2010 

The Honorable John F. Tierney 

Chairman 

Subcommittee on National Security and Foreign Affairs 

Committee on Oversight and Government Reform 

House of Representatives 

Dear Mr. Chairman: 

Sexual assault is a crime that has a far-reaching negative impact on 

communities, families, and individuals and has additional implications for 

the military services because it undermines their core values, degrades 

mission readiness and esprit de corps, subverts strategic goodwill, and 

raises financial costs. Since we reported on these implications in 2008, 

incidents of sexual assault have continued to occur; in fiscal year 2008, the 

Department of Defense (DOD) reported nearly 3,000 alleged sexual assault 

cases, and the U.S. Coast Guard reported about 80.1

 However, it is 

impossible to accurately analyze trends or to draw conclusions from these 

data about the incidence of sexual assault in the military services because, 

as we have previously reported, DOD and the Coast Guard have not been 

using standardized reporting requirements.2

Since 2004, Congress has repeatedly taken steps to address sexual assault 

in the military, including passing legislation that directs the Secretary of 

Defense to develop a comprehensive policy for DOD on the prevention of 

and response to sexual assaults involving members of the Armed Forces. 

The comprehensive policy is to include procedures for confidentially 

reporting sexual assault incidents. Further, the Secretary of Defense is 

1

In fiscal year 2008, DOD reported 2,908 alleged incidents of sexual assault involving 

military servicemembers, and the Coast Guard reported 84. However, data on the reported 

alleged sexual assault incidents in DOD and the Coast Guard are imprecise representations 

of the extent to which sexual assault is occurring in the military services because they may 

include incidents that occurred before a victim’s military service began or before fiscal year 

2008. Furthermore, these data are reported regardless of the final outcome and therefore 

some of these reports may turn out to be unsubstantiated. The military services’ fiscal year 

2009 sexual assault incident data were not included in our report because they will not be 

published by DOD until March 15, 2010. 

2

GAO, Military Personnel: DOD’s and the Coast Guard’s Sexual Assault Prevention and 

Response Programs Face Implementation and Oversight Challenges, GAO-08-924

(Washington, D.C.: Aug. 29, 2008). 

 Sexual Assault Prevention Programs 
 

required to submit an annual report to Congress on reported sexual 

assault incidents involving servicemembers.3

 In 2008, we issued two 

reports that have helped inform congressional deliberations on sexual 

assault in the military; the first, in January 2008,4

 addressed sexual assault 

at the DOD and Coast Guard academies, while the second, in August 2008,5

addressed sexual assault in the military and Coast Guard services. Our 

August 2008 report found that while DOD and the Coast Guard have taken 

positive steps to prevent and respond to sexual assault, program 

implementation was hindered by several issues, such as the lack of an 

oversight framework—that is, a plan to improve the Office of the Secretary 

of Defense’s (OSD) oversight of the programs; limited support from some 

commanders; and training that was not consistently effective.6

Accordingly, we made a number of recommendations to improve DOD and 

Coast Guard programs, including recommending the development of an 

oversight framework to assess program effectiveness and the evaluation of 

program guidance, training, and installation-level staffing processes to 

enhance program implementation. We also raised as a matter for 

congressional consideration that the Coast Guard be required to annually 

submit to Congress sexual assault incident and program data that are 

methodologically comparable to those required of DOD. DOD and the 

Coast Guard concurred with all of the recommendations in our August 

2008 report, which are reprinted in the Background section of this report. 

In addition, we testified twice before your Subcommittee: in July 2008,7

 to 

discuss our preliminary observations on DOD’s and the Coast Guard’s 

sexual assault prevention and response programs, and in September 2008, 

to discuss the findings and recommendations included in our August 2008 

report.8

 

3

Pub. L. No. 108-375, § 577 (2004). 

4

GAO, Military Personnel: The DOD and Coast Guard Academies Have Taken Steps to 

Address Incidents of Sexual Harassment and Assault, but Greater Federal Oversight Is 

Needed, GAO-08-296 (Washington, D.C.: Jan.17, 2008). 

5

GAO-08-924. 

6

GAO-08-924. 

7

GAO, Military Personnel: Preliminary Observations on DOD’s and the Coast Guard’s 

Sexual Assault Prevention and Response Programs, GAO-08-1013T (Washington, D.C.: 

July 31, 2008). 

8

GAO, Military Personnel: Actions Needed to Strengthen Implementation and Oversight 

of DOD’s and the Coast Guard’s Sexual Assault Prevention and Response Programs, 

GAO-08-1146T (Washington, D.C.: Sept. 10, 2008). 

Page 2 GAO-10-215 Sexual Assault Prevention Programs
 

In November 2008, you requested that we continue to monitor DOD and 

Coast Guard efforts to strengthen the implementation and oversight of 

their respective sexual assault prevention and response programs. This 

report builds upon our previous work related to sexual assault in the 

military services, and assesses the extent to which (1) DOD has taken 

steps to implement our recommendations from 2008 and has further 

developed its programs to prevent and respond to sexual assault; (2) DOD 

has taken steps to address a congressional requirement to establish a 

centralized, case-level sexual assault incident database; and (3) the Coast 

Guard has taken steps to implement our recommendations from 2008 and 

has further developed its programs to prevent and respond to sexual 

assault. 

To assess the extent to which DOD has implemented our previous 

recommendations, we reviewed current DOD policies and programs and 

compared them with our prior findings and recommendations. We also 

interviewed DOD officials to supplement our analyses of program 

modifications. To assess the extent to which DOD has addressed the 

congressional requirement to establish a centralized, case-level sexual 

assault database, we reviewed applicable legislation9

 to identify statutory 

provisions that direct DOD to make changes to its processes for collecting 

and maintaining sexual assault data. We also reviewed applicable DOD 

documentation, compared it to DOD, federal, and industry guidance and to 

key system acquisition best practices; and interviewed DOD officials to 

obtain information on the status of the department’s efforts to establish 

the database. To assess the extent to which the Coast Guard has 

implemented our previous recommendations, we reviewed current Coast 

Guard policies and programs and compared them with our prior findings 

and recommendations. We also interviewed Coast Guard officials to 

supplement our analyses of program modifications. Further details about 

our scope and methodology can be found in appendix I. 

We conducted this performance audit from February 2009 to February 

2010 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. 

 

9

Pub. L. No. 110-417, § 563 (2008). 

Page 3 GAO-10-215 Sexual Assault Prevention Programs
 

DOD has taken steps to implement our August 2008 recommendations to 

improve its sexual assault prevention and response program; however, its 

efforts reflect various levels of progress, and opportunities exist for 

further program improvements. In August 2008, we made nine 

recommendations to address the program issues we identified, and DOD 

has taken a number of steps to implement four of these 

recommendations.10 For example, OSD suggested policy revisions that 

have led to interim guidance for implementing sexual assault prevention 

and response programs in joint and deployed environments. Also, OSD 

chartered the Health Affairs Sexual Assault Task Force, which evaluated 

and subsequently issued recommendations to address factors that may 

hinder access to health care following a sexual assault. However, DOD’s 

steps toward implementing the five other recommendations from 2008 

reflect less progress, which is likely to hinder the effectiveness of DOD’s 

efforts to oversee its programs. For example, although OSD has drafted an 

oversight framework, as we recommended, to guide the implementation 

and assessment of the department’s sexual assault prevention and 

response programs, the framework does not contain all the key elements 

needed for comprehensive oversight. Specifically, it lacks criteria for 

measuring progress, although OSD does plan to develop these within the 

next 2 years. The framework also lacks an indication of how it will use the 

information derived from such measurement to improve its programs. Our 

2008 recommendation called for the oversight framework to include longterm goals, objectives, and milestones; performance goals and strategies; 

and criteria for measuring progress. Our prior work has also shown that 

results-oriented organizations use the resulting information to guide the 

development of future initiatives and identify how to budget available 

resources to achieve program goals.11 But OSD’s draft oversight 

framework does not identify how it will use or report the results of its 

performance assessments, does not identify how OSD’s budgeting of 

resources relates to its achievement of strategic program objectives, and 

does not correlate with the program’s two strategic plans. Until OSD 

incorporates these key elements into its draft oversight framework, it will 

be limited in its ability to effectively manage program development and 

determine the extent to which its programs help prevent the occurrence of 

sexual assaults. We are recommending that OSD strengthen its over

Results in Brief 

sight 

 

10GAO-08-924. 

11GAO, Managing for Results: Agency Progress in Linking Performance Plans With 

Budgets and Financial Statements, GAO-02-236 (Washington, D.C.: Jan. 4, 2002). 

Page 4 GAO-10-215 Sexual Assault Prevention Programs
 

of sexual assault prevention and response programs by incorporating all 

key elements into its oversight framework. 

 

DOD has taken preliminary steps to establish the Defense Sexual Assault 

Incident Database—-a centralized, case-level sexual assault incident 

system—but given what has been accomplished to date and what remains 

to be accomplished, DOD officials did not develop this database in time to 

meet the statutorily mandated January 2010 implementation deadline.12

Moreover, DOD lacks a reliable schedule to guide acquisition and 

implementation tasks and activities. In addition, other key information 

technology management practices that are essential to successfully 

acquiring and implementing the database also remain to be accomplished. 

These include assessing the program’s potential overlap with and 

duplication of related programs, justifying investment in the program on 

the basis of reliable estimates of life cycle costs and benefits, effectively 

developing and managing system requirements, adequately testing system 

capabilities, and effectively managing program risks. DOD officials agree 

that these key practices need to be implemented; however, they have yet 

to develop plans or timeframes for doing so. Therefore, until these 

practices are implemented effectively, DOD could face challenges in 

successfully delivering a database that meets mission needs and does not 

exceed cost and schedule commitments. As DOD moves forward with its 

development of the Defense Sexual Assault Incident Database, we are 

recommending that it adhere to key system development and acquisition 

management processes and controls. 

While the Coast Guard has partially implemented one of our 

recommendations to further develop its sexual assault prevention and 

response program, it has not implemented the other. In August 2008, we 

reported that the Coast Guard’s sexual assault prevention and response 

program was hindered by several issues, and we made two 

recommendations to strengthen its program’s implementation.13 To its 

credit, in June 2009, the Coast Guard began assessing its program staff’s 

workload to address our recommendation to evaluate its processes for 

staffing key installation-level positions in its sexual assault prevention and 

response program. However, while the Coast Guard has broadly identified 

program objectives, it has not addressed our recommendation to develop 

an oversight framework that provides comprehensive and specific 

12Pub. L. No. 110-417, § 563 (2008). 

13GAO-08-924. 

Page 5 GAO-10-215 Sexual Assault Prevention Programs
 

guidance for operating its program. As a result, the Coast Guard is unable 

to measure program progress, accurately identify program needs, and 

optimize the use of available resources. Moreover, the Coast Guard lacks a 

systematic process for assembling, documenting, and maintaining sexual 

assault incident data, and lacks quality control procedures to ensure that 

the program data being collected are reliable. In fiscal year 2008, for 

example, different Coast Guard offices documented conflicting numbers 

of sexual assault reports: the Coast Guard Program Office documented 30, 

while the Investigative Office documented 78. Without a systematic 

process for tracking its data, the Coast Guard lacks reliable knowledge on 

the occurrence of sexual assaults. We are recommending that the Coast 

Guard develop a systematic process for tracking its data to ensure that 

program information collected is valid and reliable. 

In written comments on a draft of this report, both DOD and the Coast 

Guard concurred with all of our recommendations. DOD further noted in 

its comments that while it concurred with our recommendations, our 

report contains technical inaccuracies and misstatements that diminish 

the department’s efforts. We believe that our report accurately represents 

DOD’s progress to address our recommendations from 2008 and we 

incorporated technical corrections from DOD, where appropriate. DOD’s 

comments are reprinted in appendix II, and the Coast Guard’s comments 

are reprinted in appendix III. 

Background 

Department of Defense In October 2004, Congress included a provision in the Ronald W. Reagan 

National Defense Authorization Act for Fiscal Year 2005 that required the 

Secretary of Defense to develop a comprehensive policy for DOD on the 

prevention of and response to sexual assaults involving members of the 

Armed Forces.14 The legislation required that the policy be based on the 

recommendations of the Defense Task Force on Care for Victims of Sexual 

 

14Pub. L. No. 108-375, § 577 (2004). 

Page 6 GAO-10-215 Sexual Assault Prevention Programs
 

Assaults and on other matters as the Secretary deemed appropriate.15

Among other things, the legislation requires the Secretary to establish a 

standardized departmentwide definition of sexual assault, and to develop 

a policy, using the standardized definition, to address a number of issues, 

including the confidential reporting of sexual assault incidents and the 

uniform collection of data on the incidence of sexual assault. The law also 

requires DOD to submit an annual report to Congress on reported sexual 

assault incidents involving members of the Armed Forces. 

In October 2005, DOD issued DOD Directive 6495.01, which contains its 

policy for the prevention of and response to sexual assault.16 In June 2006, 

DOD issued DOD Instruction 6495.02, which provides guidance for 

implementing this policy.17 DOD’s directive defines sexual assault as 

follows: 

“intentional sexual contact, characterized by use of force, threats, 

intimidation, abuse of authority, or when the victim does not or 

cannot consent. Sexual assault includes rape, forcible sodomy 

(oral or anal sex), and other unwanted sexual contact that is 

aggravated, abusive or wrongful (to include unwanted and 

inappropriate sexual contact), or attempts to commit these acts. 

“Consent” means words or overt acts indicating a freely given 

agreement to the sexual conduct at issue by a competent person. 

An expression of lack of consent through words or conduct means 

there is no consent. Lack of verbal or physical resistance or 

submission resulting from the accused’s use of force, threat of 

force, or placing another person in fear does not constitute 

consent. A current or previous dating relationship by itself or the 

manner of dress of the person involved with the accused in the 

sexual conduct at issue shall not constitute consent.” 

 

15In February 2004, the Secretary of Defense directed the Under Secretary of Defense for 

Personnel and Readiness to undertake a 90-day review to assess sexual assault policies and 

programs in DOD and the services and recommend changes to increase prevention, 

promote reporting, enhance the quality of support provided to victims especially within 

combat theaters, and improve accountability for offender actions. Among the 

recommendations of the task force was that DOD establish a single point of accountability 

for all sexual assault policy matters within the department. 

16Department of Defense Directive 6495.01, Sexual Assault Prevention and Response 

(SAPR) Program (Oct. 6, 2005), as updated by subsequent changes. 

17Department of Defense Instruction 6495.02, Sexual Assault Prevention and Response 

Program Procedures (June 23, 2006), as updated by subsequent changes. 

Page 7 GAO-10-215 Sexual Assault Prevention Programs
 

In October 2008, Congress passed the Duncan Hunter National Defense 

Authorization Act for Fiscal Year 2009, which includes a provision 

requiring the Secretary of Defense to implement a centralized, case-level 

database for the collection and maintenance of information regarding 

sexual assaults involving members of the Armed Forces.18 The law 

specifies that the database include information, if available, about the 

nature of the assault, the victim, the offender, and the outcome of any legal 

proceedings associated with the assault, and requires DOD to implement 

the database by January 2010—which is 15 months from the day of its 

enactment. 

In OSD, the Under Secretary of Defense for Personnel and Readiness has 

the responsibility for developing the overall policy and guidance for the 

department’s sexual assault prevention and response program. Under the 

Office of the Under Secretary of Defense for Personnel and Readiness, 

OSD’s Sexual Assault Prevention and Response Office (within the Office of 

the Deputy Under Secretary of Defense for Plans) serves as the 

department’s single point of responsibility for sexual assault policy 

matters.19 These responsibilities include providing the military services 

with guidance and technical support and facilitating the identification and 

resolution of issues; developing programs, policies, and training standards 

for the prevention of, reporting of, and response to sexual assault; 

developing strategic program guidance and joint planning objectives; 

overseeing the department’s collection and maintenance of data on 

reported alleged sexual assaults involving servicemembers; establishing 

mechanisms to measure the effectiveness of the department’s sexual 

assault prevention and response program; and preparing the department’s 

annual report to Congress. The Deputy Under Secretary of Defense for 

Plans has the responsibility for programming, budgeting, and allocating 

funds and other resources for the Sexual Assault Prevention and Response 

Office. 

Each military service has established a sexual assault prevention and 

response office with responsibility for overseeing and managing its sexual 

assault matters. Further, DOD’s instruction requires the military services 

 

18Pub. L. No. 110-417, § 563 (2008). 

19This responsibility does not include responsibility for legal processes provided under the 

Uniform Code of Military Justice and Manual for Courts-Martial and criminal investigative 

policy matters that are assigned to the judge advocates general of the military services and 

DOD’s Inspector General, respectively. 

Page 8 GAO-10-215 Sexual Assault Prevention Programs
 

to establish Sexual Assault Response Coordinator positions and states that 

at the services discretion, these positions may be staffed by members of 

the military, civilian employees, or DOD contractors.20 Sexual Assault 

Response Coordinators are generally responsible for implementing their 

respective services’ sexual assault prevention and response programs, 

including coordinating the response to and reporting of sexual assault 

incidents. Other responders include victim advocates, judge advocates, 

medical and mental health providers, criminal investigative personnel, law 

enforcement personnel, and chaplains. 

Coast Guard The Coast Guard has had a sexual assault prevention and response 

program in place since 1997, and in December 2007, the Coast Guard 

updated its instruction to generally mirror DOD’s policy. According to 

Coast Guard officials, in January 2009, they revised their instruction to 

incorporate what officials have stated is a more comprehensive definition 

of the term “sexual assault,” modify titles of certain program personnel to 

better reflect their responsibility, and clarify processes for reporting a 

sexual assault.21

The Coast Guard’s Office of Work-Life (within the Health, Safety, and 

Work-Life Directorate, which is under the Office of the Assistant 

Commandant for Human Resources) is responsible for overseeing and 

managing sexual assault matters. At the installation level, the Coast Guard 

has established Employee Assistance Program Coordinators to manage the 

response to and reporting of sexual assault incidents. Like DOD’s, the 

Coast Guard’s sexual assault prevention and response program utilizes 

other responders to manage sexual assault incidents, including victim 

advocates, judge advocates, medical and mental health providers, criminal 

investigative personnel, law enforcement personnel, and chaplains. 

 

20Department of Defense Instruction 6495.02, Sexual Assault Prevention and Response 

Program Procedures (Jun. 23, 2006). 

21U.S. Coast Guard Commandant Instruction 1754.10D, Sexual Assault Prevention and 

Response (SAPR) Program (Jan. 16, 2009). 

Page 9 GAO-10-215 Sexual Assault Prevention Programs
 

In August 2008, we issued a report containing nine recommendations to 

DOD and two recommendations to the Coast Guard to improve program 

implementation.23 With respect to DOD, we recommended that the 

Secretary of Defense take the following actions: 

Recommendations from 

2008 GAO Report22

• Review and evaluate the department’s policies for the prevention of 

and response to sexual assault to ensure that adequate guidance is 

provided to effectively implement the program in deployed 

environments and joint environments. 

• Direct the military service secretaries to emphasize to all levels of 

command their responsibility for supporting the program, and review 

the extent to which commanders support the program and resources 

are available to raise servicemembers’ awareness of sexual assault 

matters. 

• Systematically evaluate and develop an action plan to address any 

factors that may prevent or discourage servicemembers from 

accessing health services following a sexual assault. 

• Direct the Defense Task Force on Sexual Assault in the Military 

Services to begin its examination immediately, now that all members 

of the task force have been appointed, and to develop a detailed plan 

with milestones to guide its work. 

• Require the Sexual Assault Prevention and Response Office to develop 

an oversight framework to guide continued program implementation 

and to evaluate program effectiveness. At a minimum, such a 

framework should contain long-term goals, objectives, and milestones; 

performance goals; strategies to be used to accomplish goals; and 

criteria for measuring progress. 

• Review and evaluate sexual assault prevention and response training 

to ensure that the military services are meeting training requirements 

and to enhance the effectiveness of the training. 

• Evaluate the military services’ processes for staffing and designating 

key installation-level program positions—such as coordinators—at 

installations in the United States and overseas, to ensure that these 

 

22GAO-08-924. 

23GAO-08-924. 

Page 10 GAO-10-215 Sexual Assault Prevention Programs
 

individuals have the ability and resources to fully carry out their 

responsibilities. 

• Direct the military service secretaries to provide installation-level 

incident data to the Sexual Assault Prevention and Response Office 

annually or as requested to facilitate the analysis of sexual assaultrelated data and to better target resources over time. 

• Improve the usefulness of the department’s annual report as an 

oversight tool both internally and for congressional decision makers by 

establishing baseline data to permit the analysis of data over time and 

to distinguish cases in which (1) evidence was insufficient to 

substantiate an alleged assault, (2) a victim recanted, or (3) the 

allegations of sexual assault were unfounded. 

With respect to the Coast Guard, we recommended that the Commandant 

of the Coast Guard take the following actions: 

• Evaluate the Coast Guard’s processes for staffing key installation-level 

program positions—such as coordinators—to ensure that these 

individuals have the ability and resources to fully carry out their 

responsibilities. 

• Develop an oversight framework to guide continued program 

implementation and to evaluate program effectiveness. At a minimum, 

such a framework should contain long-term goals, objectives, and 

milestones; performance goals; strategies to be used to accomplish 

goals; and criteria for measuring progress. 

We also suggested as a matter for congressional consideration that the 

Coast Guard be required to annually submit to Congress sexual assault 

incident and program data that are methodologically comparable to those 

required of DOD. In commenting on a draft of that report, both DOD and 

the Coast Guard concurred with all of our recommendations.24

 

24GAO-08-924. 

Page 11 GAO-10-215 Sexual Assault Prevention Programs
 

DOD has made varying levels of progress in implementing our 

recommendations from 2008 to improve its sexual assault prevention and 

response programs. To its credit, DOD has implemented four of the nine 

recommendations in our August 2008 report. However, DOD’s efforts 

toward implementing the other five recommendations reflect less 

progress, which is likely to hinder the effectiveness of DOD’s efforts to 

oversee its programs. 

DOD’s Efforts to 

Address GAO’s 

Recommendations 

from 2008 Reflect 

Varying Levels of 

Progress 

DOD Has Implemented 

Four of Our 

Recommendations from 

2008 

During fiscal years 2008 and 2009, DOD implemented four of the 

recommendations in our August 2008 report on DOD and Coast Guard 

sexual assault prevention and response programs. First, OSD established a 

working group to address our recommendation to review and evaluate the 

adequacy of DOD policies for implementing its sexual assault prevention 

and response program in joint and deployed environments. Based on the 

working group’s findings, OSD submitted a memorandum to the Joint Staff 

in April 2009 detailing its suggested revisions to joint policy, which a Joint 

Staff official told us they are using to modify related publications. 

Additionally, according to a Joint Staff official, the Joint Staff has issued 

interim guidance to support the implementation of sexual assault 

prevention and response programs in joint and deployed environments 

until the new joint publications are approved.25

Second, the military service secretaries have taken a variety of steps to 

address our recommendation to emphasize responsibility for program 

support to all levels of command. For example, the military services’ top 

leadership spoke at their respective services’ sexual assault prevention 

summits, during which they emphasized the need for “ownership” of the 

programs and commitment to the prevention of and response to sexual 

assault. Specifically, in the spring of 2009, the Secretary of the Army spoke 

to noncommissioned officers—the personnel responsible for program 

implementation—on the importance of modifying the Army’s culture to 

actively reject sexual assault and other inappropriate behavior. In the fall 

of 2009, the Secretaries of the Air Force and Navy and the Commandant of 

the Marine Corps gave similar presentations to their personnel, during 

which they stressed their commitment to eradicating sexual assault in the 

military services. The military services have taken even more far-reaching 

 

25Memorandum for the Director, Joint Staff (J-1), Sexual Assault Prevention and Response 

Guidance for Joint Publications (Apr. 7, 2009). 

Page 12 GAO-10-215 Sexual Assault Prevention Programs
 

steps to relay their support for and to commit resources to sexual assault 

prevention and response programs. For example, the Secretary of the 

Navy recently established the Navy’s Sexual Assault Prevention and 

Response Office that reports directly to the Secretary, which Navy officials 

assert will foster additional support and accountability for its sexual 

assault program initiatives. The Marine Corps, following a review of its 

program staffing, established full-time Sexual Assault Response 

Coordinator positions at four installations with the highest troop 

concentrations and is in the process of establishing full-time coordinator 

positions at installations with at least 1,000 troops as a way to better 

manage its sexual assault prevention and response programs. Additionally, 

the Army has incorporated an assessment of sexual assault program 

awareness into promotional boards for noncommissioned officers to 

promote accountability for the implementation of prevention and response 

initiatives. 

DOD has also taken a variety of steps to emphasize support for and to 

further develop its sexual assault prevention and response programs. For 

example, in fiscal year 2008, representatives from OSD and the military 

services visited selected military installations to assess, among other 

things, the extent to which commanders—company and field grade 

officers—support sexual assault prevention and response programs. OSD 

found that while most program personnel had demonstrable support from 

their command, command support of sexual assault prevention and 

response programs varied from installation to installation, and stronger 

command support of the program was required. OSD further reported that 

it is working with its stakeholders to address its findings. Additionally, 

each of the military services has incorporated interactive, scenario-based 

training programs to promote increased involvement by participants and 

to enhance the retention of the material being presented. For example, the 

Army contracts with a company that offers a nationally recognized 

presentation called “Sex Signals”—a 90-minute program that uses 

interactive skits to address the topics of dating, rape, consent, and 

intervention. The Air Force has implemented bystander intervention 

training that incorporates techniques such as role-playing to motivate 

servicemembers to take actions if they see, hear, or otherwise recognize 

signs of an inappropriate or unsafe situation. The Marine Corps has 

implemented and the Navy is in the process of adopting a program called 

Mentors in Violence Prevention training. Like the Air Force’s program, this 

consists of role-playing exercises that allow students to construct and 

practice ways to respond or intervene in incidents of harassment, abuse, 

or violence. 

Page 13 GAO-10-215 Sexual Assault Prevention Programs
 

Third, OSD chartered the Health Affairs Sexual Assault Task Force to 

address our recommendation to evaluate and develop an action plan to 

address factors that may prevent or discourage servicemembers from 

seeking health services. In March 2009, the task force made a number of 

recommendations intended to improve the availability of health care, such 

as (1) chartering a military health system Sexual Assault Health Care 

Integrated Policy Team to review department-level policies regarding 

clinical practice guidelines, standards of care, research gaps and 

opportunities, personnel and staffing, training requirements and 

responsibilities, continuity of care, and in-theater equipment and supplies; 

(2) drafting model memorandums of understanding for use by all service 

military treatment facilities as they establish continuity of care 

relationships with local community providers; and (3) reviewing DOD 

policy, including performing peer reviews of sexual assault cases to ensure 

that they are aligned with civilian practices. 

Fourth, in August 2008, the Defense Task Force on Sexual Assault in the 

Military Services began its examination of matters relating to sexual 

assault, as we recommended. According to task force staff, the task force 

has conducted interviews and focus groups with sexual assault prevention 

and response program personnel at approximately 60 locations throughout 

the world. However, the task force did not meet its August 11, 2009, 

reporting deadline. It was granted an extension, which it met by releasing 

its report on December 1, 2009.26

DOD’s Efforts toward 

Implementing the Five 

Other Recommendations 

from 2008 Reflect Less 

Progress 

DOD’s efforts to implement the five other recommendations we made in 

our report issued in August 2008 reflect less progress. Further, remaining 

issues with OSD’s strategic planning efforts and DOD’s annual report to 

Congress on alleged sexual assault incidents are likely to hinder the 

effectiveness of DOD’s efforts to oversee its programs. 

 

26Section 576 of the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 

2005 directed the task force to conduct an examination of matters relating to sexual assault 

in cases involving members of the Armed Forces, and required the task force to submit a 

report not later than 1 year after initiation of its examination. Section 566 of the National 

Defense Authorization Act for Fiscal Year 2010, Pub. L. No. 111-84 (2009), amended the 

previous statute and provided a deadline of no later than December 1, 2009. The Report of 

the Defense Task Force on Sexual Assault in the Military Services was released on 

December 1, 2009. 

Page 14 GAO-10-215 Sexual Assault Prevention Programs
 

OSD recently drafted an oversight framework, but the framework only 

partially satisfies our recommendation in that the framework does not 

contain all the elements that we previously recommended as necessary for 

effective strategic planning and program implementation. Further, the 

draft oversight framework cannot be implemented until it is approved—a 

step that OSD officials stated will occur once they have incorporated 

revisions from and obtained the endorsements of the military service 

secretaries. Based on our prior work on the importance of strategic 

program planning guidance and our finding that OSD had not established 

an oversight framework to guide the implementation of its programs, we 

recommended in August 2008 that OSD develop an oversight framework 

that includes, at a minimum, (1) long-term goals, objectives, and 

milestones; (2) performance goals and strategies to be used to accomplish 

goals; and (3) criteria for measuring progress.27

OSD’s Oversight Framework 

Has Been Drafted, but It Lacks 

Key Elements Necessary for 

Comprehensive Oversight 

To its credit, OSD, in October 2009, completed drafting and is preparing to 

begin a 3-year implementation of its oversight framework to improve the 

oversight and integration of the department’s sexual assault prevention 

and response programs. This draft oversight framework contains longterm goals, objectives, and milestones for implementation. For example, it 

identifies nine objective-like elements—called “improvement 

opportunities”—to facilitate program oversight. Examples of the 

improvement opportunities include defining core oversight roles and 

responsibilities, standardizing performance measures and reports, and 

improving communication with stakeholders. The draft framework also 

identifies action-oriented steps that correspond with and are designed to 

facilitate the achievement of these opportunities. For example, the draft 

framework specifies that OSD will “define and document the policy 

development, coordination, and approval process” and “define and 

document the process to review alignment between policy and program 

development” as specific steps toward the achievement of its objective of 

defining core oversight roles and responsibilities. Table 1 details the nine 

opportunities and selected steps for achieving them that are contained in 

the draft framework. 

 

27GAO, The Results Act: An Evaluator’s Guide to Assessing Agency Annual Performance 

Plans, GAO/GGD-10.1.20 (Washington, D.C.: April 1998); Managing for Results: Critical 

Issues for Improving Federal Agencies’ Strategic Plans, GAO/GGD-97-180 (Washington, 

D.C.: Sept. 16, 1997); and GAO-08-924. 

Page 15 GAO-10-215 Sexual Assault Prevention Programs
 

Table 1: Nine Improvement Opportunities and Selected Corresponding Target Improvement Initiatives Contained in OSD’s 

Draft Oversight Framework 

Improvement opportunity Target improvement initiatives 

Standardize core oversight processes • Define policy development, coordination, and approval process 

• Define process to review alignment between policy and program guidance 

Develop and standardize 

performance measures 

• Develop baseline measures for program performance data 

• Develop standard data collection and management plan to be tracked across DOD 

Promote command support of 

programs 

• Develop and execute survey to gauge combatant command planning status for program 

implementation in contingency operations 

• Assess education/training for commanders and establish required training 

Leverage inspectors general in 

evaluation of compliance with policy 

• Identify success factors of program policy to be communicated to DOD and service 

inspectors general 

• Provide training to DOD and service inspectors general on emerging sexual assault 

prevention and response topics 

Improve working group/subcommittee 

structure 

• Evaluate whether the Sexual Assault Advisory Council operating structure could be 

improved to better meet DOD community needs 

• Develop subcommittee and working group charters to better define roles and 

responsibilities 

Capture victim experience data • Develop and implement a mechanism to capture victim experience data 

• Integrate victim quality assurance mechanism into existing victim inquiry process 

Implement DOD quarterly review 

meetings 

• Conduct DOD-specific oversight meetings outside of the Sexual Assault Advisory Council 

operating structure 

• Review budget programming by services and commands to support adequate staffing 

levels 

Collaborate with external partners • Establish common understanding of data definitions within DOD sexual assault prevention 

and response community 

• Improve sharing of research and effective practices 

Improve proactive communication of 

information to stakeholders 

• Develop and execute a comprehensive communications plan that incorporates proactive 

communication strategies and key messaging for core stakeholders 

• Develop capability for OSD staff to regularly provide military services with relevant 

legislative affairs data 

Source: DOD. 

OSD’s draft oversight framework is a positive step toward stronger 

management of the department’s sexual assault prevention and response 

programs. Further, OSD recently restructured its Sexual Assault Advisory 

Council and established the Oversight Steering Committee to more 

actively involve DOD’s top leadership in the development and 

implementation of the department’s sexual assault prevention and 

response initiatives. For example, DOD’s instruction specifies that the 

Sexual Assault Advisory Council shall be chaired by the Under Secretary 

of Defense for Personnel and Readiness and shall comprise top DOD 

leadership, including the Deputy Under Secretary of Defense for Plans, the 

military departments’ assistant secretaries for manpower and reserve 

Page 16 GAO-10-215 Sexual Assault Prevention Programs
 

affairs, and the Vice Chairman of the Joint Chiefs of Staff. While the 

establishment of such committees is an important step toward successful 

implementation of the oversight framework, implementation will require 

the personal involvement of top DOD leadership to maintain the long-term 

focus on and accountability for program objectives. 

Further, OSD’s draft oversight framework is missing key elements that are 

needed to provide comprehensive oversight of DOD’s sexual assault 

prevention and response programs. Specifically, OSD’s framework lacks 

performance measures, does not identify how it will use or report the 

results of its performance assessments, does not identify how OSD’s 

budgeting of resources relates to its achievement of strategic program 

objectives, and does not correlate with the program’s two strategic plans. 

OSD’s draft oversight framework does not satisfy our recommendation 

from 2008 in that it does not yet contain performance measures, which are 

needed to facilitate the evaluation of program performance and the 

identification of areas needing improvement. Our prior work has shown 

that managers can use performance information to identify problems and 

develop solutions that will improve program results.28 Currently, OSD has 

plans to develop a standardized set of performance measures and targets 

by the second year of its 3-year plan for implementing its oversight 

framework. We note that our prior work has highlighted the importance of 

performance measures and that they should include quantifiable, 

numerical targets or other measurable values for determining (1) whether 

the desired performance results are being achieved and (2) overall 

program progress.29 Until performance measures are established, OSD 

cannot accurately assess the progress of the department’s initiatives or 

correctly identify and implement actions to improve program 

performance. 

Draft Oversight Framework 

Lacks Performance Measures 

and Details on How Measures 

Will Be Used to Guide Program 

Improvements

In addition to its lack of performance measures, OSD’s framework does 

not identify how OSD’s budgeting of resources relates to its achievement 

of strategic program objectives, which limits the department’s ability to 

inform budget formulation and execution decisions according to 

performance considerations. Our prior work has demonstrated that by 

linking program plans with budgets, organizations can more explicitly 

OSD’s Draft Oversight 

Framework Does Not Identify 

How Its Budgeting of 

Resources Relates to the 

Achievement of Strategic 

Objectives 

 

28GAO, Managing for Results: Enhancing Agency Use of Performance Information for 

Management Decision Making, GAO-05-927 (Washington, D.C.: Sept. 9, 2005). 

29GAO/GGD-10.1.20. 

Page 17 GAO-10-215 Sexual Assault Prevention Programs
 

guide budget discussions and can assist management by correlating total 

resources consumed with actual results achieved.30 While these 

correlations have not been made in the draft framework, OSD officials told 

us that the process of developing the framework helped to identify the 

need and gain approval for 21 full-time employees, which is three times the 

number of staff originally approved for that office. However, until OSD 

explicitly correlates its budgeting of resources to the achievement of 

strategic program objectives, it will be challenged in its justification of 

future budget requests. 

OSD’s strategic planning documents do not correlate with the program’s 

two strategic plans. Our prior work has shown that clear linkages among 

long-term strategic goals, objectives, strategies, and day-to-day activities 

are critical for enabling a strategic plan to drive an organization’s 

operations. In addition to its draft oversight framework, OSD drafted an 

internal strategic plan to guide the initiatives of DOD’s Sexual Assault 

Prevention and Response Office, and a DOD-wide strategic plan to guide 

initiatives across the larger DOD community. According to OSD officials, 

the oversight framework, when approved, will support OSD’s ability to 

meet the goals of its strategic plans, which were designed to serve as the 

overarching program planning guidance. 

Draft Oversight Framework 

Does Not Correlate with the 

Program’s Strategic Plans 

However, the intended correlation among these three documents is not 

clear because they do not use similar terminology to clearly link their 

purposes. For example, OSD’s internal strategic plan is based on five 

“strategic objectives” that are identical to the five “strategic sexual assault 

prevention and response priorities” contained in the DOD-wide strategic 

plan. In contrast, the draft oversight framework contains terminology that 

is different from both strategic plans, and it refers to its nine objective-like 

elements as “future state improvement opportunities.” As a result, the 

correlation between these three documents is not clear. Further, the two 

strategic plans and the draft oversight framework do not clearly illustrate 

how each supports the achievement of the objectives and strategies 

contained in the other two documents. In commenting on a draft of this 

report, DOD further defined the relationship between the draft oversight 

framework and its two strategic plans for sexual assault prevention and 

response programs. DOD also noted that the objective-like elements in its 

draft oversight framework were purposely not tied to the program 

objectives in the two strategic plans. However, without consistent 

 

30GAO-02-236. 

Page 18 GAO-10-215 Sexual Assault Prevention Programs
 

terminology and clearly correlated objectives and strategies among these 

three documents, the prioritization of and responsibility for these 

initiatives will remain unclear. (See app. II for DOD’s comments) 

While OSD has taken steps to evaluate the effectiveness of the sexual 

assault prevention and response training provided to DOD 

servicemembers, training programs cannot be assessed because OSD’s 

strategic plans and draft oversight framework do not contain measures 

against which to benchmark performance. As we reported in August 2008, 

DOD’s sexual assault prevention and response training was not 

consistently administered or evaluated for effectiveness. Accordingly, we 

recommended that DOD undertake an evaluation of the department’s 

training programs.31 To its credit, OSD’s training subcommittee reviewed 

the military services’ training policies and found that they continue to 

provide initial and refresher training for all personnel. However, it also 

found that a greater level of detail was needed in policy to guide the 

execution of training requirements. OSD’s training subcommittee 

developed an action plan for fiscal year 2009 that included visits to 

selected military installations to review sexual assault prevention and 

response training programs. 

Training Effectiveness Cannot 

Be Fully Determined without 

Performance Measures 

Nevertheless, OSD’s draft oversight framework does not include 

performance measures, thus limiting OSD’s ability to assess the 

effectiveness of training programs and other initiatives. OSD officials, as 

part of their recent strategic planning efforts, have acknowledged the need 

for and are planning to develop a standard set of DOD-wide performance 

measures over the next few years for DOD sexual assault prevention and 

response programs. However, they have stated that these performance 

measures will not be established until at least the second year of DOD’s 3-

year implementation plan for the oversight framework. Until these 

measures are established, we continue to assert that OSD cannot ensure 

that the department’s sexual assault prevention and response training 

effectively imparts an awareness of the subject matter to servicemembers. 

DOD has not implemented our recommendation to evaluate the military 

services’ processes for staffing key installation-level program positions to 

ensure that they have the ability and resources to fully carry out their 

responsibilities. In fiscal year 2008, OSD and the military services 

examined program staffing processes during OSD’s assessments of 

Staffing of Key InstallationLevel Program Positions Has 

Not Been Evaluated 

 

31GAO-08-924. 

Page 19 GAO-10-215 Sexual Assault Prevention Programs
 

selected military installations, and similarly concluded that DOD’s policy 

on selection criteria and scope of duty for key program personnel should 

be further evaluated. However, OSD officials stated that they had not 

taken action to address their findings because personnel from the 

congressionally mandated Defense Task Force on Sexual Assault in the 

Military Services advised OSD that they would be making related 

recommendations in their December 2009 report to Congress. Until DOD 

implements our 2008 recommendation, it cannot ensure that it is able to 

adequately staff and resource its sexual assault prevention and response 

programs. 

While the military services have agreed to provide installation-level data 

on sexual assault incidents, OSD officials told us that they will not collect 

them until they have implemented the statutorily mandated centralized 

database to maintain these data. (For a discussion of this database, see a 

later section of this report.) As we reported in our August 2008 report, 

OSD could not conduct a comprehensive cross-service trend analysis 

because it did not have access to installation-level data on sexual assault 

incidents from the military services.32 As such, we recommended that the 

military services provide these data to OSD to facilitate the analysis of 

sexual assault-related data and to better target resources over time. 

However, OSD is not currently collecting these data, despite their 

availability, because it has not yet completely standardized its data 

definitions and data elements. OSD and its stakeholders have started to 

create a standardized set of sexual assault data elements, thus delineating 

the types of data to be provided by each of the services. However, OSD 

officials told us that the process of developing and training the numerous 

program personnel worldwide to collect and report standardized data 

elements will be a very complex and time-consuming undertaking. 

Further, OSD officials stated that they plan to finalize the data definitions 

in the coming months, but added that similar to the data elements, they 

will not require that the definitions be used by the military services until 

the implementation of DOD’s sexual assault incident database, the date of 

which is not yet known. Therefore, it is unknown when OSD will establish 

baseline data, which are needed to conduct trend analyses of the military 

services’ sexual assault data. 

Installation-Level Data Are Not 

Being Collected While 

Centralized Database Is under 

Development 

 

32GAO-08-924. 

Page 20 GAO-10-215 Sexual Assault Prevention Programs
 

While OSD introduced some changes in DOD’s annual report to Congress, 

these changes have not sufficiently improved the report to ensure that 

congressional stakeholders are better informed on DOD’s prevention of 

and response to incidents of sexual assault. As we previously reported, 

DOD’s annual report may not have been effectively characterizing 

incidents of sexual assault in the military services, and thus we 

recommended that the department improve the usefulness of its annual 

report as an oversight tool.33 To its credit, OSD incorporated new charts 

and graphics into DOD’s fiscal year 2008 annual report that more 

specifically illustrated the demographics of individuals involved and the 

locations in which sexual assaults in the military have been occurring. 

Further, OSD and its stakeholders have started to create a standardized set 

of sexual assault data elements and definitions. However, the 

standardization is not yet complete, and as noted previously, OSD officials 

told us that developing definitions and data elements for and training the 

numerous program personnel worldwide on how to consistently report on 

the data elements collected, is very complex and time-consuming. OSD 

officials added that the standardization of data definitions is something 

that they expect to accomplish in the near term, while standardizing data 

elements will take longer since it is a task that will be completed in 

conjunction with their development of a centralized sexual assault 

database. Further, OSD has not provided its own analysis of the military 

services’ reports and programs, and we do not believe that it will be able 

to do so until it establishes performance measures with which it can 

assess program effectiveness. 

DOD’s Annual Report to 

Congress Is Not 

Comprehensive 

We believe that the format of the information provided in DOD’s annual 

report to Congress continues to complicate the reader’s ability to establish 

a comprehensive understanding of the department’s sexual assault 

prevention and response programs. Our prior work shows that the 

usefulness of data ultimately depends on the degree of confidence that 

users have in the data being presented. Higher confidence can be achieved 

by providing key information about the data being reported, including 

efforts to validate data and the implications of the data limitations that 

have been identified.34 However, we believe the sexual assault incident 

data are not qualified at the outset of DOD’s annual report to disclose that 

incident data may include an alleged sexual assault that occurred prior to 

 

33GAO-08-924. 

34GAO, Agency Performance Plans: Examples of Practices That Can Improve Usefulness 

to Decisionmakers, GAO/GGD/AIMD-99-69 (Washington, D.C.: Feb. 26, 1999). 

Page 21 GAO-10-215 Sexual Assault Prevention Programs
 

the victim’s or perpetrator’s military service or outside of the year in which 

it was reported. Our prior work shows that standardized data with 

common definitions are critical to ensuring that comparable information 

from multiple sources is accurately represented.35 However, the military 

services’ sections in the annual report contain similar but not comparable 

types of information. For example, the Army and Air Force structure their 

respective reports according to the category of program information, and 

the Navy and Marine Corps structure their report according to the 

responses received from program personnel involved in their sexual 

assault prevention and response initiatives. While we do not advocate for 

one military service’s approach over another’s, the dissimilar report 

formats make it difficult, if not impossible, to compare program efforts. 

OSD officials told us that they have taken initial steps to address some 

data inconsistencies by providing the military services with a data 

collection template to begin the process of standardizing the collection 

and reporting of sexual assault program information in DOD’s fiscal year 

2009 annual report to Congress. This is an important first step; however, it 

does not fully address our concerns in that the military services may still 

be reporting data that are based on different criteria. Further, while we 

recognize that the complete standardization of the type, amount, and 

format of the military services’ data will be a significant undertaking, OSD 

will not be able to report consistent data on the status and condition of 

DOD’s sexual assault prevention and response programs until these issues 

are resolved. Until OSD and the military services reach consensus on the 

data elements and begin disseminating the new data collection and 

reporting requirements to program personnel, DOD will continue to lack 

key information needed for oversight. 

DOD has taken preliminary steps to implement a centralized, case-level 

sexual assault incident database. However, the database was not 

implemented by the statutorily mandated deadline of January 2010. 

Moreover, when the database will be implemented is uncertain because a 

reliable schedule to guide acquisition and implementation tasks and 

activities has yet to be developed. In addition, other key information 

technology management practices that are essential to successfully 

acquiring and implementing the database also remain to be accomplished. 

DOD Has Yet to 

Establish a 

Centralized Sexual 

Assault Database 

 

35GAO, Managing for Results: Barriers to Interagency Coordination, GAO/GGD-00-106

(Washington, D.C.: Mar. 29, 2000). 

Page 22 GAO-10-215 Sexual Assault Prevention Programs
 

DOD officials agreed that these key practices need to be implemented; 

however, they have yet to develop plans or time frames for doing so. 

The National Defense Authorization Act for Fiscal Year 2009 required DOD 

to implement a centralized, case-level database for collecting and 

maintaining information on sexual assaults involving members of the 

Armed Forces, including information, if available, about the nature of the 

assault, the victim, the offender, and the outcome of any legal proceedings 

in connection with the assault.36 The law also required the Secretary of 

Defense to submit a concept plan for this database to Congress by January 

2009 and to implement the database by January 2010. In response to these 

statutory requirements, the Under Secretary of Defense for Personnel and 

Readiness instructed the Sexual Assault Prevention and Response Office 

to develop the Defense Sexual Assault Incident Database. According to 

OSD officials, this database is to generate congressionally mandated 

annual reports, run ad hoc queries, track sexual assault victim support 

services, support program administration, meet program reporting 

requirements, and perform data analysis. Among other things, the database 

is also to ensure the privacy and restricted reporting options of victims. 

DOD Did Not Meet the 

Statutory Deadline for 

Implementing the 

Database, and It Does Not 

Have a Schedule with 

Reliable Time Frames for 

Doing So 

DOD has established conceptual plans for acquiring and deploying a 

centralized sexual assault incident database. According to these plans, the 

database will be delivered in two increments, with the first increment 

consisting of four phases. (See table 2 for a description of the increments 

and phases.) However, these phases have not yet been decomposed into 

meaningful work tasks, activities, and events, including timeframes and 

resources needed to execute them. Moreover, other important practices 

associated with creating a reliable schedule of when and how these phases 

will be accomplished have yet to be satisfied. Specifically, our research 

has identified nine practices associated with developing and maintaining a 

reliable schedule.37 These practices are (1) capturing all key activities, (2) 

sequencing all key activities, (3) assigning resources to all key activities, 

(4) integrating all key activities horizontally and vertically, (5) establishing 

the duration of all key activities, (6) establishing the critical path for all 

key activities, (7) identifying float between key activities, (8) conducting a 

schedule risk analysis, and (9) updating the schedule using logic and 

 

36Pub. L. No. 110-417, § 563 (2008). 

37GAO, GAO Cost Estimating and Assessment Guide: Best Practices for Developing and 

Managing Capital Program Costs, GAO-09-3SP (Washington, D.C.: March 2009). 

Page 23 GAO-10-215 Sexual Assault Prevention Programs
 

durations to determine the dates for all key activities. According to 

program officials, the steps and associated time frames for the increments 

and phases identified in table 2 cannot be reliably determined until the 

development and implementation contractor is hired, which will not occur 

until sometime after March 31, 2010. This means that the program office 

currently lacks the necessary means by which to execute a system 

acquisition, gauge progress, identify and address potential problems, and 

promote accountability. 

Table 2: Summary of Increments and Phases for Acquiring DOD’s Defense Sexual Assault Incident Database 

Increment Phase Description 

1 • Configure the database, and establish roles and permission lists, initial reporting, data entry/case 

management and interface development. 

• Present proof-of-concept to Congress to demonstrate that the database addresses initial reporting 

concerns. 

2 • Develop reporting and data entry/case management requirements and successful interfaces 

between the database and the Air Force’s Investigative Information Management System and 

Automated Military Justice Analysis and Management System. 

• Evolve proof-of-concept to include reporting, data entry/case management and interface 

development. 

3 • Develop interfaces between the database and the Army’s Sexual Assault Data Management System 

and the Marine Corps Sexual Assault Incident Reporting Database. 

• Provide proof-of-concept presentations for Congress regarding business management. 

1 

4 • Develop business management requirements and interfaces between the database and the Navy’s 

Sexual Assault Victim Intervention, the Department of Navy’s Criminal Justice Information System, 

and the Consolidated Law Enforcement Operations Center. 

2 • Expand data entry/case management functionality to address National Guard requirements. 

• Expand interfaces to capture any updates to military service-specific systems based on new data 

requirements. 

• Expand reporting functionality. 

Source: DOD. 

In addition, DOD’s current plans include a few general milestones. For

example, OSD officials told us that the first phase of the initial increment 

was to have been achieved when they provided a “proof-of-concept” 

document to Congress in January 2010. However, this document has yet to 

be approved. Further, they stated that they intend to release a Request for 

Proposals for a database developer in the second quarter of fiscal year 

2010. Based on these milestones and the absence of a reliable program 

schedule, DOD did not meet its legislative mandate to implement the 

database by January 2010, and when it will implement the database is 

uncertain. 

Page 24 GAO-10-215 Sexual Assault Prevention Programs
 

OSD program officials stated that they received milestone approval in July 

2009 from the milestone decision authority,38 the Acting Deputy Under 

Secretary of Defense for Program Integration, to conclude the Materiel 

Solution Analysis (previously Concept Refinement) phase and begin the 

Technology Development phase of DOD’s acquisition system.39 Associated 

with this progression, DOD has taken steps to begin employing a number 

of key information technology acquisition management disciplines that are 

provided for in DOD and related guidance.40 Our research and evaluations 

of information technology programs across the federal government have 

shown that adhering to such disciplines is essential to delivering promised 

system capabilities and benefits on time and within budget. Among other 

things, these disciplines include assessing a program’s overlap with and 

duplication of related programs through architecture compliance, 

justifying investment in the proposed system solution on the basis of 

reliable estimates of life cycle costs and benefits, effectively developing 

and managing system requirements, adequately testing system capabilities, 

and effectively managing program risks. However, DOD has yet to 

progress to the point that it can demonstrate that these disciplines have 

been fully implemented, as discussed below. Until it does, the chances of it 

successfully delivering the database are reduced. 

DOD’s Success in 

Acquiring and 

Implementing the 

Database Depends on Its 

Use of Key Management 

Practices 

 

38According to Department of Defense Directive 5000.01, The Defense Acquisition System 

(May 12, 2003), a milestone decision authority (MDA) is the designated individual with 

overall responsibility for the program. The MDA has the authority to approve entry of an 

acquisition program into the next phase of the acquisition, including approving the program 

to proceed through its acquisition cycle on the basis of, for example, the acquisition plan, 

an economic analysis, and the Acquisition Program Baseline. 

39Department of Defense Instruction 5000.02, Operation of the Defense Acquisition System 

(Dec. 8, 2008), establishes a simplified and flexible management framework for translating 

capability needs and technology opportunities into stable, affordable, and well-managed 

acquisition programs. The system consists of five key program life cycle phases and three 

related milestone decision points—(1) Materiel Solution Analysis (previously Concept 

Refinement), followed by Milestone A; (2) Technology Development, followed by Milestone 

B; (3) Engineering and Manufacturing Development (previously System Development and 

Demonstration), followed by Milestone C; (4) Production and Deployment; and (5) 

Operations and Support. 

40See, for example, Department of Defense Instruction 5000.02, Operation of the Defense 

Acquisition System; Institute of Electrical and Electronics Engineers, Standard 1012-

2004 for Software Verification and Validation (New York: June 8, 2005); and GAO-09-3SP. 

Page 25 GAO-10-215 Sexual Assault Prevention Programs
 

• Architectural alignment: DOD’s guidance and other guidance41

recognize the importance of investing in business systems within the 

context of an enterprise architecture.42 Additionally, our experience in 

reviewing federal agencies has shown that making investments 

without the context of a well-defined enterprise architecture often 

results in systems that are, among other things, duplicative of other 

systems.43 Within DOD, the means for avoiding business system 

duplication and overlap is the department’s process for assessing 

compliance with DOD’s business enterprise architecture and its 

associated investment review and decision-making processes. DOD 

officials told us that the database was assessed for compliance with 

the business enterprise architecture and received investment review 

board approval as compliant in July 2009. However, a complete set of 

system-level architecture products needed to perform a thorough and 

meaningful compliance assessment are not yet available. As we have 

previously reported,44 architecture compliance is not a onetime event 

but rather a determination that needs to be made at key junctures in a 

 

41Department of Defense Architecture Framework, Version 1.5, Volume 1 (April 2007); 

GAO, Information Technology: A Framework for Assessing and Improving Enterprise 

Architecture Management (Version 1.1), GAO-03-584G (Washington, D.C.: April 2003); 

Chief Information Officers Council, A Practical Guide to Federal Enterprise Architecture, 

Version 1.0 (February 2001); and Institute of Electrical and Electronics Engineers (IEEE), 

Standard for Recommended Practice for Architectural Description of Software-Intensive 

Systems 1471-2000 (Sept. 21, 2000). 

42A well-defined enterprise architecture provides a clear and comprehensive picture of an 

entity, whether it is an organization (e.g., a federal department) or a functional or mission 

area that cuts across more than one organization (e.g., personnel management). This 

picture consists of snapshots of both the enterprise’s current, or “as is,” environment and 

its target or “to be” environment, as well as a capital investment road map for transitioning 

from the current to the target environment. These snapshots consist of integrated “views,” 

which are one or more architecture products that describe, for example, the enterprise’s 

business processes and rules; information needs and flows among functions, supporting 

systems, services, and applications; and data and technical standards and structures. 

43See, for example, GAO, Information Technology: FBI Is Taking Steps to Develop an 

Enterprise Architecture, but Much Remains to Be Accomplished, GAO-05-363

(Washington, D.C.: Sept. 9, 2005); Homeland Security: Efforts Under Way to Develop 

Enterprise Architecture, but Much Work Remains, GAO-04-777 (Washington, D.C.: Aug. 6, 

2004); Information Technology: Architecture Needed to Guide NASA’s Financial 

Management Modernization, GAO-04-43 (Washington, D.C.: Nov.21, 2003); and DOD 

Business Systems Modernization: Important Progress Made to Develop Business 

Enterprise Architecture, but Much Work Remains, GAO-03-1018 (Washington, D.C.: Sept. 

19, 2003). 

44GAO, DOD Business System Modernization: Key Navy Programs’ Compliance with 

DOD’s Federated Business Enterprise Architecture Needs to Be Adequately 

Demonstrated, GAO-08-972 (Washington, D.C.: Aug. 7, 2008). 

Page 26 GAO-10-215 Sexual Assault Prevention Programs
 

system’s acquisition life cycle. If it is not, unnecessary overlap and 

duplication with other systems, as well as system interoperability 

shortfalls, can occur. 

• Economic justification: Our prior work has shown that a reliable 

cost estimate is critical to informed investment decision making, 

realistic budget formulation and justification, program resourcing, 

meaningful progress measurement, proactive course correction, and 

accountability for results. Further, according to Office of Management 

and Budget (OMB) guidance,45 justifications for an investment should 

include an analysis of the investment’s total life cycle cost.46 DOD 

developed a business case for the database in June 2009 that provides 

the department’s proposal and justification for its database (i.e., 

system solution), and this business case includes a program cost 

estimate of $12.6 million. While the cost estimate was derived in 

accordance with some best practices identified in relevant cost 

estimating guidance, such as estimating software costs with a 

parametric tool that incorporates GAO cost estimating best practices 

and relying on the costs of analogous existing systems, it was not done 

in accordance with others.47 For example, it does not include all costs 

over the system’s life cycle, and it has not been adjusted to account for 

program risks. More specifically, program officials stated that the $12.6 

million does not include program office and management costs, 

relevant development costs (e.g., testing), or sustainment costs (i.e., 

operations and maintenance). OSD officials told us that they intend to 

develop a reliable cost estimate once the development contract is 

awarded. Without reliable estimates, a proposed system solution 

cannot be adequately justified on the basis of costs and benefits, and 

DOD may be at increased risk of experiencing cost overruns, schedule 

slippages, and performance shortfalls. 

 

45Office of Management and Budget, Circular A-11, Preparation, Submission, and 

Execution of the Budget (Washington, D.C., Executive Office of the President, August 

2009), and Capital Programming Guide: Supplement to Office of Management and Budget, 

Circular A-11, Part 7, Preparation, Submission, and Execution of the Budget (Washington, 

D.C., Executive Office of the President, June 2006). 

46Office of Management and Budget, Circular A-94, Guidelines and Discount Rates for 

Benefit-Cost Analysis of Federal Programs (Washington, D.C., Executive Office of the 

President, Oct. 29, 1992), defines “life cycle cost” as “the overall estimated cost for a 

particular program alternative over the time period corresponding to the life of the 

program, including direct and indirect initial costs plus any periodic or continuing costs of 

operation and maintenance.” 

47GAO-09-3SP. 

Page 27 GAO-10-215 Sexual Assault Prevention Programs
 

Beyond not having a reliable cost estimate, DOD’s business case does 

not comply with other OMB guidance.48 According to OMB, the 

economic analysis used to justify an investment should meet certain 

criteria to be considered reasonable, including comparing alternatives 

on the basis of net present value and conducting an uncertainty 

analysis of benefits. While the business case includes an explanation of 

why the database is needed, it does not address the costs and benefits 

associated with each of the four database alternatives that were 

considered (i.e., commercial-off-the-shelf case management system 

software product, custom-built system, enhancement of an existing 

military service system, or maintenance of the status quo). Moreover, 

the four alternatives were not assessed on the basis of net present 

value, including using the proper discount rate to account for inflation. 

Instead, only the selected alternative was evaluated quantitatively. 

Without a meaningful analysis of alternatives, DOD lacks sufficient 

assurance that it has selected the most cost-effective system solution. 

• Requirements development and management: Well-defined and 

well-managed requirements are the cornerstone of effective system 

development and acquisition.49 Effective requirements development 

and management includes, among other things, (1) effectively eliciting 

user needs early and continuously in the system life cycle process, (2) 

establishing a stable baseline set of requirements and placing the 

baseline under configuration management, (3) ensuring that systemlevel requirements can be traced back to higher-level business or 

operational requirements (e.g., concept of operations) and forward to 

system design documents (e.g., software requirements specification) 

and test plans, and (4) controlling changes to baseline requirements. 

DOD has begun to take steps to engage users in the development of 

requirements. For example, it formed a working group composed of 

representatives from each of the military services and the National 

Guard to develop high-level system requirements. Further, program 

 

48Office of Management and Budget, Circular A-94, Guidelines and Discount Rates for 

Benefits-Cost Analysis of Federal Programs, and Circular A-11, Part 7, Planning, 

Budgeting, Acquisition and Management of Capital Assets (Washington, D.C., November 

2009). 

49The Capability Maturity Model®

 Integration for Development, developed by the Software 

Engineering Institute of Carnegie Mellon University, defines key practices that are 

recognized hallmarks for successful organizations that if effectively implemented, can 

greatly increase the chances of successfully developing and acquiring software and 

systems. Carnegie Mellon University, Software Engineering Institute, Capability Maturity 

Model® Integration for Development, Version 1.2 (Pittsburgh, August 2006). 

Page 28 GAO-10-215 Sexual Assault Prevention Programs
 

officials stated that additional actions are planned or under way to 

reach agreement on system interfaces, which is important given that 

the database is to draw data from multiple systems to satisfy statutory 

requirements. They also said that users will be further involved in 

developing requirements. For example, DOD is working with the Air 

Force and National Guard to define more specific functional, 

performance, and data requirements, and has initiated discussions 

with the Army, Navy, and Marine Corps to do the same. In addition, 

program officials stated that once the high-level system requirements 

are baselined, the Change Control Board, comprising representatives 

from DOD and the user community, will be established to control 

changes to the baseline requirements. While these ongoing and 

planned actions are positive, they represent only the beginning of a 

series of actions that are associated with effectively defining and 

managing requirements over a system’s acquisition life cycle. To the 

extent that this series of actions is not well detailed and implemented, 

the risk of the database not performing as intended, and costing more 

and taking longer to implement than necessary, is increased. 

• Test management: According to DOD and other relevant guidance, 

system testing should be progressive, meaning that it should consist of 

a series of test events that first focus on the performance of individual 

system components, then on the performance of integrated system 

components, followed by system-level tests that focus on whether the 

system (or major system increments) are acceptable, interoperable 

with related systems, and operationally suitable to users.50 Among 

other things, effective testing should ensure that (1) all test events are 

governed by a well-defined test management structure, (2) each test 

event is executed in accordance with well-defined plans, and (3) the 

results of each test event are captured and used to ensure that 

problems discovered are disclosed and corrected. Program officials 

stated that they plan to work with the development contractor to 

establish an effective test management structure, develop test plans, 

and capture and resolve problems found during testing. In addition, 

they plan to engage an independent test organization. However, DOD 

has not yet developed milestones for its testing plans or activities. 

 

50See, for example, Department of Defense Instruction 5000.02, Operation of the Defense 

Acquisition System; Defense Acquisition University, Test and Evaluation Management 

Guide; Institute of Electrical and Electronics Engineers, Standard 1012-2004 for Software 

Verification and Validation; and Carnegie Mellon University, Software Engineering 

Institute, Capability Maturity Model Integration for Acquisition, Version 1.2, CMU/SEI2007-TR-017(Pittsburgh, November 2007). 

Page 29 GAO-10-215 Sexual Assault Prevention Programs
 

Unless adequate testing is performed and key test management 

structures and controls are established, it is unlikely that the database 

will meet user expectations and mission needs, and the risk of it 

costing more and taking longer than planned is increased. 

• Risk management: Proactively managing program risks is a key 

acquisition management control that if done properly, can increase the 

chances of programs delivering promised capabilities and benefits on 

time and within budget. Relevant guidance, including DOD’s Risk 

Management Guide for DOD Acquisition, recognizes the importance 

of conducting effective risk management.51 Among other things, 

effective risk management includes (1) establishing and implementing 

a written plan and defined process for risk identification, analysis, and 

mitigation; (2) assigning responsibility for managing risks to key 

stakeholders; (3) encouraging programwide participation in risk 

management; and (4) examining the status of identified risks during 

program milestone reviews. Program officials stated that they intend 

to document and implement a risk management strategy that is 

consistent with DOD’s Risk Management Guide. To its credit, the 

program office has begun to identify key risks. For example, it cited 

identified risks related to (1) what officials believed to be an 

unattainable congressionally mandated database implementation date 

of January 2010; (2) staffing shortages that complicate the office’s 

ability to develop and gain approval of a large number of key 

documents (e.g., privacy impact assessments, documentation required 

for investment reviews, and updates of relevant DOD instructions, 

etc.); (3) potential shortfalls in system development and maintenance 

funding issues; (4) limitations of the military services’ systems, which 

are expected to provide data to DOD’s database; and (5) the military 

services’ competing priorities, which may jeopardize their support and 

involvement.52 However, they have yet to begin proactively managing 

these risks. Unless this is done, the risks could evolve into actual cost, 

schedule, and performance shortfalls. 

 

51Department of Defense, Risk Management Guide for DOD Acquisition, 6th Edition, 

Version 1.0, http://www.acq.osd.mil/sse/ed/docs/2006-RM-Guide-4Aug06-final-version.pdf

(accessed Nov. 27, 2009), and Carnegie Mellon University, Software Engineering Institute, 

CMMI for Acquisition, Version 1.2. 

52The Department of the Air Force stated that to date, it has not identified any expected 

limitations for providing data from other systems or expressed any concerns about 

competing priorities. 

Page 30 GAO-10-215 Sexual Assault Prevention Programs
 

The Coast Guard has partially implemented one of our recommendations 

from 2008 to further develop its sexual assault prevention and response 

program, but it has not addressed the other. To its credit, the Coast Guard 

conducted an assessment of its processes for staffing key program 

positions and has continued to develop, through a variety of initiatives, 

other components of its sexual assault prevention and response program. 

However, the Coast Guard has not addressed our recommendation to 

develop an oversight framework, and its program is challenged by the lack 

of a systematic process for collecting, documenting, and maintaining 

sexual assault data and by the lack of training for program coordinators. 

Coast Guard Has 

Partially Implemented 

One of Our Two 

Recommendations 

from 2008 

The Coast Guard Has 

Taken Steps to Implement 

One of Our 

Recommendations from 

2008 and Has Continued 

Developing Its Programs 

The Coast Guard has taken steps to implement our previous 

recommendation to evaluate its processes for staffing key program 

positions. As we previously reported, Coast Guard officials told us that its 

Sexual Assault Response Coordinators do not have the time to effectively 

implement a sexual assault prevention and response program. Thus we 

recommended that the Coast Guard evaluate its processes for staffing key 

program positions to ensure that they have the ability and resources to 

fully carry out their responsibilities.53 Coast Guard officials told us that 

current levels of full-time staffing continue to hinder their ability to 

appropriately implement various components of their sexual assault 

prevention and response program, adding that the continuity of care for 

victims is negatively affected since its coordinators do not possess the 

time or the training to provide consistent case management services. To 

address this, the Coast Guard, in June 2009 initiated an assessment of the 

current workload requirements and resource allocations for its Sexual 

Assault Response Coordinators. Officials told us that they plan to use the 

results of this assessment to determine whether the responsibilities of the 

position or associated resource levels need to be revised. Coast Guard 

officials also noted that the assessment is to be completed by December 

2009, and that they hope to address any program recommendations within 

2 years of the assessment’s completion. While these are positive first steps, 

they do not fully address our findings and recommendation from 2008 

because the Coast Guard has yet to complete its assessment and decide 

what, if any, program modifications it will make. The Coast Guard also 

established two new program positions in response to findings in our 

previous report. Specifically, in September 2008, the Coast Guard 

established a headquarters-level program manager position to oversee the 

 

53GAO-08-924. 

Page 31 GAO-10-215 Sexual Assault Prevention Programs
 

management of, training for, and evaluation of its sexual assault 

prevention and response program. The Coast Guard also established a 

Sexual Assault Response Coordinator position at its academy to manage 

its sexual assault prevention and response program. 

While the Coast Guard is not generally subject to the departmental 

direction or statutory requirements that apply to DOD, it has developed an 

instruction that charges responsible personnel with establishing policies 

and procedures for its program.54 To the Coast Guard’s credit, Coast Guard 

officials stated that they frequently leverage program information and 

materials obtained through their regular participation in OSD’s Sexual 

Assault Advisory Council subcommittees and working groups and the 

military services’ conferences and summits. For example, the Coast Guard 

recently modeled its victim advocate training after the Navy’s curriculum, 

and it is revising its data collection requirements to mirror those of DOD. 

The Coast Guard is also modifying its sexual assault prevention and 

response program instruction to clarify its definition of sexual assault and 

revise its description of selected program positions to better reflect 

program responsibilities. Coast Guard officials stated that they plan to 

issue the revised instruction in spring 2010. 

The Coast Guard Has Not 

Implemented Our Second 

Recommendation from 

2008, and Its Program Is 

Hindered by 

Accountability Issues 

With respect to our second recommendation, the Coast Guard’s efforts to 

establish a program oversight framework have been limited. Although the 

Coast Guard has identified broad program objectives, it has not addressed 

our recommendation to develop an oversight framework that provides 

comprehensive and specific guidance for operating its programs. Further, 

the Coast Guard’s program lacks a systematic process for assembling, 

documenting, and maintaining sexual assault incident data, lacks quality 

control procedures to ensure that the program data being collected are 

reliable, and the Coast Guard has yet to complete the development and 

implementation of training for key program personnel. As a result, the 

Coast Guard’s program development efforts continue to be hindered by its 

inability to evaluate program effectiveness, to accurately account for 

sexual assault incidents, to prioritize program initiatives, and to help 

ensure that program personnel are trained to properly execute their 

responsibilities. 

 

54U.S. Coast Guard Commandant Instruction 1754.10D, Sexual Assault Prevention and 

Response (SAPR) Program (Jan. 16, 2009). 

Page 32 GAO-10-215 Sexual Assault Prevention Programs
 

The Coast Guard has not developed an oversight framework to guide its 

program development and implementation, despite its concurrence with 

our August 2008 recommendation that it do so. Our prior work has 

demonstrated the importance of results-oriented performance measures to 

successful program oversight, and has shown that having an effective plan 

for implementing initiatives and measuring progress can help decision 

makers determine whether initiatives are achieving their desired result.55

As we previously reported, the Coast Guard was not able to fully evaluate 

the results achieved by its efforts, and thus we recommended that it 

develop an oversight framework that at a minimum includes long-term 

goals, objectives, and milestones; performance goals; strategies to be used 

to accomplish goals; and criteria for measuring progress.56 The Coast 

Guard revised its program instruction to clarify departmental oversight 

roles, and it has developed an action plan that broadly defines program 

goals, objectives, strategies, milestones, and criteria. However, based on 

our prior work on developing and enhancing program oversight, the Coast 

Guard’s efforts do not sufficiently encompass the key components of an 

oversight framework. For example, the Coast Guard’s action plan does not 

contain performance measures, nor does it identify how it plans to use the 

results of its program evaluations to revise its future program objectives. 

Furthermore, the strategies identified in its action plan are too vague to 

enable an assessment of whether they would help achieve program goals 

and objectives. For example, the Coast Guard’s action plan includes as one 

of the long-term program objectives, “provide updated, consistent 

information on program reporting options and resources,” and the 

corresponding strategy is simply, “purchase and distribute marketing 

materials to the field,” without specifying how or when it plans to achieve 

this objective. 

Coast Guard Has Not 

Developed an Oversight 

Framework 

Further, the Coast Guard has not correlated program objectives and 

strategies with its internal budget requests, which limits its ability to 

effectively allocate and account for program resources. As we noted 

previously, our prior work shows that having program plans clearly linked 

with budgets allows an organization to more explicitly guide budget 

discussions and can assist program management by connecting total 

resources consumed with actual results achieved.57 Thus, we continue to 

 

55GAO, Results-Oriented Cultures: Implementation Steps to Assist Mergers and 

Organizational Transformations, GAO-03-669 (Washington, D.C.: July 2, 2003). 

56GAO-08-924. 

57GAO-02-236. 

Page 33 GAO-10-215 Sexual Assault Prevention Programs
 

believe that our recommendation has merit, and that the Coast Guard will 

remain limited in its ability to manage and evaluate its sexual assault 

prevention and response program until it develops and implements an 

oversight framework. 

The Coast Guard does not have a systematic process to collect, document, 

and maintain its sexual assault data and related program information. The 

Coast Guard’s instruction charges responsible program personnel with 

establishing a reporting system to evaluate statistical data related to 

sexual assault incidents, maintaining records to identify victims and track 

services provided, and providing oversight of quality assurance review 

processes to ensure the provision of quality services.58 Additionally, our 

prior work has shown that organizations striving to meet program goals 

must have information systems in place to meet the modern need for fast, 

reliable, and accurate information.59 However, the Coast Guard’s sexual 

assault program does not currently have a systematic process to collect, 

document, and maintain its sexual assault incident data. One individual 

maintains a hard copy log, informed by reports from coordinators in the 

field, and if necessary, may call these coordinators to get additional 

information. At the conclusion of our review, Coast Guard officials told us 

that they are in the process of developing a prototype to enable personnel 

to electronically manage sexual assault cases, and that they expect to 

conduct an assessment of prototype capabilities in early 2010. However, 

until the Coast Guard establishes a systematic process for the collection, 

documentation, and maintenance of these data, it will be challenged in its 

ability to efficiently retrieve data and its visibility over sexual assault 

incidents will remain limited. 

Coast Guard Does Not Have a 

Systematic Process to Collect, 

Document, and Maintain 

Sexual Assault Incident 

Information 

Additionally, the Coast Guard has not instituted quality control processes 

to ensure the reliability of the sexual assault incident and program data 

being collected. Our prior work has highlighted the importance of 

organizations assessing the quality of their program data and ensuring that 

these data are complete and reliable.60 However, the Coast Guard has not 

 

58The Coast Guard’s instruction specifically charges the Sexual Assault Prevention and 

Response Program Manager with establishing the reporting system, and specifically 

charges the Employee Assistance Program Coordinator/Sexual Assault Response 

Coordinator with maintaining records to identify victims and track services provided. 

59GAO, Executive Guide: Effectively Implementing the Government Performance and 

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996). 

60GAO/GGD-96-118. 

Page 34 GAO-10-215 Sexual Assault Prevention Programs
 

established a process to periodically assess the sufficiency of the program 

information it collects. For example, Coast Guard officials noted that in 

fiscal year 2008, the Coast Guard Investigative Service, in the course of its 

investigations, documented 78 reports of sexual assault, while Coast 

Guard Headquarters, using the hard copy log of reports from its 

coordinators, had documented only 30. Further, the Coast Guard’s sexual 

assault prevention and response instruction requires that commanding 

officers “ensure completion of mandatory annual training on sexual 

assault prevention by all unit personnel.” However, officials told us that 

the current system used to track training is designed to report training 

compliance at the unit level, and while individual training compliance can 

be discerned, the process to do so is overly cumbersome. As a result, this 

practice complicates the Coast Guard’s ability to oversee whether 

personnel are completing their required training. Officials added that unit 

compliance with training is assessed during inspections that occur every 2 

to 3 years, and the responsible command is notified if any problems are 

identified. Further, Coast Guard officials told us that while there is no 

systematic process for following up on the findings from these 

inspections, they are confident that the issues are taken seriously and 

appropriately addressed. However, we believe that until the Coast Guard 

establishes a systematic process to assess the quality and reliability of its 

data, it cannot be sure that the information it collects is relevant to and 

sufficient for the achievement of its program goals. 

The Coast Guard recently developed and is starting to conduct training for 

its victim advocates however, it has not provided training for its Sexual 

Assault Response Coordinators—the personnel who manage the victim 

advocates. The Coast Guard’s instruction requires that all Coast Guard 

Sexual Assault Response Coordinators be trained to perform relevant 

duties, and prohibits them from accepting a restricted sexual assault 

report until the training has been completed. However, Coast Guard 

officials stated that they have not developed a curriculum or implemented 

training for the Coast Guard’s 16 Sexual Assault Response Coordinators, 

because, alternatively, they were developing and implementing a training 

curriculum for victim advocates. Coast Guard officials initially told us that 

it would likely take up to 2 years to develop a formalized curriculum for 

Coast Guard Sexual Assault Response Coordinators, but that in the 

meantime, they have scheduled a training session for coordinators in 

January 2010 to review policy revisions and reporting processes. At the 

conclusion of our review, Coast Guard officials stated that they have since 

updated their plans to train Sexual Assault Response Coordinators, noting 

that they plan to complete a formalized curriculum by May 2010 and have 

scheduled training for the Coordinators during the week of May 4, 2010. 

The Coast Guard Has Not 

Trained Its Program 

Coordinators 

Page 35 GAO-10-215 Sexual Assault Prevention Programs
 

However, until such training is administered, Sexual Assault Response 

Coordinators will lack formalized Coast Guard sexual assault prevention 

and response training, and according to Coast Guard officials, they will 

rely instead only on the general mandated training provided to all 

personnel, their own professional experience, and their interpretation of 

the Coast Guard’s sexual assault prevention and response policy. 

Additionally, the Coast Guard’s Sexual Assault Program Manager plans to 

travel to Coast Guard installations throughout the country to administer 

annual victim advocate training, which will eventually be administered by 

coordinators. However, this may not be the most effective use of 

resources, as the training could be administered by trained Sexual Assault 

Response Coordinators. Until a formal curriculum is developed and 

implemented, the Coast Guard cannot be sure that it has effectively 

imparted program responsibilities and requirements to its Sexual Assault 

Response Coordinators. 

Since the release of our August 2008 report, DOD has taken a number of 

positive steps toward addressing our recommendations to further 

strengthen its sexual assault prevention and response programs and to 

develop the statutorily mandated sexual assault incident database. 

Additionally, each service has proactively developed and implemented a 

variety of initiatives—beyond what we recommended—to increase 

program awareness and to improve prevention of and response to 

occurrences of sexual assault. While such progress is noteworthy, DOD’s 

efforts have not fully established a sound management framework, which 

must build upon the foundation of a comprehensive strategic framework 

that guides program development and implementation. Without such a 

foundation, DOD’s programs lack the institutional support, long-term 

perspective, and clear lines of accountability that are needed to withstand 

the administrative, fiscal, and political pressures that confront federal 

programs on a daily basis. Until OSD finalizes and fully implements its 

oversight framework and strategic plans, it will continue to lack the ability 

to synergize its prevention and response initiatives, and it may not be able 

to effect the change in military culture that is needed to ensure that 

programs are institutionalized. Additionally, successful implementation of 

the oversight framework will require the personal involvement of top DOD 

leadership to maintain the long-term focus on and accountability for 

program objectives. 

Conclusions 

While the Coast Guard is not generally subject to the departmental 

program direction or statutory requirements that apply to DOD, it 

Page 36 GAO-10-215 Sexual Assault Prevention Programs
 

continues to proactively develop its sexual assault prevention and 

response program. The Coast Guard has, however, experienced challenges 

similar to those of DOD because it lacks the long-term strategic 

perspective needed to structure its program development and 

implementation. Until the Coast Guard develops an oversight framework 

that includes specific management improvement steps, key milestones, 

and performance measures, it will be unable to accurately demonstrate 

that its programs are achieving its goals of establishing a culture of 

prevention, sensitive response, and accountability. Further, the Coast 

Guard may not be able to demonstrate that program elements, such as its 

sexual assault prevention and response training, are being implemented in 

a manner that most effectively ensures its achievement of program goals. 

We recommend that the Secretary of Defense take the following 10 

actions: 

• To improve the management, strategic planning, and 

comprehensiveness of OSD’s oversight of the department’s sexual 

assault prevention and response programs, direct the Under Secretary 

of Defense for Personnel and Readiness to strengthen OSD’s oversight 

framework by 

Recommendations for 

Executive Action 

• identifying how the results of performance assessments 

will be used to guide the development of future program 

initiatives, 

• identifying how OSD’s program resources correlate to its 

achievement of strategic program objectives, and 

• correlating its oversight framework to the program’s two 

strategic plans so that program objectives, timelines, and 

strategies for achieving objectives are synchronized. 

• To enhance visibility over the incidence of sexual assaults involving 

DOD servicemembers, the department’s sexual assault prevention and 

response programs, and the pending implementation of the Defense 

Sexual Assault Incident Database, direct the Under Secretary of 

Defense for Personnel and Readiness to standardize the type, amount, 

and format of the data in the military services’ annual report 

submissions. 

• To enhance the oversight of the sexual assault prevention and 

response program in DOD, direct the Under Secretary of Defense for 

Personnel and Readiness to ensure that the development and 

implementation of the Defense Sexual Assault Incident Database 

Page 37 GAO-10-215 Sexual Assault Prevention Programs
 

includes adherence to the following key system development and 

acquisition management processes and controls 

• developing a reliable integrated master schedule that 

addresses the nine key practices discussed in this report, 

• adequately assessing the program’s overlap with and 

duplication of related programs through architecture 

compliance, 

• adequately justifying investment in the proposed approach 

on the basis of reliable estimates of life cycle costs and 

benefits, 

• effectively developing and managing system requirements, 

• adequately testing system capabilities, and 

• effectively managing program risks. 

We are recommending that the Commandant of the Coast Guard take the 

following three actions: 

• To improve the oversight and accountability of the Coast Guard’s 

sexual assault prevention and response program 

• establish a systematic process for collecting, documenting, 

and maintaining sexual assault incidence data, and 

• establish quality control processes to ensure that program 

information collected is valid and reliable. 

• To improve execution of sexual assault prevention and response 

programs, we recommend that the Commandant of the Coast Guard 

establish and administer a curriculum for all key program personnel to 

ensure that they can provide proper advice to Coast Guard personnel. 

In written comments on a draft of this report, both DOD and the Coast 

Guard concurred with all of our recommendations. DOD noted in its 

comments that our report contained technical inaccuracies, which we 

addressed where appropriate, based on the technical comments received 

from both DOD and the Coast Guard. Further, DOD asserted that the 

report also contained misstatements that improperly diminished the 

department’s efforts to address our recommendations. We believe that our 

report accurately represents DOD’s progress to address our 

recommendations from 2008. DOD’s comments are reprinted in appendix 

II, and the Coast Guard’s comments are reprinted in appendix III. 

Agency Comments 

and Our Evaluation 

In concurring with our recommendations aimed at improving the 

management, strategic planning, and comprehensiveness of OSD’s 

oversight of the department’s sexual assault prevention and response 

programs—including that OSD should strengthen its oversight framework 

Page 38 GAO-10-215 Sexual Assault Prevention Programs
 

by (1) identifying how the results of performance assessments will be used 

to guide the development of future program initiatives, (2) identifying how 

OSD’s program resources correlate with its achievement of strategic 

program objectives, and (3) correlating its oversight framework with the 

program’s two strategic plans—DOD commented that several efforts are 

underway or are planned to address these issues. For example, DOD 

stated that in the early part of 2010, it will have a plan in place that details 

how it will track its progress toward the performance objectives laid out in 

the DOD-wide strategic plan, and it will develop a procedure to report 

back on progress toward objectives and any needed corrective steps. DOD 

also stated that starting with the 2012 budget cycle, OSD plans to align its 

budget categories with specific performance objectives laid out in its 

strategic plan. Further, DOD noted that the process it plans to use to track 

its progress toward performance objectives will also allow the department 

to synchronize the objectives, timelines, and strategies of its two strategic 

plans. We commend DOD for taking immediate steps in response to our 

recommendations, and encourage the department to continue taking 

positive actions toward fully implementing them. 

In its concurrence with our recommendation that the department 

standardize the type, amount, and format of the data in the military 

services’ annual report submissions, DOD acknowledged that achieving 

uniformity among the military services for all required data elements will 

greatly enhance its oversight capabilities. DOD added that it recently 

established definitions for case disposition data and developed a 

standardized program report template, and that both are being used by the 

military services to compile their respective data for the department’s 

fiscal year 2009 report on sexual assault in the military services. DOD 

stated that the comprehensive process of linking all of its data elements 

will ultimately be accomplished through its development of the Defense 

Sexual Assault Incident Database. Our report credits DOD with taking 

initial steps toward developing standardized data elements and definitions, 

and acknowledges the data template it developed and is using to collect a 

more standardized set of data from the military services for the 

department’s fiscal year 2009 annual report to Congress. However, as we 

noted in our report, OSD officials stated that full standardization of data 

elements and definitions will not be achieved until it implements the 

Defense Sexual Assault Incident Database—for which DOD does not 

currently have a reliable implementation schedule. While we recognize 

that this will be a complex and time-consuming task, we continue to assert 

that the full establishment and implementation of standardized data 

elements and definitions will facilitate a more comprehensive 

understanding of DOD’s sexual assault prevention and response programs. 

Page 39 GAO-10-215 Sexual Assault Prevention Programs
 

In concurring with our recommendation to develop a reliable integrated 

master schedule for the Defense Sexual Assault Incident Database, DOD 

stated that it will give priority to doing so, and will follow GAO schedule 

estimating guidance. However, it added that while the department has thus 

far developed schedules that it characterized as capturing broader scope 

key activities, it would not be able to capture key schedule activities or 

estimate a timeframe for identifying key activities that are fundamental to 

developing a reliable schedule until it acquired the assistance of the 

system development contractor. DOD noted that this is because only the 

contractor will know the steps and time required to adopt proprietary 

materials to DOD’s requirements for the database. We understand the role 

that the development contractor plays in developing a reliable integrated 

master schedule, which is why our recommendation does not specify a 

timeframe for developing the schedule, and thus allows DOD to first 

acquire a contractor’s services. Further, while we agree with the 

department’s comment that our report does not include an assessment of 

the viability of a 15-month deadline contained in statute61 for the 

database’s design, acquisition, and implementation, we note that we told 

program officials during the course of our review that such an assessment 

was not part of the scope of our work because the 15-month deadline was 

a statutory requirement rather than a DOD schedule-driven milestone. 

In concurring with our recommendation to adequately assess the 

program’s overlap with related programs through architecture compliance, 

the department stated that it acknowledges the benefits derived from 

doing so. It added, however, that our report inaccurately asserts that DOD 

has not complied with DOD guidance governing architecture compliance 

by stating that a complete set of system-level architecture products are not 

yet available to perform a thorough architecture compliance assessment. 

In this regard, it stated that DOD guidance does not call for the 

development of system-level architecture products until the Technology 

Development Phase in the Defense Acquisition System. We agree with the 

department’s comment as to the timing of system-level architecture 

products, which is why we do not conclude that DOD has not assessed 

architecture compliance. As stated in this report, architecture compliance 

is not a onetime event but rather a determination that needs to be made at 

key junctures in a system’s acquisition life cycle. Thus, the intent of our 

statement and our recommendation is to emphasize the importance of 

 

61Pub. L. No. 110-417, § 563 (2008). 

Page 40 GAO-10-215 Sexual Assault Prevention Programs
 

conducting compliance activities once a complete set of system-level 

architecture products is available. 

In concurring with our recommendation to adequately justify investment 

in the proposed database approach on the basis of reliable estimates of life 

cycle costs and benefits, the department stated that it agreed that the cost 

estimate in the existing business case does not account for all life cycle 

costs and risks. However, it added that DOD guidance does not require 

comprehensive cost estimates in the business case and that the cost 

estimate in the business case was derived using cost estimating best 

practices. While we agree that DOD guidance does not explicitly state that 

business case cost estimates must be comprehensive, both DOD guidance 

and OMB guidance state that these cost estimates should include all costs 

over the system’s life cycle, which is a recognized best practice. Further, 

while the cost estimate was derived in accordance with some cost 

estimating best practices, such as estimating software costs with a 

parametric tool and relying on the costs of analogous existing systems, it 

was not done in accordance with others. For example, it was not risk 

adjusted. Further the business case did not include a comparison of 

alternatives on the basis of net present value. 

In concurring with our recommendation to effectively develop and manage 

system requirements, DOD noted that it has continued to work with the 

military services in developing system requirements and that its progress 

in doing so is much greater than our report states. It also noted that since 

the database was legislated, Congress expanded its annual sexual assault 

reporting requirements, which in turn necessitated additional 

requirements development work with stakeholders. Further, it stated that 

it will institute a Change Control Board, which is a key requirements 

management control mechanism, and is using a range of system life cycle 

management tools that support requirements development and 

management. We support DOD’s continued efforts to work with 

stakeholders to further develop requirements and capture them in a range 

of requirements documents, as such efforts are consistent with our 

recommendation. Also consistent with our recommendation are its plans 

to institute a Change Control Board and use relevant requirements-related 

tools. 

In concurring with our recommendation to adequately test system 

capabilities, DOD stated that our report does not sufficiently describe its 

efforts to develop a detailed test plan defining the program’s testing 

approach and strategy, including the entrance and exit criteria for each 

testing phase. We agree that our report does not cite the development of 

Page 41 GAO-10-215 Sexual Assault Prevention Programs
 

this plan because no such plan was provided to us as part of the 

documentation set submitted for the database’s milestone acquisition 

approval, nor were we made aware of the existence of such a plan. 

Moreover, program officials told us that a test plan would be developed 

after the contractor was hired, and DOD’s comments on our draft report 

acknowledge that a final test plan has yet to be created. 

In concurring with our recommendation to effectively manage program 

risks, DOD noted that our statement that risk management has yet to begin 

is incorrect because key risks have been identified. We agree that risk 

identification, which is the first step in risk management, has begun, as our 

report recognizes. We also agree that the statement in our draft report that 

risk management has yet to begin is not consistent with its recognition of 

these risk identification efforts. As a result, we have modified the report to 

note that many aspects of risk management have yet to begin, which DOD 

also states in its comments on our draft report. 

The Coast Guard also concurred with our recommendations aimed at 

improving the oversight, accountability, and execution of its sexual assault 

prevention and response programs, including (1) establishing a systematic 

process for collecting, documenting, and maintaining sexual assault 

incidence data; (2) establishing quality control processes to ensure that 

program information collected is valid and reliable; and (3) establishing 

and administering a curriculum for all key program personnel to ensure 

that they can provide proper advice to Coast Guard personnel. In 

commenting on our draft report, the Coast Guard noted that it has several 

initiatives underway to continue developing its sexual assault prevention 

and response program. For example, the Coast Guard stated that an 

electronic database to track sexual assault reports is in the prototype 

development phase, and based on current progress, it expects to complete 

the database in 2010. Further, the Coast Guard noted that it has completed 

an assessment of workload requirements and resource allocations for its 

Sexual Assault Response Coordinators, and upon release of the final 

report, the Coast Guard plans to review and analyze the recommendations 

and, as appropriate, incorporate additional resource requirements into its 

annual budget process. We commend the Coast Guard for the steps it has 

taken and its plans for further developing its sexual assault prevention and 

response program, and we encourage the service to continue taking 

positive actions toward fully implementing our recommendations. 

Page 42 GAO-10-215 Sexual Assault Prevention Programs
 

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until thirty days from 

the report date. At that time, we will send copies to interested members of 

Congress; the Secretaries of Defense, Homeland Security, the Army, the 

Navy, and the Air Force; the Commandant of the Marine Corps; and the 

Commandant of the Coast Guard. The report also will be available at no 

charge on the GAO Web site at http://www.gao.gov. 

If you or your staff have any questions concerning this report, please 

contact Brenda Farrell at (202) 512-3604 or farrellb@gao.gov or Randolph 

Hite at (202) 512-3439 or hiter@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. Key contributors to this report are listed in appendix IV. 

Sincerely yours, 

Brenda S. Farrell 

Director, Defense Capabilities and Management 

Randolph C. Hite 

Director, Information Technology Architecture and Systems 

Page 43 GAO-10-215 Sexual Assault Prevention Programs
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To determine the extent to which the Department of Defense (DOD) has 

taken steps to address our previous recommendations in GAO-08-924

regarding programs to prevent and respond to sexual assault, we reviewed 

relevant statutory requirements and obtained and analyzed DOD’s policies, 

guidance, and procedures for the prevention of and response to sexual 

assault incidents. We also interviewed officials in DOD, the Army, the Air 

Force, the Navy, the Marine Corps, and the Defense Task Force on Sexual 

Assault in the Military Services to gain a comprehensive understanding of 

their efforts to address our previous recommendations. We also obtained 

and analyzed the Office of the Secretary of Defense’s (OSD) strategic plans 

and draft oversight framework for the department’s sexual assault 

prevention and response efforts to determine whether they contained the 

elements necessary for effective program implementation. In addition, we 

obtained and analyzed DOD’s annual reports to Congress on sexual assault 

in the military services for fiscal years 2007 and 2008 to assess the extent 

to which OSD addressed our recommendation to improve the usefulness 

of DOD’s annual report. 

To determine the extent to which DOD has taken steps to address a 

statutory requirement to establish a centralized, case-level sexual assault 

incident database, we reviewed statutory provisions related to DOD’s 

process for collecting and maintaining sexual assault data. We also 

interviewed DOD officials to obtain information on the department’s 

efforts to establish the database; reviewed documentation related to 

database development; and compared this documentation to relevant 

DOD, federal, GAO, and industry guidance. 

To determine the extent to which the U.S. Coast Guard has taken steps to 

address our previous recommendations regarding policies and programs 

to prevent and respond to sexual assault, we identified relevant legislative 

requirements and obtained and analyzed the Coast Guard’s policies, 

guidance, and procedures for the prevention of and response to sexual 

assault incidents. We also interviewed Coast Guard officials to gain a 

comprehensive understanding of their efforts to address our previous 

recommendations. We also obtained and analyzed the Coast Guard’s 

action plan for sexual assault prevention and response to determine the 

extent to which it consisted of the elements that we recommended be 

included in an oversight framework. 

Page 44 GAO-10-215 Sexual Assault Prevention Programs 
Appendix I: Scope and Methodology 

We visited or contacted the following organizations during our review: 

Department of Defense 

• Defense Task Force on Sexual Assault in the Military Services, 

Alexandria, Virginia 

• Sexual Assault Prevention and Response Office, Arlington, Virginia 

• Office of the Assistant Secretary of Defense for Health Affairs, Falls 

Church, Virginia 

• Defense Center of Excellence for Psychological Health and 

Traumatic Brain Injury, Rosslyn, Virginia 

Office of the Chairman, Joint Chiefs of Staff 

• J-1, Manpower and Personnel, Washington, D.C. 

Department of the Army 

• Sexual Harassment/Assault Response and Prevention Program Office, 

Washington, D.C. 

Department of the Air Force 

• Office of the Assistant Secretary (Manpower and Reserve Affairs), 

Washington, D.C. 

• Office of the Deputy Assistant Secretary (Force 

Management Integration), Washington, D.C. 

• Deputy Chief of Staff for Manpower, Personnel and Services, 

Washington, D.C. 

• Sexual Assault Prevention and Response Program Office, 

Washington, D.C. 

Department of the Navy 

• Sexual Assault Prevention and Response Office, Washington, D.C. 

United States Marine Corps 

• Manpower and Reserve Affairs 

• Sexual Assault Prevention and Response Office, Quantico, 

Virginia 

Page 45 GAO-10-215 Sexual Assault Prevention Programs
Appendix I: Scope and Methodology 

U.S. Coast Guard 

• Health, Safety and Work-Life Directorate, Office of Work-Life, 

Washington, D.C. 

We conducted this performance audit from February 2009 through 

February 2010 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. 

Page 46 GAO-10-215 Sexual Assault Prevention Programs
Appendix II: Comments from the Department Appendix II: Comments from the Department of Defense 

of Defense 

Page 47 GAO-10-215 Sexual Assault Prevention Programs 
Appendix II: Comments from the Department 

of Defense 

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Appendix II: Comments from the Department 

of Defense 

Page 49 GAO-10-215 Sexual Assault Prevention Programs
Appendix II: Comments from the Department 

of Defense 

Page 50 GAO-10-215 Sexual Assault Prevention Programs
Appendix II: Comments from the Department 

of Defense 

Page 51 GAO-10-215 Sexual Assault Prevention Programs
Appendix II: Comments from the Department 

of Defense 

Page 52 GAO-10-215 Sexual Assault Prevention Programs
Appendix II: Comments from the Department 

of Defense 

Page 53 GAO-10-215 Sexual Assault Prevention Programs
Appendix II: Comments from the Department 

of Defense 

Page 54 GAO-10-215 Sexual Assault Prevention Programs
Appendix II: Comments from the Department 

of Defense 

Page 55 GAO-10-215 Sexual Assault Prevention Programs
Appendix II: Comments from the Department 

of Defense 

Page 56 GAO-10-215 Sexual Assault Prevention Programs
Appendix II: Comments from the Department 

of Defense 

Page 57 GAO-10-215 Sexual Assault Prevention Programs
Appendix III: Comments from the U.S. Coast 

Guard 

Page 58 GAO-10-215 

Appendix III: Comments from the U.S. Coast 

Guard 

 Sexual Assault Prevention Programs 
Appendix III: Comments from the U.S. Coast 

Guard 

Page 59 GAO-10-215 Sexual Assault Prevention Programs
Appendix IV: 

A

GAO Contacts and Staff 

cknowledgments 

Page 60 GAO-10-215 

Appendix IV: GAO Contacts and Staff 

Acknowledgments 

Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov 

Randolph C. Hite, (202) 512-3439 or hiter@gao.gov 

In addition to the contacts named above, key contributors to this report 

include Marilyn K. Wasleski, Assistant Director; Neelaxi Lakhmani, 

Assistant Director; Divya Bali; Stacy Bennett; Steve Caldwell; Elizabeth 

Curda; Matt Dove; K. Nicole Harms; Jim Houtz; Ron La Due Lake; Kim 

Mayo; Geoffrey Peck; Adam Vodraska; and Cheryl A. Weissman. 

 Sexual Assault Prevention Programs 

GAO Contacts 

Acknowledgments 

(351324) 
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