United States Government Accountability Office

GAO Report to Congressional Committees

MILITARY 

PERSONNEL 

Additional Actions 

Needed to Improve 

Oversight of Reserve 

Employment Issues 

February 2007 

 

GAO-07-259 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

February 2007

MILITARY PERSONNEL

Additional Actions Needed to Improve 

Highlights of GAO-07-259, a report to Oversight of Reserve Employment Issues 

congressional committees 

www.gao.gov/cgi-bin/getrpt?GAO-07-259.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Derek B. 

Stewart at (202) 512-5559 or 

stewartd@gao.gov. 

Since September 11, 2001, the

Department of Defense (DOD) has 

mobilized more than 500,000

reservists. As reservists demobilize,

concerns exist about difficulties 

with their civilian employment. 

Public Law 109-163 required GAO

to report on reservists’ civilian 

employer data and employment

matters. GAO assessed (1) the 

status of DOD’s efforts to capture 

reservists’ employer data; (2) DOD, 

Labor, Justice, and Office of

Special Counsel processes to track 

and address reservists’ USERRA 

complaints; and (3) the four federal 

agencies’ efforts to track reservists’ 

USERRA complaints related to 

disabilities incurred while on active

duty. GAO reviewed policies and

procedures for reporting and 

tracking complaints; DOD’s civilian 

employer database for reservists

and reservists’ USERRA 

complaints; and data reliability and 

quality checks. 

What GAO Recommends

To improve oversight of reservists’ 

complaints, Congress should 

consider changing the law to 

require Labor’s annual report to 

include DOD complaint data; DOD

should improve its reporting of

employer information; Labor 

should make aggregate complaint 

data available to DOD; and 

agencies should adopt uniform data

elements, and track disabilityrelated USERRA complaints. In 

commenting on a draft of this

report, DOD, Labor, and Office of

Special Counsel generally agreed

with GAO’s recommendations. 

Justice had no agency comments. 

DOD has made progress in capturing employment information on reservists, 

but challenges remain. The percent of reservists reporting employer 

information increased from about 60 percent in August 2005 to about 77 

percent as of August 2006. However, only one of seven reserve components 

has met DOD’s employment reporting goal of 95 percent for the Selected 

Reserve–the largest category of reservists. DOD does not have specific time 

frames for reserve components to achieve the reporting goals. In addition, 

some employment information reported may not be current because the 

services have not established a formal mechanism to remind reservists to 

update their reported employment information. Finally, DOD’s verification 

process is not adequate to verify civilian employer data for 24 percent of 

reservists that reported employer information. 

The four federal agencies responsible for assisting reservists with USERRA 

complaints—DOD, the departments of Labor and Justice, and the Office of 

Special Counsel—track and address these complaints. Between fiscal years 

2004 and 2006, the four agencies addressed approximately 16,000 informal

and formal complaints. However, no one agency has total visibility over all 

the complaints, and only a small percentage of complaints are reported to 

Congress. For example, DOD has visibility over all complaints in its system, 

but its visibility over complaints in Labor’s system is limited to those 

originally filed with DOD and then later refiled with Labor. The Department 

of Labor does not make aggregate complaint data available to DOD. 

Furthermore, Labor’s annual report to Congress on reservists’ complaints for 

fiscal years 2004 and 2005 did not include almost 10,000 informal complaints 

filed with DOD, or 80 percent of the total informal and formal complaints 

addressed by the four agencies during this period. Labor is required to 

report formal complaints addressed by the three agencies, but not DOD. 

Consequently, Congress does not have the comprehensive information 

necessary to allow for complete oversight of reservists’ employment and 

reemployment problems. Finally, the information GAO obtained on the 

approximately 16,000 reservists’ complaints filed between fiscal years 2004 

and 2006 showed that the nature of those complaints has not been uniformly 

categorized to completely reveal trends in the kinds of problems some 

returning reservists experience because the agencies use different complaint 

categories to characterize the complaints. 

Agencies responsible for assisting reservists with USERRA issues can not 

systematically record and track disability-related employment complaints 

because they do not use consistent and compatible complaint categories or 

have a mechanism in place for distinguishing disability-related complaints 

from others. Without the ability to track disabled reservists’ USERRA 

complaints, DOD may be unaware of the effect disabilities incurred while on 

active duty have on reservists’ employment and what additional assistance 

may be needed to help transition this population back into the workforce. 
Contents 

Letter 1

Results in Brief 5 

Background 9

DOD Has Made Progress Capturing Reserve Employment 

Information, but Challenges Remain 15 

Congress and DOD Do Not Have the Comprehensive Information 

Necessary to Allow for Oversight of Reservists’ USERRA 

Complaints 25

Disabled Reserve Members’ USERRA Complaints Are Not 

Systematically Recorded or Tracked 32 

Conclusions 36

Matter for Congressional Consideration 37 

Recommendations for Executive Action 37 

Agencies’ Comments and Our Evaluation 38 

Appendix I Scope and Methodology 43 

Appendix II Profiles on Reservists’ Civilian Employment 48 

Appendix III Profiles on Employers of Reservists 54 

Appendix IV Comments from the Department of Defense 68 

Appendix V Comments from the Department of Labor 71 

Appendix VI Comments from the Office of Special Counsel 73 

Appendix VII GAO Contact and Staff Acknowledgments 74 

 

Page i GAO-07-259 Reserve Employment Matters
Tables 

Table 1: DOD and Reserve Components’ Ready Reserve Strength, 

August 2006 9 

Table 2: Reserve Population and Percent of Compliance Achieved 

Toward Civilian Employment Reporting Goals by DOD and 

the Reserve Components, August 2006 17 

Table 3: Number and Percent of Selected Reservists Reporting 

Employment by Small Businesses with Less than 50 

Employees by Reserve Component and Total 23 

Table 4: Informal and Formal Complaints Reservists Filed with 

DOD’s Employer Support of the Guard and Reserve, the 

Veterans’ Employment and Training Service, and the 

Office of Special Counsel, Fiscal Years 2004 and 2005 27 

Table 5: Type of USERRA Disability-Related Complaint 

Classifications by Agency 34 

Table 6: Reported Civilian Employment Status of Selected 

Reservists by DOD and its Reserve Components 48 

Table 7: Selected Reservists Reporting Full-Time or Part-Time 

Civilian Employment by Employment Sector for DOD and 

Its Reserve Components 49 

Table 8: Number of Selected Reservists Reporting Full-Time or 

Part-Time Private Civilian Employment by Employer Size 

for DOD and Its Reserve Components 50 

Table 9: Number of Selected Reservists in DOD Reporting SelfEmployment by Occupation Code and Description 51 

Table 10: Number of Selected Reservists in each Reserve 

Component Reporting Self-Employment by Standard 

Occupation Code and Description 52 

Table 11: Reported Employers of Reservists by Employment 

Sector, for DOD and Its Reserve Components 54 

Table 12: Reported Private Employers of Reservists by Number of 

Employees by DOD and Its Reserve Components 55 

Table 13: Reported Number of Private Employers of DOD’s 

Reservists by Two-Digit Standard Industrial Classification 

Code 55 

Table 14: Reported Number of Private Employers of Reservists by 

Two-Digit Standard Industrial Classification Code by 

Reserve Component 58 

Table 15: Industries of Reported Small (Less than 50 Employees) 

Private Employers of DOD’s Reservists, by Two-Digit 

Standard Industrial Classification Code 61 

Page ii GAO-07-259 Reserve Employment Matters
Table 16: Reported Number of Private Employers of Reservists by 

Two-Digit Standard Industrial Classification Code and 

Reserve Component 64 

Figures 

Figure 1: Process to Resolve a USERRA Complaint Using Federal 

Assistance 12

Figure 2: Number and Percent of Selected Reservists Reporting 

Work in the Private Sector by Business Size (Number of 

Employees) 22

Figure 3: Occupations with the Greatest Amount of 23,871 SelfEmployed Reservists Reporting 24 

Abbreviations 

GAO Government Accountability Office 

DOD Department of Defense 

USERRA Uniformed Services Employment and Reemployment 

Rights Act 

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Page iii GAO-07-259 Reserve Employment Matters
United States Government Accountability Office

Washington, DC 20548 

February 8, 2007 

The Honorable Carl Levin 

Chairman 

The Honorable John McCain 

Ranking Minority Member 

Committee on Armed Services 

United States Senate 

The Honorable Ike Skelton 

Chairman 

The Honorable Duncan Hunter 

Ranking Minority Member 

Committee on Armed Services 

House of Representatives 

Since September 11, 2001, the Department of Defense (DOD) has 

mobilized more than 500,000 members of the National Guard and Reserves 

in support of the Global War on Terrorism. As DOD continues to rely 

heavily on reservists,1

 and as demobilized reservists eventually return to 

civilian life, their civilian employment and the difficulties they face in 

dealing with reemployment matters remain areas of interest. In addition, a 

recent estimate indicated that one in four reservists returning from Iraq 

and Afghanistan has filed for disability benefits. Consequently, reservists 

returning from active duty with a disability may be further challenged in 

their ability to resume their civilian employment. 

DOD’s Ready Reserve is comprised of military members of the Reserve 

and National Guard, organized in units, or as individuals, liable for recall 

to active duty to augment the active component in time of war or national 

emergency. Within the Ready Reserve there are three subcategories: the 

Selected Reserve, Individual Ready Reserve, and the Inactive National 

Guard. The Selected Reserve consists of units and individuals designated 

by their respective services and approved by the Chairman of the Joint 

Chiefs of Staff as so essential to the initial wartime mission that they have 

 1

For the purpose of this report, the terms reserve component and reservists refer to the

collective forces of the Army National Guard, Air National Guard, Army Reserve, Air Force

Reserve, Navy Reserve, Marine Corps Reserve, and Coast Guard Reserve. 

Page 1 GAO-07-259 Reserve Employment Matters
priority for training, equipment, and personnel over all other categories of

reservists. The Individual Ready Reserve consists of about 260,000 

servicemembers who have had training and served previously in the active

component or selected reserve and have some period of their military 

service obligation remaining. The Inactive National Guard has over 1,900 

members2

 who are Army National Guard personnel who are attached to a 

specific National Guard unit. Although they do not participate in training 

activities, members of the Inactive National Guard are required to come 

together once a year with their unit and would mobilize with their units if 

recalled to active duty. 

DOD maintains and uses employer information to help manage its reserve 

forces. For example, the department considers several factors when 

deciding which reservists should be activated, including the civilian 

occupations of reservists such as emergency responders—police officers, 

firefighters, and medical personnel—necessary to maintain the national

health, safety, and interests. In addition, DOD and the Department of 

Labor have a responsibility to inform reservists and their civilian 

employers about their rights and responsibilities under the Uniformed 

Services Employment and Reemployment Rights Act (USERRA) of 1994.3

Among other things, USERRA requires employers to promptly reemploy 

those eligible servicemembers returning from active duty, generally in the 

same or like position, and to provide the seniority, rights, benefits, and 

promotions they would have received if they had remained continuously 

employed. Likewise, USERRA requires reservists to provide their 

employers with advance notice prior to departure for military duty. DOD’s 

Employer Support of the Guard and Reserve organization retains 

reservists’ employer information to conduct employer outreach, 

education, and training. Reservists have both informal and formal options 

to report their USERRA complaints. Informal sources include their 

military chain of command and DOD’s Employer Support ombudsmen 

services, which are available to provide informal mediation of USERRArelated issues. Servicemembers may also contact the Department of 

Labor’s Veterans’ Employment and Training Service to formally report 

 2

Numbers are as of August 2006.

3

Pub. L. No. 103-353 (1994), as amended, codified at 38 U.S.C. §4301-4334. 

Page 2 GAO-07-259 Reserve Employment Matters
USERRA-related issues.4

 At the reservist’s request, the Department of 

Labor can also transfer the complaint for possible litigation to the 

Department of Justice—if the complaint involves State or local

governments and private employers—or to the Office of Special Counsel—

if the complaint involves federal executive agencies. Under a 

demonstration project,5

 the Office of Special Counsel now receives some 

USERRA complaints directly from certain servicemembers. 

In prior reports, we cited problems with DOD’s ability to track civilian 

employment data and address reservists’ USERRA complaints.6

 DOD did 

not have sufficient information on employers of reservists and the 

agencies addressing reservist complaints did not have the ability to 

efficiently and effectively address complaints because the data systems 

were incompatible and the processes they used hindered visibility. In 

response to the recommendations in these reports, DOD required its 

reservists to provide contact information for their civilian employers and 

status of their civilian employment. In addition, the four agencies 

responsible for addressing USERRA complaints began measures to 

improve interagency information exchange and data-sharing capabilities. 

The National Defense Authorization Act for Fiscal Year 20067

 required 

GAO to report on reservists’ civilian employer data and the reemployment 

difficulties faced by reservists as a result of active duty service, including

those related to disabilities incurred while activated. For this report, our 

objectives were to determine: (1) the status of DOD’s efforts to capture 

data identifying employers of reservists, (2) the extent to which agencies 

track and address USERRA complaints from reservists, and (3) the extent 

to which agencies track and address USERRA complaints related to 

reservists’ disabilities incurred while on active duty. 

 4

Federal agencies use a variety of terms to describe allegations of USERRA violations, 

including “complaints,” “claims,” “matters,” and “referrals.” For clarity and consistency 

throughout this report, we use the term complaint to describe these allegations. We refer to

complaints to DOD as “informal complaints” and complaints to the Department of Labor,

Department of Justice, and Office of Special Counsel as “formal complaints.” 

5

Veterans Benefits Improvement Act of 2004, Pub. L. No. 108-454, § 204 (2004). 

6

GAO, Reserve Forces: DOD Actions Needed to Better Manage Relations between 

Reservists and their Employers, GAO-02-608 (Washington, D.C.: June 13, 2002); and GAO,

Military Personnel: Federal Management of Servicemember Employment Rights Can Be

Further Improved, GAO-06-60 (Washington, D.C.: October 2005). 

7

Pub. L. No. 109-163, §517 (2006). 

Page 3 GAO-07-259 Reserve Employment Matters
To accomplish these objectives, we reviewed agency policies, procedures,

and processes for reserve employment reporting and for tracking and 

addressing USERRA complaints including the informal complaints filed 

with DOD’s Employer Support and the formal complaints filed with the 

Department of Labor’s Veteran’s Employment and Training Service and 

the Office of Special Counsel.8

 We obtained and analyzed employer data 

for the Ready Reserve from DOD’s civilian employment information 

database as of August 2006 and DOD’s reserve disabled totals from fiscal 

years 2003 through 2006. In addition, we obtained information on the over

16,000 total USERRA informal complaints filed with DOD’s Employer 

Support, and the formal complaints filed with the Department of Labor’s

Veterans’ Employment and Training Service, and the Office of Special

Counsel for fiscal years 2004 through 2006, including any identified as 

related to disabilities. We interviewed officials from the Office of the 

Assistant Secretary of Defense for Reserve Affairs and the Reserve 

Components about civilian employer reporting; and we talked to 

representatives from DOD’s Employer Support of the Guard and Reserve 

(including ombudsmen, who are civilian volunteers throughout the 

country who assist reservists in resolving employment disputes), the 

Department of Labor’s Veterans’ Employment and Training Service, the 

Department of Justice, and the Office of Special Counsel about reservist 

USERRA complaints. In addition, we visited Army National Guard, Army 

Reserve, Air Force Reserve, and Marine Corps Reserve units that were 

previously activated and held group discussions with over 100 officers and 

enlisted personnel about their knowledge of USERRA and the rights it 

provides them, reporting of employment information, and any USERRA 

issues they may have experienced as a result of their activation. We also 

discussed reservist-related USERRA and disability issues with several 

military relief, veterans, and reserve organizations. Finally, we reviewed 

the reliability of data that we used from the four agencies. 9

 Our work was

performed from April 2006 to December 2006 in accordance with generally 

 8

The Attorney General is assigned enforcement responsibilities under USERRA, but the 

Department of Justice is not authorized to receive USERRA complaints directly from 

servicemembers. It may represent individuals involving private sector or State or local 

government complaints that are referred from the Department of Labor. 

9

Reliability refers to the accuracy and completeness of computer-processed data. We

conducted a mix of electronic testing and reviews of data quality controls the agencies 

have in place. We found the data we used from three of the data sources to be sufficiently 

reliable for the purposes of this engagement. However, an ongoing review within our 

agency continues to assess the Department of Labor’s USERRA data. We found two of the

data sources to be of undeterminable reliability for the purpose of this engagement. 

Page 4 GAO-07-259 Reserve Employment Matters
accepted government auditing standards. Additional information on our

scope and methodology is presented in appendix I.

DOD has made progress capturing employment information on its 

reservists since August 2005, but several challenges remain. In August 

2004, DOD changed employer reporting by reservists from voluntary to 

mandatory. The number of reservists reporting employer information to 

DOD increased from 60 percent in August 2005 to about 77 percent in 

August 2006. However, we found that reservists have not fully reported 

civilian employment information, reported employment data are not 

necessarily current, and DOD’s employer verification process is not 

adequate. Complete and current civilian employer information is 

important to DOD for several reasons, including its ability to provide 

sufficient outreach to employers. In August 2004, DOD established a 95 

percent goal for reporting employment information for the Selected

Reserve and a 75 percent reporting goal for the Individual Ready Reserve 

and Inactive National Guard. As of August 2006, about 91 percent of 

Selected Reserve members had reported this information, whereas only 30 

percent of Individual Ready Reserve or Inactive National Guard Members 

with good addresses had complied. Currently, the Army Reserve has met 

the Selected Reserve reporting goal and the Army National Guard has met 

the Inactive National Guard reporting goal and nearly met the Selected 

Reserve goal, while the other reserve components have met neither goal.

Moreover, DOD does not have specific time frames for when reserve 

components are to achieve their reporting goals, and has not directed the 

service components to take actions to assure compliance. In addition, the 

DOD instruction10 requires reservists to update their employment 

information when changes occur; however, during focus groups we found 

that reservists generally were not aware of the need to update employer 

information when employers changed. As such, some employer 

information in DOD’s database may not be current because the services 

have not established a formal mechanism to remind reservists to review 

their personnel information and update it as necessary to reflect changes

in their current employment. Lastly, DOD relies on Dun and Bradstreet to 

verify the accuracy of the employer data provided by reservists and to 

provide DOD with additional employer business characteristics. However, 

DOD has not been able to determine the accuracy of all of its reported 

employer information, including small businesses that employ less than 50 

Results in Brief 

 10DODI 7730.54, enclosure 10 (Aug. 6, 2004). 

Page 5 GAO-07-259 Reserve Employment Matters
people. For example, of the 453,596 reservists reporting civilian employer 

information, DOD was unable to verify employer information for 

approximately 24 percent, or 108,125 reservists reporting employment. 

DOD acknowledges that its process for verifying employment data has 

been particularly difficult for small business and is working to identify 

alternative sources for this information. Without better information for 

these employers of reservists, DOD may be limited in its efforts to provide 

outreach to employers. We are making a number of recommendations to 

the Secretary of Defense to improve the reporting of reserve employment 

information, and to encourage reservists to keep their employer data 

current. 

The four federal agencies responsible for assisting reservists with 

USERRA complaints—DOD’s Employer Support of the Guard and 

Reserve, the Department of Labor, the Department of Justice, and the 

Office of Special Counsel—track and address these complaints; however, 

Congress does not have the comprehensive information necessary to allow 

for complete oversight of all reservists’ USERRA complaints. For example, 

the Secretary of Labor is required by law to provide an annual report to 

Congress that includes information on the number of cases it reviewed, 

the nature and status of each case reported, as well as the number of cases 

referred to the Attorney General or Office of Special Counsel.11 The 

Department of Labor and the Office of Special Counsel, for fiscal years 

2004 and 2005, tracked and addressed 2,446 formal USERRA complaints, 

which were reported to Congress. However, the Secretary’s report to 

Congress for fiscal years 2004 and 200512 was not required to include 9,975 

informal USERRA complaints that were tracked and addressed by DOD’s 

Employer Support of the Guard and Reserve. Additionally, DOD’s 

Employer Support of the Guard and Reserve organization lacks complete 

information on all reserve USERRA complaints filed because the 

Department of Labor does not provide DOD with aggregate USERRA 

complaint data by complaint type. Although DOD’s Employer Support is 

able to produce aggregate reports on complaints that originate within the 

agency, it is not able to produce aggregate reports for cases that begin

 1138 U.S.C. § 4332. 

12The Department of Labor’s USERRA Annual Report to Congress includes information on

all reemployment complaints reported to the Department of Labor, which include 

complaints from all persons protected under USERRA. At the time we performed our 

analysis, the Department of Labor had not provided its fiscal year 2006 report to Congress. 

The fiscal year 2006 report to Congress is not due until February 2007. 

Page 6 GAO-07-259 Reserve Employment Matters
with the Department of Labor. According to the Standards for Internal 

Control,13 management should ensure that there are adequate means of 

communicating with, and obtaining information from, others who may 

have a significant impact on the agency’s ability to achieve its goals. 

Finally, we obtained information on the over 16,000 total informal and 

formal USERRA complaints filed by reservists between fiscal years 2004 

and 2006.14 These data showed that the nature of those complaints has not 

been uniformly categorized to completely reveal trends in the types of 

problems that some returning reservists experience—such as being 

refused job reinstatement, denied an appropriate pay rate, or being denied 

vacation time—because the four agencies involved use different complaint 

categories to characterize USERRA complaints. In line with the Standards 

for Internal Control in the Federal Government, it is essential that different 

sets of related data be compared and assessed so that analyses of the 

relationships can be made and corrective actions taken, if needed. Current 

reporting practices limit congressional oversight of reserve USERRA 

complaints and DOD’s awareness of complaints filed with other agencies 

and the nature of these issues. To gain a full perspective on the number 

and nature of USERRA complaints filed by reservists upon returning from 

active duty, Congress should consider amending 38 U.S.C. §4332 to require 

the Department of Labor to include data from DOD’s Employer Support of 

the Guard and Reserve in its annual report to Congress. We are also 

recommending that the Secretary of Labor provide aggregate USERRA 

complaint data to DOD’s Employer Support of the Guard and Reserve, and 

we are recommending that the Secretary of Labor and Secretary of 

Defense adopt uniform complaint categories in the future that will allow 

aggregate trend analysis to be performed across their agencies’ databases.

Agencies responsible for addressing reservists’ USERRA issues cannot 

systematically record and track disability-related employment complaints 

because they do not use consistent and compatible complaint categories 

for tracking purposes and they do not have a system in place for 

distinguishing disability-related complaints from other types of 

complaints. Our analysis of DOD’s Employer Support of the Guard and 

 13GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 

(Washington, D.C.: Nov. 9, 1999). 

14This total includes informal complaints filed by reservists with DOD’s Employer Support

between fiscal years 2004 and 2006, and the formal complaints reported by the Department 

of Labor’s Veterans’ Employment and Training Service in its fiscal year 2004 and 2005 

reports to Congress. The fiscal year 2006 report was not available within the time frames of

our review. 

Page 7 GAO-07-259 Reserve Employment Matters
Reserve and the Veterans’ Employment and Training Service data 

indicated that about 200 reservists’ USERRA complaints filed and 

addressed in fiscal years 2004 to 2006 were identified as disability-related.

We believe, however, that the number of disability-related complaints may 

be understated because the agencies may have recorded disability-related

complaints in categories other than the specific categories we analyzed.

Without systematic tracking of disabled reservists’ complaints to provide 

visibility over this group, DOD may not be fully aware of (1) the effect

disabilities received by reservists while on active duty had on

reemployment if the reservists filed formal complaints directly with the 

Department of Labor and (2) what additional assistance may be needed to

help transition this population back into the workforce. In order for 

agencies to have more complete information regarding the numbers and 

types of disability-related USERRA complaints from disabled reservists, 

we are recommending that the Secretary of Labor develop a system for 

recording and tracking these types of complaints and share it with the 

other agencies responsible for addressing USERRA complaints. 

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

Labor generally concurred with our findings and recommendations that 

were directly applicable to their respective agencies. The Office of Special

Counsel also provided written comments indicating that it concurred with 

our recommendations and found the report to be comprehensive and 

accurate as it related to the responsibilities of the Office of Special 

Counsel. Also, the Department of Labor and the Office of Special Counsel 

concurred with our matter for congressional consideration that Congress 

should consider amending 38 U.S.C. §4332 to require the Department of 

Labor to include complaint data from DOD’s Employer Support of the 

Guard and Reserve in its annual report to Congress. The Department of 

Justice reviewed a draft of this report and had no comments. The other 

agencies’ comments and our evaluation of them are discussed later in this 

report. 

Page 8 GAO-07-259 Reserve Employment Matters
The purpose of the reserve components is to provide trained units and 

qualified persons available for active duty in the armed forces in time of 

war or national emergency or as otherwise required for national security.15

Since the end of the Cold War, the nation has relied more heavily on the 

reserves as an integrated part of the military services. As of August 2006,

reserve components comprised about 1.1 million members or 44 percent 

of the nation’s total military force. Reserve units are primarily filled by 

members of the Selected Reserve, who are authorized training consisting 

of regularly scheduled unit training period in an Inactive Duty Status (48 

periods a year). Reservists can also volunteer to serve on active duty or be 

involuntarily mobilized to active duty. 

The strength numbers for DOD’s Ready Reserves as of August 2006 by 

reserve component are shown in table 1 below. 

Table 1: DOD and Reserve Components’ Ready Reserve Strength, August 2006 

Reserve component Strength numbers

Army National Guard 345,207

Army Reserve 285,611

Navy Reserve 131,739

Marine Corps Reserve 100,678

Air National Guard 105,517

Air Force Reserve 118,472

Coast Guard Reserve 12,659

DOD total 1,099,883

Source: DOD summary strength report. 

In 1994, Congress passed USERRA to “encourage non-career service in the 

uniformed services by eliminating or minimizing the disadvantages to 

civilian careers and employment which can result from such service.”16

Background 

DOD’s Reserve 

Components 

USERRA Coverage and 

Protections 

 1510 U.S.C. §10102. 

1638 U.S.C. §4301. 

Page 9 GAO-07-259 Reserve Employment Matters
The act protects millions of individuals17 as they transition between their 

federal duties and their civilian employment. Prior to USERRA, 

reemployment rights were set forth in the Vietnam Era Veteran’s 

Readjustment Act of 1974.18 Congress reviewed the effectiveness of the 

1974 act after receiving a number of questions and complaints about 

reemployment rights from military servicemembers and employers 

following the 1991 Gulf War.19 USERRA covers not only those individuals 

who have served in the reserve components, but also large numbers of 

active duty servicemembers and veterans, including those who served 

prior to the passage of the act. Servicemembers retain reemployment 

rights under USERRA as long as they meet a few basic requirements. 

Among the eligibility requirements are (1) the absence of the receipt of a 

dishonorable or other disqualifying discharge, (2) giving proper notice 

prior to departure, and (3) returning to work or applying for 

reemployment in a timely manner after conclusion of service. Provided 

servicemembers meet their USERRA requirements, they are entitled to 

• prompt reinstatement to the position they would have held if they had

never left their employment, or to positions of like seniority, status, and 

pay; 

• health coverage for a designated period of time while absent from their 

employers and immediate reinstatement of health coverage upon 

return; 

• training, as needed, to requalify for their jobs; 

• periods of protection against discharge based on the length of service; 

and 

• nonseniority benefits that are available to other employees with similar 

seniority, status, and pay who are on leaves of absence. 

 17In addition to military servicemembers and veterans, the act covers the commissioned

corps of the Public Health Service and other persons designated by the President in time of

war or national emergency.

18Pub. L. No. 93-508 (1974). 

19According to DOD, an interagency committee was formed in 1987 with representatives 

from DOD, the Department of Labor, the Department of Justice, and the Office of 

Personnel Management to review existing law and recommend legislative changes. This 

committee forwarded proposed legislation to Congress in March 1991. 

Page 10 GAO-07-259 Reserve Employment Matters
USERRA also provides employment and reemployment protection to 

reservists who incur or aggravate a medical disability during their military 

service.20 In these instances, generally a three-part reemployment scheme 

is required. First, the employer must make reasonable efforts to 

accommodate a person’s disability so that the person can perform the 

position that he or she would have held if continuously employed. Second,

if regardless of accommodation efforts a person is not qualified for his or 

her original position due to a disability, he or she must be offered 

employment in a position of equivalent seniority, status, and pay—so long 

as the employee is qualified to perform the duties of that position or could 

become qualified with reasonable efforts by the employer. Finally, if the 

employee cannot become qualified for his or her prior position or its 

equivalent, he or she must be offered employment in a position that most 

nearly approximates the prior position in terms of seniority, status, and 

pay consistent with the circumstances of the person’s case. 

Figure 1 shows the process for servicemembers to resolve a USERRA 

complaint using federal assistance. 

 20 38 U.S.C. §4313 (a)(3). 

Page 11 GAO-07-259 Reserve Employment Matters
Figure 1: Process to Resolve a USERRA Complaint Using Federal Assistance 

File a complaint with Department 

of Labor so that a Veterans 

Employment and Training Service 

investigator can try to resolve the 

situation through education and 

formal mediation.

Use an ombudsman trained by the 

Employer Support of the Guard

and Reserve organization to help

resolve the problem through

education and informal mediation.

From February 8, 2005, to September 30, 

2007, Office of Special Counsel will 

investigate USERRA complaints from certain 

servicemembers who work for federal 

executive agencies. Complaints can come 

directly from servicemembers or be referred 

to Office of Special Counsel from Department 

of Labor. Like non-demonstration 

project cases, Office of Special Counsel 

may prosecute meritorious cases on 

behalf of the servicemember.

If a servicemember cannot resolve an alleged

USERRA violation directly with his or her employer, 

he or she can seek assistance from:

Department of Defense Department of Labor Office of Special Counsel

Office of Special Counsel

(Demonstration Project)

 Department of Justice

Source: GAO, Art Explosion.

When a servicemember requests a referral, 

Department of Justice reviews the findings of the 

Department of Labor's Veterans 

Employment and Training Service investigator and 

regional solicitor and then performs its own 

evaluation of the merits of the complaint, and 

obtains additional information as necessary. If 

Department of Justice determines the complaint 

has merit, it represents the servicemember against 

his or her private employer or state or local 

government employer in federal district court. If 

the Department of Justice finds that the complaint 

has no merit, it would notify the claimant of his or 

her right to pursue a private cause of action.

When a servicemember requests a referral, Office 

of Special Counsel reviews the findings of the 

Department of Labor's Veterans 

Employment and Training Service investigator and 

regional solicitor, then performs its own evaluation 

of the merits of the complaint, and obtains 

additional information as necessary. If Office of 

Special Counsel determines the complaint has 

merit, it represents the servicemember against his 

or her federal executive agency employer before 

the Merit Systems Protection Board. If the Office of 

Special Counsel finds that the complaint has no 

merit, it would notify the claimant of his or her right 

to pursue a private cause of action.

««« »»»

DOD shares responsibility with the Department of Labor to inform 

servicemembers and their employers of their rights, benefits, and 

Page 12 GAO-07-259 Reserve Employment Matters
obligations under USERRA.21 DOD’s Employer Support of the Guard and 

Reserve provides this training to reservists. The Office of the Under 

Secretary of Defense (Personnel and Readiness) develops the policies, 

plans, and programs that manage the readiness of both active and reserve 

forces, and within that office, the Assistant Secretary of Defense for 

Reserve Affairs oversees that activities of Employer Support. Much of 

Employer Support’s work is done through its more than 4,000 volunteers, 

who help to educate servicemembers and employers about USERRA. A 

subgroup of about 800 specially trained volunteers act as impartial 

ombudsmen to informally mediate USERRA issues that arise between 

reservists and their employers. Ombudsmen handle complaints of 

reservists who are located geographically nearby. When ombudsmen 

cannot resolve a complaint informally, they notify the reservist of other 

options available to formally address complaints, such as filing a 

complaint with the Department of Labor or hiring private counsel. 

The Department of Labor provides assistance to servicemembers with 

USERRA formal complaints primarily through its Veterans’ Employment 

and Training Service. When a servicemember leaves active duty and a 

USERRA-related complaint develops against his or her civilian employer, 

the servicemember can file a formal complaint via computer at 

www.vets1010.dol.gov or can file a printed copy of the complaint with the 

Secretary of Labor. A Veterans’ Employment and Training Service 

investigator located close to the employer will examine the complaint and 

attempt to resolve the complaint between servicemember and employer. If 

the Department of Labor is unable to resolve the complaint, it informs the 

servicemembers that the complaint can be referred to the Department of 

Justice or to the Office of Special Counsel. Before formal complaints are 

sent to the Department of Justice or the Office of Special Counsel, the 

Veterans’ Employment and Training Service prepares a memorandum of 

referral, which includes an analysis of the key evidence and issues so as to 

ensure that the investigations were thorough and documentation is 

accurate and sufficient. The referrals are also reviewed by a Department of 

Labor Solicitor’s Office, which analyzes all legal issues raised by the 

complainants. Although both the Veterans’ Employment and Training 

Service and the Solicitor’s Office determine if the complaints have merit, 

the Department of Labor is required to pass the complaints onto the 

 21The law also gives outreach responsibilities to the Secretary of Veterans Affairs, but we 

did not review actions of the Department of Veterans Affairs in supporting USERRA 

because its role is more limited than that of the other four federal agencies. 

Page 13 GAO-07-259 Reserve Employment Matters
Department of Justice or the Office of Special Counsel if requested by 

servicemembers. 

The Department of Justice receives employment complaints from the 

Department of Labor related to State or local government or private 

employers. The Department of Justice reviews the file and determines 

whether a complaint has merit. If so, the Department of Justice offers the 

claimant representation and may pursue litigation; if not, it declines 

representation. The Employment Litigation Section of the Civil Rights 

Division handles most of the USERRA complaints, and under some 

circumstances may refer a complaint to the appropriate United States 

Attorney’s Office for review or prosecution. 

The Office of Special Counsel enforces USERRA rights on complaints the 

Department of Labor receives about federal executive agencies. Under a 

demonstration project authorized by the Veterans Benefits Improvement

Act of 2004,22 the Office of Special Counsel may now receive USERRA 

complaints as soon as they are filed by certain members.23 Thus, the Office 

of Special Counsel can use information from the Department of Labor to 

review a referred complaint, but it can also review a complaint directly 

from a servicemember without Department of Labor input. If the Office of 

Special Counsel determines that the complaint has merit, it negotiates 

with the servicemember’s federal employer. If an agreement cannot be 

reached, the Office of Special Counsel may represent the servicemember 

before the Merit Systems Protection Board and can appeal a decision in 

the U.S. Court of Appeals for the Federal Circuit. In response to a 

congressional mandate, we are currently assessing the Office of Special

Counsel’s demonstration project and will issue a separate report in the 

spring of 2007. 

 22Pub. L. No. 108-454, §204 (2004). 

23Under the demonstration project, established by the Veterans Benefits Improvement Act

of 2004, the Secretary of Labor refers to the Office of Special Counsel all federal sector

USERRA claims that contain an allegation of a prohibited personnel practice over which 

the Office of Special Counsel has jurisdiction. The Secretary transfers all USERRA claims 

against a federal executive agency brought by claimants whose social security numbers 

end in odd numbers. 

Page 14 GAO-07-259 Reserve Employment Matters
Although DOD has established reporting requirements and compliance 

goals for reservists to provide their employer information and has made 

progress capturing much employer information, most reserve components 

have not met these reporting goals. In addition, DOD does not know 

whether the employer data it has obtained are current. Lastly, DOD has 

been unable to verify employer data for approximately 24 percent of its 

reservists reporting civilian employment. DOD acknowledges its 

verification process is not adequate for determining the accuracy of all

employer information, particularly for small business. 

Although DOD and the reserve components have made progress in 

capturing employer information, most of the established reporting 

compliance goals have not been met. In 2001, DOD established a database 

to collect voluntarily reported employer information from reserve 

component members, but few servicemembers submitted the data.

Following a recommendation in our 2002 report,24 DOD took steps to make 

the submission of employer information mandatory. In March 2003, the 

Under Secretary of Defense for Personnel and Readiness signed a 

memorandum25 directing each military department to implement a civilian 

employment information program for the collection of employer 

information and cited the need to utilize the information in accomplishing 

employer outreach. Having complete civilian employer information is also 

important to DOD’s ability to make informed decisions concerning which 

reservists should be called for active duty to minimize the impact that 

mobilizations might have on occupations such as law enforcement, and to 

determine how businesses may be affected by reserve activation. In 

August 2004, DOD implemented regulations that required each military 

department to implement employment-related information reporting 

requirements for each officer, warrant officer, and enlisted person 

assigned to the Ready Reserve. These Reservists are required to report 

employment data—including whether they are employed part-time or fulltime, are a student, have specified voluntary service,26 or are not currently 

DOD Has Made 

Progress Capturing 

Reserve Employment 

Information, but 

Challenges Remain 

DOD Has Made Progress 

Capturing Employer 

Information, but Most 

Components Have Not Met 

Reporting Goals 

 24GAO, Reserve Forces: DOD Actions Needed to Better Manage Relations between 

Reservists and Their Employers, GAO-02-608 (Washington, D.C.: June 13, 2002). 

25Under Secretary of Defense for Personnel and Readiness Memorandum on Civilian 

Employment Information Program, March 21, 2003. 

26Specified voluntary service includes activities such as those performed in the United

States Coast Guard Auxiliary and the Civil Air Patrol, or as a volunteer to a community 

service organization. 

Page 15 GAO-07-259 Reserve Employment Matters
employed. If the reservist is employed, the reporting instruction also asks 

for the employer’s name and address, date of employment, occupation 

code, and whether the reservist is self-employed. According to DOD 

policy, this employment reporting is to be accomplished when a member 

affiliates with the reserves, either through DOD’s Defense Manpower Data 

Center’s Guard-Reserve Employer Web site or through their reserve 

component, which then forwards the employment information to DOD on 

a weekly basis. The Army National Guard, Air Force Reserve, Air National 

Guard, and Marine Corps Reserve members input their data in the Defense 

Manpower Data Center’s Guard-Reserve Employer Web site. The Navy 

Reserve, Coast Guard Reserve, and Army Reserve members first enter 

their employment data into their personnel systems and then the 

components forward the information to the Defense Manpower Data 

Center. We have included details as of August 2006 on the civilian 

employment status reported by reservists in the Selected Reserve from 

DOD’s civilian employment information program in appendix II and on the 

profiles of reported employers of reservists in the Selected Reserve from 

DOD’s civilian employment information program in appendix III. 

The department has established a 95 percent reporting compliance goal 

for the Selected Reserve and a 75 percent compliance goal for the 

Individual Ready Reserve and Inactive National Guard. Prior to 2004, DOD 

had limited success in obtaining employer-related data from the reserve 

components. However, the percentage of Ready Reservists in compliance 

with employment-related reporting requirements has increased from about 

60 percent in August 2005 to about 77 percent in August 2006. DOD 

statistics show an overall compliance rate of 91 percent for the Selected 

Reserve and 30 percent for the Individual Ready Reserve and Inactive 

National Guard with good addresses as of August 2006. Table 2 illustrates 

the employment reporting compliance rates and strength numbers for 

Selected Reserve members as well as the Individual Ready Reserve and 

the Inactive National Guard in each of the seven reserve components and

DOD. 

Page 16 GAO-07-259 Reserve Employment Matters
Table 2: Reserve Population and Percent of Compliance Achieved Toward Civilian Employment Reporting Goals by DOD and 

the Reserve Components, August 2006 

Reserve components

Percent of component 

compliance achieved

toward DOD’s 95% goal 

for Selected Reserve

Selected

Reserve 

population

Percent of component compliance

achieved toward DOD’s 75% goal 

for Individual Ready Reserve and

Inactive National Guard

population 

Individual Ready 

Reserve and Inactive 

National Guard

population

Army National Guard 93% 302,538 95% 1,927

Army Reserve 97 165,518 24 58,606

Navy Reserve 89 55,885 45 56,940

Marine Corps Reserve 71 33,819 25 58,664

Air National Guard 85 90,265 a a

Air Force Reserve 85 71,339 23 38,545

Coast Guard Reserve 78 7,922 13 4,284

DOD total 91% 727,286 30% 218,966

Source: DOD. 

a

The Air National Guard does not have any Inactive National Guard or Individual Ready Reserve 

members.

As table 2 shows, compliance rates vary widely among the different 

reserve components, and few have met the established reporting goals. 

The Army National Guard, which accounts for 32 percent of all members 

of the reserve components, has met the Inactive National Guard reporting 

goal and has nearly met the Selected Reserve goal, and the Army Reserve, 

which accounts for an additional 26 percent of all reservists, has met the 

Selected Reserve reporting goal. The other reserve components have not

met either of DOD’s established compliance goals. The compliance rates 

for the Individual Ready Reserve and Inactive National Guard are 

substantially lower for the most part than they are for the Selected 

Reserve. Selected Reservists in some reserve components such as the 

Army Reserve and Air Force Reserve have established certain checks to 

capture their employment information. For example, the Army’s Human 

Resources Command call center has an automatic pop-up screen which 

identifies soldiers with missing employer data when they call in for 

assistance. According to a Command official, if a soldier has not reported 

his or her employment information, he or she is automatically routed to 

the Communications Hub Office to get this employment data entered 

before obtaining assistance with other matters. Career Managers have the 

same pop-up screen if the soldier is able to bypass the main call line, so 

the manager can acquire and enter employment data if a soldier has not 

reported that information. Further, Air Force’s online personnel system 

has similar reminders to prompt airmen about this employment data. 

Page 17 GAO-07-259 Reserve Employment Matters
Although the Army Reserve and Army National Guard have met some of 

the reporting goals for the Selected Reserve and the Individual Ready

Reserve and Inactive National Guard, other reserve components have not. 

DOD does not have specific time frames for reserve components to 

achieve their reporting goals, and has not directed the service components 

to take actions to assure compliance. According to the DOD official 

responsible for managing the employment information database, the 

services’ civilian employment reporting requirements are relatively new 

and while the consequences for noncompliance are defined, the official

was not aware of any enforcement actions that reserve components have 

taken at this time. The Under Secretary of Defense for Personnel and 

Readiness mandated the collection of employer information in a March 

2003 memorandum. According to the memorandum, a member of the 

Ready Reserve who refuses to provide the information or who knowingly 

provides false information may be subject to administrative action or 

punishment under the Uniformed Code of Military Justice. However, 

reserve component officials we interviewed indicated that they were not 

aware of situations where the department had imposed any punishment or 

administrative action for members failing to report employment-related 

information. DOD acknowledges a need to obtain additional information 

on members of the Individual Ready Reserve and Inactive National Guard,

which, as of August 2006, comprised approximately one-quarter of the 

Ready Reserve, with over 218,000 members. However, DOD has not placed 

emphasis on collecting employer information for these reservists. The 

Office of the Assistance Secretary of Defense for Reserve Affairs 

acknowledged that it has concentrated its efforts on obtaining

employment information for members of the Selected Reserves, especially

the Army Reserve and Army National Guard, which are the larger part of 

the Ready Reserve and are more frequently deployed. According to a DOD 

official, compliance is more difficult with regard to the Individual Ready

Reserve and Inactive National Guard, because the reserve components 

face challenges in locating these members. 

In recent years, we have issued a number of reports highlighting concerns 

regarding the availability of Individual Ready Reservist contact 

Page 18 GAO-07-259 Reserve Employment Matters
information.27 Specifically, in April 2003, we reported that many of the 

Individual Ready Reserve members were not available for mobilization 

because the services did not have valid contact information (addresses or 

phone numbers) for these individuals. At that time, we recommended that

the Secretary of Defense direct the service secretaries to develop and use 

results-oriented performance metrics to guide service efforts to gain and 

maintain improved information on Individual Ready Reserve members and 

review and update their Individual Ready Reserve policies. Also, in 

September 2004, we recommended that DOD should gather better 

information about its reserve component forces. Additionally, in 

September 2006, we reported that the time needed to identify, locate, and 

contact members of the Army’s Individual Ready Reserve would be a 

significant drawback for meeting future requirements. Without better 

employment information, DOD’s ability to conduct employer outreach and

make mobilization decisions that might affect first responders and 

communities is limited. 

Some Reserve 

Employment Data May 

Not Be Current 

Some of reported employer data in DOD’s employer database may not 

reflect current employment since the services have not established a 

formal mechanism to encourage reservists to keep this information up to 

date. Although reservists are required to update their employment 

information when changes occur, the extent to which this update is 

occurring and the extent to which DOD’s employer data include current 

employer information is unknown. Information obtained during our site 

visits to Reserve and National Guard units raised doubts about the 

currency of reported employment data. We held a total of 17 group 

discussions with over 100 reservists—which were stratified to include 

senior officers, junior officers, senior enlisted, and junior enlisted 

members—to discuss employer reporting and USERRA issues. A common 

theme that emerged from these discussions was that reservists generally 

were aware of the DOD requirement to report employer information and 

had at some point reported their employment status, but were not aware 

of the requirement to update their employer information when they 

 27GAO, Military Personnel: DOD Needs to Address Long-term Reserve Force Availability 

and Related Mobilization and Demobilization Issues, GAO-04-1031 (Washington, D.C.:

Sept. 15, 2004); GAO, Force Structure: DOD Needs to Integrate Data into Its Force 

Identification Process and Examine Options to Meet Requirements for High-Demand

Support Forces, GAO-06-962 (Washington, D.C.: Sept. 5, 2006); GAO, Military Personnel: 

DOD Actions Needed to Improve the Efficiency of Mobilizations for Reserve Forces, 

GAO-03-921 (Washington, D.C.: Aug.. 21, 2003). 

Page 19 GAO-07-259 Reserve Employment Matters
changed employers. After our initial site visits, we discussed the issue of 

current employer data with the DOD official responsible for managing the 

employer database. The official confirmed that DOD policy requires 

reservists to update their employer information when changes occur, but 

DOD does not have a formal mechanism in place to encourage reservists 

to do so. 

While not a formal review process, some reserve components such as the 

Army Reserve and Air Force Reserve indicated they have a tool in place 

that prompts their members to review and update employment 

information and other personnel data yearly on the month of their 

enlistment anniversary. Further, reservists in these components are 

reminded to update their employer information when accessing their 

online personnel or human resources system. The Office of the Assistant 

Secretary of Defense for Reserve Affairs is considering revising its 

employment reporting instruction to require annual reviews and updates 

of reported employer information, but DOD and the services do not 

currently have a formal review mechanism in place to encourage reservists

to review employment-related data on a recurring basis. 

Even if DOD and the services meet established civilian employment 

reporting goals, it means little if the employer data are not current. 

Without current data, DOD’s ability to determine which reserve members 

to activate, including those employed in civilian positions related to health

care and law enforcement that are essential to maintaining national health

and safety, is limited. The extent to which reservists’ employer data are 

not current also affects DOD’s ability to conduct employer outreach. 

Current Data Verification 

Process Is Not Adequate 

for Some Civilian 

Employers 

Although DOD has taken steps to verify the accuracy of reservist-reported 

employment data, its process is not adequate for verifying some civilian 

employers, including small businesses that employ less than 50 people. 

The department has a particular interest in obtaining information on small 

businesses that employ reservists and self-employed reservists because of

the potential impact that mobilizations may have on small business and 

self-employed reservists. The impact of reservists’ mobilizations on 

businesses depends upon the position or function performed by the 

reservist employed. Although large and small businesses are both affected 

by mobilizations, the loss of a single employee from a small business is 

more likely to have an immediate and significant impact on the business. 

The department currently relies on Dun and Bradstreet to verify and 

supplement employer data submitted by reserve members. Dun and 

Page 20 GAO-07-259 Reserve Employment Matters
Bradstreet maintains a comprehensive global business database, 

consisting of over 107 million companies. Its database contains data 

elements on each of those businesses that range from basic identification 

to value-added business intelligence information. Basic data identification

elements include items such as company name, physical address, mailing 

address, and phone number. Value-added business intelligence includes 

information such as number of employees, and standard industrial codes. 

DOD has been unable to verify employer information for approximately 24 

percent of reservists (108,125 of 453,596) reporting full-time or part-time 

civilian employment as of August 2006. Dun and Bradstreet have been 

unable to verify this information for DOD because either the employer 

information did not match its data or some industry details were missing. 

DOD and Dun and Bradstreet officials acknowledge the difficulties 

involved in capturing data on some employers, especially those that are

small businesses. A challenge to collecting small business data involves 

employing mechanisms for collecting accurate information on new 

businesses and for tracking changes to the businesses, such as location 

and mergers. Verification of employer information for small business 

represents a particular challenge since small businesses in general such as 

doctors, lawyers, accountants, and carpenters are far less likely to be 

captured in the verification process than large corporations. 

Figure 2 illustrates the breakout of the 181,438 selected reservists 

employed in the private sector by business size whose reported 

employment has been verified as private sector related. For this group, the 

data show that 35 percent (63,634 of 181,438) were employed by small 

businesses with less than 50 employees. 

Page 21 GAO-07-259 Reserve Employment Matters
Figure 2: Number and Percent of Selected Reservists Reporting Work in the Private

Sector by Business Size (Number of Employees) 

Note: The unmatched category includes employer information that was partially verified but 

incomplete information was available to determine company size.

Table 3 shows a breakdown of these 63,634 Selected Reserve members 

with verified employer information who are employed in small businesses 

for each reserve component by number and percent. The Army National 

Guard and the Army Reserve have the greatest number and percent of 

members who are employed in small business when compared to the DOD 

total. 

Page 22 GAO-07-259 Reserve Employment Matters
Table 3: Number and Percent of Selected Reservists Reporting Employment by

Small Businesses with Less than 50 Employees by Reserve Component and Total 

Reserve 

component 

Number of 

reservists 

employed in small 

business a

Percent of

component’s

reservists employed

in small business 

Percent of

component’s

reservists employed

in small business 

compared to total 

Army National 

Guard 23,698 37% 37%

Air National 

Guard 5,769 31 9

Army Reserve 19,172 37 30

Air Force 

Reserve 4,968 27 8

Navy Reserve 7,799 33 12

Marine Corps 

Reserve 1,784 38 3

Coast Guard 

Reserve 444 40 1

Total 63,634 35% 100% b

Source: DOD’s Civilian Employment Information Database. 

a

For purposes of this report, small businesses are identified as businesses having 50 employees or 

less. 

b

Percent may not add due to rounding. 

As of August 2006, about 5 percent of employed reservists, 23,871 of the 

453,596, reported they were self-employed. As shown in figure 3, the 

largest number of self-employed reservists report working in occupations

related to management, construction and extraction, and healthcare 

practitioners and technical occupations. 

Page 23 GAO-07-259 Reserve Employment Matters
Figure 3: Occupations with the Greatest Amount of 23,871 Self-Employed 

Reservists Reporting

0 2,000 4,000 6,000 8,000 10,000

Occupations

Amount

Source: DOD’s Civilian Employment Information Database.

3,635

3,082

2,261

2,046

1,762

1,474

1,205

8,406 All other

Managment

Construction

and extraction

Healthcare

practionioners

and technical

Sales

and related

Installation,

maintenance,

and repair

Business

and financial

operations

Legal

According to Office of the Assistant Secretary of Defense for Reserve 

Affairs officials, they are currently exploring alternative resources for 

verifying small business employer information. DOD has begun 

discussions with the Census Bureau to obtain aggregate information on 

small business addresses. Additionally, DOD is in the process of working 

with the Small Business Administration in an attempt to develop strategies

to improve the collection and management of employer information on 

small businesses. 

Page 24 GAO-07-259 Reserve Employment Matters
The four federal agencies responsible for assisting reservists with 

USERRA complaints—DOD’s Employer Support of the Guard and 

Reserve, the Department of Labor’s Veterans’ Employment and Training 

Service, the Department of Justice, and the Office of Special Counsel—

track and address these complaints; however, Congress does not have the

comprehensive information necessary to allow for complete oversight of 

all reservist USERRA complaints. The Secretary of Labor is required by 

law to provide an annual report to Congress on the number of formal 

USERRA complaints reviewed by the agency and referred to the Attorney 

General or Office of Special Counsel. However this report does not include 

informal complaints filed with DOD’s Employer Support of the Guard and 

Reserve, which account for approximately 80 percent of all reservists’ 

reemployment complaints. In addition, DOD lacks complete information 

on all reservists’ USERRA complaints filed because it does not have 

visibility over complaints reported directly to the Veterans’ Employment 

and Training Service or the Office of Special Counsel. Finally, the 

information we obtained on the more than 16,000 total informal and 

formal complaints revealed that the nature of these USERRA complaints 

could not be uniformly categorized to completely reveal trends in the 

types of problems that reservists returning from deployment experience 

because of differences in complaint categories. 

The complaint data that the Department of Labor reported to Congress for 

fiscal years 2004 and 2005 did not include 80 percent, or 9,975 of the 12,421 

total informal and formal USERRA complaints filed by reservists during 

that period. The Secretary of Labor is required by law to provide an annual 

report that includes information on the number of cases it reviewed, the 

nature and status of each case reported, as well as the number of cases 

referred to the Attorney General or the Office of Special Counsel.28

Relatively few formal complaints reach the Department of Justice and the

Office of Special Counsel each year since the formal process begins at 

Veterans’ Employment and Training Service, and complaints may be 

resolved there and not forwarded to the Department of Justice or the 

Congress and DOD 

Do Not Have the 

Comprehensive 

Information 

Necessary to Allow 

for Oversight of 

Reservists’ USERRA 

Complaints 

Data in the Department of 

Labor’s Report to Congress 

Represent Only 20 Percent 

of Complaints Filed 

 28Section 4332 of Title 38, U.S.C. requires that the Secretary of Labor, in consultation with 

the Attorney General and the Special Counsel, prepare an annual report to Congress. The

law previously specified that the report was to be transmitted by February 1, 1996, and 

annually thereafter through 2000. The act was amended in 2004 to require a report by

February 1, 2005, and annually thereafter. 

Page 25 GAO-07-259 Reserve Employment Matters
Office of Special Counsel.29 Nonetheless, the Secretary of Labor is required 

by law to include information on the number of complaints filed by the 

Attorney General, as well as an indication of whether there are any 

apparent patterns of violation and recommendations for administrative or 

legislative action that the Secretary, the Attorney General, or the Special 

Counsel considers necessary for the effective implementation of USERRA. 

In additional to filing formal complaints with these agencies, complainants

can also file informal USERRA complaints with DOD’s Employer Support 

of the Guard and Reserve. However, Congress is not informed about these 

informal complaints because USERRA does not require the Secretary of 

Labor to include informal complaint information from DOD in its annual 

report to Congress. Further, DOD’s Employer Support of the Guard and 

Reserve does not provide information to Congress, in any form, on the 

number and nature of informal USERRA complaints that it receives each 

year. The informal complaints filed with DOD’s Employer Support are 

similar in nature and no less significant than the formal complaints filed 

with the Department of Labor or other agencies. For example, in fiscal 

year 2006, discrimination for military obligations was the top complaint 

filed with both DOD’s Employer Support and the Veterans’ Employment 

and Training Service. By contacting DOD’s Employer Support, reservists’ 

USERRA issues may be resolved more expeditiously, as the organization 

tries to resolve pay-related USERRA complaints in 7 days and other 

USERRA complaints within 14 days. According to the agency data, more 

than 95 percent of informal complaints reported to DOD’s Employer 

Support are resolved without being forwarded to the Department of Labor 

for action. 

According to a ranking DOD official, based on projections from the May 

2004 Defense Manpower Data Center survey, of the reservists who sought 

assistance for a USERRA issue, between 53 and 79 percent sought 

assistance from DOD’s Employer Support, but only between 15 and 37 

percent sought help from the Veterans’ Employment and Training Service. 

As shown in table 4, reservists filed a total of 9,975 informal USERRA 

complaints with DOD’s Employer Support in fiscal years 2004 and 2005.

These numbers represent USERRA complaints that reservists filed and do 

not include the many calls that DOD’s Employer Support receives for basic 

 29As noted earlier, the demonstration project will affect the number of complaints filed at 

the Office of Special Counsel since it has received complaints directly from certain 

servicemembers since the project began.

Page 26 GAO-07-259 Reserve Employment Matters
information.30 However, the Secretary of Labor’s annual report to Congress 

included only the 2,446 formal USERRA complaints filed for that same 

time period. 

Table 4: Informal and Formal Complaints Reservists Filed with DOD’s Employer Support of the Guard and Reserve, the 

Veterans’ Employment and Training Service, and the Office of Special Counsel,a Fiscal Years 2004 and 2005 

Fiscal 

year 

Informal complaints 

reported to DOD’s

employer support b

Formal complaints reported 

to Veterans’ Employment

and Training Service

Formal complaints 

reported to the Office of 

Special Counsel 

Grand total of informal and 

formal complaints

2004 5,839 1,280 c 7,119

2005 4,136 1,054 112 5,302

Total 9,975 2,334 112 12,421

Source: GAO based on the Department of Labor’s USERRA Annual Report to Congress, fiscal years 2004 and 2005 and data from

DOD’s Employer Support. 

a

The data reported by the Office of Special Counsel in the Department of Labor’s Annual Report to 

Congress includes information on all USERRA complaints filed with the agency under the 

demonstration project, including reservists, veterans (including disabled veterans), and others, 

including members of the Commissioned Corps of the U.S. Public Health Service, former active duty

personnel who alleged USERRA rights violations based on their enlistment in the Armed Forces, 

persons who filed both on the bases of their prior military service (i.e., veteran status) and present 

military service obligation (i.e., Guard or Reserve duty), persons whose connection with a uniformed 

service was unknown, and persons who could not establish membership in a uniformed service. 

b

The complaint data from DOD’s Employer Support are based on the number of cases closed for 

fiscal years 2004 and 2005. The complaint data from the Veterans’ Employment and Training Service

and the Office of Special Counsel are based on the number of cases opened for that same time 

period. 

c

The Office of Special Counsel demonstration project did not begin until February 8, 2005; therefore, 

there were no formal complaints filed with the Office of Special Counsel included in the Department of

Labor’s Annual Report to Congress in fiscal year 2004. 

Without data from DOD’s Employer Support of the Guard and Reserve, 

Congress has limited visibility over the full range of USERRA issues that 

reservists face following deployment. Further, without these data, 

Congress may lack the information for its oversight of reserve employment 

matters needed to take actions that may be necessary to more effectively

implement USERRA. 

 30DOD’s Employer Support also receives calls that it refers to as “information only.” The

calls pertain to any issue that is not a potential USERRA violation. 

Page 27 GAO-07-259 Reserve Employment Matters
DOD’s Employer Support does not have information on, and therefore 

cannot track, reservists’ USERRA complaints reported directly to the 

Veterans’ Employment and Training Service and the Office of Special

Counsel. As noted in the Standards for Internal Control in the Federal 

Government,31 management should ensure there are adequate means of 

obtaining information from others that may have a significant impact on 

the agency achieving its goals. However, despite recent enhancements to 

the Veterans’ Employment and Training Service database which were 

designed to increase interagency coordination in managing USERRA case 

information, the Department of Labor’s system allows each agency

visibility over only those complaints that originate within their agency. 

DOD Lacks Complete 

Information on All 

USERRA Complaints 

Following a recommendation in our 2005 report,32 the Veterans’ 

Employment and Training Service implemented an enhancement to its 

USERRA Information Management System in October 2006 to enable the 

four USERRA coordinating agencies to electronically transfer case 

information between agencies. The database enhancement allows DOD’s 

Employer Support of the Guard and Reserve, the Veterans’ Employment

and Training Service, the Department of Justice, and the Office of Special 

Counsel to access and update the status of cases using the internet.33 In 

cases where a reservist files a formal complaint with the Veterans’ 

Employment and Training Service and identifies DOD’s Employer Support 

involvement in the case, the enhanced database will send an automated email message to DOD’s Employer Support. The e-mail will contain a link 

by which DOD’s Employer Support can enter case information on the 

claimant. In addition, DOD’s Employer Support will receive an e-mail 

notification each time the status of cases originating with it changes. An 

automatic e-mail notification will also be sent to the Department of Justice 

or the Office of Special Counsel when a reservist decides to refer a case to

either agency. Additionally, the Office of Special Counsel’s USERRA unit 

chief will receive an automated e-mail notification when the Veterans’ 

 31GAO/AIMD-00-21.3.1. 

32GAO, Military Personnel: Federal Management of Servicemember Employment Rights 

Can be Further Improved, GAO-06-60 (Washington, D.C.: Oct. 19, 2005). 

33All information related to Office of Special Counsel demonstration project cases will be 

stored in a separate dataset throughout the entire life cycle of all demonstration project 

cases. 

Page 28 GAO-07-259 Reserve Employment Matters
Employment and Training Service opens, refers, or resolves a federal 

sector claim opened during the term of the demonstration project.34

Officials from each agency are able to see USERRA complaint information 

such as whether a case is open or closed, which agency is currently 

addressing it, and how long it took to resolve, and they are able to produce 

a report containing aggregate USERRA complaint data on the cases over 

which they have jurisdiction. However, only the Veterans’ Employment 

and Training Service has visibility over the entire USERRA complaint 

process for all USERRA cases from submission—with the Veterans’ 

Employment and Training Service—to resolution. Even though DOD’s 

Employer Support of the Guard and Reserve has coresponsibility with the 

Veterans’ Employment and Training Service for overseeing 

implementation of USERRA,35 the system does not make aggregate 

reservist USERRA complaint data available to DOD’s Employer Support.

DOD’s Employer Support has visibility over only those complaints that 

originated with its office, provided the complainant notified the Veterans’ 

Employment and Training Service that he or she had previously notified

DOD’s Employer Support. Likewise, the Department of Justice and Office 

of Special Counsel have visibility over only those complaints that have 

been reported or referred to them, but the number of reservists’ USERRA 

complaints that these two agencies address are relatively few in 

comparison to the total. 

According to Veterans’ Employment and Training Service officials, when 

the enhancement was being developed, the Department of Labor’s 

Solicitor’s Office determined that, due to the sensitive nature of the 

information that could be contained in the database, each agency’s access 

would be limited to information about which it has a need to know. 

However, just as it is important for the Veterans’ Employment and 

Training Service to have visibility over all USERRA cases, it is also 

important for DOD’s Employer Support of the Guard and Reserve to have 

aggregate information on all reserve USERRA cases, excluding those 

details of a sensitive nature, even if those cases did not originate with their 

Employer Support organization. DOD’s Employer Support also has direct 

 34The demonstration project runs from February 8, 2005, through September 30, 2007. 

According to Veterans’ Employment and Training Service officials, the Office of Special 

Counsel will begin entering case information into the system for fiscal year 2007 through 

the end of the pilot project. 

35 38 U.S.C. § 4333. 

Page 29 GAO-07-259 Reserve Employment Matters
responsibility for the reservists who are experiencing USERRA issues. 

Without knowledge of the USERRA complaints filed with the Veterans’ 

Employment and Training Service and the Office of Special Counsel, DOD 

does not have complete information on the reemployment issues that its 

reservists have experienced. 

USERRA Complaints 

Could Not Be Uniformly 

Categorized to Reveal 

Trends on the Types of 

USERRA Issues 

Experienced by Reservists 

The information we obtained on the more than 16,000 total informal 

complaints filed with DOD’s Employer Support and formal complaints 

filed with the Department of Labor’s Veterans’ Employment and Training 

Service and the Office of Special Counsel between fiscal years 2004 and 

2006 showed that the nature of those complaints could not be uniformly 

categorized in order to reveal trends on the kinds of problems that 

returning reservists experience because the four USERRA agencies 

responsible for addressing complaints use different complaint categories 

to characterize these issues.36 In line with the Standards for Internal 

Control in the Federal Government,

37 it is essential that different sets of 

related data be compared and assessed so that analyses of the 

relationships can be made and corrective actions taken, if necessary. 

However, because the databases of the four agencies responsible for 

USERRA were created for different purposes, the data collected are not 

conducive to a meaningful comparison. In particular, the two agencies that 

see the highest volume of cases, DOD’s Employer Support of the Guard 

and Reserve and the Department of Labor’s Veterans’ Employment and 

Training Service, use different complaint categories to identify reservists’ 

USERRA complaints, such as being refused job reinstatement, denied an 

appropriate pay rate, or being denied vacation time. 

The databases of the USERRA coordinating agencies were created for 

different purposes. For example, Veterans’ Employment and Training 

Service developed its database to track USERRA complaints to fulfill its 

reporting requirement to Congress.38 However, DOD’s Employer Support 

USERRA Coordinating 

Agencies’ Databases Collect 

Different Data for Different 

Purposes 

 36As noted earlier, this total includes informal complaints filed by reservists with DOD’s

Employer Support between fiscal years 2004 and 2006, and the formal complaints reported

by the Department of Labor’s Veterans’ Employment and Training Service in its fiscal year 

2004 and 2005 reports to Congress. The fiscal year 2006 report was not available within the

time frames of our review. In addition, the Department of Justice is assigned enforcement 

responsibilities under USERRA, but the Department of Justice is not authorized to receive

USERRA complaints directly from servicemembers. 

37GAO/AIMD-00-21.3.1.

3838 U.S.C. § 4332. 

Page 30 GAO-07-259 Reserve Employment Matters
began tracking USERRA complaint information in a centralized database 

as a result of our 2002 finding39 that it did not have an accurate count of 

complaints handled by ombudsmen. Because these two agencies created 

their databases for different purposes, they do not have uniform complaint 

categories. For example, for DOD’s Employer Support there are several

issues that fall under the category of pay: 

• employee paid less than others in comparable positions; 

• employee not given a raise; 

• pay of salaried employee reduced because of military absence; and 

• employee did not receive paid military leave in accordance 

with employer policy. 

For the Veterans’ Employment and Training Service, the pay rate 

complaint category addresses the following: 

• failure to meet the requirement that the reservist be restored to a 

position with the same rate of pay as would have been paid had the 

reservist not been absent for military service. 

Unlike DOD’s Employer Support, this category does not include 

complaints regarding paid military leave. 

While the complaint categories used by the Department of Justice and the

Office of Special Counsel to categorize USERRA complaints are also 

different from DOD’s Employer Support and the Department of Labor, the 

number of complaints that these two agencies address are few in 

comparison to the total. In addition, complaints do not originate with the 

Department of Justice; they are referred from the Department of Labor. 

Therefore the complaints contained in the Department of Justice’s 

database would already be contained in the Department of Labor’s system. 

Further, although the Office of Special Counsel has directly received

certain Federal USERRA complaints under the demonstration project,40 to 

 39GAO-02-608. This report found that reporting by ombudsmen had been sporadic and some

field offices had gone an entire year without reporting any complaints at all. 

40The demonstration project was authorized by the Veterans Benefits Improvement Act of 

2004, Pub. L. No. 108-454, § 204 (2004). 

Page 31 GAO-07-259 Reserve Employment Matters
date it has received few, relative to the total number of complaints filed 

(federal and nonfederal).41

The complaint categories used by DOD’s Employer Support and the 

Department of Labor’s Veterans’ Employment and Training Service, which 

handle the largest number of USERRA complaints, are not completely 

compatible. As a result of the incompatibility of the complaint categories, 

neither DOD nor the Veterans’ Employment and Training Service have yet 

to consolidate information to identify complete trends on the nature of 

reservists’ USERRA complaints that may not be readily apparent. As 

reservists continue to demobilize and the possibility of a USERRA 

complaint exists, this trend information on USERRA issues may assist 

Congress and DOD in making informed decisions concerning USERRA.

The four agencies—DOD’s Employer Support, the Department of Labor’s 

Veterans’ Employment and Training Service, the Office of Special Counsel, 

and the Department of Justice—responsible for addressing and tracking 

USERRA claims cannot systematically record and track disability-related 

employment complaints. In essence, these agencies do not record 

disability-related complaints using consistent and compatible complaint 

categories or distinguish disability-related complaints from other types of

complaints for tracking and reporting purposes.42 Therefore, the nearly 200

disability-related USERRA claims filed with DOD’s Employer Support and 

the Department of Labor’s Veterans’ Employment and Training Service 

from fiscal year 2004 through fiscal year 2006 may be understated. Further, 

DOD may only have knowledge of those claims initially filed with 

Employer Support. DOD may not be aware of 43 formal disability-related 

complaints if they were filed directly with the Veterans’ Employment and 

Training Service. Without tracking disabled reservists’ employment 

complaints, DOD may not be completely aware of the effect that 

disabilities incurred by reservists while on active duty have on their 

Disabled Reserve 

Members’ USERRA 

Complaints Are Not 

Systematically 

Recorded or Tracked 

 41According to the Department of Labor’s most recent report to Congress, fiscal year 2005, 

the Office of Special Counsel opened 112 federal cases under the demonstration project,

which began February 8, 2005. In this report, the Department of Labor reported opening

1,241 (federal and nonfederal) new cases. This number includes reservists, military 

veterans, and persons with no prior or current military membership. 

42The Office of Special Counsel recently modified its database to permit the identification 

of eight additional allegation categories, including Injured Reservist-Discrimination, Injured

Reservist-Reemployment, Injured Guardsman-Discrimination, and Injured GuardsmanReemployment. 

Page 32 GAO-07-259 Reserve Employment Matters
reemployment, and what additional assistance may be needed to help 

transition this population back into the workforce. 

Agencies Do Not Use 

Consistent, Compatible 

Categories to Track 

Disability-Related 

Complaints 

Specifically, agency officials indicated that all four agencies involved in

tracking and addressing USERRA disability-related complaints, such as an 

employer’s failure to provide reasonable accommodation, like any other 

type of USERRA complaint; however, they do not record disability-related

complaints using consistent and compatible categories to allow 

information analysis and reporting. For example, DOD’s Employer 

Support classifies USERRA disability-related complaints within three 

categories including medical benefits, job placement, and time limits for 

reemployment, while the Department of Labor’s Veterans’ Employment 

and Training Service uses one category, reasonable accommodation and 

retraining for disabled, to classify USERRA disability-related complaints. 

The Department of Justice classifies and tracks USERRA complaints, 

including those that may be disability related, within 11 categories such as 

assignment, benefit, discharge, reemployment, and termination; and the 

Office of Special Counsel uses four categories—reprisal, discrimination, 

disabled veteran discrimination, and reemployment rights—to record 

USERRA complaints, including those that may be disability related. Table 

5 shows the complaint classifications used by DOD’s Employer Support, 

the Department of Labor’s Veterans’ Employment and Training Service, 

the Department of Justice, and the Office of Special Counsel to record 

disability-related complaints. 

Page 33 GAO-07-259 Reserve Employment Matters
Table 5: Type of USERRA Disability-Related Complaint Classifications by Agency 

How disability-related claim may be classified

by agencies 

DOD’s Employer 

Support

Veterans’ 

Employment and 

Training Service

Department of 

Justice

Office of 

Special 

Counsel

Medical benefits: Employee incurred/ aggravated 

medical disability during service 

X

Job placement: Employer does not accommodate 

returning disabled employee 

X

Time limits for reemployment: Employee

incurred/aggravated disability during service

X

Reasonable accommodations/retraining for 

disabled 

X

Disabled veteran discrimination X

Reprisal X

Reemployment X X

Discrimination X X

Assignment X

Benefit X

Discharge X

Discipline X

Hiring X

Promotion X

Retaliation X

Termination X

Miscellaneous X

Source: GAO analysis of agency reporting codes. 

Agencies Do Not Have a 

System to Distinguish 

Disability-Related 

Complaints from Other 

Types of Complaints 

While the categories depicted above may include disability-related cases, 

other disability-related complaints may not be classified as such. Some 

claimants may not have identified their disability when filing a case or the 

case worker may not have classified the disability as the primary 

complaint. For example, DOD Employer Support customer service 

personnel and ombudsmen do not specifically inquire if cases are related 

to a disability. If the complainant indicates that the case involves a 

disability, DOD’s Employer Support will classify it accordingly. Otherwise, 

the case may be categorized within other DOD Employer Support 

classifications as determined by the case worker taking the complaint. 

In addition, a single USERRA complaint may involve a number of different 

issues or violations that complicates case classification and categorization

Page 34 GAO-07-259 Reserve Employment Matters
by the agencies. As a result, disability-related complaints may not be 

distinguishable from any other types of complaints for tracking and 

reporting purposes. During fiscal year 2003 through fiscal year 2005, for 

example, the Office of Special Counsel filed three discrimination cases and 

one reemployment rights case with the Merit System Protection Board. 

One of the cases, initially classified as a discrimination case, was based on 

a USERRA disability-related violation that involved a U.S. Postal Service 

employee who had been called to active military service. As a Postal 

Service employee, this person’s job entailed the lifting of heavy packages. 

While on active duty, he suffered a shoulder injury that prevented him 

from doing his job when he returned to his civilian employer. According to

the complaint, the Postal Service terminated the reservist without making 

any effort to find him a suitable alternative position. The Office of Special

Counsel later alleged violations of both the antidiscrimination provisions 

and reemployment rights provisions of USERRA when a suit was filed. 

Additionally, the Department of Justice routinely classifies USERRA 

complaints involving multiple violations within all applicable categories. 

No distinction is made concerning the relevance of one violation 

compared to another within the various categories. The Department of 

Labor officials also indicated that to ensure that all disability-related cases 

were properly categorized, virtually all case notes and case files would 

have to be reviewed. 

DOD Does Not Have 

Complete Visibility over 

Disability-Related 

Employment Complaints 

Our analysis of DOD’s Employer Support and the Department of Labor’s 

Veterans’ Employment and Training Service disability-related complaint 

categories indicated that about 200 disability-related USERRA claims were 

filed with them from fiscal year 2004 through fiscal year 2006. We believe,

however, this number may be understated because DOD Employer 

Support may have classified undisclosed disability-related complaints in 

other categories and the Department of Labor’s Veterans’ Employment and 

Training Service may have classified disability-related employment 

complaints that included other USERRA violations in categories other 

than the specific categories we reviewed and analyzed. Consequently, 

DOD may not be fully aware of the actual number of disability-related 

complaints filed by its reservists or the specific employment issues being 

experienced by reservists seeking reemployment. Without such 

information, DOD may find it difficult to assess the needs of its disabled 

reservists experiencing reemployment issues and provide whatever 

additional assistance may be needed to help transition this population 

back into the workforce. 

Page 35 GAO-07-259 Reserve Employment Matters
From fiscal years 2003 to 2006, DOD identified nearly 12,000 reservists as 

disabled. These disabilities include physical impairments as well mental 

distress received while on active duty. GAO has previously reported on the 

risk of servicemembers returning from combat developing post-traumatic 

stress disorder.43 Mental Health experts estimate that the intensity of 

warfare in Iraq and Afghanistan could cause more than 15 percent of 

servicemembers returning from these conflicts to develop post-traumatic 

stress disorder. As long as current operations continue, servicemember 

will place themselves at risk for becoming injured or potentially being 

mentally traumatized, which could require DOD to make a greater 

investment in offering assistance to these individuals. 

Without better employer information, DOD cannot manage activities such 

as conducting outreach to help employers understand their USERRA 

responsibilities or know if its decisions are adversely affecting 

communities by activating a large number of its first responders or 

healthcare professionals, or disproportionately impacting small business 

employers. 

Conclusions 

Currently, the Department of Labor’s annual report to Congress includes 

information about only formal USERRA complaints, which accounted for 

about 20 percent of all reservist complaints filed in fiscal year 2005. With 

the Department of Labor reporting only reservists’ formal USERRA 

complaint data, Congress may not have enough information for its 

continued oversight of reserve employment matters, and to help determine 

whether any revisions to USERRA are warranted based on the nature of 

both formal and informal complaints. Currently, DOD lacks complete 

information on all informal and formal USERRA complaints filed by its 

reserve members. Thus, DOD may be unable to determine the full extent 

of USERRA issues that its reservists are facing. Lastly, as long as the 

agencies responsible for addressing complaints continue to classify 

USERRA complaints differently in their databases, consolidation of this 

information to identify complete trends may prove to be difficult, limiting 

DOD’s knowledge of the nature of reservists’ USERRA issues and the 

 43GAO, Post-Traumatic Stress Disorder: DOD Needs to Identify the Factors Its Providers 

Use to Make Mental Health Evaluation Referrals for Servicemembers, GAO-06-397 

(Washington, D.C.: May 11, 2006); and GAO, VA Health Care: VA Should Expedite the

Implementation of Recommendations Needed to Improve Post-Traumatic Stress Disorder 

Services, GAO-05-287 (Washington, D.C.: Feb. 14, 2005). 

Page 36 GAO-07-259 Reserve Employment Matters
ability to take action on the most common complaints to better assist 

reservists upon their return from deployment. 

Without systematic tracking of disabled reservists’ reemployment 

complaints, Congress and DOD may lack information about the actual 

number of disability-related reemployment complaints filed by this group 

of reservists after their demobilization and recovery. Further, without 

visibility over disability-related complaints, DOD may find it difficult to 

assess the reemployment challenges that its disabled reservists experience 

upon their return to civilian employment and whether additional 

assistance may be needed to help transition this population back into the 

workforce. Having the ability to identify disability-related reemployment 

complaints will become more crucial in the future as reservists continue to

face combat and expose themselves to serious injury in operations in Iraq 

and Afghanistan. 

To gain a full perspective of the number and nature of USERRA 

complaints filed by reservists in gaining reemployment upon returning 

from active duty, Congress should consider amending 38 U.S.C. §4332 to 

require the Department of Labor to include data from DOD’s Employer 

Support of the Guard and Reserve in its annual report to Congress. 

To improve the reporting of reserve employment information and to 

enable the components to meet the reporting compliance rate of 95 

percent for the Selected Reserve and 75 percent for the Individual Ready

Reserve and Inactive National Guard, we recommend that the Secretary of 

Defense direct the Office of the Assistant Secretary of Defense for Reserve 

Affairs to establish specific time frames for reservists to report their 

employment data, set specific time frames for reserve components to 

achieve the established compliance reporting goals, and direct the service 

components to take action to assure reporting compliance. 

Matter for 

Congressional 

Consideration 

Recommendations for 

Executive Action 

To encourage reservists to provide DOD with current employer data, we 

recommend that the Secretary of Defense direct the Office of Assistant 

Secretary for Reserve Affairs to update DODI 7730.54, Enclosure 10 on 

civilian employment-related information reporting to instruct all military 

departments to establish a formal review mechanism that would require all

reservists to review and update at least annually their reported 

employment-related information. 

Page 37 GAO-07-259 Reserve Employment Matters
To provide DOD with increased visibility over reserve USERRA 

complaints, we recommend that the Secretary of Labor provide aggregate

USERRA complaint data to DOD’s Employer Support for the Guard and 

Reserve. 

To allow for complete analysis of trends in reporting reservist USERRA 

complaints, we recommend that the Secretary of Defense and Secretary of

Labor adopt uniform complaint categories in the future that will allow 

aggregate trend analysis to be performed across the databases. 

To provide the agencies responsible for addressing USERRA complaints 

with better information about disability-related employment complaints, 

we recommend that the Secretary of Labor direct the Veterans’ 

Employment and Training Service to develop a system for recording and 

tracking disability-related USERRA complaints reported by reservists, 

such as establishing consistent and compatible complaint categories and 

distinguishing disability-related complaints from other types of 

complaints. The Veterans’ Employment and Training Service should then

share this system with the other agencies responsible for addressing 

USERRA complaints. 

In written comments on a draft of this report, the Department of Defense 

(DOD) and the Department of Labor generally concurred with our findings 

and recommendations that were directly applicable to their respective

agencies. The Office of Special Counsel also provided written comments 

indicating that it concurred with our recommendations and found the 

report to be comprehensive and accurate as it related to the

responsibilities of the Office of Special Counsel. Also, the Department of 

Labor and the Office of Special Counsel concurred with our matter for 

congressional consideration that Congress should consider amending 38 

U.S.C. §4332 to require the Department of Labor to include complaint data 

from DOD’s Employer Support of the Guard and Reserve in its annual 

report to Congress. The Department of Justice reviewed a draft of this 

report and had no comments. Each agency’s comments are printed in its 

entirety in appendices IV through VI. The agencies also provided technical 

comments, which we incorporated as appropriate. 

Agencies’ Comments 

and Our Evaluation 

In DOD’s written comments, the department partially concurred with our 

recommendation that the Secretary of Defense direct the Office of the

Assistant Secretary of Defense for Reserve Affairs to establish specific 

time frames for reservists to report their employment data and direct the 

service components to take action to assure compliance. DOD cited 

Page 38 GAO-07-259 Reserve Employment Matters
Instruction 7730.54 issued on August 6, 2004, which directed the services 

to obtain a 95 percent compliance rate for Civilian Employment 

Information for the Selected Reserve and to obtain a 75 percent 

compliance rate for the Individual Ready Reserve and Inactive National 

Guard with good addresses, effective the date of the issuance of the 

Instruction (August 6, 2004). DOD also noted that the Under Secretary of 

Defense for Personnel and Readiness issued a memorandum to the Service 

Secretaries on November 19, 2004, requesting their assistance in collecting 

reservists’ employment information by February 1, 2005. Based on the 

instruction and the Under Secretary’s memorandum, DOD commented 

that specific time frames are in place for the compliance reporting of 

civilian employment information. We disagree. As our report points out, in 

August 2005—6 months after the February 2005 reporting time frame—not 

all reservists had complied with the reporting requirement. In August 2005, 

the overall number of Ready Reservists reporting employer information to 

DOD was about 60 percent. This number improved to about 77 percent 

overall in August 2006, but still short of DOD’s goals. We continue to 

believe that DOD needs to establish a new deadline by which reservists 

must report their employer information to DOD. In addition to establishing 

new reporting requirements for individual reservists, we noted throughout 

our draft report that DOD has not set specific time frames for reserve 

components to achieve the established compliance reporting goals. We 

believe it is essential that DOD establish such time frames. In its written 

comments, DOD agreed to issue a memorandum directing the reserve 

components to meet the full compliance reporting for members of the 

Selected Reserve. However, DOD did not state that the memorandum 

would include a specific deadline by which reserve components would 

have to achieve full compliance reporting. Also, DOD stated that the 

memorandum would address only the goals for the Selected Reserve. We

also believe this memorandum should direct the reserve components to 

meet full compliance reporting for the Individual Ready Reserve and

Inactive National Guard members, as well. We have modified our 

recommendation to state that the Assistant Secretary of Defense for 

Reserve Affairs should set specific time frames for reserve components to 

achieve the established compliance reporting goals. 

DOD concurred with our recommendation that the Secretary of Defense 

direct the Office of the Assistant Secretary for Reserve Affairs to update 

DOD instruction 7730.54 Enclosure 10 on civilian employment-related 

information reporting to instruct all military departments to establish a 

formal review mechanism that would require all reservists to review and 

update their reported employment-related information at least annually. 

DOD stated that it has drafted a revision to DOD instruction 7730.54 that

Page 39 GAO-07-259 Reserve Employment Matters
requires an annual review of civilian employment information. According 

to DOD, while this revision is being processed for reissuance, the Army 

National Guard has recommended consideration of adding a pop-up 

screen to its existing Web site to prompt service members to validate

employment data and capture the validation date. Navy Operational 

Support Centers will also ensure an annual verification of employment 

data and record changes in this information when notified. 

DOD also concurred with our recommendation that the Secretary of 

Defense and the Secretary of Labor adopt uniform complaint categories in 

the future that will allow aggregate trend analysis to be performed across 

the databases. DOD noted that National Committee for Employer Support 

of the Guard and Reserve staff members are working with Department of 

Labor staff to facilitate uniformity of complaint categories which will 

allow for like data points in each department’s database. 

In the Department of Labor’s written comments, the department 

concurred with our recommendation that the Secretary of Labor make 

aggregate USERRA complaint data available to the DOD’s Employer 

Support for the Guard and Reserve. It noted that it has provided such 

information to Reserve Affairs, the National Guard Bureau, and the 

Defense Manpower Data Center. The Department of Labor has agreed to

start providing aggregate information to DOD’s Employer Support of the 

Guard and Reserve on a quarterly basis. 

The Department of Labor also concurred with our recommendation that 

the Secretary of Defense and the Secretary of Labor adopt uniform 

complaint categories in the future that will allow aggregate trend analysis 

to be performed across the databases. It noted that it is working with 

DOD’s Employer Support of the Guard and Reserve to determine the 

appropriate means to achieve that goal. The Department of Labor is 

enhancing its USERRA information management system in cooperation 

with DOD’s Employer Support, the Department of Justice, and the Office 

of Special Counsel to effect our recommendation. The Department of 

Labor stated that these changes will improve case handling and aid in 

compiling accurate and meaningful case data, including pertinent data 

involving USERRA disability cases from DOD’s Employer Support and the 

Department of Labor’s Veterans’ Employment and Training Service. 

The Department of Labor also concurred with our recommendation that 

the Secretary of Labor direct the Veterans’ Employment and Training 

Service to develop a system for recording and tracking disability-related 

complaints reported by reservists, such as establishing consistent and 

Page 40 GAO-07-259 Reserve Employment Matters
compatible complaint categories and distinguishing disability-related 

complaints from other types of complaints. The Veterans’ Employment 

and Training Service should then share this system with the other agencies

responsible for addressing USERRA complaints. It noted that its statutory 

authority to collect such disability-related data is limited to USERRA 

complaints. It also noted that to avoid ambiguity with its recommendation, 

GAO may want to clarify that the recommendation covers only the 

identification of USERRA complaints where the servicemember’s 

disability is a factor in the case rather than a requirement to capture all

disability complaints that reservists might raise. In response to the 

Department of Labor’s comments, we revised this recommendation to 

make clear that we are not asking the Department of Labor to collect

information that extends beyond its USERRA statutory authority. 

Finally, the Department of Labor’s comments state that our report does 

not adequately differentiate between “informal inquiries” and “formal 

complaints,” and that we categorize all inquiries as complaints, regardless 

of content. The Department of Labor further states that our report’s lack 

of differentiation unnecessarily inflates the total number of USERRA 

complaints by 9,975. We disagree for the following reasons. First, we do 

not use the term “informal inquiries” anywhere in our report. We use the 

terms “informal complaints” and “formal complaints.” Second, we took 

great care throughout the report to differentiate our use of the terms 

“informal” and “formal” complaints. For example, our report’s 

introduction section very carefully stipulates that reservists have both 

“informal” and “formal” options to report their USERRA complaints. We 

note that DOD’s Employer Support program and the military chain of 

command are “informal” sources available to reservists, and clearly 

stipulate, both in narrative and in a footnote, that complaints filed with 

DOD’s Employer Support are “informal complaints,” while complaints 

filed with the Departments of Labor and Justice, and the Office of Special

Counsel are “formal” complaints. Regarding Labor’s assertion that our 

report categorizes all inquiries as complaints, we disagree. We were 

meticulous in our requests for complaint data and very thorough in our 

analyses of these data to ensure that inquiries for information and/or 

requests for technical assistance were excluded from our complaint totals. 

Moreover, Labor is incorrect in its assertion that the 9,975 informal 

complaints filed by reservists with DOD’s Employer Support represent 

“inquiries” and serve to unnecessarily inflate the total number of USERRA 

complaints. We were very careful to request from DOD’s Employer 

Support only bona fide USERRA complaints, and not inquiries for 

information. Upon receipt of the data, we again confirmed with DOD that 

the data represented only valid USERRA complaints. Our draft report, 

Page 41 GAO-07-259 Reserve Employment Matters
both in the narrative and a footnote, clearly stipulated that the 9,975 

complaints pertained only to complaints related to USERRA violations, 

and not inquiries. 

We are sending copies of this report to the Secretary of Defense; the 

Secretary of Labor; the Attorney General; the Special Counsel; the 

Secretaries of the Army, the Navy, and the Air Force; the Commandant of 

the Marine Corps; the Chairman of the Joint Chiefs of staff; the Director, 

Homeland Security; the Director, Office of Management and Budget; and 

other interested congressional committees. We will also make copies 

available to others upon request. In addition, the report will be available at 

no charge on the GAO Web site at www.gao.gov.

If you or your staff have any questions about this report, please contact me 

at (202) 512-5559 or stewartd@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix VII. 

Sincerely yours, 

Derek B. Stewart 

Director, Defense Capabilities and Management 

Page 42 GAO-07-259 Reserve Employment Matters
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

To assess the status of the Department of Defense’s (DOD) efforts to 

capture data on employers of reservists, we gathered and analyzed data

provided by the Office of the Assistant Secretary of Defense for Reserve 

Affairs from DOD’s civilian employer information database as of August 

2006. Specifically, we obtained employment-related data from the civilian 

employment information file for about 758,000 selected reservists, 

including categories such as those who were employed full or part time, a 

student, a civilian volunteer, or not currently employed. The 

approximately 70,000 reservists who were listed as Active Guard and 

Reserve members were not included in the analysis. For reservists who 

reported full- or part-time employment, we obtained and analyzed 

information to identify reservists employed in private, public, or education

sector jobs. For private sector employment we obtained and analyzed 

information on the type and size of business by number of employees. We

also obtained and analyzed data on the number of reservists who reported 

self-employment and the business occupations involved. We analyzed 

similar information to identify profiles of the employers of reservists. To 

identify progress DOD had made in capturing employer information, we 

reviewed agency policies, procedures, and processes for reserve 

employment reporting, and obtained and analyzed data on the percent of 

reporting compliance DOD and its reserve components had achieved 

toward the established goals of 95 percent employer reporting for 

members of the Selected Reserve and 75 percent employer reporting for 

members of the Individual Ready Reserve and Inactive National Guard. We 

also interviewed officials from the Office of the Assistant Secretary of 

Defense for Reserve Affairs and Reserve Components about employer 

reporting, data verification, and ongoing initiatives. In addition, we 

interviewed members of reserve units about their employer reporting 

during site visits. 

To assess agencies’ tracking and addressing of USERRA complaints, 

including those related to disabilities incurred while on active duty, we 

obtained information on all of the more than 16,000 total USERRA 

complaints filed as informal complaints with DOD’s Employer Support of 

the Guard and Reserve and as formal complaints with the Department of 

Labor’s Veterans’ Employment and Training Service, and the Office of 

Special Counsel.1

 1

As previously noted, the Department of Justice is not authorized to receive USERRA 

complaints directly from servicemembers. It represents individuals involving private sector 

or state or local government complaints that it receives from the Department of Labor. 

Page 43 GAO-07-259 Reserve Employment Matters
Appendix I: Scope and Methodology 

We obtained and reviewed the results of the Department of Labor’s 

Assistant Secretary for Veterans’ Employment and Training Service 

USERRA Annual Report to Congress for fiscal years 2004 and 2005. Our 

testing indicated that the data used to produce the report would be 

sufficiently reliable for our purposes. In addition, we also obtained data

on the number of informal complaints reported to DOD’s Employer 

Support between fiscal years 2004 and 2006 to determine the number and 

types of complaints that were being filed by reservists. We also analyzed

data from the Department of Justice and the Office of Special Counsel to 

determine the number and type of USERRA referrals that were being 

handled by the agency. In addition, we reviewed data from the Office of 

Special Counsel on the number and type of cases handled under the 

demonstration project. We also followed up on our 2005 report to 

determine whether the Secretary of Defense, the Secretary of Labor, the 

Attorney General, and the Special Counsel developed procedures or 

systems to allow the electronic transfer of information between offices. In

addition, to assess how efficiently and effectively DOD’s Employer 

Support, Department of Labor, Department of Justice, and Office of 

Special Counsel addressed servicemember complaints, we obtained and

analyzed information about complaint-processing practices, including 

applicable law, guidance, and operations manuals. We also obtained and

reviewed the memorandums of understanding between the Department of 

Labor and DOD’s Employer Support, the Department of Justice, the Office 

of Special Counsel, and the Department of Veterans Affairs. We discussed 

the agency data related to USERRA complaints and methods used to 

collect these data with responsible agency officials from the following 

offices: 

• Department of Defense, Employer Support of the Guard and Reserve, 

Arlington, Va.; 

• Department of Defense, Office of the Assistant Secretary of Defense for 

Reserve Affairs, Arlington, Va.; 

• Defense Manpower Data Center, Arlington, Va. and Seaside, Calif.; 

• Department of Labor, Washington, D.C.; 

• Department of Labor, Veterans Employment and Training Service, 

Regional Office in Atlanta, Ga.; 

• Department of Labor, Office of the Solicitor, Washington, D.C.; 

Regional Office in Atlanta, Ga.; 

Page 44 GAO-07-259 Reserve Employment Matters
Appendix I: Scope and Methodology 

• Department of Justice, Washington, D.C.; 

• Office of Special Counsel, Washington, D.C.; 

• U.S. Coast Guard Headquarters, Washington, D.C.; and 

• Department of Veterans Affairs, Washington, D.C. 

In addition, we also contacted the following commands to obtain 

information on component-specific USERRA and disability-related surveys

and initiatives: U.S. Army Reserve Command, Fort McPherson, Ga.; and

National Guard Bureau, Arlington, Va. 

We obtained and analyzed similar information from these agencies for the

disability-related claims. Specifically, we imported data from the Veterans’ 

Employment and Training Service USERRA Information Management 

System into an Access database and queried the data to look at the 

number of formal disability-related complaints handled by the Department 

of Labor between fiscal years 2004 and 2006. We also obtained data on the 

number of informal disability-related complaints reported to DOD’s 

Employer Support between fiscal years 2004 and 2006. In addition, we 

reviewed data on reservists wounded in action in Iraq and Afghanistan 

from October 7, 2001, through October 14, 2006, and the number of 

reservists classified as disabled by DOD between fiscal years 2003 and 

2006. We also obtained information about the Army Wounded Warrior 

Program. 

We also discussed reserve employment issues with 8 of DOD’s Employer 

Support Ombudsmen from around the country. The 8 ombudsmen were 

selected from a larger sample of 30 Ombudsmen drawn by DOD’s 

Employer Support based on our criteria, which included the Ombudsmen

who had (1) handled the most cases and/or (2) been ombudsman the 

longest, and (3) are geographically dispersed. In addition, we held a total 

of 17 group discussions with over 100 reservists, which were stratified to 

include senior officers, junior officers, and senior enlisted and junior 

enlisted members from units that were previously activated to discuss 

their knowledge of USERRA and the rights it provides them, reporting of 

employment information, and any USERRA issues they may have 

experienced as a result of their activation. These discussions included 

members from an Army National Guard unit, the 276th Engineering 

Battalion, at A.P. Hill, Va.; an Army Reserve unit, the 328th Combat 

Support Hospital, at Ft. Douglas, Utah; an Air Force Reserve unit, the 

Page 45 GAO-07-259 Reserve Employment Matters
Appendix I: Scope and Methodology 

446th Airlift Wing, at McChord AFB, Wash.; and a Marine Corps Reserve 

unit, Headquarters Battery, 5th Battalion, 14th Regiment 4th Marine 

Division at Seal Beach, Calif. 

Also, we interviewed officials from the Army Emergency Relief 

organization and the Air Force Aid Society on the type of assistance 

provided to reservists awaiting resolution of a USERRA complaint. We 

also contacted representatives from the following organizations to obtain 

information on potential USERRA studies, and their views on reserve 

USERRA issues, including those related to disabilities incurred while on 

active duty:

• Veterans of Foreign Wars of the United States, Washington, D.C.; 

• Paralyzed Veterans of America, Washington, D.C.; 

• The American Legion, Washington, D.C.; 

• Vietnam Veterans of America, Silver Spring, Md.; 

• Reserve Officers Association, Washington, D.C.; and 

• Military Officers Association of America, Alexandria, Va. 

We assessed the reliability of reported reservist employer data from DOD’s 

civilian employment information database, and reserve USERRA 

complaint data from DOD’s Employer Support, Department of Labor’s 

Veterans’ Employment and Training Service, Department of Justice, and 

the Office of Special Counsel. We used a variety of methods to accomplish 

this assessment including electronic testing of the Department of Labor’s

USERRA data and interviewing officials regarding their data quality 

protocols. As a result of this, we determined that data from the 

Department of Justice and the Office of Special Counsel were sufficiently 

reliable for our purposes. In addition, our limited testing of the 

Department of Labor’s data also showed that the data were sufficiently 

reliable for purposes of this report. However, an ongoing review within 

our agency continues to assess the Department of Labor’s USERRA data. 

DOD’s civilian employment information and DOD’ Employer Support 

databases were found to be of undeterminable reliability. The validity of 

the employer data depends, on (1) the accuracy of the reservists’ entries 

and (2) the verification algorithm used by the private company that DOD 

has an arrangement with for providing business-related details. Some data 

Page 46 GAO-07-259 Reserve Employment Matters
Appendix I: Scope and Methodology 

entry checks occur at the Reserve unit level and at the Defense Manpower 

Data Center. The private company’s business name-matching algorithm is 

multistepped and was not subject to our evaluation. Data that are matched 

are assigned a confidence code of 1 to 10 with 7-10 considered as high 

confidence of the match, 5-6 considered as medium, and 4 considered as 

low and suggesting the likelihood of inaccurate automated matching. 

Somewhat more than 9 percent of the matches fall into the last category,

and almost 20 percent of the entries in the recently reported set of 

reservists found no matches at all. In addition, small businesses in general

such as doctors, lawyers, accountants, and carpenters are far less likely to

be captured in the matching process. As such, we report the numbers from 

the employer database for suggestive purposes, but they should not be 

regarded as definitive. 

For DOD’s Employer Support data, we did not directly test the complaint 

data, but the Oracle integrity constraints serve some data reliability 

purposes. However, after data are entered there are no agency spot 

checks, systematic reviews, or exception reports. As such, the reliability of

these data is undetermined and we use these data to simply characterize 

the complaints and to suggest the ratios among those complaints. 

We conducted our work from April 2006 through December 2006 in 

accordance with generally accepted government auditing standards. 

Page 47 GAO-07-259 Reserve Employment Matters
Appendix II: Profiles on Reservists’ Civilian Appendix II: Profiles on Reservists’ Civilian Employment 

Employment 

Tables 6 through 10 provide civilian employment details for approximately 

758,000 Selected Reservists, excluding the Active Guard and Reserve. The

data represent information reported by reservists from the Department of 

Defense’s (DOD) civilian employment database as of August 2006. 

According to a DOD official, all employer information has not been fully 

verified by DOD, however the data are the best information available on 

reservists’ civilian employment. Appendix III provides information on the 

employers of reservists. Table 6 shows the reservists’ civilian employment 

status by full-time, part-time, civilian volunteer, student, not employed, 

and unknown categories by DOD total and by each reserve component. 

Table 6: Reported Civilian Employment Status of Selected Reservists by DOD and its Reserve Components 

Employment 

status DOD total

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

Full-time 418,917 150,928 104,864 3,392 59,721 47,298 12,586 40,128

Part-time 34,679 15,226 6,241 238 5,236 2,973 2,739 2,026

Civilian volunteer 988 334 287 10 148 148 26 35

Student 61,798 33,717 16,134 347 5,775 2,944 1,343 1,538

Not employed 129,720 75,218 34,020 1,913 3,440 4,535 6,777 3,817

Unknown a 112,080 40,655 13,355 2,052 17,986 14,253 13,804 9,975

Total 758,182 316,078 174,901 7,952 92,306 72,151 37,275 57,519

Source: DOD’s Civilian Employment Information Database. 

a

Unknown includes cases where reservists have not filled out the civilian employment information 

profile. 

Table 7 shows the breakout for the 453,596 reservists reporting full-time or 

part-time civilian employment by the sector they are employed including 

private sector, state and local government, education, and federal 

government for DOD and its reserve components. It also includes 

information as unknown for those cases where a reservist has reported 

employment information but either the information did not match with 

verification checks or a standard industrial classification code was 

missing. 

Page 48 GAO-07-259 Reserve Employment Matters
Appendix II: Profiles on Reservists’ Civilian 

Employment 

Table 7: Selected Reservists Reporting Full-Time or Part-Time Civilian Employment by Employment Sector for DOD and Its 

Reserve Components

Employment sector DOD total 

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air

 National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

Private sector 181,438 63,866 51,612 1,120 18,339 18,226 4,724 23,551

State and local

government 48,794 21,446 11,229 659 6,323 4,228 797 4,112

Education 13,374 4,169 4,523 123 1,494 1,285 216 1,564

Unknowna 108,125 44,621 26,192 920 11,511 8,760 8,770 7,351

Federal government 101,865 32,052 17,549 808 27,290 17,772 818 5,576

Total 453,596 166,154 111,105 3,630 64,957 50,271 15,325 42,154

Source: DOD’s Civilian Employment Information Database. 

a

Unknown includes cases where a match was not found, or the employer match was found and the 

standard industrial classification code was missing to identify the employment sector.

Table 8 shows the number of selected reservists who have reported fulltime or part-time civilian employment in the private sector by employer 

size defined by its number of employees for DOD and each reserve 

component. These data also include an unknown category where 

employer information was partially verified but incomplete information 

was available to determine company size. 

Page 49 GAO-07-259 Reserve Employment Matters
Appendix II: Profiles on Reservists’ Civilian 

Employment 

Table 8: Number of Selected Reservists Reporting Full-Time or Part-Time Private Civilian Employment by Employer Size for 

DOD and Its Reserve Components 

Private 

employer size DOD total 

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

1-4 29,071 10,316 9,301 207 2,480 2,273 809 3,685

5-9 10,407 3,845 3,123 75 1,021 774 307 1,262

10-19 10,347 4,144 2,840 71 948 831 287 1,226

20-49 13,809 5,393 3,908 91 1,320 1090 381 1,626

50-99 9,141 3,559 2,528 44 840 792 253 1,125

100-249 10,189 3,863 2,805 64 988 889 271 1,309

250-499 6,710 2,558 1,858 40 601 629 147 877

500-1,000 6,474 2,323 1,881 29 663 650 144 784

1000-9999 26,087 8,487 7,582 158 2,755 2,982 514 3,609

10,000-99,999 33,764 10,558 9,004 197 3,916 4,483 836 4,770

100,000+ 19,917 6,665 5,275 108 2,284 2,336 630 2,619

Unknown a 5,522 2,155 1,507 36 523 497 145 659

Total 181,438 63,866 51,612 1,120 18,339 18,226 4,724 23,551

Source: DOD’s Civilian Employment Information Database. 

a

Unknown includes cases where there was incomplete information on the company size. 

Table 9 shows the 23,871 DOD reservists reporting self-employment by the 

occupation groups in which they work. There are also some unknown 

amounts in this chart for where incomplete information was available on 

the business to determine the occupation of the self-employed reservist. 

Page 50 GAO-07-259 Reserve Employment Matters
Appendix II: Profiles on Reservists’ Civilian 

Employment 

Table 9: Number of Selected Reservists in DOD Reporting Self-Employment by

Occupation Code and Description

Self-employed 

occupation code Occupation group description DOD total

11 Management 3,635

13 Business and financial operations 1,474

15 Computer and mathematical 649

17 Architecture and engineering 617

19 Life, physical, and social science 207

21 Community and social services 564

23 Legal 1,205

25 Education, training, and library 450

27 Arts, design, entertainment, sports, and media 794

29 Healthcare practitioners and technical 2,261

31 Healthcare support 232

33 Protective service 1,169

35 Food preparation and serving related 269

37 Building and grounds cleaning and maintenance 466

39 Personal care and service 454

41 Sales and related 2,046

43 Office and administrative support 463

45 Farming, fishing, and forestry 446

47 Construction and extraction 3,082

49 Installation, maintenance, and repair 1,762

51 Production 578

53 Transportation and material moving 967

Unknowna81

Total 23,871

Source: DOD’s Civilian Employment Information Database. 

a

Unknown includes cases where there was incomplete information on these businesses. 

Table 10 provides details on the number of selected reservists in each 

reserve component reporting self-employment by occupation code. 

Page 51 GAO-07-259 Reserve Employment Matters
Appendix II: Profiles on Reservists’ Civilian 

Employment 

Table 10: Number of Selected Reservists in each Reserve Component Reporting Self-Employment by Standard Occupation

Code and Description

Standard

occupation 

code

Occupation group 

description

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

11 Management 700 1,312 55 314 362 65 827

13 Business and

financial operations 261 699 16 126 145 64 163

15 Computer and

mathematical 130 270 1 78 70 28 72

17 Architecture and

engineering 97 258 7 54 65 17 119

19 Life, physical, and 

social science 20 131 0 16 14 7 19

21 Community and

social services 87 283 5 61 91 4 33

23 Legal 192 736 4 63 80 39 91

25 Education, training,

and library 97 220 1 56 47 9 20

27 Arts, design,

entertainment, 

sports, and media 106 488 5 71 54 26 44

29 Healthcare

practitioners and 

technical 245 1,244 2 262 322 4 182

31 Healthcare support 66 83 1 30 41 5 6

33 Protective service 470 312 7 169 139 45 27

35 Food preparation

and serving related 95 80 2 41 30 18 3

37 Building and

grounds cleaning 

and maintenance 165 196 4 44 25 22 10

39 Personal care and

service 79 265 1 39 53 7 10

41 Sales and related 442 946 6 233 243 109 67

43 Office and

administrative 

support 114 209 2 55 55 16 12

45 Farming, fishing,

and forestry 169 155 1 45 37 27 12

47 Construction and

extraction 923 1,505 18 224 184 155 73

Page 52 GAO-07-259 Reserve Employment Matters
Appendix II: Profiles on Reservists’ Civilian 

Employment 

Standard

occupation 

code

Occupation group 

description

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

49 Installation,

maintenance, and 

repair 582 482 8 383 217 61 29

51 Production 162 251 7 71 58 16 13

53 Transportation and

material moving 335 243 6 161 163 31 28

Unknowna4 12 1 4 0 44 16

Total 5,541 10,380 160 2,600 2,495 819 1,876

Source: DOD’s Civilian Employment Information Database. 

a

Unknown includes cases where there was incomplete information on these businesses. 

Page 53 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of Appendix III: Profiles on Employers of Reservists 

Reservists 

Tables 11 through 16 provide details on the employers of reservists in the 

Selected Reserve from Department of Defense’s (DOD) civilian 

employment information program. All employer data are as of August 

2006. Although all employer information has not been fully verified by 

DOD, it considers the data to be the best information available on 

employers of reservists. The data represent unique employers of 

reservists; thus a company that employs more than one reservist is 

counted only once. Table 11 shows a breakout of the 113,478 civilian 

employers of reservists employed full-time or part-time by federal and 

nonfederal sectors for DOD and its reserve components. Information on 

reservists’ civilian employment is contained in appendix II. 

Table 11: Reported Employers of Reservists by Employment Sector, for DOD and Its Reserve Components 

All employers DOD 

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

Private sector 88,452 36,912 30,346 983 10,631 10,040 3,543 14,540

State & local government 9,801 4,597 3,802 385 1,616 1,413 506 1,776

Education 5,796 2,516 2,526 116 1,036 860 189 1,110

Unknowna9,356 7,695 156 7 2,190 1,289 3 65

Federal agencies 73 47 62 25 38 48 30 52

Total 113,478 51,767 36,892 1,516 15,511 13,650 4,271 17,543

Source: DOD’s Civilian Employment Information Database. 

a

Unknown means that the reported employer information matched, but no valid standard industrial 

classification code was available to identify employment sector. 

Table 12 shows the details for the 88,452 reported employers of reservists 

in the private sector by employer size defined by number of employees by

DOD and each reserve component. 

Page 54 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

Table 12: Reported Private Employers of Reservists by Number of Employees by DOD and Its Reserve Components 

Employer size by

number of 

employees DOD 

Army 

 National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air

 National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

1-4 24,958 9,166 8,146 203 2,205 2,107 791 3,446

5-9 9,283 3,554 2,826 73 898 728 303 1,210

10-19 9,055 3,628 2,564 68 881 785 283 1,194

20-49 11,933 4,891 3,440 91 1,224 1,015 373 1,530

50-99 7,590 3,120 2,262 42 798 723 243 1,042

100-249 7,715 3,241 2,426 63 872 824 268 1,195

250-499 4,233 1,932 1,506 39 505 538 140 741

500-1,000 3,107 1,463 1,344 30 512 509 133 656

1000-9999 5,130 3,118 3,400 144 1,482 1,572 421 2,043

10,000-99,999 876 733 870 148 626 643 358 754

100,000+ 67 62 74 40 61 67 68 76

Unknowna4,505 2,004 1,488 42 567 529 162 653

Total 88,452 36,912 30,346 983 10,631 10,040 3,543 14,540

Source: DOD’s Civilian Employment Information Database. 

a

Unknown means those cases where there was incomplete information on the company size. 

Table 13 shows the 88,452 private employers reported by DOD’s reservists 

by two-digit standard industrial classification code. In this depiction, the 

most employers of reservists are in heath services, business services, and

special trade contractor areas. 

Table 13: Reported Number of Private Employers of DOD’s Reservists by Two-Digit 

Standard Industrial Classification Code

SIC 

1987 U.S. Standard industrial classification

 (SIC) code description

Number of 

employers

01 Agricultural production- crops 441

02 Agricultural production- livestock 243

07 Agricultural services 1,084

08 Forestry 67

09 Fishing, hunting, and trapping 15

10 Metal mining 18

12 Coal mining 38

13 Oil and gas extraction 240

14 Nonmetallic minerals, except fuels 92

Page 55 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

SIC 

1987 U.S. Standard industrial classification

 (SIC) code description

Number of 

employers

15 General building contractors 2,671

16 Heavy construction contractors 887

17 Special trade contractors 5,795

20 Food and kindred products 609

21 Tobacco manufactures 6

22 Textile mill products 148

23 Apparel and other textile products 152

24 Lumber and wood products 623

25 Furniture and fixtures 252

26 Paper and allied products 259

27 Printing and publishing 755

28 Chemicals and allied products 491

29 Petroleum and coal products 84

30 Rubber and miscellaneous plastics products 538

31 Leather and leather products 19

32 Stone, clay, glass, and concrete products 429

33 Primary metal industries 366

34 Fabricated metal products 1,069

35 Industrial machinery and equipment 1,422

36 Electrical and electronic equipment 690

37 Transportation equipment 626

38 Instruments and related products 472

39 Miscellaneous manufacturing industries 370

40 Railroad transportation 86

41 Local and interurban passenger transit 775

42 Motor freight transportation and warehousing 1,767

43 U.S. Postal Service 1

44 Water transportation 165

45 Transportation by air 503

46 Pipelines, except natural gas 8

47 Transportation services 610

48 Communications 952

49 Electric, gas, and sanitary services 790

50 Wholesale trade—durable goods 3,713

51 Wholesale trade—nondurable goods 1,675

52 Building materials, hardware, garden supply, & mobile home 872

Page 56 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

SIC 

1987 U.S. Standard industrial classification

 (SIC) code description

Number of 

employers

53 General merchandise stores 252

54 Food stores 1,303

55 Automotive dealers and gasoline service stations 2,783

56 Apparel and accessory stores 476

57 Furniture, home furnishings and equipment stores 1,157

58 Eating and drinking places 5,273

59 Miscellaneous retail 2,701

60 Depository institutions 1,052

61 Nondepository credit institutions 643

62 Security, commodity brokers, and services 323

63 Insurance carriers 361

64 Insurance agents, brokers, and service 1,036

65 Real estate 2,287

67 Holding and other investment offices 363

70 Hotels, rooming houses, camps, and other lodging places 979

72 Personal services 1,189

73 Business services 7,456

75 Automotive repair, services, and parking 1,773

76 Miscellaneous repair services 839

78 Motion pictures 251

79 Amusement and recreational services 1,532

80 Health services 8,569

81 Legal services 1,736

82 Educational services 0

83 Social services 2,548

84 Museums, art galleries, botanical & zoological gardens 122

86 Membership organizations 2,941

87 Engineering and management services 5,134

88 Private households 0

89 Miscellaneous services 485

Total 88,452

Source: DOD’s Civilian Employment Information Database. 

Table 14 shows the number of private employers reported by reservists by 

two-digit standard industrial classification code by reserve component. 

Page 57 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

Table 14: Reported Number of Private Employers of Reservists by Two-Digit Standard Industrial Classification Code by 

Reserve Component 

SIC 

1987 U.S. Standard

industrial 

classification code

(SIC) description

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

01 Agricultural productioncrops 237 117 5 38 18 7 32

02 Agricultural productionlivestock 148 58 0 11 16 5 20

07 Agricultural services 465 343 11 95 73 40 103

08 Forestry 32 16 3 8 5 1 8

09 Fishing, hunting, and 

trapping 9 2 0 1 0 1 2

10 Metal mining 14 4 0 5 1 1 4

12 Coal mining 23 15 0 7 3 1 1

13 Oil and gas extraction 145 72 2 24 18 21 28

14 Nonmetallic minerals, 

except fuels 52 29 0 9 11 1 9

15 General building

contractors 1,174 801 24 248 153 116 340

16 Heavy construction 

contractors 480 221 6 81 88 31 114

17 Special trade 

contractors 2,617 1588 54 556 375 228 756

20 Food and kindred 

products 322 241 3 98 70 38 117

21 Tobacco manufactures 3 5 0 0 2 0 1

22 Textile mill products 91 52 1 17 10 5 23

23 Apparel and other 

textile products 63 54 0 13 17 6 25

24 Lumber and wood 

products 383 179 5 46 44 14 71

25 Furniture and fixtures 137 83 3 33 27 10 37

26 Paper and allied 

products 140 109 4 37 38 14 51

27 Printing and publishing 321 271 9 78 86 27 149

28 Chemicals and allied 

products 246 204 14 96 93 29 138

29 Petroleum and coal 

products 29 33 0 17 16 3 21

Page 58 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

SIC 

1987 U.S. Standard

industrial 

classification code

(SIC) description

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

30 Rubber and 

miscellaneous plastics 

products 304 208 3 68 58 18 75

31 Leather and leather 

products 9 7 0 2 1 2 5

32 Stone, clay, glass, and 

concrete products 232 154 6 47 33 15 64

33 Primary metal industries 212 151 3 43 47 17 83

34 Fabricated metal 

products 566 355 5 131 90 49 171

35 Industrial machinery 

and equipment 670 441 19 206 177 64 285

36 Electrical and electronic 

equipment 271 259 11 133 127 41 213

37 Transportation 

equipment 360 227 18 109 112 34 135

38 Instruments and related

products 168 161 9 85 110 33 141

39 Miscellaneous 

manufacturing 

industries 157 118 2 37 40 15 58

40 Railroad transportation 46 31 2 20 11 6 15

41 Local and interurban

passenger transit 347 258 21 105 119 21 160

42 Motor freight 

transportation and 

warehousing 921 622 11 172 168 68 255

43 U.S. Postal Service 1 1 2 1 1 1 1

44 Water transportation 67 46 28 17 13 7 45

45 Transportation by air 180 121 12 176 167 40 150

46 Pipelines, except 

natural gas 6 4 1 3 2 1 2

47 Transportation services 232 227 4 86 73 16 97

48 Communications 320 326 16 214 133 67 215

49 Electric, gas, and 

sanitary services 399 293 21 165 128 33 220

50 Wholesale trade—

durable goods 1,534 1123 32 504 397 190 641

51 Wholesale trade—

nondurable goods 777 569 17 172 151 80 279

Page 59 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

SIC 

1987 U.S. Standard

industrial 

classification code

(SIC) description

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

52 Building materials, 

hardware, garden 

supply, & mobile home 473 216 10 78 53 41 87

53 General merchandise 

stores 128 91 7 48 40 23 44

54 Food stores 726 436 8 119 107 65 127

55 Automotive dealers and 

gasoline service

stations 1,372 827 38 270 201 130 297

56 Apparel and accessory 

stores 203 207 5 57 71 40 72

57 Furniture, home 

furnishings and

equipment stores 501 391 11 119 92 61 150

58 Eating and drinking 

places 2,901 1,723 28 429 294 223 366

59 Miscellaneous retail 1113 919 21 305 296 134 395

60 Depository institutions 414 398 22 185 155 46 213

61 Nondepository credit 

institutions 216 229 12 84 69 37 122

62 Security, commodity 

brokers, and services 107 122 7 49 51 20 88

63 Insurance carriers 149 174 13 82 86 16 107

64 Insurance agents, 

brokers, and service 326 393 6 121 118 38 170

65 Real estate 780 759 29 232 214 73 390

67 Holding and other 

investment offices 118 109 4 51 47 16 68

70 Hotels, rooming

houses, camps, and 

other lodging places 468 323 11 112 106 49 127

72 Personal services 466 418 7 113 97 34 148

73 Business services 2,758 2,642 87 879 963 340 1,399

75 Automotive repair, 

services, and parking 854 513 18 142 113 87 198

76 Miscellaneous repair 

services 339 240 7 103 75 34 140

78 Motion pictures 108 83 8 35 24 20 35

79 Amusement and 

recreational services 701 499 19 149 145 86 183

80 Health services 2,538 3,773 57 1,210 1,597 92 1,830

Page 60 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

SIC 

1987 U.S. Standard

industrial 

classification code

(SIC) description

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

81 Legal services 409 752 22 141 161 60 338

82 Educational services 0 0 0 0 0 0 0

83 Social services 990 947 27 276 294 46 349

84 Museums, art galleries, 

botanical & zoological 

gardens 43 45 4 11 14 2 15

86 Membership 

organizations 999 939 35 407 399 57 473

87 Engineering and

management services 1,625 1821 69 756 799 236 1,170

88 Private households 0 0 0 0 0 0 0

89 Miscellaneous services 177 158 4 54 37 20 79

Total 36,912 30,346 983 10,631 10,040 3,543 14,540

Source: DOD’s Civilian Employment Information Database. 

Table 15 shows the number of small private employers (with less than 50 

employees) reported by DOD’s reservists by two-digit standard industrial 

classification code. 

Table 15: Industries of Reported Small (Less than 50 Employees) Private Employers 

of DOD’s Reservists, by Two-Digit Standard Industrial Classification Code

SIC 

1987 U.S. Standard industrial classification 

(SIC) code description

Number of 

employers

01 Agricultural production- crops 389

02 Agricultural production- livestock 205

07 Agricultural services 983

08 Forestry 48

09 Fishing, hunting, and trapping 13

10 Metal mining 7

12 Coal mining 8

13 Oil and gas extraction 122

14 Nonmetallic minerals, except fuels 34

15 General building contractors 2,134

16 Heavy construction contractors 457

17 Special trade contractors 4,396

20 Food and kindred products 136

Page 61 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

SIC 

1987 U.S. Standard industrial classification 

(SIC) code description

Number of 

employers

21 Tobacco manufactures 0

22 Textile mill products 33

23 Apparel and other textile products 70

24 Lumber and wood products 276

25 Furniture and fixtures 90

26 Paper and allied products 51

27 Printing and publishing 347

28 Chemicals and allied products 100

29 Petroleum and coal products 23

30 Rubber and miscellaneous plastics products 115

31 Leather and leather products 7

32 Stone, clay, glass, and concrete products 130

33 Primary metal industries 76

34 Fabricated metal products 334

35 Industrial machinery and equipment 565

36 Electrical and electronic equipment 197

37 Transportation equipment 145

38 Instruments and related products 155

39 Miscellaneous manufacturing industries 231

40 Railroad transportation 29

41 Local and interurban passenger transit 295

42 Motor freight transportation and warehousing 882

43 U.S. Postal Service 0

44 Water transportation 65

45 Transportation by air 235

46 Pipelines, except natural gas 3

47 Transportation services 407

48 Communications 435

49 Electric, gas, and sanitary services 286

50 Wholesale trade—durable goods 1,961

51 Wholesale trade—nondurable goods 743

52 Building materials, hardware, garden supply, & mobile home 571

53 General merchandise stores 130

54 Food stores 770

55 Automotive dealers and gasoline service stations 1,413

56 Apparel and accessory stores 286

Page 62 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

SIC 

1987 U.S. Standard industrial classification 

(SIC) code description

Number of 

employers

57 Furniture, home furnishings and equipment stores 803

58 Eating and drinking places 2,572

59 Miscellaneous retail 1,972

60 Depository institutions 320

61 Nondepository credit institutions 383

62 Security, commodity brokers, and services 195

63 Insurance carriers 78

64 Insurance agents, brokers, and service 805

65 Real estate 1,590

67 Holding and other investment offices 257

70 Hotels, rooming houses, camps, and other lodging places 346

72 Personal services 973

73 Business services 4,833

75 Automotive repair, services, and parking 1,474

76 Miscellaneous repair services 654

78 Motion pictures 163

79 Amusement and recreational services 973

80 Health services 4,282

81 Legal services 1,236

82 Educational services 0

83 Social services 1,300

84 Museums, art galleries, botanical & zoological gardens 71

86 Membership organizations 2,291

87 Engineering and management services 2,963

88 Private households 0

89 Miscellaneous services 454

Total 51,376

Source: DOD’s Civilian Employment Information Database. 

Table 16 shows the number of reported small private employers (with less 

than 50 employees) of reservists by two-digit standard industrial 

classification code by reserve component. 

Page 63 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

Table 16: Reported Number of Private Employers of Reservists by Two-Digit Standard Industrial Classification Code and 

Reserve Component 

SIC 

1987 U.S. Standard

industrial 

classification code

(SIC) description

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

01 Agricultural productioncrops 204 102 2 33 16 5 30

02 Agricultural productionlivestock 121 45 0 9 14 4 13

07 Agricultural services 416 300 9 82 66 33 85

08 Forestry 24 10 1 6 2 1 5

09 Fishing, hunting, and 

trapping 8 2 0 1 0 0 2

10 Metal mining 4 1 0 1 0 0 1

12 Coal mining 5 3 0 1 0 0 0

13 Oil and gas extraction 67 27 0 11 7 5 8

14 Nonmetallic minerals, 

except fuels 18 8 0 1 2 1 4

15 General building

contractors 942 606 17 176 111 81 231

16 Heavy construction 

contractors 248 106 4 33 41 12 37

17 Special trade 

contractors 1,988 1,158 45 380 254 168 490

20 Food and kindred 

products 60 47 0 9 7 4 14

21 Tobacco manufactures 0 0 0 0 0 0 0

22 Textile mill products 12 10 0 5 1 2 3

23 Apparel and other 

textile products 24 26 0 7 3 4 9

24 Lumber and wood 

products 162 62 2 14 12 6 22

25 Furniture and fixtures 43 19 1 8 8 4 9

26 Paper and allied 

products 23 12 0 2 6 3 6

27 Printing and publishing 132 106 6 27 27 11 50

28 Chemicals and allied 

products 42 23 0 6 9 2 22

29 Petroleum and coal 

products 8 9 0 1 5 0 3

Page 64 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

SIC 

1987 U.S. Standard

industrial 

classification code

(SIC) description

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

30 Rubber and 

miscellaneous plastics 

products 47 41 0 8 6 4 13

31 Leather and leather 

products 2 2 0 0 0 2 2

32 Stone, clay, glass, and 

concrete products 60 39 2 10 6 6 12

33 Primary metal 

industries 26 29 0 6 5 1 11

34 Fabricated metal 

products 159 81 1 26 13 20 46

35 Industrial machinery 

and equipment 236 149 1 52 41 25 81

36 Electrical and 

electronic equipment 64 49 1 24 25 6 40

37 Transportation 

equipment 74 29 3 16 18 5 16

38 Instruments and 

related products 43 36 1 17 28 7 36

39 Miscellaneous 

manufacturing 

industries 97 69 1 23 15 7 29

40 Railroad transportation 14 8 0 4 5 0 5

41 Local and interurban

passenger transit 124 76 6 32 26 8 40

42 Motor freight 

transportation and 

warehousing 426 246 4 60 50 25 108

43 U.S. Postal Service 0 0 0 0 0 0 0

44 Water transportation 22 15 11 5 4 1 9

45 Transportation by air 70 42 4 57 55 10 44

46 Pipelines, except 

natural gas 2 1 0 0 0 0 0

47 Transportation services 147 139 2 54 39 11 50

48 Communications 133 119 2 80 42 17 73

49 Electric, gas, and 

sanitary services 130 73 1 38 20 4 38

50 Wholesale trade—

durable goods 768 531 13 209 151 74 279

51 Wholesale trade—

nondurable goods 319 217 4 54 59 21 96

Page 65 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

SIC 

1987 U.S. Standard

industrial 

classification code

(SIC) description

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

52 Building materials, 

hardware, garden 

supply, & mobile home 297 133 4 49 31 23 43

53 General merchandise 

stores 60 32 1 20 13 4 13

54 Food stores 388 229 0 55 46 24 61

55 Automotive dealers 

and gasoline service 

stations 671 371 15 120 97 52 123

56 Apparel and accessory 

stores 103 109 1 22 27 9 24

57 Furniture, home 

furnishings and

equipment stores 334 250 4 73 49 32 82

58 Eating and drinking 

places 1,394 741 11 153 109 101 150

59 Miscellaneous retail 766 622 10 178 171 77 250

60 Depository institutions 127 93 6 52 26 11 46

61 Nondepository credit 

institutions 118 125 5 39 31 16 63

62 Security, commodity 

brokers, and services 52 60 2 23 24 6 40

63 Insurance carriers 30 24 3 8 10 0 12

64 Insurance agents, 

brokers, and service 242 295 5 83 71 28 112

65 Real estate 506 537 20 153 121 41 251

67 Holding and other 

investment offices 88 67 3 33 31 12 37

70 Hotels, rooming

houses, camps, and 

other lodging places 152 104 0 28 22 8 42

72 Personal services 358 340 5 84 71 28 110

73 Business services 1,663 1600 42 459 468 172 769

75 Automotive repair, 

services, and parking 706 413 11 100 75 59 143

76 Miscellaneous repair 

services 265 176 6 69 45 23 92

78 Motion pictures 67 46 4 16 11 10 23

79 Amusement and 

recreational services 403 313 5 72 79 47 99

80 Health services 994 1618 19 500 598 36 775

Page 66 GAO-07-259 Reserve Employment Matters
Appendix III: Profiles on Employers of 

Reservists 

SIC 

1987 U.S. Standard

industrial 

classification code

(SIC) description

Army 

National 

Guard

Army 

Reserve

Coast 

Guard

Reserve

Air 

National 

Guard

Air Force 

Reserve 

Marine

Corps 

Reserve

Navy 

Reserve

81 Legal services 301 526 18 90 93 34 210

82 Educational services 0 0 0 0 0 0 0

83 Social services 439 492 16 131 123 19 161

84 Museums, art galleries, 

botanical & zoological 

gardens 26 23 2 7 6 2 10

86 Membership 

organizations 760 704 23 301 286 35 353

87 Engineering and

management services 891 925 23 326 330 101 553

88 Private households 0 0 0 0 0 0 0

89 Miscellaneous services 167 147 3 48 32 16 70

Total 19,882 15,788 411 4,880 4,295 1,626 6,789

Source: DOD’s Civilian Employment Information Database. 

Page 67 GAO-07-259 Reserve Employment Matters
Appendix IV: Comments from the Department Appendix IV of Defense : Comments from the 

Department of Defense 

Page 68 GAO-07-259 Reserve Employment Matters
Appendix IV: Comments from the Department 

of Defense 

Page 69 GAO-07-259 Reserve Employment Matters
Appendix IV: Comments from the Department 

of Defense 

Page 70 GAO-07-259 Reserve Employment Matters
Appendix V: Comments from the Department Appendix V of Labor : Comments from the Department 

of Labor 

Page 71 GAO-07-259 Reserve Employment Matters
Appendix V: Comments from the Department 

of Labor 

Page 72 GAO-07-259 Reserve Employment Matters
Appendix VI: Comments from the Office of Appendix VI: Comments from the Office of Special Counsel 

Special Counsel 

Page 73 GAO-07-259 Reserve Employment Matters
Appendix VII: 

A

GAO Contact and Staff 

cknowledgments 

Page 74 GAO-07-259

Appendix VII: GAO Contact and Staff 

Acknowledgments 

Derek B. Stewart (202) 512-5559 

James Bancroft, Sean Bell, Tracy Burney, Susan Ditto, 

Laura Durland, K. Nicole Harms, Kenya Jones, Jeanett Reid, Gina Ruidera, 

Joseph Rutecki, Jerry Sandau, Jay Smale Jr., Norris Smith, and Vasiliki 

Theodoropoulos also made significant contributions to the report. 

Reserve Employment Matters

GAO Contact 

Acknowledgments 

(350858) 
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