DOD HEALTH

Actions Needed to 

Ensure PostTraumatic Stress 

Disorder and 

Traumatic Brain Injury 

Are Considered in 

Misconduct 

Separations

Report to Congressional Committees

May 2017

GAO-17-260

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-17-260, a report to 

congressional committees

May 2017

DOD HEALTH

Actions Needed to Ensure Post-Traumatic 

Stress Disorder and Traumatic Brain Injury Are 

Considered in Misconduct Separations

What GAO Found

GAO’s analysis of Department of Defense (DOD) data show that 62 percent, or 

57,141 of the 91,764 servicemembers separated for misconduct from fiscal years 

2011 through 2015 had been diagnosed within the 2 years prior to separation 

with post-traumatic stress disorder (PTSD), traumatic brain injury (TBI), or 

certain other conditions that could be associated with misconduct. Specifically, 

16 percent had been diagnosed with PTSD or TBI, while the other conditions, 

such as adjustment and alcohol-related disorders, were more common. Of the 

57,141 servicemembers, 23 percent, or 13,283, received an “other than 

honorable” characterization of service, making them potentially ineligible for 

health benefits from the Department of Veterans Affairs (VA).

GAO found that the military services’ policies to address the impact of PTSD and 

TBI on separations for misconduct are not always consistent with DOD policy. 

For example, contrary to DOD policy, Navy policy does not require a medical 

examination—or screening—for certain servicemembers being separated in lieu 

of trial by court-martial to assess whether a PTSD or TBI diagnosis is a 

mitigating factor in the misconduct charged. This type of separation occurs when 

a servicemember facing a trial by court-martial requests, and is approved, to be 

discharged administratively. In addition, GAO found that two of the four military 

services have TBI training polices that are inconsistent with DOD policy.

GAO also found that the Army and Marine Corps may not have adhered to their 

own screening, training, and counseling policies related to PTSD and TBI. For 

example, GAO found that 18 of the 48 nongeneralizable sample separation 

packets reviewed for Marine Corps servicemembers administratively separated 

for misconduct lacked documentation showing that the servicemember had been 

screened for PTSD and TBI. During interviews with Army officers, GAO found 

that some officers may not have received training to identify mild TBI symptoms,

despite Army policy that all servicemembers should be trained. Further, GAO 

found instances in which both Army and Marine Corps may not have adhered to

their counseling policies, which require that servicemembers, specifically prior to 

requesting separation in lieu of trial by court-martial, be counseled about their 

potential ineligibility for VA benefits and services. For 11 of the 48 separation 

packets included in GAO’s analysis of Army servicemembers who requested

separation in lieu of trial by court-martial, there was no documented evidence—

or the evidence was unclear—as to whether the servicemembers received 

counseling.

Finally, while Army and Marine Corps have some available data on 

servicemembers’ screenings, training, and counseling, the military services do 

not use these data to routinely monitor whether they are adhering to relevant 

policies. Federal internal control standards call for agencies to establish 

monitoring activities to ensure internal control systems and evaluate results.

Without monitoring adherence to these policies, the military services cannot 

provide assurance that servicemembers with PTSD and TBI are receiving

adequate consideration of their conditions as well as the services DOD has 

established for them.

View GAO-17-260. For more information, 

contact Randall B. Williamson at (202) 512-

7114 or williamsonr@gao.gov.

Why GAO Did This Study

The Carl Levin and Howard P. “Buck” 

McKeon National Defense 

Authorization Act for Fiscal Year 2015 

contains a provision that GAO examine 

the effect of PTSD, TBI, and certain 

other conditions on separations for 

misconduct. This report examines (1) 

the number of servicemembers 

separated for misconduct who were 

diagnosed with PTSD, TBI, or certain 

other conditions and were potentially 

ineligible for VA benefits and services; 

(2) the extent to which military 

services’ policies to address the impact 

of PTSD and TBI on separations for 

misconduct are consistent with DOD’s 

policies; (3) the extent to which Army 

and Marine Corps have adhered to

their policies; and (4) the extent to 

which DOD, Army, and Marine Corps 

monitor adherence to the policies. 

GAO analyzed DOD data; reviewed 

applicable policies; interviewed DOD, 

Army, Marine Corps, Air Force, and 

Navy officials; visited two Army and 

one Marine Corps sites selected on 

factors such as separation rates; and 

reviewed a nongeneralizable sample of 

Army and Marine Corps 

servicemember misconduct separation 

documents.

What GAO Recommends

GAO is making five recommendations, 

including that DOD direct the Air Force 

and Navy to address inconsistencies in 

their screening and training policies

and ensure that the military services 

monitor adherence to their screening, 

training, and counseling policies. DOD 

agreed with four of GAO’s 

recommendations, but did not agree to 

address inconsistencies in training 

policies. GAO maintains 

inconsistencies should be addressed, 

as discussed in the report. 
Page i GAO-17-260 DOD Misconduct Separations

Letter 1

Background 6

Many Servicemembers Separated for Misconduct Had PTSD, TBI, 

or Certain Other Conditions; About a Quarter Were Potentially 

Ineligible for VA Benefits and Services 12

Some Military Services’ Screening and Training Policies Related 

to PTSD and TBI Are Inconsistent with DOD Policy 16

Army and Marine Corps May Not Have Adhered to Their Own 

Policies Related to PTSD and TBI Screening, Training, and 

Counseling 22

DOD, Army, and Marine Corps Do Not Routinely Monitor 

Adherence to Policies to Address the Impact of PTSD and TBI 

on Servicemembers 27

Conclusions 30

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 32

Appendix I Additional Information on GAO’s Data Analyses 35

Appendix II Prior Diagnoses for Servicemembers Separated for 

Misconduct from Fiscal Years 2011 through 2015 38

Appendix III Additional Information on Separations for Active Duty 

Servicemembers, Fiscal Years 2011 through 2015 43

Appendix IV Characterization of Service for Servicemembers Separated for 

Misconduct from Fiscal Years 2011 through 2015 and Previously 

Diagnosed with PTSD, TBI, or Certain Other Conditions 46

Appendix V Military Services’ Policies that Address the Impact of PTSD 

and TBI on the Separation of Servicemembers for Misconduct 50

Contents
Page ii GAO-17-260 DOD Misconduct Separations

Appendix VI Comments from the Department of Defense 55

Appendix VII GAO Contact and Staff Acknowledgments 59

Tables

Table 1: Diagnosis of PTSD, TBI, and Certain Other Conditions in 

Servicemembers Separated for Misconduct from Fiscal 

Years 2011 through 2015 13

Table 2: Military Services’ TBI Training Policy Consistency with 

DOD Requirements, as of April 2017 21

Table 3: Diagnosis of PTSD or TBI, Certain Other Conditions, or 

None of the Conditions in Servicemembers Separated for 

Misconduct from Fiscal Years 2011 through 2015 38

Table 4: Diagnosis of Certain Conditions in Servicemembers 

Administratively Separated for Misconduct from Fiscal 

Years 2011 through 2015 39

Table 5: Diagnosis of Certain Conditions in Servicemembers 

Administratively Separated in Lieu of Trial by CourtMartial from Fiscal Years 2011 through 2015 41

Table 6: Total Separations, Active Duty Servicemembers, Fiscal 

Years 2011 through 2015 43

Table 7: Administrative Separations for Misconduct, Active Duty 

Servicemembers, Fiscal Years 2011 through 2015 44

Table 8: Administrative Separations In Lieu Of Trial by CourtMartial, Active Duty Servicemembers, Fiscal Years 2011 

through 2015 45

Table 9: Characterization of Service for Servicemembers 

Administratively Separated for Misconduct, Fiscal Years 

2011 through 2015, by Diagnosis 46

Table 10: Characterization of Service for Servicemembers 

Administratively Separated in Lieu of Trial by CourtMartial, Fiscal Years 2011 through 2015, by Diagnosis 48

Table 11: Military Services’ Policies Related to Screening 

Servicemembers Prior to Separation for Misconduct 50

Table 12: Military Services’ Policies Related to Training 

Servicemembers on How to Identify Mild Traumatic Brain 

Injury in the Deployed Setting 52
Page iii GAO-17-260 DOD Misconduct Separations

Table 13: Military Services’ Policies Related to Counseling on 

Potential Ineligibility for Benefits and Services from the 

Department of Veterans Affairs 53

Figures

Figure 1: Process for Administrative Separation for Misconduct 

and Administrative Separation in Lieu of Trial by CourtMartial for Enlisted Servicemembers 7

Figure 2: Diagnosis Status and Characterization of Service for 

Servicemembers Separated for Misconduct from Fiscal 

Years 2011 through 2015 15

Figure 3: Military Services’ Screening Policy Consistency with Key 

DOD Requirements, as of April 2017 18
Page iv GAO-17-260 DOD Misconduct Separations

Abbreviations

DHA Defense Health Agency

DMDC Defense Manpower Data Center

DOD Department of Defense

PTSD post-traumatic stress disorder

TBI traumatic brain injury

VA Department of Veterans Affairs

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Page 1 GAO-17-260 DOD Misconduct Separations

441 G St. N.W.

Washington, DC 20548

May 16, 2017

The Honorable John McCain

Chairman

The Honorable Jack Reed

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Mac Thornberry

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

Mental health conditions and cognitive impairments such as posttraumatic stress disorder (PTSD) and traumatic brain injury (TBI) are 

“signature wounds” of the conflicts in Afghanistan and Iraq, according to 

the Department of Defense (DOD) and published research.1 PTSD, TBI, 

and other mental and physical conditions can go unrecognized and 

unacknowledged by the military, family members, and society in general. 

Because these conditions can adversely affect servicemembers’ moods, 

thoughts, and behavior, they may lead to disciplinary infractions and 

subsequent separations for misconduct from the military. Misconduct 

separations can result from actions and behaviors such as drug use, 

insubordination, absence from the military without leave, and criminal 

behavior. In some cases, servicemembers separated for misconduct are 

not eligible for benefits and services from the Department of Veterans 

Affairs (VA).

Congress and others have raised questions about whether 

servicemembers with PTSD or TBI resulting from their military service 

may be separated for misconduct without appropriate consideration of 

these conditions. For example, Congress has passed a law requiring the 

 1

For examples of published research see, Terri Tanielian and Lisa Jaycox, eds., Invisible 

Wounds of War: Psychological and Cognitive Injuries, Their Consequences, and Services 

to Assist Recovery, (Santa Monica, Calif.: RAND Corporation, 2008) and Institute of 

Medicine, Treatment for post-traumatic stress disorder in military and veteran populations: 

Final assessment, (Washington, D.C.: The National Academies Press, 2014).

Letter
Page 2 GAO-17-260 DOD Misconduct Separations

military services—Army, Marine Corps, Air Force, and Navy—to assess 

the impact of a PTSD or TBI diagnosis before separating certain 

servicemembers for misconduct under regulations prescribed by DOD.

2

To implement this requirement, DOD has issued policies, and each of the 

military services has its own policies to address servicemember 

separations for misconduct that involve PTSD or TBI. Nevertheless, 

advocacy groups and media reports have described instances of 

servicemembers with symptoms of PTSD and TBI being discharged for 

misconduct without adequate treatment or consideration of these 

symptoms.3 In May 2016, the Army’s Audit Agency weighed in on this 

topic, finding that the Army did not have sufficient documentation to 

demonstrate that it had considered whether PTSD or TBI was a mitigating 

factor in certain servicemembers’ behavior prior to separating them for 

misconduct.4

The Carl Levin and Howard P. “Buck” McKeon National Defense 

Authorization Act for Fiscal Year 2015 contains a provision that we

examine the impact of mental and physical trauma, including PTSD, TBI, 

and other combat traumas, on the separation of servicemembers from the 

military services for misconduct.5 In this report, we examine

1. the number of servicemembers separated for misconduct in fiscal 

years 2011 through 2015 who were diagnosed with PTSD, TBI, or

 2

National Defense Authorization Act for Fiscal Year 2010, Pub. L. No. 111-84, § 512, 123 

Stat. 2190, 2280-82 (2009) (codified, as amended, at 10 U.S.C. § 1177).

3

Rebecca Ruiz, “Is the Army Improperly Discharging Wounded, Ill Soldiers for 

Misconduct?” Forbes, August 2, 2013, accessed August 14, 2015, 

http://www.forbes.com/sites/rebeccaruiz/2013/08/02/is-the-army-improperly-dischargingwounded-ill-soldiers-for-misconduct/#1e278f391037. Dave Philipps, “Pattern of 

Misconduct: Psychological Screenings Prompt Call for More Reforms,” The Gazette,

October 7, 2013, accessed on August 14, 2015, 

http://cdn.csgazette.biz/soldiers/day4.html.

4

Department of the Army, U.S Army Audit Agency, Soldiers with Mental Health Conditions 

Separated from Active Duty for Misconduct, A-2016-0084-MTM (Fort Belvoir, V.A.: May 

2016). Department of the Army, U.S Army Audit Agency, Follow-on Audit of Soldiers with 

Mental Health Conditions Separated from Active Duty for Misconduct, A-2016-0085-MTM 

(Fort Belvoir, V.A.: May 2016).

5

See Carl Levin and Howard P. “Buck” McKeon National Defense Authorization Act for 

Fiscal Year 2015, Pub. L. No. 113-291, § 588, 128 Stat. 3292, 3394 (2014). For the 

purposes of this report, we focus on two types of administrative separations for enlisted 

servicemembers—administrative separations for misconduct and administrative 

separations in lieu of trial by court martial—which we refer to collectively as “separations 

for misconduct.” In addition, we refer to mental and physical traumas as conditions.
Page 3 GAO-17-260 DOD Misconduct Separations

certain other conditions and were potentially ineligible for VA benefits 

and services;

2. the extent to which the military services’ policies to address the impact 

of PTSD and TBI on the separation of servicemembers for misconduct 

are consistent with DOD’s policies;

3. the extent to which the Army and Marine Corps have adhered to their 

policies to address the impact of PTSD and TBI on the separation of 

servicemembers for misconduct; and

4. the extent to which DOD, the Army, and Marine Corps monitor 

adherence to policies to address the impact of PTSD and TBI on the 

separation of servicemembers for misconduct.

To examine the number of servicemembers who were separated for 

misconduct in fiscal years 2011 through 2015, diagnosed with PTSD, TBI, 

or certain other conditions, and potentially ineligible for VA benefits and 

services, we obtained data from three sources.6 We obtained separation 

data from DOD’s Defense Manpower Data Center (DMDC), medical data 

from DOD’s Defense Health Agency (DHA), and data on VA eligibility 

determinations from the Veterans Benefits Administration. We limited our 

analysis to active duty servicemembers, both officers and enlisted, who 

were separated for misconduct from the Army, Marine Corps, Air Force, 

or Navy in fiscal years 2011 through 2015.7 We assessed the reliability of 

the DMDC, DHA, and VA data in several ways, including discussing the 

reliability of the data with DOD and VA officials, performing electronic 

tests of the data to identify any outliers or anomalies, reviewing relevant 

documentation, and comparing the data with data from published 

sources. We determined that the data were sufficiently reliable for the 

purposes of our reporting objectives. For additional information about the 

data analysis, see appendix I.

 6

In this report, “certain other conditions” refers to adjustment disorders, alcohol-related 

disorders, depressive disorders, substance abuse disorders, anxiety disorders, personality 

disorders, and bipolar disorders. Like PTSD and TBI, these conditions could be 

associated with misconduct, according to our review of relevant publications and 

consultation with clinical experts. While servicemembers can be involuntarily separated for 

personality disorder and acute adjustment disorder, we included these conditions in our 

review of separations for misconduct as there have been reports of PTSD or TBI being 

misdiagnosed as these conditions.

7

We excluded Reservists and National Guard members from our analysis because 

reliable separation data were not available for the Army Reserve and National Guard, 

according to DOD officials.
Page 4 GAO-17-260 DOD Misconduct Separations

To examine the extent to which the military services’ policies to address 

the impact of PTSD and TBI on the separation of servicemembers for 

misconduct are consistent with DOD’s policies, we reviewed the military 

services’ policies related to (1) assessing the impact of a PTSD or TBI 

diagnosis prior to separating certain servicemembers for misconduct, (2) 

training servicemembers on how to identify mild TBI symptoms in the 

deployed setting, and (3) counseling servicemembers being separated for 

misconduct about potential ineligibility for VA benefits and services.8 We 

compared the extent to which the military services’ policies, as provided 

by these military services, are consistent with DOD’s related policies in 

the above three areas.9 In addition, we interviewed DOD and military 

service officials regarding the policies. For this and subsequent 

objectives, we focused our review on the screening and counseling of 

enlisted servicemembers because they represented the vast majority (98 

percent) of separations for misconduct identified in our first objective. We 

focused our review of TBI training requirements on the training of officers, 

consistent with our reporting objectives under the Carl Levin and Howard 

P. “Buck” McKeon National Defense Authorization Act for Fiscal Year 

2015.10

To examine the extent to which the Army and Marine Corps have 

adhered to their policies designed to address the impact of PTSD and TBI 

on the separation of servicemembers for misconduct, at the national level 

we reviewed separation documents contained in final personnel files for a 

small, nongeneralizable sample of Army and Marine Corps enlisted 

servicemembers who were separated during fiscal years 2011 through 

 8

Our review of counseling policies did not include Transition Assistance Program policies 

because these counseling sessions occur after anticipated separation dates have been 

set for misconduct separations.

9

Some of the DOD policies we reviewed have a statutory basis. Where this was the case, 

we first determined whether the DOD policies were consistent with applicable law in order 

to assure that our evaluation was based on a comparison with appropriate DOD policies. 

We excluded from our analysis any DOD policies that appeared to be inconsistent with 

statute. We also informed appropriate officials of any apparent inconsistences to enable 

them to review the issues and take action, as appropriate. 

10In this report, we refer to commissioned officers and noncommissioned officers 

collectively as “officers.”
Page 5 GAO-17-260 DOD Misconduct Separations

2015.

11 We also interviewed Army and Marine Corps headquarter 

officials. In addition, we reviewed relevant documents and interviewed 

officials regarding screening, training, and counseling during three site 

visits. Specifically, we visited two Army installations—Fort Bragg (NC) 

and Fort Sill (OK)—and one Marine Corps installation—Camp Pendleton 

(CA). We selected the sites based on the number of servicemembers 

separated for misconduct and geographic variation.12 We limited our 

review to the Army and the Marine Corps for this and subsequent 

objectives because of the resource intensive nature of the site visits. We 

selected the Army and Marine Corps because, as of 2014, these two 

military services represented over half (almost 60 percent) of all 

servicemembers in the United States military forces.

To examine the extent to which DOD, the Army, and the Marine Corps 

monitor adherence to policies to address the impact of PTSD and TBI on 

the separation of servicemembers for misconduct, we reviewed relevant 

documents and interviewed officials from DOD, the Army, and the Marine 

Corps. We determined whether or to what extent they collect and monitor 

data related to the military services’ adherence to screening, training, and 

counseling policies. We compared these efforts to relevant standards for 

internal control in the federal government.13

We conducted this performance audit from August 2015 to May 2017 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

 11We obtained separation documentation uploaded to the Official Military Personnel File 

for servicememembers in our small, nongeneralizable sample. We interviewed Army and 

Marine Corps separation officials and Army Judge Advocate General’s Corps officials to 

determine which screening and counseling documentation should be in servicemembers’ 

separation packets. We then worked with Army and Marine Corps officials to obtain 

separation packets through the Army’s Interactive Personnel Electronic Records 

Management System and the Defense Personnel Records Information Retrieval System.

12According to a Marine Corps official responsible for managing separation policy and 

procedures, most of the Marine Corps’ separations are processed at two installations—

Camp Lejeune (NC) and Camp Pendleton (CA).

13GAO, Standards for Internal Control in the Federal Government GAO/AIMD-00-23.3.1

(Washington, D.C.: November 1999) and GAO, Standards for Internal Control in the 

Federal Government GAO-14-704G (Washington, D.C.: September 2014). Internal control 

is a process effected by an entity’s oversight body, management, and other personnel that 

provides reasonable assurance that the objectives of an entity will be achieved.
Page 6 GAO-17-260 DOD Misconduct Separations

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

When a servicemember is charged with misconduct—such as drug use, 

insubordination, absence from the military without leave, or criminal 

behavior—the military can take action to separate the servicemember 

through either a punitive discharge or an administrative separation. A 

punitive discharge generally involves a trial by court-martial, where 

charges are filed and the case is adjudicated in a military court. In 

contrast, administrative separations involving misconduct charges are 

handled through a nonjudicial administrative process and can include 

attempts to correct and rehabilitate behavior and to counsel 

servicemembers on the impact of being separated for misconduct.

There are two main types of separations for misconduct for enlisted 

servicemembers: administrative separations for misconduct and 

administrative separations in lieu of trial by court-martial.14

• Administrative separation for misconduct is an involuntary 

separation of a servicemember who is unqualified for further military 

service. Examples of the behaviors that can lead to an administrative 

separation for misconduct include behaviors ranging from a pattern of 

minor disciplinary infractions to the commission of a serious military or 

civilian offense.

• Administrative separation in lieu of trial by court-martial is when 

a servicemember facing trial by court-martial voluntarily requests to be 

discharged from military service, and, if approved, the separation case 

is then handled through the administrative process.

The process for separating servicemembers varies slightly between the 

two separation types. (See fig. 1.)

 14This report describes the separation process for certain enlisted servicemembers. 

Commissioned officers follow a different separation process. In addition, a servicemember 

who is within the first 180 days of continuous active duty military service and commits 

misconduct may be separated under the entry-level performance and conduct process 

instead of the administrative separation for misconduct basis.

Background

Separations for 

Misconduct: Types and 

Processes
Page 7 GAO-17-260 DOD Misconduct Separations

Figure 1: Process for Administrative Separation for Misconduct and Administrative Separation in Lieu of Trial by CourtMartial for Enlisted Servicemembers

Notes: This figure describes the separation process for certain enlisted servicemembers. 

Commissioned officers follow a different separation process. In addition, an enlisted servicemember 

who is within the first 180 days of continuous active duty military service and commits misconduct 

may be separated through the entry-level performance and conduct process instead of either of the 

depicted processes.

a

Servicemembers have the right to consult with military or civilian counsel. Servicemembers have the 

right to waive counsel after being afforded a reasonable opportunity to consult with counsel and be 

advised that failure to respond will constitute a waiver of the right.

b

All servicemembers receive a physical prior to separation, but additional medical examination 

requirements apply in certain circumstances. Specifically, DOD policy, pursuant to 10 U.S.C. § 1177, 

requires that a servicemember diagnosed as experiencing PTSD or TBI, or who reasonably alleges 

the influence of PTSD or TBI based on deployed service in support of a contingency operation during 

the previous twenty-four months, must receive a medical examination—or screening—to assess 

whether PTSD or TBI was a mitigating factor in the behavior that resulted in the misconduct charge.

These physicals could occur simultaneously with other process steps. In addition, each of the military 
Page 8 GAO-17-260 DOD Misconduct Separations

services has a medical evaluation board process where medical examinations are conducted and 

decisions are made regarding a servicemember’s ability to continue to serve in the military.

c

Separation paperwork for all servicemembers is reviewed by the separating official. Servicemembers 

with 6 or more years of service or facing an “other than honorable” characterization of service can 

also request an Administrative Separation Board to review documents, hear their case, and make a 

recommendation to the separating official.

d

Servicemembers facing trial by court-martial have the right to consult with counsel to discuss the 

adverse nature of the possible characterization of service and its consequences.

When a servicemember separates from the military, DOD characterizes 

the nature of that servicemember’s military service. Administrative 

separations generally result in one of three potential characterizations of 

service, which determine a servicemember’s eligibility for VA benefits and 

services. Specifically,

• servicemembers who receive an “honorable” characterization of 

service are eligible for all VA benefits and services;

• servicemembers who receive a “general” characterization of service 

are eligible for most VA benefits and services, with the exception of 

some VA education assistance; and

• servicemembers who receive an “other than honorable” 

characterization of service may not be eligible for any VA benefits and 

services, including health care.15

According to DOD policy, servicemembers separating under either type of 

administrative misconduct separation will normally receive a 

characterization of service of “other than honorable,” though other 

characterizations may be warranted depending on the circumstances.

Congress has enacted several laws and DOD has established several 

additional policies governing the military services’ handling of misconduct 

separations in cases involving PTSD and TBI.

 15VA makes the ultimate determination of eligibility—referred to as VA’s character of 

service determination—for VA benefits and services for servicemembers who receive an 

“other than honorable” characterization of service. However, VA does not initiate this 

determination unless a servicemember makes a claim to obtain VA benefits and services. 

In addition, these servicemembers may be eligible for VA benefits and services based on 

prior periods of service, depending on their characterization upon prior separations and 

any character of service determinations that VA performed for those periods of service.

Service Characterization 

for Separating 

Servicemembers: 

Potential Impact on VA 

Benefits and Services

Legislative and DOD 

Policy Requirements
Page 9 GAO-17-260 DOD Misconduct Separations

Screening servicemembers prior to separation. The National Defense 

Authorization Act for Fiscal Year 2010, as amended, requires each 

military service to provide, under policies established by DOD, a medical 

examination for certain servicemembers diagnosed with PTSD or TBI 

who are facing administrative separation under conditions other than 

honorable, including administrative separations in lieu of court-martial.16

The purpose of the medical examination—or screening—is to assess 

whether these conditions were a mitigating factor in the behavior that 

resulted in the misconduct charge.17 The law prohibits the administrative 

separation of these servicemembers under conditions other than 

honorable until the results of the screening have been reviewed by 

appropriate authorities responsible for the separation case, as determined 

by the relevant military service.18

The law’s screening requirements only apply to certain servicemembers 

facing administrative separation under conditions other than honorable. 

As relevant here, the law requires a screening for those servicemembers 

who have been deployed overseas in support of a contingency operation 

during the previous 24 months and have been diagnosed with PTSD or 

TBI by one of five provider types: (1) a physician, (2) clinical psychologist, 

(3) psychiatrist, (4) licensed clinical social worker, or (5) psychiatric 

advanced practice registered nurse.19

 16Pub. L. No. 111-84, § 512, 123 Stat. 2190, 2280-82 (2009), as amended by the National 

Defense Authorization Act for Fiscal Year 2013, Pub. L. No. 112-239, § 518, 126 Stat. 

1632, 1720 (2013), the National Defense Authorization Act for Fiscal Year 2014, Pub. L. 

No. 113-66, § 522, 127 Stat. 672, 755 (2013), and the National Defense Authorization Act 

for Fiscal Year 2017, Pub. L. No. 114-328, § 524, 130 Stat. 2000, 2116 (2016) (codified at 

10 U.S.C. § 1177).

17In this report, a “PTSD or TBI screening” refers to the medical examination to assess 

whether the effects of PTSD or TBI constitute matters in extenuation of a charge that the 

service was “other than honorable” under 10 U.S.C. § 1177(b). The law’s screening 

requirements do not apply to courts-martial or other proceedings conducted pursuant to 

the Uniform Code of Military Justice, only to administrative separations, including 

administrative separations in lieu of courts-martial. 10 U.S.C. § 1177(c).

1810 U.S.C. § 1177(a)(2). The law does not restrict the discretion of the separation 

authority in determining what impact the screening results should have on the service 

characterization.

19In the absence of a diagnosis by a qualifying provider, a servicemember may

nevertheless be entitled to a screening if the servicemember otherwise reasonably alleges 

the influence of PTSD or TBI based on the service of the member while deployed. 10 

U.S.C. § 1177(a)(1).
Page 10 GAO-17-260 DOD Misconduct Separations

The list of providers eligible to diagnose PTSD and TBI is not the same as 

the list of providers eligible to conduct PTSD screenings or the list of 

providers eligible to conduct TBI screenings. Specifically, the statute 

restricts PTSD screenings to one of four provider types—(1) a clinical 

psychologist, (2) psychiatrist, (3) licensed clinical social worker, or (4) 

psychiatric advanced practice registered nurse. In comparison, TBI 

screenings may be performed by (1) a physician, (2) clinical psychologist, 

(3) psychiatrist, or (4) other health care professional, as appropriate.20 As 

a result of this statutory scheme, physicians may diagnose PTSD and 

TBI, and they may also perform TBI screenings. However, they may not 

perform PTSD screenings.21

DOD updated its separation policy first in 2010 and most recently in 2014 

in response to changes in the law. Among other things, DOD required 

each of the military services to issue its own guidance to implement the 

new requirements within that military service.22

Training on PTSD and TBI. Although not required by law, DOD has 

established a policy for the management of mild TBI, also known as 

concussion, in the deployed setting. The policy directs the military 

services to develop and support effective training plans for 

servicemembers on early detection of potential mild TBI in the deployed 

setting.

23 While DOD does not have—nor is it legally required to have—

any identifiable policies that require training of PTSD-specific symptoms, 

it does have a policy that requires training on combat and operational 

stress reactions, which may include sleep disturbance, anger and 

 2010 U.S.C. § 1177(a)(3).

21Compare 10 U.S.C. § 1177(a)(1) with 10 U.S.C. § 1177(a)(3).

22In 2010, DOD released a temporary policy that required military services to develop 

implementation guidance for the new PTSD and TBI screening requirements. See 

Department of Defense Directive-Type Memorandum 10-022, Implementing Required 

Medical Exam Before Administrative Separation for Post-Traumatic Stress Disorder 

(PTSD) or Traumatic Brain Injury (TBI) (July 25, 2010). (Hereinafter cited as DTM 10-022 

(July 25, 2010)). These requirements were then incorporated into a formal policy, which 

outlines the administrative separation process for enlisted servicemembers. Department of 

Defense Instruction 1332.14, Enlisted Administrative Separations, Encl. 5, Sec. 9 (Dec. 4, 

2014). (Hereinafter cited as DODI 1332.14 (Dec. 4, 2014)).

23Department of Defense Instruction 6490.11, DOD Policy Guidance for Management of 

Mild Traumatic Brain Injury/Concussion in the Deployed Setting, Encl. 2, Para. 6(c) (Sept. 

18, 2012). (Hereinafter cited as DODI 6490.11 (Sept. 18, 2012)). For ease of reference, 

we may refer to this policy as a TBI training policy, although it is specific to symptoms of 

mild TBI. 
Page 11 GAO-17-260 DOD Misconduct Separations

difficulty concentrating.24 While combat and operational stress reactions 

may overlap with PTSD symptoms, the conditions are distinct.

Counseling on potential ineligibility for VA benefits and services.

DOD has several policies related to counseling servicemembers on 

aspects of DOD’s separation policy. Some counseling policies apply to all 

servicemembers or to those separating under honorable or general 

conditions. One is specific to separations in lieu of trial by court-martial.

• DOD policy requires the military services to establish procedures for 

periodically counseling all servicemembers throughout their careers 

on DOD’s separation policy, including the types of separation and how 

particular actions might affect a servicemember’s eligibility for VA 

benefits and services.25

• DOD policy requires that the military services offer legal counsel to 

servicemembers requesting separation in lieu of trial by court-martial 

prior to the servicemember submitting his or her request to be 

separated. The servicemember may refuse to meet with counsel, but 

must state in the written request for separation that he or she 

understands that such request may result in an “other than honorable” 

characterization of service and the consequences, such as potential 

loss of benefits, associated with that characterization.26

 24DOD’s combat and operational stress control policy requires the military services to 

establish programs that ensure training to officers on how to identify the indicators of 

combat and stress reactions in themselves and in the servicemembers in their units that 

may require further consultation with mental health providers. Department of Defense 

Instruction 6490.05, Maintenance of Psychological Health in Military Operation, Encl.2, 

Para. 2(f) (Oct. 2, 2013).

25DODI 1332.14, Encl. 5, Para. 8 (Dec. 4, 2014).

26DODI 1332.14, Encl. 3, Para. 11 (Dec. 4, 2014).
Page 12 GAO-17-260 DOD Misconduct Separations

Our analysis of DOD data shows that 91,764 servicemembers were 

separated for misconduct from fiscal years 2011 through 2015; of these 

servicemembers, 57,141—62 percent—had been diagnosed within the 2 

years prior to their separation with PTSD, TBI, or certain other conditions 

that could be associated with misconduct.27 More specifically, 16 percent, 

or 14,816 of the 91,764 servicemembers who were separated for 

misconduct, had been diagnosed with PTSD or TBI. Looking at the 

conditions individually, 8 percent had been diagnosed with PTSD and 11 

percent had been diagnosed with TBI, while other conditions, such as 

adjustment and alcohol-related disorders were more common.28 (See 

table 1.) For additional data on prior diagnoses of servicemembers 

separated for misconduct, see appendix II.

 27These separations include both administrative separations for misconduct and 

administrative separations in lieu of trial by court-martial. Out of the 57,141 

servicemembers, most—53,649—were administratively separated for misconduct. The 

remaining 3,492 servicemembers were administratively separated in lieu of trial by courtmartial.

The other conditions included in our study are adjustment disorders, alcohol-related 

disorders, anxiety disorders, bipolar disorders, depressive disorders, personality 

disorders, and substance-related disorders.

28The proportion of servicemembers, out of those separated for misconduct, who were 

diagnosed with PTSD or TBI (16 percent) does not represent the sum of the proportion 

diagnosed with PTSD (8 percent) and the proportion diagnosed with TBI (11 percent) 

because some servicemembers had been diagnosed with both conditions.

Many 

Servicemembers 

Separated for 

Misconduct Had

PTSD, TBI, or Certain 

Other Conditions; 

About a Quarter Were 

Potentially Ineligible 

for VA Benefits and 

Services
Page 13 GAO-17-260 DOD Misconduct Separations

Table 1: Diagnosis of PTSD, TBI, and Certain Other Conditions in Servicemembers 

Separated for Misconduct from Fiscal Years 2011 through 2015

Condition

Percentage of 

servicemembers 

separated for 

misconducta

Adjustment disordersb 35%

Alcohol-related disorders 29

Depressive disorders 22

Substance abuse disordersc 20

Anxiety disorders 17

Traumatic brain injuries (TBI) 11

Post-traumatic stress disorders (PTSD) 8

Personality disordersd 4

Bipolar disorderse 2

Source: GAO analysis of Department of Defense data. | GAO-17-260

Notes: The data include data for active duty officers and enlisted servicemembers who were 

administratively separated for misconduct or administratively separated in lieu of trial by court-martial 

identified through our analyses of Defense Manpower Data Center data. In addition, the data include 

only diagnoses made within the 2 years prior to a servicemember’s separation date. Servicemembers 

may fall into multiple diagnosis categories if they were diagnosed with multiple conditions.

a

This column contains the percentage of servicemembers who were diagnosed with the applicable 

condition within the 2 years prior to separation for misconduct. The percentages do not sum to 100 

percent as servicemembers could have been diagnosed with multiple conditions.

b

Adjustment disorder is a psychological response to one or more stressors. The diagnosis includes 

four components—the stressors, symptoms, the lack of an alternative explanation for the symptoms, 

and the timing of the symptoms. Stressors may occur once, multiple times, or be chronic.

c

Substance abuse disorder is a maladaptive pattern of substance use leading to clinically significant 

impairment or distress, as manifested by behavior including recurrent substance abuse resulting in a 

failure to fulfill major role obligations at work, school, or home, occurring at any time in the same 12-

month period.

d

Personality disorder is a long-standing, inflexible pattern of behavior that deviates markedly from 

expected behavior, has an onset in adolescence or early adulthood, and leads to distress or 

impairment.

e

Bipolar disorder is an episodic, potentially life-long, disabling disorder characterized by periods of 

abnormally elevated mood or irritability, which may alternate with periods of depressed mood or a mix 

of symptoms.

The 57,141 servicemembers who were separated for misconduct and 

diagnosed within the 2 years prior to separation with PTSD, TBI, or 

certain other conditions had, on average, 4 years of active military 

service. Almost all, or 98 percent, were enlisted servicemembers, rather 

than officers, and two-thirds had not been deployed overseas within the 2 

years prior to separation. For additional data on total separations and 

separations for misconduct, see appendix III.
Page 14 GAO-17-260 DOD Misconduct Separations

Further, of these servicemembers, 23 percent, or 13,283, received an 

“other than honorable” characterization of service, making them 

potentially ineligible for VA benefits and services, including health care.29

The majority—that is, 71 percent—of the servicemembers who were 

separated for misconduct and diagnosed within the 2 years prior to 

separation with PTSD, TBI, or certain other conditions received a 

“general” characterization of service.30 (See fig. 2.) Within the smaller 

population of servicemembers separated for misconduct and diagnosed 

with PTSD or TBI, these proportions were the same—that is, 23 percent 

received an “other than honorable” characterization of service and 71 

percent received a “general” characterization of service.31

 29Twenty percent of servicemembers who were administratively separated for misconduct 

and previously diagnosed with one of the conditions we reviewed received an “other than 

honorable” characterization. In contrast, about 80 percent of servicemembers who were 

administratively separated in lieu of trial by court-martial and previously diagnosed with 

one of the conditions we reviewed received an “other than honorable” characterization.

30An additional 3 percent were separated with an “honorable” characterization of service, 

while 3 percent were separated with a characterization that was unknown, not applicable, 

or uncharacterized.

31Four percent were separated with an “honorable” characterization of service, and 2 

percent were separated with a characterization that was unknown, not applicable, or 

uncharacterized.
Page 15 GAO-17-260 DOD Misconduct Separations

Figure 2: Diagnosis Status and Characterization of Service for Servicemembers Separated for Misconduct from Fiscal Years 

2011 through 2015

Notes: The data include data for active duty officers and enlisted servicemembers who were 

separated to civilian life. Other separations, such as those due to death, joining officer commissioning 

programs, or separating to the National Guard or Reserve, have been excluded. We defined 

separations for misconduct as administrative separations for misconduct and administrative 

separations in lieu of trial by court-martial. We defined diagnoses of PTSD, TBI, or certain other 

conditions as diagnoses made within 2 years prior to a servicemember’s separation date. The other 

conditions included in our study are adjustment disorders, alcohol-related disorders, anxiety 

disorders, bipolar disorders, depressive disorders, personality disorders, and substance-related 

disorders. While in this figure we present data on characterization of service for servicemembers 

diagnosed with PTSD, TBI, or certain other conditions, these proportions largely held true for the 

smaller population of servicemembers diagnosed with PTSD or TBI. Specifically, 71 percent of 

servicemembers diagnosed with PTSD or TBI received “general,” 23 percent received “other than 

honorable,” 4 percent received “honorable,” and 2 percent received other characterizations of service.

a

This category does not include servicemembers who were also diagnosed with PTSD or TBI. For the 

purpose of our analyses, we included these servicemembers only in the “diagnosed with PTSD or 

TBI” category.

b

Other is defined as non-applicable, uncharacterized, or unknown.

Our analysis of VA data shows that as of June 2016, of the 13,283 

servicemembers who were separated for misconduct with an “other than 

honorable” characterization and diagnosed with one of the conditions we 

reviewed, 87 percent had not submitted a claim to VA for benefits and 
Page 16 GAO-17-260 DOD Misconduct Separations

services or completed VA’s determination process.32 Twelve percent 

submitted a claim and were determined eligible for at least some VA 

benefits and services, including health care, while the remaining 1 

percent submitted a claim and were determined ineligible for all VA 

benefits and services.33 For additional data on the characterizations of 

service for servicemembers separated for misconduct and previously 

diagnosed with PTSD, TBI, or certain other conditions, see appendix IV.

We found two of the four military services’ policies are inconsistent with 

DOD policies related to screening servicemembers for PTSD and TBI 

prior to separation and training servicemembers on the early detection of 

mild TBI symptoms in the deployed setting. In contrast, we found that the 

counseling policies for all four military services are consistent with DOD 

policy. (See appendix V for more information on the individual policies 

that the Army, Marine Corps, Air Force, and Navy identified as 

implementing applicable DOD policy requirements.)

Screening servicemembers prior to separation. We found that the 

Marine Corps’ screening policies are consistent with DOD’s screening 

policies, the Army’s policy is consistent but set to expire March 31, 2018, 

and the Air Force’s and Navy’s screening policies are not consistent with 

DOD policy. (See fig. 3.) For the purposes of this review, we compared 

the military services’ screening policies to DOD’s policy governing 

screenings for certain servicemembers deployed overseas in support of a 

contingency operation during the previous 24 months. Our assessment 

was based on the following requirements set forth in DOD’s screening 

policy, which align with applicable statutory requirements:

1. do the military services’ screening policies apply to servicemembers 

diagnosed with PTSD or TBI by a physician, clinical psychologist, 

psychiatrist, licensed clinical social worker, or psychiatric advanced 

practice registered nurse;

 32For the purpose of our analyses, we included only claims submitted and VA 

determinations completed on the day of or after servicemembers were separated for 

misconduct. Servicemembers may have submitted claims and received determinations of 

eligibility from VA for prior periods of service.

33We obtained claims data from VA’s Veterans Benefits Administration on the extent to 

which servicemembers who were administratively separated for misconduct or in lieu of 

trial by court-martial and previously diagnosed with PTSD, TBI, or certain other conditions 

were deemed ineligible by VA for benefits and services.

Some Military 

Services’ Screening 

and Training Policies 

Related to PTSD and 

TBI Are Inconsistent 

with DOD Policy
Page 17 GAO-17-260 DOD Misconduct Separations

2. do the military services’ screening policies apply to servicemembers 

facing administrative separation under conditions other than 

honorable, including those separating in lieu of trial by court-martial;

and

3. do the military services’ screening policies identify an appropriate 

official to review the results of the screening before deciding whether 

the servicemember’s service was “other than honorable?”

We did not assess the military services’ consistency with DOD’s 

screening policy regarding the types of providers eligible to perform 

screenings because at the time of our review, DOD’s policy was

inconsistent with the law in one respect. In particular, DOD’s policy 

permitted physicians to conduct PTSD screenings, whereas the law only 

authorizes clinical psychologists, psychiatrists, licensed clinical social 

workers, and psychiatric advanced practice registered nurses to do so.

34

DOD officials stated that they would take steps to correct this issue, which 

they did on February 27, 2017 by publishing a revised policy that 

removed physicians from the list of providers who can conduct PTSD 

screenings.35

 34Compare 10 U.S.C. § 1177(a)(3) with DODI 1332.14, Encl. 5, Sec. 9, Para. 2 (Dec. 

2014).

35Where a military service’s policy on authorized screening providers appeared to be 

inconsistent with the law, we informed appropriate officials of the issue to enable them to 

review the matter and take action, as appropriate. See Marine Corps Order 1900.16, 

Separation and Retirement Manual, Para. 6110(3)(a) (Aug. 7, 2015) (Marine Corps policy 

that allows physicians to conduct PTSD screening); see also Military Personnel Manual 

1910-702, General Guidance for Separation Authorities, Para. (1)(a)(3) (July 7, 2009) 

(hereinafter MILPERSMAN 1910-702 (July 7, 2009)) and Secretary of the Navy, 

Memorandum: Disability Evaluation System Dual Processing (June 1, 2016) (Navy 

policies that do not specify the providers authorized by statute to conduct PTSD or TBI 

screenings).
Page 18 GAO-17-260 DOD Misconduct Separations

Figure 3: Military Services’ Screening Policy Consistency with Key DOD 

Requirements, as of April 2017

a

We considered a military service’s policy consistent with DOD’s policy as long as a diagnosis by a 

(1) physician, (2) clinical psychologist, (3) psychiatrist, (4) licensed clinical social worker, or (5) 

psychiatric advanced practice registered nurse was sufficient to trigger the screening requirement. 

Where a policy required a screening based upon a PTSD or TBI diagnosis without identifying the 

provider, we interpreted the policy as capturing a diagnosis by any provider, including the five types of 

providers required by DOD.

b

Army’s policy is temporary and will expire in March 2018.

c

Air Force’s policy is temporary and set to expire no later than June 2017.

Specifically we found that:

• The Marine Corps’ screening policy not only meets, but exceeds, key 

DOD policy requirements. In particular, the Marine Corps’ screening 

policy requires screenings for servicemembers who have been 

previously diagnosed with PTSD or TBI or who allege its effects, 

regardless of the characterization of their service or whether they 

served overseas in support of a contingency operation.

• In April 2017, the Army reissued its temporary policy requiring 

separation authorities to ensure screenings for servicemembers 

diagnosed with PTSD or TBI, consistent with DOD policy. The policy 

applies to servicemembers deployed overseas in support of a 

contingency operation during the previous 24 months and who are 

facing administrative separation under conditions other than 

honorable, including those separating in lieu of trial by court-martial. 

While this policy is consistent with DOD’s screening policy, it is set to 

expire on March 31, 2018, and the Army’s permanent separation 
Page 19 GAO-17-260 DOD Misconduct Separations

regulation has not yet been updated to reflect DOD’s screening 

requirements under the statute, as amended.36

• The Air Force’s screening policy, which is set to expire no later than 

June 2017, is inconsistent with DOD’s policy in two respects. First, the 

screening requirement under DOD’s policy extends to 

servicemembers who request separation in lieu of trial by courtmartial, whereas the Air Force’s policy excludes this group. An Air 

Force official told us that PTSD and TBI screenings are, in fact, given 

to this group because separating servicemembers are required to be 

asked about PTSD and TBI symptoms as part of their physical prior to 

separation.37 However, a separation physical does not meet the 

requirements of a PTSD or TBI screening for the purpose of 

determining whether the condition is a possible mitigating factor in the 

separation characterization of servicemembers who request

separation in lieu of trial by court-martial, as required by DOD policy. 

Second, DOD policy requires that any qualifying servicemember who 

is diagnosed with PTSD or TBI by one of five specified provider types, 

including a licensed clinical social worker or psychiatric advanced 

practice registered nurse, must receive a screening to determine 

whether the condition is a potentially mitigating factor in the conduct in 

question. However, Air Force policy does not require such a screening 

unless the diagnosis is made by a doctoral-level provider, thereby not 

recognizing diagnoses made by licensed clinical social workers and 

psychiatric advanced practice registered nurses. An Air Force official 

 36The Army Audit Agency’s May 2016 review of Army compliance with 10 U.S.C. § 1177 

found that “[s]ince the 2014 NDAA amended the provisions of 10 U.S.C. § 1177, Army 

regulations have not been updated to reflect the applicability of 10 U.S.C. § 1177 to 

separations in lieu of trial by court-martial.” See Army Regulation 635-200, Active Duty 

Enlisted Administrative Separations, Para. 1-32 (Sept. 6, 2011).The Army Audit Agency 

noted the existence of relevant sub-regulatory guidance, but still recommended that Armywide regulations be revised to be consistent with the updated legal requirements. While 

the Army has not yet updated its permanent separation regulation implementing 10 U.S.C 

§1177, it has updated another regulation to clarify that separations in lieu of trial by courtmartial are covered by that statute. However, unlike the separation policy set to expire on 

March 31, 2018, the updated regulation does not identify the separation official who must 

review the results of the PTSD or TBI screenings, as required by law and DOD policy. 

Compare Army Regulation 40-501, Standards of Medical Fitness, Para. 8-24a(3) (Dec. 22, 

2016) with All Army Activities Message 026/2017, Required Medical Examination 

Guidance for Soldiers Being Processed for Administrative Separation Under Conditions 

Other Than Honorable (April 2017) (hereinafter cited as ALARACT 026/2017). 

37The Separation History and Physical Examination includes a review of a 

servicemember’s medical history and a physical exam. It is a pre-separation requirement 

for servicemembers who have served at least 180 days. The Separation History and 

Physical Examination facilitates the continuity of care from the DOD to the VA.
Page 20 GAO-17-260 DOD Misconduct Separations

told us that the intent of the policy is to ensure that diagnoses made

by these providers are reviewed and confirmed by doctoral-level 

providers. However, imposing such a condition on the diagnoses 

made by these provider types is inconsistent with DOD policy, which 

recognizes that their diagnoses are sufficient to trigger the screening 

requirement.

• Similar to the Air Force, the Navy’s screening policy excludes 

servicemembers who request separation in lieu of trial by court-martial 

and is likewise inconsistent with DOD’s screening policy. This is 

because the Navy’s separation policy only requires screenings prior to 

involuntary separations, whereas the Navy elsewhere defines a 

separation in lieu of trial by court-martial as a voluntary separation.38

While the Navy, like the Air Force, requires all servicemembers to 

undergo a separation physical that includes questions about PTSD 

and TBI, such a procedure does not meet the requirement of a 

screening for the purpose of assessing whether the condition is a 

mitigating factor in the misconduct charged in the separation case.

Our review did not evaluate whether the inconsistencies we identified had 

an impact on any individual servicemember who may have been entitled 

to a screening. However, unless the military services rectify these 

inconsistences, DOD is at risk that some servicemembers may be 

deprived of a required screening for PTSD or TBI or may not have the 

results of a screening taken into account as a possible mitigating factor in 

their misconduct, as required by DOD policy.

Some of the inconsistencies in military service screening policies appear 

to have existed since DOD updated its screening policy in 2014 in 

response to various statutory amendments enacted in 2013. For example, 

neither the Navy nor Air Force have updated their policies to expressly 

require PTSD or TBI screenings for servicemembers requesting 

separation in lieu of trial by court-martial for the purpose of determining 

whether the condition is a mitigating factor in the servicemember’s 

separation characterization. While each military service has released at 

least one policy update to correspond with other updates made by DOD 

in 2014, none of the Navy or Air Force updates pertain to 

servicemembers requesting separation in lieu of trial by court-martial.

 38See Military Personnel Manuel 1910-100, Reasons for Separation, Para. 1 (Sept. 20, 

2011), and MILPERSMAN 1910-702 (July 7, 2009). Navy officials stated they are in the 

process of updating MILPERSMAN 1910-702 (July 7, 2009) and other relevant policies to 

address the inconsistences GAO identified.
Page 21 GAO-17-260 DOD Misconduct Separations

Training on PTSD and TBI. We found that two of the four military

services’ TBI training policies are inconsistent with DOD policy. (See table 

2.) DOD policy requires the military services to develop effective training 

plans for all servicemembers on the early detection of potential 

concussion or mild TBI in the deployed setting.

39 As previously noted, 

DOD does not have a specific policy that requires training on how to 

identify the symptoms of PTSD.

Table 2: Military Services’ TBI Training Policy Consistency with DOD Requirements, 

as of April 2017

Consistent with DOD policy to ensure 

that all servicemembers receive training 

on detection of potential concussion or 

mild TBI in the deployed setting

Army Yesa

Marine Corps Yes

Air Force No

Navy No

Legend: TBI = traumatic brain injury

Source: GAO analysis of TBI training policies identified by officials from DOD and the military services. | GAO-17-260

a

The Army’s policy is scheduled to expire May 31, 2017.

We found that the Army’s temporary policy and the Marine Corps’ policy

are consistent with DOD’s policy requiring that all servicemembers be 

trained on how to identify mild TBI symptoms in the deployed setting, but 

the Air Force’s and the Navy’s policies are not.40 Specifically we found 

that:

• the Air Force training policy incorporates DOD’s policy by reference 

and assigns responsibility to an Air Force component to develop 

training plans. However, as of April 2017, Air Force officials had not 

identified whether this component had issued such training plans.41

 39See DODI 6490.11(Sept. 18, 2012).

40According to Army officials, they plan to update their TBI training policy, which is set to 

expire on May 31, 2017. Based on our review, such action would be necessary before 

May 31, 2017 to ensure that the Army policy remains consistent with DOD policy.

41The Air Force commented that it does train all deploying servicemembers consistent 

with DOD’s policy. However, we were unable to confirm this fact based upon any 

documented training plans.
Page 22 GAO-17-260 DOD Misconduct Separations

• While the Navy’s TBI policy requires that training be provided to 

certain health providers assigned to military treatment facilities, the 

policy does not extend to all servicemembers in the deployed setting, 

consistent with DOD’s policy.

Because of these inconsistencies, Air Force and Navy increase their risk 

that some servicemembers, including officers, may not be getting trained 

on how to identify symptoms of mild TBI in the deployed setting.

Counseling on potential ineligibility for VA benefits and services. All 

four military services have policies that require all servicemembers to be 

counseled about their eligibility for VA benefits and services at multiple 

points in their career, with additional counseling requirements for 

servicemembers who are requesting separation in lieu of trial by courtmartial.42 This is consistent with DOD policy. All four military services 

established periodic counseling policies, including a requirement for 

servicemembers to be briefed on eligibility for VA benefits and services at 

least twice in the first year of service. All four military services also 

established policies requiring that servicemembers who are considering 

separating in lieu of trial by court-martial be offered legal counsel who, 

among other things, advises the servicemember on his or her potential 

ineligibility for VA benefits and services as a result of an “other than 

honorable” characterization of service.

In our review of separation documents and interviews with installationlevel Army and Marine Corps officials we found that the Army and Marine 

Corps may not have adhered to their own screening, training, and 

counseling policies.

Screening servicemembers prior to separation. Our review of the 

Army and Marine Corps implementation of screening policies identified 

instances in which servicemembers may not always have been screened 

for PTSD and TBI and that screening results may not have been reviewed 

by the appropriate officials as required by the military services’ policies.

 42We evaluated each military services’ policies to determine whether they are consistent 

with the following DOD requirements: (1) servicemembers are to be informed of the 

various types of separations and their possible effects on veterans’ benefits at least twice 

in the first year of service, and (2) servicemembers requesting separation in lieu of trial by 

court-martial are to be offered counsel prior to submitting his or her request.

Army and Marine 

Corps May Not Have 

Adhered to Their Own 

Policies Related to 

PTSD and TBI 

Screening, Training, 

and Counseling
Page 23 GAO-17-260 DOD Misconduct Separations

In our review of separation packets for Army servicemembers, we found 

the following:

• In 2010, the Army issued a policy requiring PTSD and TBI screening 

for servicemembers administratively separated for misconduct who 

meet certain requirements.43 In our review of 46 separation packets 

for Army servicemembers separated for administrative misconduct 

from fiscal years 2011 to 2015, we did not find screening 

documentation in 16 packets, and in 1 of the packets the 

documentation was unclear.44

• In October 2013, the Army updated its policy to require screenings for 

servicemembers separating in lieu of trial by court-martial. In our 

review of 7 separation packets for Army servicemembers separated in 

lieu of trial by court-martial after the policy update to the end of fiscal 

year 2015, we did not find screening documentation in 5 of the 

packets.45

 43The Army issued OTSG/MEDCOM Policy Memorandum 10-040, Screening 

Requirements for Post-Traumatic Stress Disorder (PTSD) and mild Traumatic Brain Injury 

(mTBI) for Administrative Separations of Soldiers on June 9, 2010 in response to DOD 

DTM 10-022 (July 25, 2010). DOD DTM 10-022 (July 25, 2010) required military services 

to develop implementing guidance for the new PTSD and TBI screening requirements 

outlined in 10 U.S.C. § 1177.

44Using Defense Manpower Data Center separation data and Defense Health Agency 

diagnosis data, we requested separation packets of a random, nongeneralizable sample 

of 50 Army servicemembers administratively separated for misconduct and 50 Army 

servicemembers who requested separation in lieu of trial by court-martial during fiscal 

years 2011 through 2015. Our final analysis included 46 packets of servicemembers who 

were administratively separated for misconduct and 48 packets of servicemembers who 

requested separation in lieu of trial by court-martial. We excluded 6 packets from our 

analysis; 3 packets belonged to officers, 2 packets belonged to servicemembers who 

separated under “general” characterization, and 1 packet was a duplicate.

45See All Army Activity Message 262-2013. Required Medical Examination for Soldiers 

Being Processed for Administrative Separation Under Conditions Other Than Honorable

(October 2013) (hereinafter cited as ALARACT 262-2013). ALARACT 262/2013 required 

that PTSD and TBI screenings are to be completed for any servicemember, officer or 

enlisted, pending administrative separation under conditions other than honorable who 

has deployed overseas in support of a contingency operation during the previous 24 

months, and who is diagnosed with PTSD and/or TBI, or who otherwise reasonably 

alleges the influence of such a condition based on their service while deployed. ALARACT 

262/2013 states that the requirements apply to all administrative separations, including 

separations in lieu of trial by court-martial. Furthermore, ALARACT 262/2013 states that 

no servicemember who meets the above requirements will be administratively separated 

until the results of the screening are reviewed by the separation authority.
Page 24 GAO-17-260 DOD Misconduct Separations

• In addition, the Army’s October 2013 update required the separation 

authority to review the screenings prior to making a final separation 

decision. In our review of 21 separation packets for Army 

servicemembers who were administratively separated for misconduct 

or in lieu of trial by court-martial after the policy update to the end of 

fiscal year 2015, we did not find documentation of review by the 

separation authority in 4 of the packets, and in 5 of the packets the 

documentation was unclear. As a result, PTSD or TBI may not have 

been identified as a possible mitigating factor in the separation.

In our review of separation packets for Marine Corps servicemembers, we 

found the following:

• Of those Marine Corps servicemembers who were administratively 

separated for misconduct from fiscal years 2011 to 2015, screening 

documentation was missing for 18 of the 48 separation packets we 

reviewed and in 2 packets the documentation was unclear.46 As such, 

it is unclear whether these Marine Corps servicemembers were 

screened for PTSD and TBI as required under DOD policy.

• In addition, 19 of the 48 separation packets we reviewed did not have 

documented evidence that the appropriate official reviewed the 

screening prior to separation, and in 1 packet the documentation was 

 46Similar to our analysis of Army separation packets, we used Defense Manpower Data 

Center and Defense Health Agency data to request 50 separation packets for Marine 

Corps servicemembers who were administratively separated for misconduct and 18 

separation packets for Marine Corps servicemembers who requested separation in lieu of 

trial by court-martial during fiscal years 2011 to 2015. Our final analysis included 48 

packets of servicemembers who were administratively separated for misconduct and 15 

packets of servicemembers who requested separation in lieu of trial by court-martial. We 

excluded 5 packets from our analysis; in 4 packets, we were unable to determine if the 

servicemember met DOD pre-separation screening requirements because of incomplete 

information in the servicemember’s packet, and 1 packet belonged to a servicemember 

who separated prior to fiscal year 2011.

Of the 15 separation packets for servicemembers who requested separation in lieu of trial 

by court-martial in our analysis, no packet belonged to a servicemember who made his or 

her request after the Marine Corps updated its screening policy to include this type of 

separation.
Page 25 GAO-17-260 DOD Misconduct Separations

unclear.47 As such, we cannot be certain that these Marine Corps 

servicemembers’ screening results were reviewed by the appropriate 

official prior to the servicemembers being separated.

While the absence of documentation does not prove that screenings and 

review by appropriate officials did not occur, it does suggest that Army 

and Marine Corps policies may not have been followed.

In interviews with Army and Marine Corps installation-level defense 

counsel who represent servicemembers, some additional concerns 

regarding the PTSD and TBI screenings were mentioned. For example, 

Marine Corps defense counsel raised concerns that screenings might be 

occurring after key separation recommendations are being made and that 

the tools used to determine whether servicemembers have either 

condition should have a more comprehensive exam for PTSD and TBI. 

During our review of separation packets we found one instance in which a 

screening did not occur before a board was convened; however, the 

board members did discuss PTSD during the proceedings.48 In addition, 

Army and Marine Corps defense counsel raised concerns that providers 

might be pressured by commanders to clear servicemembers.49

 47Marine Corps policy changed between fiscal years 2011-2015 as to which official should 

review the screenings prior to separation. Until fiscal year 2014, the policy stated that the 

separation authority should review the screenings prior to making the final decision. 

Marine Administrative Message 328/10, Requirements for Medical Evaluation of Marines 

Before Involuntary Administrative Separation (June 10, 2010). After fiscal year 2014, 

Marine Corps policy requires the general court-martial convening authority to review the 

screenings and document why the servicemember should be separated and with which 

service characterization in light of the identified PTSD or TBI contributing factor. Marine 

Corps Order 1900.16, Separation and Retirement Manual, Para. 6110(3)(g) (Nov. 26, 

2013). According to Marine Corps policy, the separation authority for most enlisted 

servicemembers is the officer with general court-martial convening authority. The general 

court-martial convening authority in most enlisted separations is the commanding general 

of that unit. In our review of Marine Corps separation packets we looked for 

documentation that the commanding general of the installation acknowledged the results 

of the PTSD and TBI screening results when making his or her recommendation for 

separation.

48Due to the design of our packet review, it was only feasible to identify instances in which 

the timing of the screening in relation to separation recommendations might be an issue. 

To determine if the screening occurred after key recommendations were made, we 

compared the date of the screening with the date of the administrative separation board 

hearing, if the servicemember requested one.

49Although these concerns are anecdotal, we included the information in our report 

because they were raised by defense counsel at more than one installation.
Page 26 GAO-17-260 DOD Misconduct Separations

Training on PTSD and TBI. During our Army and Marine Corps 

installation interviews, we found that some Army officers who should have 

received training on how to identify symptoms of TBI may not have; 

further, installation-level officials for both the Army and the Marine Corps 

could not produce documentation for officers who had received the 

training. During our site visits to the Army installations, noncommissioned 

officers, in particular, told us that they did not receive specific training on 

how to identify symptoms for TBI. In contrast, commissioned officers were 

more likely to recall that they had received the training, often citing the 

officer leadership courses as the way they received the information. 

When we asked officials at both Army and Marine Corps installations for 

documentation of training, officials said that while they have sign-in 

sheets for the servicemembers who participate in the training, they do not 

maintain them or other documentation, such as training logs, at the 

installations because they are not required to do so.

Officers at one of the Army and the Marine Corps installations we visited 

said that other efforts—beyond training courses—to build awareness of 

PTSD and TBI have been helpful.50 In particular, they said that a DODwide initiative to have a mental health provider “embedded” in the units 

has been beneficial in helping them to identify these symptoms in the 

servicemembers under their command. The officers added that 

discussing a servicemember’s behavior with a mental health provider 

often resulted in a medical referral instead of initiating the process for 

separating a servicemember for misconduct.

Counseling on potential ineligibility for VA benefits and services. We 

found instances in which both the Army and the Marine Corps may not 

have adhered to their own counseling policies, specifically prior to 

servicemembers’ request for separation in lieu of trial by court-martial. In 

11 of the 48 packets included in our analysis of Army servicemembers 

who requested separation in lieu of trial by court-martial, we found that 

there was no documented evidence or the evidence was unclear as to 

whether the servicemembers were counseled on their potential ineligibility 

for VA benefits and services.51 Similarly, with respect to the Marine 

 50As previously stated, DOD does not have, nor is it legally required to have, a policy 

requiring the military services to provide training on how to identify the symptoms of 

PTSD.

51One of the separation packets we received for enlisted Army servicemembers who 

requested separation in lieu of trial by court-martial was a duplicate, while another 

belonged to a servicemember separated after the end of fiscal year 2015. Therefore, the 

final number of separation packets included in the analysis was 48.
Page 27 GAO-17-260 DOD Misconduct Separations

Corps, 4 of the 15 packets we reviewed for servicemembers who 

requested separation in lieu of trial by court-martial were missing 

documented evidence that the servicemembers were made aware of their 

potential ineligibility for VA benefits and services. As such, we cannot be 

certain these servicemembers were counseled on potential ineligibility for 

VA benefits and services as required.

Army and Marine Corps installation-level defense counsel said that if a 

servicemember elects to meet with legal counsel prior to requesting 

separation in lieu of trial by court-martial, counsel reviews how receiving 

an “other than honorable” characterization can affect the 

servicemember’s eligibility for VA benefits and services as part of the 

counseling. Officials from both military services also stated that 

servicemembers are counseled on how their characterization of service 

could affect their eligibility for VA benefits and services as part of their 

initial training. Moreover, installation-level officials said that commanders 

at multiple levels discuss the impact of certain characterizations on 

eligibility for VA benefits and services as part of their misconduct 

counseling with servicemembers.52 Marine Corps officials said that early 

counseling is done through one-on-one conversations, and in many cases 

only once the formal separation is about to begin do the counseling 

sessions become documented. However, as previously reported, we 

cannot be certain that counseling policies for separations in lieu of trial by 

court-martial were always implemented as required based on the results 

of our packet review.

DOD does not routinely monitor the military services’ adherence to 

policies for screening servicemembers for PTSD and TBI prior to 

separating them for misconduct, training officers on how to identify 

symptoms of TBI in the deployed setting, and counseling servicemembers 

on eligibility for VA benefits and services. According to DOD officials, the 

expectation is that the military services are responsible for monitoring 

adherence to these polices. While both Army and Marine Corps have 

some data available that could make it possible for them to monitor 

whether their screening, training, and counseling policies are being 

adhered to as required, the two military services are not routinely using 

these data to do so because of limited resources in some instances, 

 52DOD policy requires misconduct counseling and an opportunity to overcome 

deficiencies for certain servicemembers prior to initiating separation. DODI 1332.14, Encl. 

2, Para. 10b (Dec. 4, 2014).

DOD, Army, and 

Marine Corps Do Not 

Routinely Monitor 

Adherence to Policies 

to Address the Impact 

of PTSD and TBI on 

Servicemembers
Page 28 GAO-17-260 DOD Misconduct Separations

according to an official. Federal internal control standards call for 

agencies to establish activities to monitor internal control systems and 

evaluate results. Without monitoring adherence to these policies, the 

military services cannot provide assurance that certain servicemembers 

are screened for PTSD and TBI prior to separation; all servicemembers, 

including officers at all levels, are trained on how to identify symptoms of 

mild TBI in the deployed setting; and servicemembers are counseled 

about VA benefits and services during the separation process.

Screening servicemembers prior to separation. Neither the Army nor 

the Marine Corps routinely monitors whether its screening policies related 

to PTSD and TBI are adhered to. According to an Army headquarters 

official, it is the responsibility of commanders and staff judge advocates at 

each Army installation to review a servicemember’s separation material 

and make sure that the required screening documents are included 

before final separation decisions are made. Such documents can indicate 

whether or not servicemembers have been screened for PTSD or TBI. 

However, the official added that the Army does not have a systematic 

method for monitoring whether certain servicemembers are being 

screened. As previously discussed, we found that screening documents 

were not always included in the Army separation packets that we 

reviewed.

Recent Army audits have found that the Army did not have sufficient 

documentation to demonstrate that it was always considering whether 

PTSD or TBI was a mitigating factor in servicemembers’ behavior prior to 

separating them for misconduct.53 Specifically, the Army Audit Agency 

conducted two audits that reviewed separation and medical records of 

servicemembers who had been separated with a characterization of 

service of “other than honorable” and had been deployed and diagnosed 

with PTSD or TBI within 24 months of their separation for the period of 

November 1, 2009 through July 31, 2015. The Army Audit Agency found 

that not all of the separation packets it reviewed had documentation 

showing that screening for PTSD and TBI had occurred prior to the 

servicemember’s separation for misconduct.

 53Department of the Army, U.S Army Audit Agency, Soldiers with Mental Health 

Conditions Separated from Active Duty for Misconduct, A-2016-0084-MTM (Fort Belvoir, 

V.A.: May 2016). Department of the Army, U.S Army Audit Agency, Follow-on Audit of 

Soldiers with Mental Health Conditions Separated from Active Duty for Misconduct, A2016-0085-MTM (Fort Belvoir, V.A.: May 2016).
Page 29 GAO-17-260 DOD Misconduct Separations

While the Army does not have a systematic method for monitoring, it does 

have data available that could be used to routinely monitor whether 

screening is occurring. Specifically, the Army has access to 

servicemembers’ medical records and could review the medical records 

of certain servicemembers being separated for misconduct to determine if 

they had been previously diagnosed with PTSD or TBI and therefore 

should be screened. According to Army officials, Army Behavioral Health 

System of Care personnel are building an electronic program that will 

create an automated record of all screenings. Officials added that this 

electronic program is expected to be completed in fiscal year 2017.

In the case of the Marine Corps, officials recognize that monitoring is 

necessary; however, an official told us that the Marine Corps does not 

have sufficient data to routinely monitor whether screenings are 

occurring. The officials told us the Marine Corps was exploring options for 

analyzing separation and medical data to see whether separating 

servicemembers had been screened for PTSD and TBI. The officials 

explained that the Marine Corps has a new electronic system that allows 

commanders at the installation level to input real time information about 

an administrative separation, which can be viewed by officials at Marine 

Corps headquarters. The officials stated that this system could be used to 

help identify separation issues, such as unaccounted for screenings prior 

to a servicemember being separated. However, one of the officials told us 

that the Marine Corps installations are only using the electronic system in 

forty percent of separation cases. Furthermore, the official stated that 

medical personnel would be required to review medical records of certain 

servicemembers to determine if they had been diagnosed with PTSD or 

TBI, but the Marine Corps does not have the resources to hire this 

personnel.54

Training on PTSD and TBI. Although Army and Marine Corps officials 

told us they collect data about the training provided as part of the TBI 

programs, they do not use these data to routinely monitor adherence with 

their training policies. As previously discussed, Army and Marine Corps 

officials told us they collect attendance for the servicemembers, including 

officers, who participate in the trainings. However, according to officials, 

these data are not used to identify officers who may not have received 

training or to routinely monitor whether the Army and Marine Corps are 

adhering to DOD’s policy that all servicemembers receive training on how 

 54Navy personnel provide medical support to the Marine Corps.
Page 30 GAO-17-260 DOD Misconduct Separations

to identify mild TBI symptoms in the deployed setting. Because DOD 

does not have a policy requiring PTSD training, and the military services 

have not developed such policies on their own, there is no policy for the 

DOD and the military services to monitor adherence against.

Counseling servicemembers about VA benefits and services. While 

Army and Marine Corps collect some data about the counseling provided 

to servicemembers, the two military services do not routinely use these 

data to ensure adherence with their counseling policies. For example, 

Marine Corps headquarters officials told us that they collect attendance 

records for the Marine Corps’ 90-day personnel readiness training, which 

includes counseling on VA benefits and services, but the data collected 

are not reviewed to ensure that servicemembers have received the 

required counseling. For the counseling that is provided to 

servicemembers being separated in lieu of trial by court-martial, Army and 

Marine Corps officials told us that documentation of this counseling 

should be included in each servicemember’s separation packet. However, 

officials from both military services told us that servicemembers’ 

separation packets are not reviewed by officials at the military services’ 

headquarters to ensure that counseling is occurring. Similar to how the 

PTSD and TBI screening documents are reviewed, officials explained that 

military staff at the installations should review the separation material to 

make sure that the counseling documents are included. For example, an 

Army headquarters official told us that the Army relies on staff judge 

advocates at the installations to review servicemembers’ separation 

material and make sure that the required counseling documents are 

included prior to a final separation decision. However, as previously 

noted, in our review of a sample of Army and Marine Corps separation 

packets, we found that counseling documents were not always present 

and therefore could not confirm that the counseling had occurred.

DOD’s policies and the policies of the four military services—Army, 

Marine Corps, Air Force, and Navy—are intended to ensure that PTSD 

and TBI are appropriately considered before a servicemember is 

separated for misconduct. However, we found that Air Force and Navy’s 

pre-separation screening and training policies are inconsistent with DOD 

policy. Furthermore, we found that the Army and Marine Corps may not 

always be adhering to their own policies and that monitoring of the 

policies—which could include a review of documentation, data analyses, 

or other oversight mechanisms—by DOD, Army, and Marine Corps is

limited. While we did not review whether the Air Force or Navy adhered to 

or monitored their policies, we identified inconsistencies between their 

Conclusions
Page 31 GAO-17-260 DOD Misconduct Separations

policies and DOD’s policies. As a result of policy inconsistencies and 

limited monitoring, DOD has little assurance that certain servicemembers 

diagnosed with PTSD or TBI receive the required screening and 

counseling prior to being separated for misconduct and that all 

servicemembers, including officers, have been trained on how to identify

symptoms of mild TBI in the deployed setting. Unless the policy 

inconsistencies are resolved and routine monitoring is undertaken to 

ensure adherence, the risk increases that servicemembers may be 

inappropriately separated for misconduct without adequate consideration 

of these conditions’ effects on behavior, separation characterization, or 

eligibility for VA benefits and services.

To increase its assurance that PTSD and TBI are appropriately 

considered prior to separating certain servicemembers from the military 

for misconduct, the Secretary of Defense should take the following five 

actions:

Direct the Air Force and Navy to address inconsistencies with DOD policy 

in their policies related to

• screening certain servicemembers, including servicemembers 

separating in lieu of trial by court-martial, for PTSD and TBI and 

reviewing the results prior to separation for misconduct; and

• training servicemembers, including officers, on how to identify mild 

TBI symptoms in the deployed setting.

Ensure that the military services routinely monitor adherence to policies 

related to

• screening certain servicemembers for PTSD and TBI prior to 

separation for misconduct;

• training servicemembers, including officers, on how to identify mild 

TBI symptoms in the deployed setting; and

• counseling about VA benefits and services during the process of 

separating certain servicemembers for misconduct.

Recommendations for 

Executive Action
Page 32 GAO-17-260 DOD Misconduct Separations

DOD and VA reviewed a draft of this report. DOD provided general 

comments, which are reprinted in appendix VI, and technical comments, 

which we incorporated as appropriate. VA did not provide written 

comments on this report, but the department indicated that it will continue 

to raise awareness of PTSD and TBI programs available to veterans, 

including veterans with a less than honorable discharge.

In its comments, DOD concurred with four of our five recommendations. 

Specifically, DOD agreed with our recommendation to direct the Air Force 

and the Navy to address inconsistencies in their policies related to 

screening certain servicemembers for PTSD and TBI and reviewing the 

results prior to separation for misconduct. DOD also agreed with our 

recommendations to ensure that the military services routinely monitor 

adherence to policies related to screening certain servicemembers for 

PTSD and TBI prior to separation for misconduct; counseling

servicemembers about VA benefits and services during the separation 

process; and training servicemembers, including officers, on how to 

identify mild TBI symptoms. On this last monitoring recommendation 

related to training, based on additional information from DOD we revised 

the language of the original recommendation to clarify that the military 

services should monitor the training provided to servicemembers on how 

to identify mild TBI symptoms in the deployed setting. 

DOD did not concur with our recommendation that it direct the Air Force 

and the Navy to address inconsistencies between their policies and 

DOD’s policy related to training servicemembers on how to identify mild 

TBI symptoms. In its comments, DOD said that because our 

recommendation did not specify that training to identify mild TBI 

symptoms was in the deployed setting, we were in effect creating new 

policy. We have revised the language in our recommendation to clarify 

this point. However, this clarification does not obviate the need for our 

recommendation because the inconsistencies we identified in the Air 

Force and Navy policies were material to their mild TBI training 

requirements in deployed settings. In particular, the Air Force provided no 

documentation of the training plans it was responsible for developing, 

while the Navy’s mild TBI training requirement only applied to certain 

health providers. 

DOD also raised four concerns about our data analysis. First, DOD raised 

concern that data from DOD’s Defense Manpower Data Center (DMDC) 

on the total number of separations were lower than Army and Marine 

Corps data. We obtained our data from DMDC, and over the course of 

Agency Comments

and Our Evaluation
Page 33 GAO-17-260 DOD Misconduct Separations

our audit assessed the reliability of the data provided in several ways, 

including comparing it with published sources and discussing the data 

with officials from the military services and DMDC. Differences between 

DMDC’s and the military services’ data were reviewed and, where 

necessary, explanations were identified and noted. The discrepancy in 

total number of separations noted in DOD’s comments stems largely from 

differences in which servicemembers were included. In their analyses of 

total separations, the Army and the Marine Corps included 

servicemembers who separated from active duty and transferred directly 

to National Guard or Reserve duty, whereas the data provided by DMDC 

that we used for our analysis excluded these servicemembers. We 

excluded these servicemembers because our review focuses on 

servicemembers separating to civilian life. In response to DOD’s concern,

we clarified this exclusion in the report. Further, these military services 

confirmed that DMDC’s misconduct separations data—the data on which 

our findings are based—are consistent with their data. 

Second, DOD raised concern that the number of servicemembers we 

report as having been diagnosed with PTSD or TBI—14,816—is 

inaccurate because of double counting. We disagree. As stated in the 

report, collectively, about 16 percent, or 14,816, of the 91,764 

servicemembers who were separated for misconduct had been 

diagnosed with PTSD or TBI. As we explain in footnote 28, this proportion 

is lower than the sum of the proportion diagnosed with PTSD (8 percent) 

and the proportion diagnosed with TBI (11 percent) because some 

servicemembers had been diagnosed with both conditions. However, in 

response to DOD’s concern, we made additional clarifications in the 

report.

Third, DOD expressed concern about some of the conditions included in 

our group of conditions other than PTSD and TBI that could be 

associated with misconduct. As described in our methodology, we 

developed our list of conditions through conversations with DOD and 

mental health professionals and reviews of relevant publications. We

ultimately selected conditions that could potentially be caused or 

exacerbated by military service, or that could be misdiagnosed as PTSD 

or TBI. For example, one of the reasons we included depressive 

disorders was the discussion of major depressive disorder and 

depressive symptoms in a 2008 RAND study. This study noted that 

depression could be linked to specific war experiences such as loss, and 

affects mood, thoughts, and behavior, but often goes unrecognized and 

unacknowledged. Furthermore, because we understand that there can be 

conflicting evidence on these issues, in key parts of the report we 
Page 34 GAO-17-260 DOD Misconduct Separations

separate discussions of PTSD and TBI data from the data on other health 

conditions. In response to DOD’s concern, we also included additional 

data on PTSD and TBI separately from the data related to other health 

conditions. 

Finally, DOD expressed concern that our use of the word “officials” to 

describe servicemembers’ defense counsel implied that they represented 

the interests of the military services rather than the servicemembers. In 

response, we removed the word “officials” in describing defense counsel.

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense, the Secretary of Veterans Affairs, 

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

Marine Corps, the Assistant Secretary of Defense for Health Affairs, and 

other interested parties. In addition, the report is available at no charge on 

the GAO website at http://www.gao.

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

me at (202) 512-7114 or williamsonr@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this 

report are listed in appendix VI.

Randall B. Williamson

Director, Health Care
Appendix I: Additional Information on GAO’s 

Data Analyses

Page 35 GAO-17-260 DOD Misconduct Separations

To determine the number of servicemembers—officers and enlisted—

separated for misconduct in fiscal years 2011–2015 and diagnosed with 

post-traumatic stress disorder (PTSD), traumatic brain injury (TBI), or 

certain other conditions, we obtained data from the Department of 

Defense’s (DOD) Defense Manpower Data Center (DMDC) and the 

Defense Health Agency (DHA). DMDC provided us with data on total 

separations of active duty servicemembers from the Army, Air Force, 

Marine Corps, and Navy, as well as a list of active duty servicemembers 

who were administratively separated for misconduct or in lieu of trial by 

court-martial from the military services during this timeframe.1 For each 

servicemember who was administratively separated for misconduct or in 

lieu of trial by court-martial, DMDC provided the characterization of 

service upon separation as well as other relevant data.2 For the data on 

total separations and separations for misconduct, we included only 

servicemembers who were separated to civilian life—that is, we excluded 

separations due to factors such as death, joining officer commissioning 

programs, joining military academies, or separating to the National Guard 

 1

To determine which servicemembers were administratively separated for misconduct or 

in lieu of trial by court-martial, DMDC used separation codes identified by the military 

services. Every servicemember who is separated is assigned a separation code that 

identifies the cause of the separation. However, the military services may differ in the 

separation codes they use for the various separation types. We therefore requested that 

each military service provide us with lists of separation codes that could be used for 

servicemembers who are, respectively, administratively separated for misconduct or 

administratively separated in lieu of trial by court-martial. We provided these codes to 

DMDC, and DMDC provided data on each servicemember who was separated under one 

of the codes.

We excluded two of the separation codes provided by the military services from our 

analyses. Specifically, according to Air Force officials, one of the separation codes the Air 

Force uses for administrative separations for misconduct is also used for another 

separation type. A total of 18 separations from the Air Force were performed under this 

code from fiscal years 2011 through 2015. We excluded this code—and therefore these 

18 servicemembers—from our analyses of Air Force separations since the corresponding 

separation type could not be identified. In addition, we did not obtain data from DMDC on 

one of the separation codes the Navy reported using for administrative separations for 

misconduct. However, DMDC officials reported that this code is rarely used and that only 

three Navy servicemembers were separated under the code from October 2013 through 

July 2015.

2

As servicemembers who are administratively separated may only receive “honorable,” 

“general (under honorable conditions),” or “other than honorable” characterizations, we 

excluded any servicemembers that were administratively separated for misconduct or in 

lieu of trial by court-martial as per their separation code but had other characterizations. 

Therefore, we excluded 55 servicemembers who received “bad conduct” or 

“dishonorable/dismissal” characterizations—which are only available to servicemembers 

who are punitively separated through court-martial—from our analyses.

Appendix I: Additional Information on GAO’s 

Data Analyses
Appendix I: Additional Information on GAO’s 

Data Analyses

Page 36 GAO-17-260 DOD Misconduct Separations

or Reserve. If servicemembers had multiple relevant separation dates, we 

used only the most recent date. We excluded Reservists and National 

Guard members because, according to DMDC officials, reliable data were 

not available for the Army Reserve and National Guard. For each 

servicemember who was identified by DMDC as having been 

administratively separated for misconduct or in lieu of trial by courtmartial, DHA provided us with data on whether the servicemember was 

diagnosed with PTSD, TBI, or certain other conditions within the 2 years 

prior to the servicemember’s separation date.3 To determine which 

conditions, in addition to PTSD and TBI, to include in our analysis, we 

reviewed relevant literature and consulted with clinical experts regarding 

the prevalence in the military population of conditions that cause 

behaviors that could contribute to misconduct. The conditions we selected 

are adjustment disorders, alcohol-related disorders, anxiety disorders, 

bipolar disorders, depressive disorders, personality disorders, and 

substance-related disorders.4

To determine how many of the servicemembers who were separated for 

misconduct and previously diagnosed with PTSD, TBI, or certain other 

conditions were potentially ineligible for Department of Veterans Affairs 

(VA) benefits and services, we analyzed the data provided by DMDC on 

servicemembers’ characterizations of service upon separation. In 

addition, we obtained data from VA’s Veterans Benefits Administration on 

the extent to which servicemembers who were administratively separated 

for misconduct or in lieu of trial by court-martial and previously diagnosed 

with PTSD, TBI, or certain other conditions were deemed ineligible by VA 

for benefits and services. Specifically, we provided VA with a list of 

servicemembers who DMDC and DHA data show were administratively 

separated for misconduct or in lieu of trial by court-martial in fiscal years 

2011-2015 and diagnosed within the prior 2 years with PTSD, TBI, or 

another condition included in our study. For each of these 

servicemembers, the Veterans Benefits Administration provided data on 

 3

To identify these diagnoses, DHA used codes from the International Classification of 

Diseases, 9th Revision (ICD-9), defining a diagnosis as any relevant ICD-9 code in any 

diagnosis position, regardless of the location or other aspects of the medical encounter. 

While DHA identified diagnosis codes occurring in medical records up to 2 years prior to a 

servicemember’s separation date, initial diagnoses of these conditions may have occurred 

prior to this period.

4

Servicemembers can be involuntarily separated for personality disorder and acute 

adjustment disorder. However, we included these conditions in our review of separations 

for misconduct as there have been reports of PTSD or TBI being misdiagnosed as these 

conditions.
Appendix I: Additional Information on GAO’s 

Data Analyses

Page 37 GAO-17-260 DOD Misconduct Separations

(1) whether the servicemember ever submitted a claim to VA for benefits 

or services, as well as the date of the most recent claim; (2) whether VA’s 

characterization of service determination process was ever completed for 

the servicemember, as well as the completion dates; and (3) the outcome 

of this process each time it was performed—that is, whether the 

servicemember was deemed eligible or ineligible for VA benefits and 

services.5

We assessed the reliability of the data provided by DMDC, DHA, and 

VA’s Veterans Benefits Administration in several ways, including 

discussing the reliability of the data with DOD and VA officials, performing 

electronic tests of the data to identify any outliers or anomalies, reviewing 

relevant documentation, and comparing the data with data from published 

sources. We determined that the data were sufficiently reliable for the 

purposes of our reporting objectives.

 5

Data provided by the Veterans Benefits Administration were as of June 2016. 

According to VA officials, VA’s character of service determination process has three 

possible outcomes. Specifically, VA can determine that servicemembers have one of the 

following: 1) honorable service for VA purposes—that is, they are eligible for all VA 

benefits and services, excluding certain education and burial benefits available only to 

servicemembers who receive “honorable” characterizations of service upon separation; 2) 

a regulatory bar to VA benefits and services—that is, they are eligible for health care 

benefits and services for conditions incurred in or aggravated during the period of service 

for which the VA determination was performed, but ineligible for other VA benefits and 

services; or 3) a statutory bar to VA benefits and services—that is, they are ineligible for 

all VA benefits and services.
Appendix II: Prior Diagnoses for 

Servicemembers Separated for Misconduct 

from Fiscal Years 2011 through 2015

Page 38 GAO-17-260 DOD Misconduct Separations

Table 3 provides additional information on the extent to which 

servicemembers who were separated for misconduct from fiscal years

2011 through 2015 were previously diagnosed with post-traumatic stress 

disorder (PTSD) or traumatic brain injury (TBI), previously diagnosed with 

certain other conditions, or not previously diagnosed with any of the 

conditions. Tables 4 and 5 provide additional information on the extent to 

which servicemembers who were administratively separated for 

misconduct or administratively separated in lieu of trial by court-martial 

from fiscal years 2011 through 2015 were previously diagnosed with the 

individual conditions included in our study.

Table 3: Diagnosis of PTSD or TBI, Certain Other Conditions, or None of the Conditions in Servicemembers Separated for 

Misconduct from Fiscal Years 2011 through 2015

Military 

service Diagnosis status

Number of 

servicemembers 

separated for 

misconduct

Percentage of 

servicemembers 

separated for 

misconducta

Army Previously diagnosed with PTSD or TBI 10303 21%

Previously diagnosed with certain other conditionsb 25111 51

Not previously diagnosedc 13987 28

Air Force Previously diagnosed with PTSD or TBI 1180 10

Previously diagnosed with certain other conditionsb 5124 42

Not previously diagnosedc 5781 48

Marine Corps Previously diagnosed with PTSD or TBI 1991 15

Previously diagnosed with certain other conditionsb 5418 42

Not previously diagnosedc 5599 43

Navy Previously diagnosed with PTSD or TBI 1342 8

Previously diagnosed with certain other conditionsb 6672 39

Not previously diagnosedc 9256 54

All military 

services

Previously diagnosed with PTSD or TBI 14816 16

Previously diagnosed with certain other conditionsb 42325 46

Not previously diagnosedc 34623 38

Legend: PTSD = post-traumatic stress disorder, TBI = traumatic brain injury

Source: GAO analysis of Defense Manpower Data Center and Defense Health Agency data. | GAO-17-260

Notes: The data include active duty servicemembers who were separated for misconduct—including 

administrative separations for misconduct and administrative separations in lieu of trial by courtmartial—as per our analyses of Defense Manpower Data Center data. In addition, the data include 

only diagnoses made within the 2 years prior to a servicemember’s separation date. The other 

conditions included in our study, aside from PTSD and TBI, are adjustment disorders, alcohol-related 

disorders, anxiety disorders, bipolar disorders, depressive disorders, personality disorders, and 

substance-related disorders. 

Appendix II: Prior Diagnoses for 

Servicemembers Separated for Misconduct

from Fiscal Years 2011 through 2015
Appendix II: Prior Diagnoses for 

Servicemembers Separated for Misconduct 

from Fiscal Years 2011 through 2015

Page 39 GAO-17-260 DOD Misconduct Separations

a

This column contains the percentage of servicemembers, within the applicable military service, who 

had the applicable diagnosis status within the 2 years prior to separation for misconduct. The 

percentages within military services may not sum to 100 percent due to rounding.

b

This category does not include servicemembers who were also diagnosed with PTSD or TBI. For the 

purpose of our analyses, we included these servicemembers only in the “diagnosed with PTSD or 

TBI” category.

c

This category consists of servicemembers who were not diagnosed with any of the conditions 

included in our study within the 2 years prior to separation. 

Table 4: Diagnosis of Certain Conditions in Servicemembers Administratively Separated for Misconduct from Fiscal Years 

2011 through 2015

Military 

service Previously diagnosed condition

Number of 

servicemembers 

administratively 

separated for 

misconduct

Percentage of 

servicemembers 

administratively 

separated for 

misconducta

Army Adjustment disorders 19652 45%

Alcohol-related disorders 15265 35

Anxiety disorders 8806 20

Bipolar disorders 863 2

Depressive disorders 11533 26

Personality disorders 1844 4

PTSD 4417 10

Substance-related disorders 12099 27

TBI 6468 15

Air Force Adjustment disorders 3467 29%

Alcohol-related disorders 2302 20

Anxiety disorders 1711 15

Bipolar disorders 185 2

Depressive disorders 2280 19

Personality disorders 437 4

PTSD 416 4

Substance-related disorders 888 8

TBI 790 7

Marine Corps Adjustment disorders 3385 27%

Alcohol-related disorders 3762 30

Anxiety disorders 1812 14

Bipolar disorders 202 2

Depressive disorders 2493 20

Personality disorders 600 5

PTSD 1022 8
Appendix II: Prior Diagnoses for 

Servicemembers Separated for Misconduct 

from Fiscal Years 2011 through 2015

Page 40 GAO-17-260 DOD Misconduct Separations

Military 

service Previously diagnosed condition

Number of 

servicemembers 

administratively 

separated for 

misconduct

Percentage of 

servicemembers 

administratively 

separated for 

misconducta

Substance-related disorders 2263 18

TBI 1226 10

Navy Adjustment disorders 3515 21%

Alcohol-related disorders 4247 25

Anxiety disorders 1751 10

Bipolar disorders 214 1

Depressive disorders 2665 16

Personality disorders 624 4

PTSD 499 3

Substance-related disorders 1929 12

TBI 872 5

All military 

services

Adjustment disorders 30019 35%

Alcohol-related disorders 25576 30

Anxiety disorders 14080 17

Bipolar disorders 1464 2

Depressive disorders 18971 22

Personality disorders 3505 4

PTSD 6354 7

Substance-related disorders 17179 20

TBI 9356 11

Legend: PTSD = post-traumatic stress disorder, TBI = traumatic brain injury

Source: GAO analysis of Defense Manpower Data Center and Defense Health Agency data. | GAO-17-260

Notes: The data include data for active duty servicemembers who were administratively separated for 

misconduct as identified through our analyses of Defense Manpower Data Center data. In addition, 

the data include only diagnoses made within the 2 years prior to a servicemember’s separation date, 

and servicemembers may fall into multiple diagnosis categories if they were diagnosed with multiple 

conditions.

a

This column contains the percentage of servicemembers within the applicable military service who 

were diagnosed with the applicable condition within the 2 years prior to administrative separation for 

misconduct. The percentages do not sum to 100 percent as servicemembers could have been 

diagnosed with multiple conditions or not diagnosed with any of the conditions we reviewed.
Appendix II: Prior Diagnoses for 

Servicemembers Separated for Misconduct 

from Fiscal Years 2011 through 2015

Page 41 GAO-17-260 DOD Misconduct Separations

Table 5: Diagnosis of Certain Conditions in Servicemembers Administratively Separated in Lieu of Trial by Court-Martial from

Fiscal Years 2011 through 2015

Military 

service Previously diagnosed condition

Number of 

servicemembers 

administratively 

separated in lieu of trial 

by court-martial

Percentage of 

servicemembers 

administratively 

separated in lieu of trial 

by court-martiala

Army Adjustment disorders 1914 36%

Alcohol-related disorders 1009 19

Anxiety disorders 1034 19

Bipolar disorders 173 3

Depressive disorders 1306 24

Personality disorders 252 5

PTSD 658 12

Substance-related disorders 845 16

TBI 631 12

Air Force Adjustment disorders 110 36%

Alcohol-related disorders 61 20

Anxiety disorders 67 22

Bipolar disorders 6 2

Depressive disorders 92 30

Personality disorders 18 6

PTSD 31 10

Substance-related disorders 40 13

TBI 22 7

Marine Corps Adjustment disorders 103 27%

Alcohol-related disorders 108 28

Anxiety disorders 56 14

Bipolar disorders 12 3

Depressive disorders 101 26

Personality disorders 28 7

PTSD 53 14

Substance-related disorders 80 21

TBI 35 9

Navy Adjustment disorders 148 29%

Alcohol-related disorders 102 20

Anxiety disorders 84 17

Bipolar disorders 15 3

Depressive disorders 116 23
Appendix II: Prior Diagnoses for 

Servicemembers Separated for Misconduct 

from Fiscal Years 2011 through 2015

Page 42 GAO-17-260 DOD Misconduct Separations

Military 

service Previously diagnosed condition

Number of 

servicemembers 

administratively 

separated in lieu of trial 

by court-martial

Percentage of 

servicemembers 

administratively 

separated in lieu of trial 

by court-martiala

Personality disorders 28 6

PTSD 25 5

Substance-related disorders 67 13

TBI 29 6

All military 

services

Adjustment disorders 2275 35%

Alcohol-related disorders 1280 20

Anxiety disorders 1241 19

Bipolar disorders 206 3

Depressive disorders 1615 25

Personality disorders 326 5

PTSD 767 12

Substance-related disorders 1032 16

TBI 717 11

Legend: PTSD = post-traumatic stress disorder, TBI = traumatic brain injury

Source: GAO analysis of Defense Manpower Data Center and Defense Health Agency data. | GAO-17-260

Notes: The data include data for active duty servicemembers who were administratively separated in 

lieu of trial by court-martial as identified through our analyses of Defense Manpower Data Center 

data. In addition, the data include only diagnoses made within the 2 years prior to a servicemember’s 

separation date, and servicemembers may fall into multiple diagnosis categories if they were 

diagnosed with multiple conditions.

a

This column contains the percentage of servicemembers within the applicable military service who 

were diagnosed with the applicable condition within the 2 years prior to administrative separation in 

lieu of trial by court-martial. The percentages do not sum to 100 percent as servicemembers could 

have been diagnosed with multiple conditions or not diagnosed with any of the conditions we 

reviewed.
Appendix III: Additional Information on 

Separations for Active Duty Servicemembers, 

Fiscal Years 2011 through 2015

Page 43 GAO-17-260 DOD Misconduct Separations

Table 6 provides information on total separations of active duty 

servicemembers from military service from fiscal years 2011 through 

2015. Tables 7 and 8 provide information on administrative separations 

for misconduct and administrative separations in lieu of trial by courtmartial for active duty servicemembers during this timeframe.

Table 6: Total Separations, Active Duty Servicemembers, Fiscal Years 2011 through 2015 

Military 

service

Type of servicemember Fiscal year 

2011

Fiscal year 

2012

Fiscal year 

2013

Fiscal year 

2014

Fiscal year 

2015

Total (Fiscal years 

2011 - 2015)

Army Enlisted 65034 72817 59831 52891 51009 301582

Officer 5790 5904 6270 5416 6808 30188

Total 70824 78721 66101 58307 57817 331770

Air Force Enlisted 27423 26599 27340 34550 25331 141243

Officer 5271 5208 4467 6385 5459 26790

Total 32694 31807 31807 40935 30790 168033

Marine Corps Enlisted 13371 11501 10309 9772 9483 54436

Officer 806 1068 1007 731 735 4347

Total 14177 12569 11316 10503 10218 58783

Navy Enlisted 36541 41897 34576 31778 32596 177388

Officer 3476 4041 3409 3581 3907 18414

Total 40017 45938 37985 35359 36503 195802

All military 

services

Enlisted 142369 152814 132056 128991 118419 674649

Officer 15343 16221 15153 16113 16909 79739

Total 157712 169035 147209 145104 135328 754388

Source: GAO analysis of Defense Manpower Data Center data. | GAO-17-260

Notes: The data include data on servicemembers’ most recent separations to civilian life, including 

retirements. Other separations, such as those due to death, joining officer commissioning programs, 

or separating to the National Guard or Reserve, have been excluded. The “officer” category includes 

warrant officers. Army and Marine Corps officials reported that according to their data, additional 

servicemembers were separated during this time frame. The differences in the Defense Manpower 

Data Center and the military services’ data may stem from factors such as variations in the 

methodology used to define separations to civilian life.

Appendix III: Additional Information on 

Separations for Active Duty Servicemembers, 

Fiscal Years 2011 through 2015
Appendix III: Additional Information on 

Separations for Active Duty Servicemembers, 

Fiscal Years 2011 through 2015

Page 44 GAO-17-260 DOD Misconduct Separations

Table 7: Administrative Separations for Misconduct, Active Duty Servicemembers, Fiscal Years 2011 through 2015

Military 

service

Type of servicemember Fiscal year 

2011

Fiscal year 

2012

Fiscal year 

2013

Fiscal year 

2014

Fiscal year 

2015

Total (Fiscal years 

2011-2015)

Army Enlisted 8849 10479 9254 8115 6612 43309

Officer 106 131 195 194 131 757

Total 8955 10610 9449 8309 6743 44066 

Air Forcea Enlisted 2634 2519 2278 2246 1965 11642

Officer 21 16 22 35 44 138

Total 2655 2535 2300 2281 2009 11780 

Marine Corps Enlisted 2994 2800 2525 2163 1939 12421

Officer 37 35 47 39 41 199

Total 3031 2835 2572 2202 1980 12620

Navyb Enlisted 3781 3667 3132 2975 2682 16237

Officer 117 96 92 109 113 527

Total 3898 3763 3224 3084 2795 16764 

All military 

services

Enlisted 18258 19465 17189 15499 13198 83609 

Officer 281 278 356 377 329 1621 

Total 18539 19743 17545 15876 13527 85230

Source: GAO analysis of Defense Manpower Data Center data. | GAO-17-260

Notes: The data include data on servicemembers’ most recent separations to civilian life, including 

retirements. Other separations, such as those due to death, joining officer commissioning programs,

or separating to the National Guard or Reserve, have been excluded. The “officer” category includes 

warrant officers.

a

According to Air Force officials, one of the separation codes the Air Force uses for administrative 

separations for misconduct is also used for another separation type. A total of 18 separations from 

the Air Force were performed under this code from fiscal year 2011 through fiscal year 2015. We 

excluded this code—and therefore these 18 servicemembers—from our analyses of Air Force 

separations since the corresponding separation type could not be identified.

b

One of the separation codes the Navy reported using for administrative separations for misconduct is 

excluded from our analyses. However, Defense Manpower Data Center officials reported that this 

code is rarely used and that only three Navy servicemembers were separated under the code from 

October 2013 through July 2015.
Appendix III: Additional Information on 

Separations for Active Duty Servicemembers, 

Fiscal Years 2011 through 2015

Page 45 GAO-17-260 DOD Misconduct Separations

Table 8: Administrative Separations In Lieu Of Trial by Court-Martial, Active Duty Servicemembers, Fiscal Years 2011 through 

2015 

Military 

service

Type of servicemember Fiscal year 

2011

Fiscal year 

2012

Fiscal year 

2013

Fiscal year 

2014

Fiscal year 

2015

Total (Fiscal years 

2011-2015)

Army Enlisted 1314 1160 1037 613 563 4687

Officer 24 88 178 199 159 648

Total 1338 1248 1215 812 722 5335 

Air Force Enlisted 54 46 49 65 77 291

Officer 2 0 3 4 5 14

Total 56 46 52 69 82 305 

Marine Corpsa Enlisted 266 109 0 0 0 375

Officer 2 7 3 1 0 13

Total 268 116 3 1 0 388 

Navy Enlisted 160 120 69 78 75 502

Officer 0 3 1 0 0 4

Total 160 123 70 78 75 506 

All military 

services

Enlisted 1794 1435 1155 756 715 5855 

Officer 28 98 185 204 164 679 

Total 1822 1533 1340 960 879 6534

Source: GAO analysis of Defense Manpower Data Center data. | GAO-17-260

Notes: The data include data on servicemembers’ most recent separations to civilian life, including 

retirements. Other separations, such as those due to death, joining officer commissioning programs, 

or separating to the National Guard or Reserve, have been excluded. The “officer” category includes 

warrant officers.

a

While the data from the Defense Manpower Data Center indicated that there were no administrative 

separations in lieu of trial by court-martial for enlisted Marine Corps servicemembers from fiscal years 

2013 through 2015, Marine Corps officials reported that enlisted servicemembers were 

administratively separated in lieu of trial by court-martial in those years, although less frequently than 

in fiscal year 2011 and fiscal year 2012. The differences between the Defense Manpower Data 

Center and Marine Corps data may stem from factors such as variations in the methodology used to 

define separations to civilian life.
Appendix IV: Characterization of Service for 

Servicemembers Separated for Misconduct 

from Fiscal Years 2011 through 2015 and 

Previously Diagnosed with PTSD, TBI, or 

Certain Other Conditions

Page 46 GAO-17-260 DOD Misconduct Separations

Tables 9 and 10 provide information on characterization of service for 

servicemembers who were administratively separated for misconduct or 

administratively separated in lieu of trial by court-martial from fiscal years 

2011 through 2015 and diagnosed within the 2 years prior to separation 

with post-traumatic stress disorder (PTSD), traumatic brain injury (TBI), or 

certain other conditions.

Table 9: Characterization of Service for Servicemembers Administratively Separated for Misconduct, Fiscal Years 2011 

through 2015, by Diagnosis

Military 

service

Characterization 

of service

Previously

diagnosed with 

PTSD or TBI

Previously

diagnosed with 

certain other 

conditionsa

Not previously 

diagnosed with 

PTSD, TBI, or 

certain other 

conditions

Total 

servicemembers 

administratively

separated for 

misconduct

Number Percent Number Percent Number Percent Number Percent

Army Honorable 415 4% 638 3% 356 3% 1409 3%

General 8219 89 21096 91 9970 87 39285 89

Other than 

honorable 617 7 1401 6 854 7 2872 7

Otherb 27 <1 151 <1 322 3 500 1

Total 9278 100 23286 100 11502 100 44066 100

Air Force Honorable 21 2% 103 2% 67 1% 191 2%

General 1066 94 4697 94 5351 95 11114 94

Other than 

honorable 46 4 195 4 188 3 429 4

Otherb 0 0 9 <1 37 1 46 <1

Total 1133 100 5004 100 5643 100 11780 100

Marine 

Corps

Honorable 65 3% 124 2% 91 2% 280 2%

General 472 25% 901 17 698 13 2071 16

Other than 

honorable 1378 72 4234 80 4646 85 10258 81

Otherb 3 <1 3 <1 5 <1 11 <1

Total 1918 100 5262 100 5440 100 12620 100

Navy Honorable 58 4% 234 4% 274 3% 566 3%

General 578 45 2983 46 3594 40 7155 43

Other than 

honorable 427 33 2179 34 3500 39 6106 36

Otherb 231 18 1078 17 1628 18 2937 18

Total 1294 100 6474 100 8996 100 16764 100

All military 

services

Honorable 559 4% 1099 3% 788 3% 2446 3%

General 10335 76 29677 74 19613 62 59625 70

Appendix IV: Characterization of Service for 

Servicemembers Separated for Misconduct from Fiscal 

Years 2011 through 2015 and Previously Diagnosed 

with PTSD, TBI, or Certain Other Conditions
Appendix IV: Characterization of Service for 

Servicemembers Separated for Misconduct 

from Fiscal Years 2011 through 2015 and 

Previously Diagnosed with PTSD, TBI, or 

Certain Other Conditions

Page 47 GAO-17-260 DOD Misconduct Separations

Military 

service

Characterization 

of service

Previously

diagnosed with 

PTSD or TBI

Previously

diagnosed with 

certain other 

conditionsa

Not previously 

diagnosed with 

PTSD, TBI, or 

certain other 

conditions

Total 

servicemembers 

administratively

separated for 

misconduct

Number Percent Number Percent Number Percent Number Percent

Other than 

honorable 2468 18 8009 20 9188 29 19665 23

Otherb 261 2 1241 3 1992 6 3494 4

Total 13623 100 40026 100 31581 100 85230 100

Legend: PTSD = post-traumatic stress disorder, TBI = traumatic brain injury

Source: GAO analysis of Defense Manpower Data Center and Defense Health Agency data. | GAO-17-260

Notes: The data include data on active duty servicemembers who were administratively separated for 

misconduct as identified through our analyses of Defense Manpower Data Center data. In addition, 

the data include only diagnoses made within the 2 years prior to a servicemember’s separation date. 

The conditions included in our analyses, aside from PTSD and TBI, are adjustment disorders, 

alcohol-related disorders, anxiety disorders, bipolar disorders, depressive disorders, personality 

disorders, and substance-related disorders.

a

This category does not include servicemembers who were also diagnosed with PTSD or TBI. For the 

purpose of our analyses, we included these servicemembers only in the “diagnosed with PTSD or 

TBI” category.

b

The “other” category includes servicemembers whose characterization of service was 

“uncharacterized,” “unknown,” or “not applicable.”
Appendix IV: Characterization of Service for 

Servicemembers Separated for Misconduct 

from Fiscal Years 2011 through 2015 and 

Previously Diagnosed with PTSD, TBI, or 

Certain Other Conditions

Page 48 GAO-17-260 DOD Misconduct Separations

Table 10: Characterization of Service for Servicemembers Administratively Separated in Lieu of Trial by Court-Martial, Fiscal 

Years 2011 through 2015, by Diagnosis

Military 

service

Characterization

of service

Previously

diagnosed with 

PTSD or TBI

Previously

diagnosed with 

certain other 

conditionsa

Not previously 

diagnosed with 

PTSD, TBI, or certain 

other conditions

Total 

servicemembers 

administratively 

separated in lieu of 

trial by court-martial

Number Percent Number Percent Number Percent Number Percent

Army Honorable 86 8% 135 7% 159 6% 380 7%

General 162 16 175 10 184 7 521 10

Other than honorable 764 75 1483 81 2005 81 4252 80

Otherb 13 1 32 2 137 6 182 3

Total 1025 100 1825 100 2485 100 5335 100

Air Force Honorable 0 0 0 0% 0 0 0 0

General 6 13% 6 5 5 4% 17 6%

Other than honorable 41 87 114 95 133 96 288 94

Otherb 0 0 0 0 0 0 0 0

Total 47 100 120 100 138 100 305 100

Marine 

Corps

Honorable 4 5% 0 0% 3 2% 7 2%

General 10 14 9 6 10 6 29 7

Other than honorable 59 81 147 94 146 92 352 91

Otherb 0 0 0 0 0 0 0 0

Total 73 100 156 100 159 100 388 100

Navy Honorable 0 0 0 0% 0 0 0 0

General 4 8% 6 3 8 3% 18 4%

Other than honorable 36 75 162 82 205 79 403 80

Otherb 8 17 30 15 47 18 85 17

Total 48 100 198 100 260 100 506 100
Appendix IV: Characterization of Service for 

Servicemembers Separated for Misconduct 

from Fiscal Years 2011 through 2015 and 

Previously Diagnosed with PTSD, TBI, or 

Certain Other Conditions

Page 49 GAO-17-260 DOD Misconduct Separations

Military 

service

Characterization

of service

Previously

diagnosed with 

PTSD or TBI

Previously

diagnosed with 

certain other 

conditionsa

Not previously 

diagnosed with 

PTSD, TBI, or certain 

other conditions

Total 

servicemembers 

administratively 

separated in lieu of 

trial by court-martial

Number Percent Number Percent Number Percent Number Percent

All military 

services

Honorable 90 8% 135 6% 162 5% 387 6%

General 182 15 196 9 207 7 585 9

Other than honorable 900 75 1906 83 2489 82 5295 81

Otherb 21 2 62 3 184 6 267 4

Total 1193 100 2299 100 3042 100 6534 100

Legend: PTSD = post-traumatic stress disorder, TBI = traumatic brain injury

Source: GAO analysis of Defense Manpower Data Center and Defense Health Agency data. | GAO-17-260

Notes: The data include data on active duty servicemembers who were administratively separated in 

lieu of trial by court-martial as identified through our analyses of Defense Manpower Data Center 

data. In addition, the data include only diagnoses made within the 2 years prior to a servicemember’s 

separation date. The conditions included in our analyses, aside from PTSD and TBI, are adjustment 

disorders, alcohol-related disorders, anxiety disorders, bipolar disorders, depressive disorders, 

personality disorders, and substance-related disorders. Percentages may not sum to 100 percent due 

to rounding.

a

This category does not include servicemembers who were also diagnosed with PTSD or TBI. For the 

purpose of our analyses, we included these servicemembers only in the “diagnosed with PTSD or 

TBI” category.

b

The “other” category includes servicemembers whose characterization of service was 

“uncharacterized,” “unknown,” or “not applicable.”
Appendix V: Military Services’ Policies that 

Address the Impact of PTSD and TBI on the 

Separation of Servicemembers for Misconduct

Page 50 GAO-17-260 DOD Misconduct Separations

All four military services have policies related to screening 

servicemembers for post-traumatic stress disorder (PTSD) and traumatic 

brain injury (TBI) prior to separation; training servicemembers, including 

officers, on how to identify mild TBI symptoms in the deployed setting; 

and counseling servicemembers on eligibility for Department of Veterans 

Affairs (VA) benefits and services. Table 11 provides a brief description of 

the screening requirements outlined in the Department of Defense (DOD) 

and the military service policies. Table 12 illustrates selected DOD and 

military service policies that include requirements for training on mild TBI

in the deployed setting.

1 Finally, Table 13 outlines the policies that require 

counseling for servicemembers.

Table 11: Military Services’ Policies Related to Screening Servicemembers Prior to Separation for Misconduct

DOD or military 

services Number Date Description

DOD DODI 1332.14 Encl. 5, Sec. 

9 

December 4, 2014 DOD policy outlines the administrative separation process for 

enlisted servicemembers, including screening and review 

requirements outlined in 10 U.S.C. § 1177.

Army AR 635-200 Para. 1-32 September 6, 2011 Army’s policy on enlisted administrative separations. It 

requires servicemembers being administratively separated 

for misconduct to undergo a mental status evaluation.

AR 40-501 Para. 8-24 December 22, 2016 Army’s policy on medical fitness standards for induction, 

enlistment, appointment, and retention. It requires PTSD and 

TBI screenings for servicemembers who meet the 

requirements outlined in 10 U.S.C. § 1177, including 

servicemembers requesting separation in lieu of trial by 

court-martial. 

ALARACT 026/2017 April 2017 Army policy, set to expire in March 2018, on PTSD and TBI 

screenings including identifying the appropriate officials who 

should review PTSD and TBI screenings, how they should 

document their review, and requiring PTSD and TBI 

screenings for servicemembers requesting separation in lieu 

of trial by court-martial.

Marine Corps MCO 1900.16 Para. 6110 November 26, 2013

August 7, 2015

Marine Corps updated its separation policy in 2013 to include 

PTSD and TBI screening and review requirements.

The 2015 update states that PTSD and TBI screening and 

review requirements apply to servicemembers requesting 

separation in lieu of trial by court-martial.

Air Force AFI 36-3208 Guidance 

Memorandum

June 24, 2016 In 2016 the Air Force renewed its policy from June 2015. 

 1

The policies reviewed were identified by officials from DOD and the military services as 

providing training on how to identify symptoms of traumatic brain injury as part of the 

Traumatic Brain Injury programs.

Appendix V: Military Services’ Policies that 

Address the Impact of PTSD and TBI on the 

Separation of Servicemembers for Misconduct
Appendix V: Military Services’ Policies that 

Address the Impact of PTSD and TBI on the 

Separation of Servicemembers for Misconduct

Page 51 GAO-17-260 DOD Misconduct Separations

DOD or military 

services Number Date Description

Navy MILPERSMAN 1900-808 April 13, 2005 Navy policy requires that servicemembers be given a 

complete physical examination within 6 months of 

separation. 

MILPERSMAN 1910-702 July 7, 2009 Navy policy requires separation authorities to review a 

servicemember’s record for certain characteristics prior to 

administrative separation. Specifically the separation 

authority should check if the servicemember served in an 

imminent danger pay area in the previous 2 years. Also if the 

servicemember has been diagnosed with PTSD and TBI, 

then a determination must be made as to whether either one 

is a contributing factor for the reason for separation. These 

requirements apply only to involuntary separations, not 

voluntary separations such as separation in lieu of trial by 

court-martial. 

Secretary of the Navy 

Memo 

July 1, 2016 This Navy policy permits Disability Evaluation System 

processing for certain involuntary administrative separations 

and requires referral to a specified authority in certain cases 

that could result in an “other than honorable” service 

characterization.

Legend: DOD = Department of Defense, PTSD = post-traumatic stress disorder, TBI = traumatic brain injury

Source: GAO analysis of Department of Defense and military polices. | GAO-17-260
Appendix V: Military Services’ Policies that

Address the Impact of PTSD and TBI on the 

Separation of Servicemembers for Misconduct

Page 52 GAO-17-260 DOD Misconduct Separations

Table 12: Military Services’ Policies Related to Training Servicemembers on How to Identify Mild Traumatic Brain Injury in the 

Deployed Setting

DOD or military 

services Number Dates Description

DOD DODI 6490.11 Encl. 2, Para. 

6

September 18, 2012 Instruction directs the military services to develop and 

support effective training plans for line leadership and 

servicemembers on early detection of potentially 

concussive events/mild TBI in the deployed setting and 

to develop policies and procedures consistent with this 

instruction.

Army HQDA EXORD 165-13 Para. 

3.B.2.B.3

June 2013

(expires May 31, 

2017)

Policy requires one-time and annual training for all 

servicemembers on identifying concussion/mild TBI in 

the garrison setting.

Marine Corps MARADMIN 294/12, Para. 

5.D

May 2012 Policy requires training all servicemembers on mild TBI

in the deployed setting upon entry, predeployment, and 

annually.

Air Force AFI 44-102 March 2015 Policy states that Air Force personnel will support DODI 

6490.11, requires the Air Force Surgeon General to 

provide the required policies and training on TBI, and 

requires all deployed medical personnel to follow the 

medical guidance outlined in DODI 6490.11.

Navy NAVMED Memorandum September 9, 2011 Policy requires certain medical providers and personnel 

in military treatment facilities to be trained on TBI.

Legend: DOD = Department of Defense, TBI = traumatic brain injury

Source: DOD analysis of TBI training policies identified by officials from DOD and the military services. | GAO-17-260
Appendix V: Military Services’ Policies that 

Address the Impact of PTSD and TBI on the 

Separation of Servicemembers for Misconduct

Page 53 GAO-17-260 DOD Misconduct Separations

Table 13: Military Services’ Policies Related to Counseling on Potential Ineligibility for Benefits and Services from the 

Department of Veterans Affairs

DOD or military 

services Number Date Description

DOD DODI 1332.14 Encl. 3

Encl. 5, Sec. 8

December 4, 2014 DOD policy outlines the process for servicemembers to 

request separation in lieu of trial by court-martial. The 

policy includes a requirement that servicemembers be 

offered counsel and acknowledge that an “other than 

honorable” characterization is authorized, which can have 

negative consequences.

DOD policy requires military services to provide periodic 

explanation of the different types of separations and 

provide information on how certain actions can affect a 

veteran’s benefits, amongst other things.

Army AR 635-200 Para. 10-2

Chap. 17

September 6, 2011 Army policy requires that servicemembers requesting 

separation in lieu of trial by court-martial be offered 

counsel prior to making their request. If elected, the 

counseling should include the potential negative effects 

associated with an “other than honorable” separation. If 

the servicemember does not elect to receive counsel, he 

or she must acknowledge the potential negative effects 

his or her request might have on benefits.

Army policy requires that commanders periodically 

counsel servicemembers throughout their career on the 

negative consequences associated with an “other than 

honorable” discharge, including eligibility for VA benefits 

and services. This counseling should occur multiple times 

during a servicemember’s career including twice within the 

first year of service. 

Marine Corps MCO 1900.16

Para. 6419

Para. 6103

August 7, 2015 Marine Corps policy requires that servicemembers 

requesting separation in lieu of trial by court-martial be 

offered counsel prior to making their request. If elected, 

the counseling should include the potential negative 

effects associated with an “other than honorable” 

separation. If the servicemember does not elect to receive 

counsel, he or she must acknowledge the potential 

negative effects his or her request might have on benefits.

Marine Corps policy requires that commanders 

periodically counsel servicemembers throughout their 

career on the negative consequences associated with an 

“other than honorable” discharge, including eligibility for 

VA benefits and services. 
Appendix V: Military Services’ Policies that 

Address the Impact of PTSD and TBI on the 

Separation of Servicemembers for Misconduct

Page 54 GAO-17-260 DOD Misconduct Separations

DOD or military 

services Number Date Description

Air Force AFI 36-3208 Para. 4.3

Para. 1.23

June 24, 2016 Air Force policy requires that servicemembers requesting 

separation in lieu of trial by court-martial be offered 

counsel prior to making their request. If elected, the 

counseling should include the potential negative effects 

associated with an “other than honorable” separation. If 

the servicemember does not elect to receive counsel, he 

or she must acknowledge the potential negative effects 

his or her request might have on benefits.

Air Force policy requires that commanders periodically 

counsel servicemembers throughout their career on the 

negative consequences associated with an “other than 

honorable” discharge, including eligibility for VA benefits 

and services.

Navy MILPERSMAN 1910-106

1910-010

May 31, 2005

September 20, 2011

Navy policy requires that servicemembers requesting 

separation in lieu of trial by court-martial be offered 

counsel prior to making their request. If elected, the 

counseling should include the potential negative effects 

associated with an “other than honorable” separation. If 

the servicemember does not elect to receive counsel, he 

or she must acknowledge the potential negative effects 

his or her request might have on benefits.

Navy policy requires that commanders periodically 

counsel servicemembers throughout their career on the 

negative consequences associated with an “other than 

honorable” discharge, including eligibility for VA benefits 

and services. 

Legend: DOD = Department of Defense

Source: GAO analysis of Department of Defense and military polices. | GAO-17-260
Appendix VI: Comments from the Department 

of Defense

Page 55 GAO-17-260 DOD Misconduct Separations

Appendix VI: Comments from the 

Department of Defense
Appendix VI: Comments from the Department 

of Defense

Page 56 GAO-17-260 DOD Misconduct Separations
Appendix VI: Comments from the Department 

of Defense

Page 57 GAO-17-260 DOD Misconduct Separations
Appendix VI: Comments from the Department 

of Defense

Page 58 GAO-17-260 DOD Misconduct Separations
Appendix VII: GAO Contact and Staff 

Acknowledgments

Page 59 GAO-17-260 DOD Misconduct Separations

Randall B. Williamson (202) 512-7114 or williamsonr@gao.gov

In addition to the contact name above, Karin Wallestad, Assistant 

Director, Deitra H. Lee, Analyst-In-Charge, Priyanka Sethi Bansal, 

Carolyn Fitzgerald, Krister Friday, Q. Akbar Husain, and Jennifer Rudisill 

made key contributions to this report. Also contributing were Christine 

Davis, Cynthia Grant, Dae Park, Vikki Porter, Steven Putansu, and James 

Whitcomb.

Appendix VII: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100260)
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