MILITARY 

EDUCATION

Improved Oversight 

and Management 

Needed for DOD’s 

Fellowship and 

Training-with-Industry 

Programs

Report to Congressional Committees

April 2012

GAO-12-367

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-367, a report to 

congressional committees

April 2012

MILITARY EDUCATION

Improved Oversight and Management Needed for 

DOD's Fellowship and Training-with-Industry 

Programs

Why GAO Did This Study

The Department of Defense (DOD), 

which includes the military services, 

selects mid- to upper-career-level 

military officers to participate in 

fellowship and training-with-industry 

programs conducted at non-DOD 

organizations such as universities, 

think tanks, private corporations, 

federal agencies, and Congress. For 

some fellowships, the military 

departments pay a fee or tuition to the 

host organization. GAO was directed to

review DOD’s use of these programs. 

GAO’s objectives were to determine: 

(1) the statutory provisions that 

authorize DOD’s fellowship and 

training-with-industry programs for 

military officers, (2) the extent of the 

Office of the Secretary of Defense’s 

(OSD) visibility over these programs, 

and (3) the extent to which the services 

are able to determine that they derive 

benefits from these programs. GAO 

analyzed relevant laws and DOD 

policies, collected data, and 

interviewed OSD and military service 

officials on their oversight and 

management roles and responsibilities 

for these programs.

What GAO Recommends

GAO is making 11 recommendations 

to DOD for improving oversight and 

management of DOD’s fellowship and 

training-with-industry programs—for 

example, submitting DOD-required 

annual reports and performing servicerequired program reviews—that would 

enhance OSD’s visibility over the 

programs and better position DOD to

determine the extent to which it derives 

benefits from them. In response to a 

draft of this report, DOD concurred with 

the 11 recommendations and stated its

action plan to implement the 

recommendations.

What GAO Found

GAO determined that DOD primarily uses two explicit statutory authorities—

section 2603 of Title 10 of the United States Code, which authorizes 

servicemembers to accept fellowships from certain organizations, and section 

2013 of Title 10 of the United States Code, which authorizes the training of 

servicemembers at nongovernmental facilities—for its fellowships and trainingwith-industry programs for military officers. For two specific types of 

fellowships—Legislative and Interagency—the underlying authorities are less 

explicit than they are for the others. 

OSD has limited visibility over its fellowship and training-with-industry programs 

for several reasons. First, OSD has not developed a mission statement that 

would clearly define the respective key purposes for these programs. Having a 

clear mission statement is critical because it defines an organization’s purpose in 

language that states desired outcomes. Additionally, OSD has not consistently 

enforced its requirement for the military departments to provide an annual report 

on fellowship and training-with-industry programs. Further, not all fellowship and 

training-with-industry programs have a designated office within each department 

for preparing the annual report. OSD’s visibility is also limited by not having a 

reliable inventory of these various programs, and by not having a clear and 

commonly shared definition of a fellowship. Without improved oversight, OSD’s 

visibility over the military departments’ compliance with its requirements 

governing these programs will remain limited. Additionally, visibility is limited over 

the legislative fellowship program in particular because oversight responsibilities 

are not clearly delineated, and because OSD does not have documented criteria 

for the placement of DOD fellows with the offices of congressional committees 

and members. OSD officials agree that such criteria would be helpful since it 

does not have enough available fellows to meet the full congressional demand.

The military services are not well positioned to determine the extent of the 

benefits they are deriving from their participation in these programs for four 

principal reasons. First, not all of the services conduct periodic program reviews, 

as are required for some programs. In addition, the reviews that are conducted 

are not comprehensive in that they do not assess the program against program 

goals using quantifiable performance measures, review the needs that prompted 

the program, incorporate feedback from fellows into the review, or document the 

results of the review. Second, they do not have clear guidance as to what 

qualifies as a postfellowship assignment—an assignment that uses the skills and 

knowledge developed during the fellowship program—or criteria for when such 

assignments can be postponed or waived, thus limiting the extent the services’ 

are able to determine they are deriving benefits from these programs. Third, the 

services do not know their overall program costs, so it is difficult to know whether 

these programs are cost-effective. Finally, some of the services do not have

memoranda of understanding with the non-DOD host organizations, such as 

think tanks, so they cannot be assured that expectations are clearly understood 

and the intended benefits are obtained. Without better management controls, the 

services’ ability to determine the benefits of these programs will remain limited. 

However, service officials believe that they obtain benefits from fellowships and 

training-with-industry programs.

View GAO-12-367. For more information, 

contact Brenda S. Farrell at (202) 512-3604 or 

farrellb@gao.gov.
Page i GAO-12-367 Military Education

Letter 1 

Background 3

DOD Uses Several Statutory Authorities for Fellowship and 

Training-with-Industry Programs 10

OSD Has Limited Visibility over Fellowship and Training-withIndustry Programs 13

Military Services Are Not Well Positioned to Determine the Extent 

of the Benefits from These Programs 23

Conclusions 40

Recommendations for Executive Action 40

Agency Comments and Our Evaluation 42

Appendix I Scope and Methodology 45

Appendix II Life-cycle Phases of a Fellowship Program 50

Appendix III Military Service Guidance on Fellowship and Training-with-Industry 

Programs 52

Appendix IV Ethics Guidance Provided to Fellows 53

Appendix V Comments from the Department of Defense 55

Appendix VI GAO Contact and Staff Acknowledgments 60

Tables

Table 1: Offices within Each Service Involved in Management of 

Fellowship and Training-with-Industry Programs 16

Table 2: Number of DOD Fellows and Training-with-Industry 

Participants for Fiscal Years 2007 through 2011 19

Contents
Page ii GAO-12-367 Military Education

Table 3: Number of Congressional Requests for DOD Legislative 

Fellows and the Number That DOD Provides, Academic 

Years 2009-2010 through 2011-2012 23

Table 4: Military Service Requirement for Periodic Program 

Reviews 25

Table 5: Military Service Guidance on Fellowships and Trainingwith-Industry Programs 52

Figures

Figure 1: Selected Military Educational Opportunities and Career 

Progression 7

Figure 2: Fellowship Program Life-cycle 50

Abbreviations

DOD Department of Defense

OSD Office of the Secretary of Defense

USD P&R Under Secretary of Defense for Personnel and Readiness

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Page 1 GAO-12-367 Military Education

United States Government Accountability Office

Washington, DC 20548

April 20, 2012

Congressional Committees

The Department of Defense (DOD), which includes the military services, 

selects mid- to upper-career-level1 military officers to participate in 

fellowship and training-with-industry programs at non-DOD organizations 

such as universities, think tanks,2 private corporations, federal agencies, 

and Congress. For some fellowships, the military departments pay a fee 

or tuition to the host organization. According to DOD, the department’s 

intent for its fellowship program is to help fulfill a present need, 

anticipated requirement, or future capability that contributes to the 

effectiveness of the participating Military Department and DOD. 

Congressional interest in these programs has grown, in part due to an 

increase in the number of military officers participating in one particular 

program—the Legislative Fellowship—starting in 2008.3

 

1 The fellowship and training-with-industry programs we reviewed were generally available 

to officer levels at the intermediate level of O-3 to O-4, and at the senior level of O-5 to 

O-6. With the exception of the Marine Corps Legislative Fellowships, we did not identify 

fellowship and training-with-industry programs available to officer levels of O-1, O-2, O-7, 

and above during the course of our review, nor did DOD officials identify such programs. 

We were 

directed, in the Senate report accompanying a bill for the National 

Defense Authorization Act for Fiscal Year 2011, to review DOD 

educational and legislative fellowships as well as training-with-industry 

programs and to report to the congressional defense committees. 

Accordingly, we examined these programs to determine: (1) the statutory 

provisions that authorize DOD’s fellowship and training-with-industry 

programs for military officers, (2) the extent of the Office of the Secretary 

of Defense’s (OSD) visibility over these programs, and (3) the extent to 

which the military services are able to determine that they derive benefits 

from these programs.

2 For the purposes of this report, a think tank is defined as nonprofit organizations that 

conduct public policy research and analysis. We used the service’s categorization of 

whether or not an organization was a think tank or an academic institution. 

3 DOD provided Congress with a report on legislative fellowships in 2009 as directed in 

Senate Report 110–335 accompanying a bill for the National Defense Authorization Act 

for Fiscal Year 2009. DOD also provided the Senate Armed Services Subcommittee on 

Personnel with a report on fellowships at think tanks and training-with-industry programs 

in 2010.

 
 

Page 2 GAO-12-367 Military Education

To address our first objective, we researched and analyzed relevant legal 

authorities for DOD to use fellowship and training-with-industry programs, 

reviewed DOD and service regulations and guidance related to these 

programs, and interviewed relevant DOD attorneys and received written 

responses to questions on DOD’s use of these authorities. For our 

second objective, we collected and analyzed available service data on the 

numbers and types of fellowships and training-with-industry programs 

offered from fiscal years 2007 through 2011; interviewed officials in OSD, 

particularly with the offices of the Under Secretary of Defense for 

Personnel and Readiness (USD P&R), and the Assistant Secretary of 

Defense for Legislative Affairs; and collected and reviewed DOD-required 

service annual reports. For the third objective, we interviewed officials 

within the four military services and reviewed DOD and service guidance 

related to these programs. Most of our interviews centered on obtaining 

information about roles and responsibilities related to overseeing and 

managing fellowship and training-with-industry programs,4

 

4 We focused our discussions with the services on fellowship and training-with-industry 

programs for military officers governed under DOD Instruction 1322.06, Fellowships, 

Scholarships, Training-with-Industry (TWI), and Grants for DOD Personnel (Nov. 15, 

2007). While we did collect some data on the number of participants in fellowships that are 

governed primarily under other instructions, the focus of our review is on fellowships and 

training-with-industry programs that are governed under DOD Instruction 1322.06.

and 

particularly on activities that provide means of ensuring that DOD 

received benefits from these programs. More specifically, we collected 

information on service program goals, program reviews, costs of the 

programs, and memoranda of understanding between the services and 

host organizations. We found the fellowship and training-with-industry 

data provided to us by the services on the number of participants in these 

programs to be sufficiently reliable regarding contextual information on 

the minimum number of participants; however, these data do not allow us 

to provide actual totals. We conducted this performance review from 

March 2011 through April 2012 in accordance with generally accepted 

government auditing standards. Those standards require that we plan 

and perform the audit to obtain sufficient, appropriate evidence to provide 

a reasonable basis for our findings and conclusions based on our audit 

objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives. 

(See app. I for a more detailed description of our scope and 

methodology.)
 

Page 3 GAO-12-367 Military Education

DOD’s fellowship and training-with-industry programs comprise a few of 

the several vehicles DOD uses to provide training and education to its 

military officers to develop and advance their careers while in the military. 

Officers have educational opportunities throughout their careers, both 

within and outside of the military educational system. These include 

attendance at intermediate- and senior-level military schools, as well as 

participation in graduate programs to obtain advanced degrees. 

Fellowship and training-with-industry programs constitute another type of 

professional development that officers may receive in addition to or in lieu 

of attendance at a military school.

To provide guidance to the services on participation in a fellowship or 

training-with-industry program, USD P&R issued DOD Instruction 

1322.06.5

• Universities. For example, Tufts University, a private university in 

Massachusetts, hosts fellows from the military services within the 

International Security Studies Program at its Fletcher School, Tufts’ 

graduate school in international affairs. Fellows at the Fletcher School 

focus on research and writing requirements and participate in 

activities both inside and outside of the classroom. The Marine Corps 

Fellows may receive a master’s degree through this program.

Under this instruction, a fellowship is defined as an assignment 

in which selected DOD personnel work away from DOD to gain education 

or experience of value to both the DOD component and the gaining 

organization. Military officers can participate in a variety of types of 

fellowships at host organizations such as universities, think tanks, 

corporations, federal agencies, and congressional committees or member 

offices. Most of these fellowships are limited to a duration of no longer 

than 12 months. The following types of organizations can host fellowship 

and training-with-industry participants:

• Think tanks. For example, the Brookings Institution, a nonprofit think 

tank based in Washington, D.C., has hosted fellows under its 21st 

Century Defense Initiative—one of Brookings’ research projects. 

 

5 DOD Instruction 1322.06, Fellowships, Scholarships, Training-with-Industry (TWI), and 

Grants for DOD Personnel (Nov. 15, 2007). While DOD Instruction 1322.06 governs most 

DOD fellowships, some of DOD’s fellowships are administered as part of other DOD 

programs. For example, the Secretary of Defense Corporate Fellowship Program is 

administered separately under DOD Instruction 1322.23, Secretary of Defense Corporate 

Fellows Program (SDCFP) (May 20, 2011).

Background 

Fellowship and Trainingwith-Industry Programs
 

Page 4 GAO-12-367 Military Education

This initiative focuses on the future of war, U.S. defense needs and 

priorities, and the defense system. Fellows from the military services 

spend a year at Brookings researching and publishing on defense 

topics and provide policy feedback to help craft realistic, applicable 

policy recommendations for the military services. Fellows at Brookings 

may also elect to attend courses to obtain an executive certificate in 

public leadership, for an additional fee.

• Corporations. For example, as part of the Secretary of Defense 

Corporate Fellowship Program, these fellows are trained at the 

executive level to learn how the host corporations use innovative 

practices and technology to plan, organize, and manage, and how 

these business practices could be applied within the military services. 

The fellows shadow corporate executives and write a paper on their 

observations and experiences upon completion of the fellowship.

• Federal agencies. For example, the United States Agency for 

International Development is one of the federal agencies that host 

fellows from the Army Interagency Fellowship program and from the 

Commandant of the Marine Corps Fellowships program. Federal 

agency fellows are placed with departments or agencies to develop a 

more thorough understanding of the host agency’s mission, culture, 

capabilities, and procedures. The Army, Marine Corps, and Air Force 

currently send fellows to other federal departments or agencies.

• Congressional committees or members’ offices, as part of DOD’s 

Legislative Fellowship program. This program offers officers an 

educational opportunity to learn more about the legislative process by 

being placed with various committees, or with the staff of the House or 

Senate Majority or Minority Leader, or with the staff of the Speaker of 

the House.6

 

6 DOD Instruction 1322.06 states that Legislative Fellowship nominees must be assigned 

to one of the following staffs: a Defense oversight committee (Senate or House Armed 

Services Committee) or appropriations subcommittee (Senate or House Appropriations 

Committee—Defense); an intelligence oversight committee (Senate Select Committee on 

Intelligence or House Permanent Subcommittee on Intelligence); Senate Homeland 

Security and Governmental Affairs; House Homeland Security; Senate Foreign Relations; 

House Foreign Affairs; Senate or House Veterans Affairs; the staff of the House or Senate 

Majority or Minority leader; or the staff of the Speaker of the House. 

In addition, the Army sends its legislative fellows to 

George Washington University to obtain Masters’ degrees in 

Legislative Affairs. The Navy, Marine Corps, and Air Force offer their 

officers the opportunity to take courses for credit or to receive a 
 

Page 5 GAO-12-367 Military Education

certificate in Legislative Affairs at the Georgetown’s Government 

Affairs Institute.7

Fellows pursue individual research and writing projects in consultation 

with host organization experts or faculty, and they may elect to become 

involved in host organization projects and participate in conferences, 

seminars, or classes. In addition, fellows share operational and service 

insights with host organization staff. Some university and think tank host 

organizations charge the military departments a fee or tuition for hosting 

fellows.

In addition to fellowship programs, DOD offers training-with-industry 

programs.8

DOD continues to provide officers participating in both fellowships and 

training-with-industry programs their normal pay and allowances. 

In exchange, after their participation, officers participating in most of the 

fellowships discussed in this report incur an active duty service 

commitment of three times the length of the term they spent in the 

fellowship or training-with-industry program.

The DOD instruction defines training-with-industry as a 

nondegree-producing program designed to provide training or skills in 

best business procedures and practices not available through existing 

military or advanced civilian schooling for identifiable DOD requirements.

The instruction states that there must be an existing need or desired 

future capability fulfilled by the gained training-with-industry experience.

The military departments generally do not pay corporations a fee or tuition 

to host training-with-industry participants.

 

7 Legislative and interagency fellowships are different from assignments known as details 

in that they include educational opportunities not found in details. For example, a 

legislative fellowship includes course work and a research paper, and a legislative detail 

does not. In addition, details are governed by DOD Directive 1000.17, Detail of DOD 

Personnel to Duty Outside the Department of Defense (Jan. 12, 2012). 

8 The Marine Corps does not currently offer a training-with-industry program.
 

Page 6 GAO-12-367 Military Education

Within DOD’s professional military educational system, officers are 

afforded several key opportunities.9 At an officer level of O3,10 selected 

officers could attend primary level education, generally at the Branch, 

warfare, or staff specialty schools. At the level of O4,11 selected officers 

attend intermediate level education, generally at the service’s command 

and staff college or an equivalent military school. At the level of O5 or 

O6,12

Military officers may participate in fellowships as either an alternative or a 

supplement to their professional military education, as shown in figure 1. 

Three of the services—the Army, the Marine Corps, and the Air Force—

grant professional military educational credit for some of their fellowship 

programs at the intermediate or senior level.

selected officers attend senior-level education, generally at the 

service’s war college or at an equivalent military school. Officers may 

earn graduate degrees upon completing their intermediate- or senior-level 

education at a military school. They additionally have other opportunities 

throughout their careers to earn graduate degrees; for example, officers 

may apply to attend a college or university to receive a master’s or PhD 

degree in a graduate educational program.

13 The Air Force, for example, 

grants professional military education credit for all of its intermediate- and 

senior-level fellowships. These fellowships replace an officer’s 

in-residence intermediate or senior professional military education.14

 

9 Professional military education opportunities are also available at officer levels O-1, O-2, 

and officer levels O-7 and above. Because the fellowship and training-with-industry 

programs we reviewed were available to officer levels O-3 to O-6, we provided information 

for professional military education at those levels.

 

10 Officer level O3 corresponds to the rank of captain in the Army, Air Force, and Marine 

Corps, and lieutenant in the Navy. 

11 The officer level 04 corresponds to the rank of major in the Army, Air Force, and Marine 

Corps, and lieutenant commander in the Navy.

12 Officer level O5 corresponds to the rank of lieutenant colonel in the Army, the Marine 

Corps, and the Air Force, and commander in the Navy. The officer level O6 corresponds 

to the rank of colonel in the Army, the Marine Corps, and the Air Force, and captain in the 

Navy.

13 The Navy does not grant professional military education credits to its officers for its 

intermediate- or senior-level education, or its fellowships.

14 Officers may also complete the intermediate- or senior-level education through 

nonresident learning programs, where the officer takes required courses online though 

correspondence or through a blended seminar program consisting of online and seminar 

study.

Professional Military 

Education 
 

Page 7 GAO-12-367 Military Education

One service program—the Army Legislative Fellowship Program—grants 

a degree.

Figure 1: Selected Military Educational Opportunities and Career Progression

Notes: This figure excludes some fellowships or other training opportunities, such as the White House 

Fellowships, the Secretary of Defense Corporate Fellowships, and training-with-industry programs. 

With the exception of the Arroyo Rand Fellowship, the Legislative Fellowships, and the Council on 

Foreign Relations Fellowships, each fellowship program is comprised of various host organizations. 

Also, for some fellowship opportunities, eligibility is extended to noncommissioned officers.

a

The Joint Forces Staff College includes the intermediate and senior Advanced Joint Professional 

Military Education, and the senior Joint Advanced Warfighting School.

When fellowship programs are provided in lieu of attendance at a military 

school, the participants are generally prohibited from also attending the 

corresponding in-residence military school program. For example, a 

fellow who attends a senior-level fellowship and is granted senior-level 
 

Page 8 GAO-12-367 Military Education

professional military education credits is prohibited from attending a 

senior in-resident War College program. Unlike most fellowships, DOD’s 

training-with-industry programs exist outside of the professional military 

educational system. These opportunities do not grant professional military 

education credits; instead, they are considered a supplemental 

professional development and training experience in private sector 

practices that are not available through existing military education and 

training programs.

USD P&R has overall responsibility for fellowship and training-withindustry policy for fellowship programs that fall under DOD Instruction 

1322.06.15 This Instruction covers most of the fellowship and trainingwith-industry programs in our review.16 As specified in the instruction, 

each military departmental secretary has oversight and management 

responsibilities for that department’s programs, with the exception of the 

Legislative Fellowship Program. For that program, each department 

selects nominees, whose names are then sent to USD P&R for 

approval.17

 

15 DOD Instruction 1322.06, Fellowships, Scholarships, Training-With-Industry (TWI), and 

Grants for DOD Personnel (Nov. 15, 2007).

The Office of the Assistant Secretary of Defense for 

Legislative Affairs places these officers with congressional committees or 

16 DOD Instruction 1322.06 does not cover certain fellowship programs that are 

administered separately; for example, the Secretary of Defense Corporate Fellowship 

Program or medical fellowships.

17 OSD has certain congressional reporting requirements concerning legislative 

fellowships. The Secretary of Defense is required by section 1104 of the John Warner 

National Defense Authorization Act for Fiscal Year 2007 (Pub. L. No. 109-364 (2006)) to

report to Congress quarterly on members of the Armed Forces and DOD civilian 

employees who have served continuously in the legislative branch for more than 

12 consecutive months in one or a combination of covered legislative fellowships. USD 

P&R officials provided us information on the five times they have reported to Congress 

since 2007. Although officials we met said that they had believed the quarterly report 

requirement to be a contingent one—that is, such a report only had to be submitted when 

the circumstance of an extended fellowship occurred, in March 2011, DOD’s Office of 

General Counsel informed USD P&R that a quarterly report is required even if the 

circumstances of an extended fellowship did not occur. USD P&R officials said they will 

report quarterly even if there have been no extended fellowships. Also, section 1104 

requires the Secretary of Defense to report to the defense and appropriations committees 

if a member of the Armed Forces is assigned to a legislative detail or fellowship as a last 

tour of duty before retirement or separation from the Armed Forces. Officials stated they 

have yet to submit such a report because a DOD fellow retiring or separating immediately 

after a legislative fellowship has not occurred to the best of their knowledge.

Roles, Responsibilities, 

and Guidance
 

Page 9 GAO-12-367 Military Education

with various congressional staffs. Additionally, some of DOD’s fellowship 

programs are administered separately; for example, the Secretary of 

Defense Corporate Fellowship Program and the Medical Professional 

Fellowship Program are administered under two other, separate DOD 

instructions,18

The DOD instruction

with different OSD offices having oversight and policy 

responsibilities for them. The Secretary of Defense Corporate Fellowship 

Program is managed by a director who is part of the National Defense 

University, under the authority, direction, and control of DOD’s Deputy 

Chief Management Officer, subject to certain exceptions. The Assistant 

Secretary of Defense for Health Affairs, under USD P&R, is responsible 

for monitoring compliance with DOD Instruction 6000.13 and providing 

additional guidance for medical fellowships, and the secretaries of the 

military departments are responsible for administering these programs.

19

 

18 DOD Instruction 1322.23, Secretary of Defense Corporate Fellows Program (SDCFP) 

(May 20, 2011) and DOD Instruction 6000.13, Medical Manpower and Personnel (June 

30, 1997).

states that the secretaries of the military 

departments are responsible for properly managing the skills gained by 

the participants in the fellowship program, and for ensuring that current 

assignments utilizing the fellowships and training-with-industry positions 

meet the intent of the program and continue to meet military department 

and DOD requirements or anticipated needs. The instruction also states 

that participants in fellowships and training-with-industry should have an 

immediate follow-on utilization tour upon completion, but that this 

requirement can be delayed or waived by a military department, as 

necessary. Utilization tour assignments are generally based upon the 

area of expertise that the fellowship or training-with-industry program is 

intended to develop. For example, utilization tour assignments for 

legislative fellows are conducted primarily within the services’ offices of 

legislative liaison or legislative affairs, or within another office that 

interacts with Congress. The utilization tours for other fellowships vary 

depending on the host organization or subject-matter expertise of the 

program. For example, a fellow who attends a university or think tank with 

a program on national security issues and strategy may be assigned to a 

utilization tour in a strategy, policy, and planning office. Fellowships with a 

more specific focus will generally have more specific utilization 

19 DOD Instruction 1322.06, Fellowships, Scholarships, Training-with-Industry (TWI), and 

Grants for DOD Personnel (Nov. 15, 2007).

Postfellowship Assignments
 

Page 10 GAO-12-367 Military Education

assignments. A fellow at a host organization with a cyber or nuclear focus 

may be assigned to a utilization tour involving the development of 

strategies for cyber or nuclear warfare. Training-with-industry participants 

are generally used in positions directly related to a corporation’s area of 

expertise. For example, a training-with-industry participant at a private 

company that specializes in logistics and the transportation of items may 

be later assigned to a DOD position in supply chain management.

The military departments are responsible for the management of their 

respective fellowship and training-with-industry programs (see app. II on 

the life-cycle phases of a fellowship program for a more detailed 

description). In addition to statutory authorities and the DOD instruction, 

the military services also have their own guidance or regulations covering 

their respective legislative fellowship, nonlegislative fellowship, and 

training-with-industry programs (see app. III for a list of service guidance).

We determined that DOD uses several statutory authorities for its 

fellowships and training-with-industry programs for military officers. 

Primarily, it uses two explicit statutory authorities. However, for two types 

of fellowships—legislative and interagency—the underlying authorities are 

less explicit than they are for the others.

We determined that DOD’s authority to pursue fellowships at non-DOD 

educational institutions, foundations, and corporations derives primarily 

from section 2603 of Title 10 of the United States Code, which authorizes 

servicemembers to accept fellowships from certain organizations, and 

section 2013 of Title 10 of the United States Code, which authorizes the 

training of servicemembers at nongovernmental facilities. Generally, 

DOD’s fellowships and training-with-industry programs are conducted 

under one or both of these authorities.

DOD Uses Several 

Statutory Authorities 

for Fellowship and 

Training-with-Industry 

Programs

DOD Primarily Uses Two 

Explicit Statutory 

Authorities 
 

Page 11 GAO-12-367 Military Education

Section 260320 allows servicemembers, subject to regulations,21

To create fellowship and training-with-industry programs with a variety of 

nongovernmental facilities, DOD also uses provisions in section 2013 that 

authorize it to enter into agreements or other arrangements for the 

training of servicemembers with nongovernmental organizations such as 

medical, scientific, technical, educational, research, or professional 

institutions, foundations, or organizations—in addition to the business, 

commercial, or industrial firms, corporations, or other nongovernmental 

facilities, as defined by section 2013. These agreements or other 

arrangements are not subject to certain requirements normally applicable 

to government contracts.

to accept 

a fellowship offered by a corporation, fund, foundation, or educational 

institution that is organized primarily for scientific, literary, or educational 

purposes, and the benefits may be accepted by the member in addition to 

the member’s military pay and allowances subject to certain conditions. 

The member is required to agree in writing to serve on active duty after 

completion of the fellowship for a period of at least three times the length 

of the period of the education or training.

22

 

20 Section 2603 was originally enacted in 1962 to address concerns that servicemembers 

would be unable to accept prestigious fellowships or scholarships (such as Rhodes 

Scholarships) from certain nongovernmental sources, and to allow DOD to offset its 

training costs in certain circumstances. As a general matter, federal officials (to include 

officers of the armed services) are prohibited from accepting pay or other things of value 

in connection with their government service from nongovernmental sources. See, e.g. 

18 U.S.C. § 209. Section 2603 provides a limited exception to this rule, by allowing DOD 

to offset some of its educational costs, while also allowing servicemembers to accept 

potentially desirable fellowships. When a servicemember accepts a fellowship, 

scholarship, or grant from a qualified source, DOD’s costs for training that servicemember 

are reduced; for example, if DOD planned to send a servicemember to a university 

research center for training, and the servicemember received a paid fellowship at that 

university, section 2603 would allow the servicemember to accept the fellowship, and 

DOD’s costs for the training in question would be reduced commensurately.

Section 2013 also authorizes DOD to pay 

21 Section 2603 provides that fellowships may be accepted under regulations to be 

prescribed by the president or his designee. Executive Order No. 11079 (as amended by 

Ex. Ord. No. 11382, Ex. Ord. No. 12608, and Ex. Ord. No. 13286) expressly designates 

the Secretary of Defense to promulgate regulations under section 2603.The Under 

Secretary of Defense (Personnel and Readiness) promulgated implementing guidance in 

DOD Instruction 1322.06, Fellowships, Scholarships, Training-with-Industry(TWI), and 

Grants for DOD Personnel (Nov. 15, 2007). 

22 For example, agreements or other arrangements entered into under section 2013 are 

not subject to generally applicable advertising requirements for government purchases in 

41 U.S.C. § 6101.
 

Page 12 GAO-12-367 Military Education

expenses in connection with training at nongovernmental facilities in 

addition to the member’s military pay.

Although most of DOD’s fellowships or training-with-industry programs 

are authorized under section 2603 and section 2013, we determined that 

the authorities DOD uses for its military personnel23 to participate in two 

specific types of fellowships—legislative and interagency—are less 

explicit. According to OSD attorneys, DOD’s legislative and interagency 

fellowships for servicemembers are conducted using a combination of 

more general departmental authorities to train personnel. For example, 

these attorneys noted that the secretaries of the military departments 

have the authority to train members of the military services within their 

respective military departments, subject to the authority, direction, and 

control of the Secretary of Defense.24 They also cited other authorities 

related to detailing personnel outside of DOD in support of these 

fellowships. These attorneys cited section 4301 of Title 10 of the United 

States Code as an example that authorizes (among other things) the 

Secretary of the Army to detail members of the Army as students or 

observers at locations such as industrial plants, hospitals, and other 

places, where they would be best suited to acquire knowledge or 

experience in certain specialties.25 These attorneys noted that, because 

legislative and interagency fellowships involve detailing servicemembers 

to “other places” best suited to acquire relevant knowledge, these 

authorities could also be used to support fellowships. OSD attorneys 

further indicated that these statutory sections provide authority to conduct 

legislative and interagency fellowships, but agreed that the authority for 

those specific programs is not as explicit as the authority provided for 

other types of fellowships, or for intra-governmental training of civilians.

 

23 Intragovernmental training of this kind for civilian personnel is authorized by

5 U.S.C. § 4104.

24 Sections 3013, 5013, and 8013 of Title 10 of the United States Code provide that the 

secretaries of the Army, Navy, and Air Force, respectively, are responsible for and have 

the authority necessary to conduct training, among other functions.

25 See also 10 U.S.C. § 9301, which provides similar authority to the Secretary of the 

Air Force.

DOD Uses Less Explicit 

Authorities for Two 

Specific Fellowship 

Programs
 

Page 13 GAO-12-367 Military Education

OSD has limited visibility over its fellowship and training-with-industry 

programs, because (1) OSD has not developed a clear mission statement 

for these programs that defines the programs’ purpose, (2) OSD has not 

consistently enforced its requirement for the military departments to 

provide annual reports on fellowship and training-with-industry programs, 

and (3) not all fellowship and training-with-industry programs have a 

designated office within each department to be responsible for preparing 

information for these programs. In turn, OSD does not have a reliable 

inventory of the various fellowship and training-with-industry programs to 

educate its military officers. The absence of a reliable inventory is due, in 

part, to OSD’s not having a clear definition of a fellowship and the lack of 

a common reporting requirement for the annual report on fellowships and 

training-with-industry to OSD, both of which complicate OSD’s ability to 

develop a reliable inventory. Additionally, OSD has limited visibility over 

one type of fellowship program—legislative—because OSD has not 

clearly delineated roles and responsibilities for overseeing this program 

and has not developed documented criteria for the placement of DOD 

fellows with congressional committees and members. OSD officials agree 

that such placement criteria would be helpful, since DOD does not have 

enough legislative fellows to meet the full congressional demand.

OSD has not developed a mission statement that would clearly define the 

respective key purposes for the legislative and nonlegislative fellowship 

and training-with-industry programs. Having a clear mission statement is 

critical because it defines an organization’s purpose in language that 

states desired outcomes.26 A mission statement ultimately describes why 

an organization exists and constitutes an important element in an 

oversight structure.27

 

26 GAO, Human Capital: A Guide for Assessing Strategic Training and Development 

Efforts in the Federal Government, 

Further, a mission statement is important because it 

serves as a basis for having quantifiable performance goals. DOD’s 

instruction on fellowships and training-with-industry provides a very 

broadly written mission statement for the legislative and training-withindustry programs, but does not provide a mission statement for the 

nonlegislative fellowship program. For the legislative fellowship program, 

the instruction identifies the need for servicemembers to learn the 

operative process of the legislative branch. For the training-with-industry 

GAO-04-546G (Washington, D.C.: Mar. 1, 2004).

27 GAO-04-546G. 

OSD Has Limited 

Visibility over 

Fellowship and 

Training-with-Industry 

Programs

OSD Has Not Developed a 

Clear Mission Statement 

for Fellowship and 

Training Programs
 

Page 14 GAO-12-367 Military Education

program, the instruction identifies the need to develop skills in private 

sector procedures and practices not available through existing military 

or advanced civilian educational and training programs. However, these 

definitions do not identify the purpose of providing participants with 

additional skills and knowledge in terms of enhancing their value to DOD 

throughout their careers. An OSD official stated that establishing a clear 

mission statement would improve its ability to conduct policy oversight of 

DOD’s fellowship and training programs. Without a clearly defined 

mission statement, OSD is not in a position to know the extent to which 

desired program outcomes are being achieved.

Prior to our review, USD P&R did not enforce its requirement that the 

military departments submit an annual report on their program reviews, 

and has not received annual reports for fiscal years 2008 and 2009. Such 

annual reports can enable USD P&R to have increased visibility over 

these programs and can assist in confirming that DOD policy is being 

implemented as expected. DOD Instruction 1322.06 directs USD P&R to 

maintain overall responsibility for DOD fellowship and training-withindustry policy. This instruction also directs the military departments to 

conduct an annual review of their respective fellowship and training-withindustry programs to ensure that they are in compliance, and to submit 

the results of their reviews to USD P&R by January 31 of each year.

Since our review began, USD P&R has taken steps toward enforcing this 

requirement with regard to the fiscal year 2010 reports. 28

• The Army reported only on one type of fellowship for fiscal year 

2010—legislative. According to some Army officials, they did not have 

any records indicating that the requested reports should include their 

nonlegislative and training-with-industry programs—a requirement 

about which they said they did not know until our review brought it to 

their attention.

However, two 

of the departments’ fiscal year 2010 reports were incomplete in that some 

covered only a portion of the programs, and the third department’s report 

was submitted significantly after the deadline. Specific details on these 

reports follow.

 

28 The Army report covered the 2010 calendar year.

OSD Has Not Consistently 

Enforced an Annual 

Reporting Requirement on 

the Respective Military 

Departments’ Programs
 

Page 15 GAO-12-367 Military Education

• The Navy and the Marine Corps, conversely, reported on their 

nonlegislative and training-with-industry programs for fiscal year 2010, 

but not on their legislative fellowships. Further, according to Navy 

program officials, USD P&R did not ask for the annual report in 2008 

and 2009. Navy officials stated that they noticed this requirement in 

2010 while seeking approval for a separate task and brought it to the 

attention of the Assistant Secretary of the Navy for Manpower and 

Reserve Affairs, who then tasked the program office to complete the 

report for the nonlegislative fellowship and training-with-industry 

programs. The Navy and Marine Corps provided their reports to USD 

P&R for the first time in February 2011.

• The Air Force report for fiscal year 2010 was submitted to USD P&R 

in December 2011 (approximately 11 months after the deadline), but 

only after USD P&R officials told Air Force officials in November 2011 

to provide them with a report. The report included general information 

on legislative and nonlegislative fellowships, and on training-withindustry programs.

USD P&R officials acknowledged that they did not request these reports 

from the services, although USD P&R had been requiring these annual 

reports as of the November 2007 revision to their instruction. Unless it 

consistently enforces the requirement for the services to submit the 

annual reports, USD P&R does not have the visibility to fully review the 

services’ fellowship and training-with-industry programs and limits its 

ability to perform its oversight responsibilities.

Certain offices have been designated by their military departments as 

responsible for compiling information on some fellowship programs for the 

OSD-required annual report; however, not all fellowship programs have a 

designated office for compiling this report. Each service has separate 

organizations that manage their legislative fellowship, nonlegislative 

fellowship, and training-with-industry programs, respectively. We 

contacted many different organizations to obtain a comprehensive picture 

of the various phases of the fellowship and training-with-industry 

programs, as shown in table 1 below,. (See app. II on the life-cycle 

phases of a fellowship program, such as monitoring the fellows’ progress 

during the fellowship, ensuring completion, and assigning the fellows to a 

follow-on utilization or postfellowship tour.) For example, we had to gather 

information from seven different organizations within the Army to obtain a 

comprehensive view for just one of that service’s programs—the Army’s 

Senior Service College Fellowships Program.

Not All Programs Have a 

Designated Office for 

Preparing Annual Reports 
 

Page 16 GAO-12-367 Military Education

Table 1: Offices within Each Service Involved in Management of Fellowship and Training-with-Industry Programs

Army

Congressional Operations Division

Combined Arms Center

Department of Academic Affairs Army War college

Interagency Student Division

Leadership Development Division 

Senior Leaders Division 

Strategic Leadership Division

Retirements and Separations Division

Navy

Education Branch

Distribution Management

Graduate Education and Training Placement

Information Dominance Corps

Legislative Liaison Office

Office of Supply Corps Personnel

Strategy Office

Marine Corps

Congressional Fellows Program Office

Marine Corps University

Officer Assignments Branch

Air Force

Congressional Support Branch

Colonel Management Office

Force Development 

Fellowships Program Office

Developmental Education Branch

Officer Promotions, Appointments, and Selective Continuation Branch

Learning Division

Acquisitions Career Management

Source: GAO analysis of DOD information.

Note: For the Secretary of Defense Corporate Fellowship, the services are responsible for selection 

of the fellows and certain limited administrative tasks. The Deputy Chief Management Officer in OSD 

has oversight and supervisory responsibilities over the program, and a director at the National 

Defense University manages the program. 

Although we interviewed officials in numerous offices within each military 

service to obtain a more comprehensive understanding of the various 
 

Page 17 GAO-12-367 Military Education

programs, only some fellowship program offices acknowledged having 

been designated as having responsibility for compiling information on 

their program for the annual report. Three service fellowship programs 

have included the requirement for the annual report in their program 

guidance—the Army Legislative Fellowship Program, the Navy Cyber 

Federal Executive Fellowship Program, and the Legislative Fellowship 

Program. However, the Air Force and Marine Corps legislative fellowship, 

nonlegislative fellowship, and training-with-industry programs and the 

Army and Navy nonlegislative fellowship and training-with-industry 

programs have not formally designated program offices for the annual 

preparation of these reports.

Officials in the policy office of the Air Force and the Navy told us that 

while they have not been formally designated as responsible for compiling 

this report, they anticipate being given the responsibility for reaching out 

to the fellowship and training-with-industry programs to obtain information 

for the report. Prior to the reports being submitted in response to 

congressional inquiries in 2009 and 2010, some program officials said 

that they were not aware that they were responsible for submitting a 

report to USD P&R because they were not tasked as the office 

responsible for this requirement. Without having a designated office within 

each department to take responsibility for reporting requirements for their 

respective fellowship and training-with-industry programs, USD P&R’s 

visibility over departmental compliance with its instruction and relevant 

laws will continue to be limited. In the course of this review, we identified 

an important consequence of USD P&R’s limited visibility over DOD’s 

various fellowship and training programs. By law,29 servicemembers in 

certain fellowships are required to complete a service obligation for a 

period of no less than three times the length of a fellowship. However, 

one Army regulation30

 

29 See 10 U.S.C. § 2603.

for certain nonlegislative fellowship programs 

stipulated a service obligation length that was not in compliance with the 

law or with the DOD instruction governing that program. In that instance, 

the Army was allowing certain officers to meet the service obligation 

requirement for a 1-year fellowship by committing to serve 2 years rather 

than the statutory 3 years. Subsequently, Army officials have informed us 

that they are in the process of taking corrective action to change the Army 

30 Army Regulation 621–7, Education: Army Fellowships and Scholarships (Aug. 8, 1997).
 

Page 18 GAO-12-367 Military Education

guidance based on our finding. USD P&R officials with whom we met 

were unaware of this instance of noncompliance.

USD P&R has not developed a reliable inventory of DOD’s fellowship and 

training-with-industry programs—an inventory that would be useful for 

enabling DOD to know how often, at what cost, and in what capacity it is 

using these alternative educational and training programs for its military 

officers to meet new and emerging skill needs, and to better fulfill its 

mission. We have previously reported31 on the importance of maintaining 

a complete inventory of the type of skills an agency needs to better 

position it to properly assess gaps in its capabilities and to appropriately 

assess risk so it can make informed decisions about the future direction, 

scope, and nature of its efforts and investments in support of emerging 

skill needs. Although USD P&R has collected some of the DOD 

instruction-required annual reports on fellowships and training-withindustry programs, these do not enable it to determine the totality of the 

fellowship participants and programs, or of the needs these programs 

address. We found that these required annual reports did not provide 

consistent and detailed information linking the fellowships with current or 

emerging needs, which are the basis for offering the various types of 

fellowship opportunities. Such information would be useful in helping USD 

P&R develop a robust inventory and identify training and educational 

solutions to fill identified gaps. We collected information, which USD P&R 

was unable to provide us, on program participants from the services 

dating back to 2007,32 and we found that, at a minimum, 1,797 mid- and 

senior-rank officers participated in fellowships and training-with-industry 

programs from fiscal years 2007 through 2011, as shown in table 2.

 

31 GAO, A Guide for Assessing Strategic Training and Development Efforts in the Federal 

Government. GAO-04-546G (Washington, D.C.: March 2004), High-Risk Series: An 

Update, GAO-11-278 (Washington, D.C.: Feb. 2011), and Military Training: DOD Needs a 

Strategic Plan and Better Inventory and Requirements Data to Guide Development of 

Language Skills and Regional Proficiency, GAO-09-568 (Washington, D.C.: June 19, 

2009). 

32 We identified each office that was involved in the fellowship and training-with-industry 

programs and then requested program participant information from these offices.

OSD Has Not Developed a 

Reliable Inventory of 

Fellowship and Trainingwith-Industry Programs 

and Participants
 

Page 19 GAO-12-367 Military Education

Table 2: Number of DOD Fellows and Training-with-Industry Participants for Fiscal Years 2007 through 2011 

Type of program Army Navy Marine Corps Air Force Total by type

Legislative 90 69 46 145 350

Nonlegislative 400 81 68 500 1,049

Training-with-industry 265 6 N/A 127 398

Total by service 755 156 114 772 1,797

Source: GAO analysis of DOD data.

Note: These numbers represent a minimum number of participants and not actual totals.

For some years, the fellows were assigned according to a calendar year or an academic year.

Calendar year fellowships were counted in the corresponding fiscal year.

The DOD instruction on fellowships and training-with-industry defines the 

term fellowship, but we found that usage of the term to describe various 

educational opportunities varies significantly from service to service, thus 

complicating the compilation of a reliable and complete inventory. For 

example, the Air Force increased its total number of fellowships offered 

when it changed the designation of some of its “internships” to 

“fellowships” after adding an interagency rotation requirement to the 

program.33

USD P&R officials said that inconsistent views as to which fellowships 

should be counted—views that reflect the absence of a clear and 

Air Force officials said that they viewed the internship as being 

more aligned with the fellowship description in the DOD instruction, and 

thus changed the designation. Army officials, on the other hand, said that 

their interagency fellowships—similar to those of the Air Force—are 

called fellowships, but are not counted as fellowships for reporting 

purposes. USD P&R officials did not know about the Air Force change 

and stated that they disagreed with it. They observed that the instruction’s 

definition of a fellowship could be made more descriptive to avoid 

ambiguities such as this. In another example, the Navy included the 

Secretary of Defense Corporate Fellows Program in its annual report for 

2010—a program that is governed by a different instruction, overseen by 

the Deputy Chief Management Officer, and managed in coordination with 

the National Defense University director. In this same report, however, 

the Navy did not include its Medical Professional Fellowship Programs, 

which are governed by a separate instruction and managed through the 

Navy Medicine Professional Development Center.

 

33 These internship opportunities are available to Air Force officers. 
 

Page 20 GAO-12-367 Military Education

commonly shared definition of what constitutes a fellowship—could hinder 

the development of an accurate inventory. Officials agreed that a more 

specific, DOD-wide definition of a fellowship, which would explain which 

opportunities warrant using the word “fellowship” in the program title, 

could be helpful. They said they anticipate conducting a review of each 

service’s policies or regulations that focus on fellowships and trainingwith-industry programs, to better ensure that all have the same definitions 

and are counting the programs and participants comparably, and that the 

services’ policies or regulations are in line with DOD Instruction 1322.06. 

This review will become even more important given that DOD will be 

drawing down its force structure and given that program officials within 

the services informed us that they are interested in increasing the number 

of fellowship and training-with-industry opportunities in the future.

The responsibilities of the Office of the USD P&R include ensuring that 

personnel and readiness policies and programs are designed and 

managed to improve standards of performance, economy, and efficiency, 

which would facilitate visibility into its various programs, including DOD 

fellowship and training-with-industry programs. Without a clear definition 

of fellowship and training-with-industry programs, USD P&R’s ability to 

maintain a reliable inventory of participants and thus oversee the service 

obligations associated with these educational fellowship and training-withindustry programs will remain limited.

With regard to the military departments’ required reports on their annual 

reviews of the education and training-with-industry fellowship programs, 

USD P&R has not provided specific instructions as to the information the 

military departments should include. As noted previously, these reports 

did not contain consistent and detailed information on these programs. 

Service officials said that they would benefit from having more detailed 

reporting guidelines to help determine what information would be most 

useful for USD P&R. USD P&R officials said that when they update their 

Instruction in late 2012, they anticipate providing specifics to facilitate 

collection of more consistent information on the number of fellows, on 

their assignments during and after the fellowships, and on the timing of 

their returns to their official duty stations. Detailed guidelines could better 

position USD P&R to fulfill its oversight responsibility for fellowship and 

training-with-industry policy, and to help ensure service adherence to 

policies. Without USD P&R specifying in the DOD instruction common 

reporting requirements for the annual reports, DOD will continue to 

experience challenges in collecting consistent information and developing 

a reliable inventory on these programs.
 

Page 21 GAO-12-367 Military Education

DOD’s Instruction 1322.06 does not delineate specific and clear roles and 

responsibilities for overseeing the fellowship and training programs for the 

Legislative Fellowship Program, and this absence of delineations has in 

some cases resulted in mutually contradictory assumptions by different 

OSD offices with respect to oversight responsibilities. We have previously 

reported that having clearly defined roles and responsibilities can be 

beneficial to address management challenges.34 The absence of defined 

oversight roles and responsibilities for the Legislative Fellowship Program 

has created some conflicting perspectives for two separate offices within 

OSD. For example, officials within the Office of the Assistant Secretary of 

Defense for Legislative Affairs said that although they assign DOD fellows 

to various congressional offices and serve as liaisons between the fellows 

and Congress, they do not have policy oversight responsibility for the 

program. However, officials within USD P&R said that they have 

responsibility for all reporting requirements for this program, but that 

otherwise the legislative affairs office manages the program. Our 

questions about roles and responsibilities concerning the Legislative 

Fellowship Program elicited contradictory information from the two offices, 

with each asserting that the other had policy oversight responsibility.

Although officials within USD P&R have subsequently revised their 

position and said that they do have oversight responsibility, we note that 

this important role is not clearly delineated in the DOD instruction. In the 

absence of clearly delineated roles and responsibilities in DOD’s 

governing instruction, OSD is at risk of not fulfilling its oversight 

responsibilities. USD P&R officials stated that they agree with our 

observation and indicated that they plan to address oversight roles and 

responsibilities for legislative fellowships when they revise the instruction 

in late 2012.

The Office of the Assistant Secretary of Legislative Affairs does not have 

documented criteria for the placement of DOD legislative fellows to 

congressional offices. We have previously reported35

 

34 GAO, Organizational Transformation: Implementing Chief Operating Officer/Chief 

Management Officer Positions, 

that agencies 

should assign employees to host organizations to make the best use of 

GAO-08-34 (Washington, D.C.: Nov. 1, 2007).

35 GAO, Interagency Collaboration: State and Army Personnel Rotation Programs Can 

Build on Positive Results with Additional Preparation and Evaluation, GAO-12-386

(Washington, D.C.: Mar. 9, 2012).

OSD Has Not Clearly 

Delineated Oversight 

Responsibilities for Its 

Legislative Fellowship 

Program

OSD Does Not Have 

Placement Criteria for Its 

Legislative Fellows
 

Page 22 GAO-12-367 Military Education

their skills and help them to develop professionally while addressing host 

organizations’ needs. However, officials in OSD’s legislative affairs office 

said that the placement of DOD fellows with host congressional 

committees or individual congressional member offices is a complicated 

and very challenging process. These officials said that placing DOD 

fellows with congressional offices involves balancing a number of factors, 

such as (1) the fellows’ educational and career needs; (2) the availability 

of fellows each year to a bipartisan and bicameral assembly of 

congressional offices and members; and (3) any specified interests of 

individual congressional members regarding a requested fellow’s military 

service, educational background, and particular field of specialization. 36

While these considerations help inform placement decisions, they do not 

enable DOD to systematically decide and explain its rationale for 

decisions on which congressional offices will receive DOD fellows. These 

officials stated that their primary intent is to provide military officers a 

broadening educational experience. In doing so, however, they have 

found an additional challenge in meeting demand when placing DOD 

legislative fellows in congressional offices because the number of 

legislative fellows requested by congressional committees and members 

has been exceeding the total number of available fellows, as shown in 

table 3.

 

36 The Assistant Secretary of Defense for Legislative Affairs solicits congressional 

leadership offices and members for their interest in a hosting a DOD legislative fellow 

annually. The DOD instruction specifies the Senate and House committees, 

subcommittees, and member offices for which legislative members, such as the staff of 

the Senate Armed Services Committee or House Permanent Subcommittee on 

Intelligence, can request a DOD fellow. According to OSD officials, any member of 

Congress assigned to one of these committees or subcommittees is a potential recipient 

of a DOD legislative fellow. DOD officials also said that the probability of a congressional 

requester receiving a fellow depends on whether the requestor is in a leadership position 

or is a member of a committee or subcommittee, and the extent to which the committee or 

subcommittee has jurisdiction over defense-related matters.
 

Page 23 GAO-12-367 Military Education

Table 3: Number of Congressional Requests for DOD Legislative Fellows and the Number That DOD Provides, Academic 

Years 2009-2010 through 2011-2012

Academic yeara Number of congressional

requests for DOD fellows 

Number of DOD

fellows provided

Number of congressional

requests not filled

2009-2010 110 80 30

2010-2011 91 85 6 

2011-2012 135 83 52

Source: Office of the Assistant Secretary of Defense for Legislative Affairs.

a

The 12 month legislative fellowship typically begins in January and ends in December, to correspond 

with the congressional cycle.

OSD legislative affairs officials said that because OSD does not have 

documented placement criteria, decisions as to which congressional 

offices receive DOD fellows are made on a case-by-case basis and are 

ultimately a judgment call, which can lead to inconsistent dealings with 

congressional offices. They said that they do their best to match the 

educational needs of the DOD fellow with the needs of the congressional 

office, but that there are not enough available fellows to meet the full 

demand. They further stated that these decisions can be difficult to 

defend to a congressional member who is denied a request for a DOD 

fellow, and that it is always difficult to turn down congressional requests.

Without documented placement criteria, OSD’s legislative affairs office 

will continue to have difficulty in ensuring consistency in the department’s 

dealings with interested committees and members of Congress 

requesting DOD fellows. Officials in OSD’s legislative affairs office said 

that having documented placement criteria would help in the decisionmaking process and would better position the office to defend its 

decisions with congressional members who were denied a request for a 

DOD fellow.

The military services believe that they derive benefits from their 

fellowships and training-with-industry programs, but they are not well 

positioned to determine the extent of these benefits for four main reasons. 

First, not all of the services conduct periodic program reviews, as required 

by their service guidance, for some or all of their programs; and the few 

reviews that have been conducted have not been comprehensive. For 

example, they do not ensure that the needs that prompted the program 

and the goals of the program are being met. Second, the services do not 

have clear guidance as to what qualifies as a follow-on utilization tour, or 

criteria for when such a tour can be postponed or waived, and this limits 

their ability to know the extent they are deriving a return on their 

Military Services Are 

Not Well Positioned to 

Determine the Extent 

of the Benefits from 

These Programs
 

Page 24 GAO-12-367 Military Education

educational investment. Third, the services do not know their overall 

program costs, including both direct and indirect costs, and therefore it is 

difficult to know whether these programs are cost-effective. Fourth, some 

of the services do not have written agreements or memoranda of 

understanding with the non-DOD host organizations providing the 

educational opportunity that spell out both parties’ roles and 

responsibilities—thus contributing to unclear expectations about the DOD 

benefit to be derived from these programs. Collectively, these limitations 

diminish the services’ assurances about the benefits they derive from 

their fellowship and training-with-industry programs. The services 

observed, however, that they use certain other program management 

practices to ensure that they derive benefits from these programs.

While each of the services has taken some steps to review its programs, 

none has conducted both periodic and comprehensive reviews of its 

fellowship and training-with-industry programs. For some of the programs, 

there is no requirement to conduct periodic program reviews. With 

respect to fellowship programs, service review requirements vary, and 

compliance with them has been uneven. Further, for those services that 

have conducted program reviews, the reviews have not been 

comprehensive and have not included assessments of the status of the 

program against program goals. As a result, some services have limited 

assurances that their fellowship or training-with-industry opportunities 

meet desired program outcomes, address emerging mission 

requirements, or provide the best venue for developing needed personnel 

skills. We have previously reported on the importance of having 

systematically planned evaluations of training and development 

programs.37 In addition, evaluating programs through periodic and 

comprehensive reviews enables an agency to identify problems and 

improve a program, as needed. The services’ variance in review 

requirements for these programs is shown in table 4.38

 

37 GAO, Human Capital: A Guide for Assessing Strategic Training and Development 

Efforts in the Federal Government, GAO-04-546G (Washington, D.C.: Mar. 1, 2004).

38 The Marine Corps does not currently have a training-with-industry program.

Services Have Not 

Conducted Periodic and 

Comprehensive Program 

Reviews
 

Page 25 GAO-12-367 Military Education

Table 4: Military Service Requirement for Periodic Program Reviews

Military 

service

Legislative 

fellowships must 

be reviewed 

Nonlegislative 

fellowships must be 

reviewed

Training-withindustry must be 

reviewed Time frame for required review

Army Yes Yes No The Army requires an annual review for 

Legislative Fellowships and no less than 

every 3 years for non-legislative fellowships.a

 

Navy Yes Yes No The Navy requires an annual review for 

Legislative and Cyber Federal Executive 

Fellowship Programs, and a minimum of once 

every 2 years for other fellowships.b 

Marine Corps Noc Yes N/A Marine Corps requires nonlegislative 

fellowship host organizations be reevaluated 

annually for recertification and continued 

assignment of fellows.

d

Air Force Yes Yes No Air Force requires all nonlegislative 

fellowships to be reviewed biennially.

e

Source: GAO analysis of military service instructions.

a

Army Regulation 621-7, Army Fellowship Programs and Army Regulation 1-202, Army 

Congressional Fellowship Program.

b

The annual reporting requirement in Bureau of Navy Personnel Instruction 1560.21E, Legislative 

Fellows Program (Nov. 12, 2010) corresponds to the requirement in the DOD instruction for an 

annual report to USD P&R. See also, Office of the Chief of Naval Operations Instruction 1590.79A, 

Cyber Federal Executive Fellowship (June 03, 2011), and Office of the Chief of Naval Operations 

Instruction 1500.72G,Navy Politico-Military Fellowships, Graduate Education Programs, and 

Community Sponsorship (June 22, 2010).

c

The Marine Corps does not have a separate instruction for its Legislative Fellowship Program. A 

Marine Corps official said that Office of the Chief of Naval Operations Instruction 1500.72G, Navy 

Politico-Military Fellowships, Graduate Education Programs, and Community Sponsorship (June 22, 

2010), Marine Corps Order 1500.41A (Aug. 20, 1996) Scholarship Program for Members of the 

Marine Corps, Marine Corps Order1560.19E (Jun. 25, 2003) Advance Degree Program, and Marine 

Corps Order 1520.9G (Jul 31, 2003) Special Education Program govern the fellowship program.

d

Marine Corps Order 1520.28B Commandant of the Marine Corps Fellows Program (Oct. 22, 1996). 

The Marine Corps conducts its review through briefings presented to senior leaders and from 

gathering feedback from fellows. The Marine Corps plans to conduct a more formal review of the 

program in April 2012.

e

Air Force Instruction 36-2301, Developmental Education (July 16, 2010). 

Of the service programs that require a periodic review, Navy officials said 

that they conducted program reviews for their nonlegislative39

 

39 The Navy Cyber Federal Executive Program has not yet conducted their first program 

review. The program began in academic year 2010-2011.

and 

legislative programs, and Marine Corps officials said they have conducted 

one nonlegislative program review. Two of the services—the Army and 

the Air Force—have not fully conducted periodic reviews of their 
 

Page 26 GAO-12-367 Military Education

programs as required in their program guidance. Although the Army is 

required to review its nonlegislative fellowships, it has not conducted 

reviews recently. In 2011, the Army began reviewing a portion of one type 

of nonlegislative fellowship—the Senior Service College Fellowships—

and officials said they expect to complete this portion of the review in 

early 2012, and to review the other fellowship programs in the near future. 

Air Force officials, on the other hand, informed us that their requirement 

for a biennial review of fellowships is an error in their instruction, and they 

plan to write this requirement out of the next version of the instruction. 

Further, these officials said that the review requirement applies only to 

graduate education programs—not fellowships. Therefore, the Air Force 

has not periodically reviewed its fellowship programs, although Air Force 

officials said that information on fellowships is incorporated into their 

annual process for designating educational and developmental 

opportunities.

None of the services has comprehensively reviewed its programs. 

A comprehensive review, as we have previously reported,40

• Using quantifiable performance measures for meeting their stated 

goals for their programs. The services have not measured the extent 

to which their programs are meeting their goals,

may include 

the following four elements: quantifiably measuring the extent to which 

the program is meeting program goals; validating that fellowships and 

training-with-industry programs meet current and emerging requirements; 

incorporating feedback from program participants and host organizations 

to improve the program; and documenting the results of the review to 

enable the service to modify its programs, as needed. However, we found 

that not all services are including these four elements in their reviews, as 

described below:

41 because they have 

not developed quantifiable performance measures for most of their 

program goals. We have previously reported on the importance of 

agencies developing and using performance measures to ensure 

accountability and assess progress toward achieving results aligned 

with goals.42

 

40 

The services vary in the extent to which they review their 

programs to measure against program goals. For example, an Army 

GAO-04-546G. 

41 Some services’ program goals were stated as the purpose or objective of the program. 

42 GAO-04-546G. 
 

Page 27 GAO-12-367 Military Education

official said that the Army has not assessed the program using 

quantifiable performance measures for its legislative fellowship

program, but the official believed that a measure that tracks the 

completion of utilization tours could be used to assess the extent to 

which they are meeting the goal of having a pool of officers from 

which some may be selected for future utilization in the field of 

congressional liaison. Similarly, a Navy official with the Cyber Federal 

Executive Fellowship Program said that the utilization tour could be 

used as a performance measure for meeting the program’s goals, 

but they plan to use it as a qualitative, not quantifiable, performance 

measure. The Marine Corps Legislative and Commandant of the 

Marine Corps Fellowship Programs have not created quantifiable 

performance measures either, although officials said they use 

qualitative measures, such as discussions with fellows and senior 

leaders, to assess the programs. The Army and Air Force have taken 

some steps to develop quantifiable measures for some programs. 

For example, in 2011 the Army surveyed fellows in the Senior Service 

College Fellowship Program to assess the extent to which these 

fellowships met their objectives. The Air Force Fellowship Program 

surveys its host organizations on the percentage of time the fellows 

spend on the Air Force’s service-specific competencies—used by Air 

Force officials as indicators that the program is meeting its goals and 

objectives. However, the Air Force has not developed quantifiable 

goals with which these survey results can be compared. Without 

reviewing their programs to assess progress against program goals, 

the services are limited in their ability to determine the effectiveness of 

their programs.

• Validating that programs meet current or future mission requirements. 

Some of the services have not periodically validated that the 

fellowship or training-with-industry assignments continue to address 

current or emerging mission requirements. The DOD instruction states 

that the secretaries of the military departments are responsible for 

ensuring that the current assignments using fellowships and trainingwith-industry positions meet the intent of the program and continue to 

meet military department and DOD requirements or anticipated 

needs. We have reported that successful organizations match training 

and development programs to their specific needs and capabilities.43

 

43

While the Navy and the Marine Corps have periodically reviewed their 

GAO-04-546G. 
 

Page 28 GAO-12-367 Military Education

programs to ensure that they meet current and emerging needs, the 

Army and the Air Force have not. The Marine Corps has informally 

validated its programs through a process that looks at the costs of the 

program, updates the list of fellowship host organizations, and 

determines which fellowships are available for the upcoming year. 

Although the Army’s instruction for nonlegislative fellowships requires 

that each fellowship program be reviewed for continued relevancy and 

to determine that it meets stated criteria and objectives, the Army has 

not conducted this review regularly. We note that Army officials stated 

that in their current review of a portion of the Senior Service College 

fellowships that they plan to revalidate the need for each or the 

uniqueness of each host organization. While the Air Force has not 

revalidated that its fellowships meet current or emerging needs 

through periodic program reviews, it stated in its December 2011 

report to USD P&R on nonlegislative fellowships that program 

oversight and management ensure validation that the programs fulfill 

a present need, anticipated requirement, or future capability.

• Incorporating feedback. While all of the services have collected some 

feedback from fellows and host organizations, they have not 

consistently incorporated this feedback into their program reviews. 

We have previously reported on the importance of agencies 

measuring training participants’ reactions to and satisfaction with their 

programs, and of measuring changes in their knowledge, skills, and 

abilities after their participation in the programs.44

 

44

The Army and the 

Air Force have conducted postfellowship surveys for some fellowships 

to gather information on the fellows’ experiences. While these surveys 

provide information on the experience of the fellowship, they do not 

provide information on how the fellowship experience has been of 

benefit to the fellows’ careers from a perspective of several years 

later. We note that the Marine Corps has conducted surveys to collect 

feedback from both recent and earlier fellows. In addition, some of the 

services gather feedback from fellows on their experiences through 

periodic reports to the program office. All of the services monitor their 

fellows and collect feedback through intermittent meetings with them. 

The Air Force also collects feedback from host organizations through 

surveys and periodic site visits, and the Army has recently conducted 

site visits to some of its host organizations. Across the services, 

however, there has not been consistent incorporation of feedback in 

program reviews.

GAO-04-546G. 
 

Page 29 GAO-12-367 Military Education

• Documenting program accomplishments. Although some of the 

services said that they document a portion of their review efforts, no 

service has documented accomplishments that covered an entire 

program review, or the entirety of its programs.45 We have previously 

reported on the importance of using program evaluations to make 

fact-based determinations of the program’s impact, and to reallocate 

or redirect resources accordingly.46 Service officials said they use or 

plan to use the information they collect to make changes to their 

fellowship and training-with-industry programs. Army officials said 

they plan to use their ongoing review of a portion of the Senior 

Service College fellowships to refine the Army’s portfolio of seniorlevel fellowships. Prior to the review, the Army had identified problems 

with the fellowship programs primarily by incident, either with the 

fellow or with the host organization. Marine Corps officials stated they 

have used feedback from the fellows to decide upon which host 

organizations to keep or to discontinue in their portfolio. Air Force 

officials said they have analyzed feedback from fellows and host 

organizations to make decisions on which host organizations to 

discontinue when overall education funding was reduced. 

Documentation of these results would enable the services to 

demonstrate that they have conducted the review and what steps, 

if any, they may take to improve the program.

Some of the services informed us that they intend to do more to review 

their programs. For example, as part of its ongoing review the Army plans 

to match fellows with host organizations that will enable them to research 

issues identified by Army leadership as critical problems facing the Army.

A Navy official said that although the Navy has not yet conducted its first 

review of the Cyber Federal Executive Fellowship, it plans to survey 2011 

fellows in the fall of 2012, a year into their utilization tour, to assess how 

the fellowship benefited their careers. Marine Corps officials said that they 

are examining a more formal process to supplement their current informal 

annual fellowship reevaluation practices. Without conducting periodic and 

comprehensive performance reviews, the services’ ability to determine 

 

45 For program reviews completed during the period we reviewed, fiscal years 2007 

through 2011. However, we note that the Army provided us documentation of a program 

review that reviewed a portion of its Senior Service College Fellowships and its Senior 

Fellowships in 2007. 

46 GAO-04-546G. 
 

Page 30 GAO-12-367 Military Education

the benefit they derive from fellowship and training-with-industry 

programs will remain limited.

The services inconsistently implement a DOD requirement47

Service officials described utilization tours to us as a benefit that DOD 

gains from conducting its fellowship and training-with-industry programs.

For example, both Army fellowship policy documents and officials with 

whom we spoke described utilization tours as a mechanism for 

maximizing the benefit derived by the Army. Navy officials described 

utilization tours as a way to receive a return on their investment and to 

meet the intent of the programs, given that they reinforce skills, promote 

continued learning, and serve to meet the requirements of the Navy. Air 

Force policy documents and officials described utilization tours as a way 

to ensure that officers use the skills they have developed.

to have 

utilization tours—assignments where program participants can apply 

knowledge and skills gained through fellowship and training-with-industry 

programs—because they do not have clear guidance as to what qualifies 

as a follow-on utilization tour, and they do not have criteria for when to 

postpone or waive this requirement. After a participant’s completion of the 

fellowship or training-with industry opportunity, the services are expected 

to assign the participant to a tour that enables him or her to make use of 

the newly gained skills, knowledge, and abilities, according to DOD 

guidance.

However, the services do not implement utilization tours for fellowships 

consistently, either within or across services. For example, within the 

same Air Force fellowship program, some fellows have a mandatory 

utilization tour, while for others it is a recommendation. According to Air 

Force officials, the decision as to whether a utilization tour is mandatory 

or recommended is made by the Air Force office responsible for 

fellowship policy on a case-by-case basis at the time it initiates the 

 

47 DOD Instruction 1322.06 states that participants in fellowships and training-withindustry programs should have an immediate follow-on utilization tour upon completion of 

the fellowship, but it notes that each of the military departments may postpone or waive 

this requirement as necessary. The instruction also states that the secretaries of the 

military departments are responsible for properly managing the skills gained by the 

participants in the fellowship program, and for ensuring that current assignments utilizing 

the fellowships and training-with-industry positions meet the intent of the program and 

continue to meet military department and DOD requirements or anticipated needs. 

Services Do Not Have 

Clear Guidance on 

Utilization Tours
 

Page 31 GAO-12-367 Military Education

fellowship. Air Force officials said they do not have established criteria for 

determining whether a utilization tour is mandatory or recommended. 

Similarly, the Army requires utilization tours for some of its fellowship 

programs, such as the legislative fellowship, but not for others. In 

contrast, the Navy and the Marine Corps generally require utilization tours 

for all of their fellowship programs, and all of the services generally

require utilization tours for their training-with-industry programs.48

Service officials said that inconsistency across the services is attributable, 

in part, to the absence of a clear definition as to what constitutes a followon utilization tour in the DOD instruction. A Navy official said that the 

differences in how the services implement utilization tours are a result of 

not having a clear definition of the requirement. Similarly, Marine Corps 

officials described fulfilling utilization tours as a judgment call, and one 

Marine Corps official said there has been an internal debate as to what 

assignments should count as utilization tours, and within what time frame 

such tours should be assigned.

Also, the services’ postponement or waivers of the requirement to 

perform utilization tours occur inconsistently, because the services do not 

have criteria to determine when it is appropriate to postpone or waive this 

requirement. As a result, the services have different implementation 

practices for postponing or waiving the utilization tour requirement. 

Generally, the services postpone or waive the utilization tour requirement 

on a case-by-case basis. For example, according to officials the Army 

postpones or waives the requirement for most, but not all, of its 

fellowships. For one Army fellowship program—the Senior Service 

College Fellowship Program—the former Army Chief of Staff provided 

written guidance in 2010 indicating that specific requirements for 

utilization tours upon completion of fellowships should not be imposed. 

Army officials stated that the utilization tour requirement was viewed as 

adding more stress and burdens to the officers during a period of high 

operational tempo and frequent deployments, and that utilization tours for 

these fellows were viewed simply as a recommendation for postfellowship 

assignments. In the case of one Navy fellowship program, on the other 

hand, Navy guidance49

 

48 The Marine Corps does not currently have a training-with-industry program.

generally requires a utilization tour, and that a 

49 Office of the Chief of Naval Operations, Instruction 1500.79A, Cyber Federal Executive 

Fellowship (June 3, 2011).
 

Page 32 GAO-12-367 Military Education

high-level Navy Personnel Command official must approve any 

exceptions; the regulation does not provide any criteria for such 

exceptions. Service officials from all of the services stated that they 

postpone assigning a utilization tour if the tour would interfere with 

another career-advancing assignment, such as being selected for a 

command position.

Some service officials said that improving the consistency of their 

implementation of the utilization tour requirement could increase 

assurances that they derive benefits from fellowship and training-withindustry programs, even though their reasons for not requiring utilization 

tours vary. Army officials informed us that they are examining steps to 

better strategically link utilization tours with the specific research focus of 

the fellow, and might begin to require utilization tours for their Senior 

Service College fellows now that they expect fewer Army officers to be 

deploying overseas. Navy officials said they are hoping to develop a 

capability to better track utilization tour completion to better ensure that 

they are getting a good return on investment. Marine Corps officials said 

they also plan to improve their process for tracking legislative fellowship 

utilization tours in 2012. In addition, Air Force officials said that 

implementing the utilization tour requirement more consistently would 

benefit their service.

We have previously reported on the importance of having agency training 

and development managers remove barriers that can impede the use of 

knowledge and skills gained in training, so as to improve performance on 

the job.50 Without having a common understanding of the follow-on 

utilization tour requirement and its waiver criteria, the services’ ability to 

determine the benefit they derive from fellows and training-with-industry 

participants using their newly developed or enhanced skills in these tours 

will remain limited, and the circumstances surrounding each waiver will 

remain uncertain. In addition, having assurances that utilization tour 

requirements are being met can better position the services to justify the 

use of appropriated funds for these programs and can better ensure that 

the services are meeting the intent of the programs by filling positions that 

meet current and anticipated needs.

 

50 GAO-04-546G. 
 

Page 33 GAO-12-367 Military Education

The services do not know the overall costs of their fellowship and trainingwith-industry programs, including both direct and indirect costs. We have 

previously reported on the importance of ensuring that training and 

development efforts are cost-effective relative to their anticipated 

benefits.51 Without having reviewed the overall costs of the programs, the 

services cannot be assured that they are cost-effective, and they will not 

have the information necessary to aid decision makers in managing 

scarce training, development, and education resources, particularly due 

to anticipated lower levels of defense spending.52

The services are not required by the DOD instruction to report on the 

overall costs of the program. However, while not uniformly required 

across the board, some of the service instructions do require reviewing a 

portion of the costs of their respective programs. The Army requires that 

host candidate organizations, within their proposals to become hosts, 

present the estimated costs to the service.53 As part of a periodic review 

for two of the Navy’s fellowship programs—the Cyber Federal Executive 

Fellowship and the Federal Executive Fellowship—the Navy reviews the 

cost of execution, utilization, and any fiscal surpluses or constraints that 

might affect future execution of the program, to help inform future 

decisions about it.54 For one of its fellowship programs—the Commandant 

of the Marine Corps Fellowships—the Marine Corps requires that a cost 

estimate is determined for tuition, fees, and travel costs to aid in budget 

planning.55 One Air Force instruction56

 

51

requires that all fellowships be 

reviewed for their cost efficiency, but, as previously mentioned, Air Force 

GAO-04-546G. 

52 In January 2012, the Secretary of Defense released strategic guidance, Sustaining U.S. 

Global Leadership: Priorities for 21st Century Defense, to help guide DOD decision making 

in light of DOD’s efforts to support deficit reduction through a lower level of defense 

spending. 

53 Army Regulation 621-7, Army Fellowships and Scholarships (Aug. 8, 1997).

54 Office of the Chief of Naval Operations, Instruction 1590.79A, Cyber Federal Executive 

Fellowship (June 3, 2011), and Office of the Chief of Naval Operations Instruction, 

1500.72G Navy Politico-Military Fellowships, Graduate Education Programs, and 

Community Sponsorship (June 22, 2010).

55 Marine Corps, Order 1520.28B, Commandant of the Marine Corps Fellows Program

(Oct. 22, 1996).

56 Air Force, Instruction 36-2301, Developmental Education (July 16, 2010).

Services Do Not Know 

Overall Program Costs 

and Cannot Determine 

Cost-Effectiveness 
 

Page 34 GAO-12-367 Military Education

officials stated that this requirement to review fellowships is an error in the 

Instruction.

The services know some of the direct costs associated with their 

fellowship programs, such as the tuition and fees paid to the universities 

and think tanks that host fellows,57 but not all of them. Service officials 

said that the tuition or fee paid to a host organization was used for the 

administrative, academic, and technological support provided to the 

fellow, as well as for the facilities and resources at the host organization. 

Some of the direct costs of the program include those associated with 

travel, research, and orientation. We collected information from the 

services on the tuition or fee amounts paid to host organizations for 

fellowships. We estimated that for the academic year 2010-2011, the 

services paid approximately $2.9 million in tuition and fees for 

approximately 270 fellows, of which the Army paid approximately 

$1.2 million; the Navy paid approximately $208,000; the Marine Corps 

paid approximately $378,000; and the Air Force paid approximately 

$1.1 million.58

For two of the services, officials said that knowing the direct costs of their 

fellowship and training-with-industry programs is difficult, given that the 

programs are financially managed by several different organizations. For 

example, funding for the cost of a fellowship may come from the 

proponent that sponsors a fellowship, or from general student and 

educational funding, or from other components, such as the National 

Guard or Reserve, depending on the fellowship and the service. In 

addition, the costs of the program may extend across more than 1 fiscal 

year, as the programs are based on academic or calendar rather than 

fiscal years.

The services paid a tuition or fee to more than half of their 

fellowship host organizations.

Service officials said that they do not know the indirect costs of the 

programs, such as administrative support, faculty, and permanent change 

of station costs, and that there are several challenges in determining 

 

57 No tuition or fee is paid to fellowships at other federal agencies, federally funded 

research centers, congressional committees or members, or corporations. In addition, no 

fee is paid to corporations that host training-with-industry participants.

58 These totals include fellowship programs that charge a tuition or fees. Some programs 

do not typically charge a tuition or fee, such as training-with-industry programs or the 

Secretary of Defense Corporate Fellowship Program.
 

Page 35 GAO-12-367 Military Education

those costs. In addition, some officials said that for their programs indirect 

costs may include the salary and benefits of the officer while participating 

in the fellowship or training-with-industry program.59

Without knowing the direct and indirect costs of these programs, the 

services are unable to compare the cost-effectiveness of attending one 

type of educational opportunity versus that of another type. Service 

officials said they experience similar challenges in knowing the overall 

costs of servicemembers attending military schools, or other professional 

development and training opportunities. Some service officials said that 

having more information about the overall costs of the programs would be 

beneficial because it would better inform them on how many fellowship 

and training-with-industry opportunities they can afford to devote 

educational and training resources to, and would provide better 

information for budgeting.

Service officials said 

that the indirect costs of the fellowship are not easily identified. For 

example, an Army official said the Army does not have a financial 

management system that would allow it to distinguish the administrative 

and faculty costs directed toward Army War College students from those 

directed toward fellows. For many of the programs, management and 

faculty support of fellows and training-with-industry participants is an 

additional duty, not the sole duty, of a service official.

 

59 The salary and benefits may be included as a direct cost if the officer is not participating 

in a fellowship in lieu of attending a military school. Basic pay during the fellowship varies 

by officer level and years of service. Using DOD basic pay in fiscal year 2011, an O-3 

would have an annual basic pay range from approximately $44,500 to $72,500; an 

O-4 would have an annual basic pay range from approximately $50,700 to $84,600; an 

O-5 would have an annual basic pay range from approximately $58,700 to $99,800; and 

an O-6 would have an annual basic pay range from approximately $70,400 to $124,700. 

Basic pay does not include other forms of pay, such as housing allowances.
 

Page 36 GAO-12-367 Military Education

Some services have not established or reviewed agreements or 

memoranda of understanding60 that would outline the responsibilities of 

the services and the think tank, university, and federal agency host 

organizations for fellowships, but several service officials we interviewed 

said this would be a best practice to incorporate. We have previously 

reported on the importance of having management controls to provide 

accountability for the use of government resources, and to outline the 

responsibilities of each party.61 We have also reported on the importance 

of having policies and procedures to ensure that training and 

development efforts and expectations are discussed and understood by 

managers, supervisors, employees, training coordinators, and others.62

The requirement for having written memoranda of understanding between 

each party varies across the services and by the type of training involved. 

DOD’s Instruction 1322.06 does not require written memoranda of 

understanding for fellowships, but it does require a written agreement for 

training-with-industry programs. The instruction states that before the 

start of a training-with-industry assignment there must be a written 

agreement shared by the private sector host, the employee, and the DOD 

component concerned. The services63 generally established these 

required agreements with host corporations. Although not required by the 

instruction for fellowships, the services have varied in the extent to which 

they have established memoranda of understanding with host 

organizations. The Army and the Marine Corps have established such 

memoranda for a small proportion of their fellowships.64

 

60 Some services use a memorandum of agreement rather than a memorandum of 

understanding. We refer to both as memoranda of understanding in this report. 

In contrast, the 

Navy and the Air Force have established memoranda of understanding 

with most of their fellowship host organizations, stating that these 

documents help them to ensure that the host organization understands 

the roles and responsibilities of each party as well as the key learning 

objectives of the program.

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

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

62 GAO-04-546G. 

63 The Marine Corps does not have a training-with-industry program.

64 For example, the Army has established memoranda with host agencies under the Army 

Intermediate Level Education Interagency Fellowship Program. 

Some of the Services Have 

Not Established or 

Reviewed Memoranda of 

Understanding with Host 

Organizations
 

Page 37 GAO-12-367 Military Education

The services have also varied in the extent to which service guidance 

require these documents to be reviewed. The respective guidance for one 

Navy and one Army fellowship program require that memoranda of 

understanding be reviewed.65 More specifically, the Navy’s Federal 

Executive Fellowship requires that its memoranda of understanding be 

reviewed every 2 years; and the Commandant of the U.S. Army War 

College is required to review and make recommendations on all 

fellowship proposals and memoranda of understanding for the Senior 

Service College Fellowships to ensure that the senior-level educational 

criteria are met. However, since the Army does not have memoranda of 

understanding for a majority of its fellowships, such reviews have rarely 

occurred.

Several service officials cited establishing and reviewing memoranda of 

understanding as a good management practice. One Navy official said 

that establishing and reviewing memoranda of understanding is a best 

practice that should be encouraged, saying these agreements would clear 

up any misunderstanding about the structure of the individual program. 

Another Navy official had positive comments about establishing and 

reviewing memoranda of understanding, saying that establishing these 

memoranda constitutes a good practice because they define roles and 

responsibilities, provide protections for ethics and payments, and make 

clear the objectives of the fellowship. Furthermore, the Army and the 

Marine Corps both agreed that establishing and reviewing memoranda of 

understanding with host organizations would be beneficial. Army officials 

said they plan to establish and update the memoranda for all their 

fellowships and to update their policy accordingly. Army officials also said 

that these memoranda would provide clarity on the costs of fellowships 

each year and thus facilitate better accounting and budgeting for their 

program. Further, Army officials said the memoranda would provide 

clarity on what makes each host organization unique, the purpose of the 

 

65 OPNAV, Instruction 1500.72G, Navy Politico-Military Fellowships, Graduate Education 

Programs and Community Sponsorship (June 22, 2010); and Army, Regulation 621-7: 

Army Fellowships and Scholarships (Aug. 8, 1997). 
 

Page 38 GAO-12-367 Military Education

fellowship, and the roles and responsibilities of the Army and the host 

organization.

Memoranda of understanding serve as a management control and 

document key information and expectations between the service and the 

host organization. As a feature of documenting key information and 

expectations, memoranda of understanding can provide protections 

against potential conflicts of interest. Several Navy memoranda of 

understanding we reviewed contained provisions that pertained to fellows 

working on certain federal projects. For example, a memorandum of 

understanding for the Federal Executive Fellowships says that the fellow 

may not work on any contract or procurement studies that would violate 

federal standards of conduct, especially those pertaining to conflicts of 

interest. Without establishing and reviewing these memoranda, the 

services cannot be assured that expectations, including safeguards 

against potential conflicts of interests and criteria for appropriate fees and 

projects, are clearly understood by the host organizations and the 

fellowship participants.

While the military services are not well positioned to determine the extent 

of their benefit from fellowship and related training programs, service 

officials believe that they do obtain benefits from these programs. For 

example, officials said these programs provide officers with a careerbroadening developmental experience; enable them to conduct research 

on topics that are important to the military; help them develop critical and 

strategic thinking skills; help them gain perspectives from the civilian 

sector; build civilian-military relationships; and develop more responsive 

leaders during times of significant change in the global security 

environment. Officials also believe that the use of fellowship and trainingwith-industry programs affords DOD flexibility in meeting new or emerging 

educational and training needs that sometimes cannot be met within the 

military educational structure—for example, in the rapidly developing new 

approaches and techniques of the cyber security area. Service officials 

said they use several program management practices to enhance the 

benefits derived from fellowship and training-with-industry programs, 

including the following:

• Competitive selection: Service officials said that having a highly 

competitive selection process that rank-orders officers who are 

eligible to compete for many fellowship and training-with-industry 

opportunities helps to produce a selection of highly qualified officers 

for these opportunities. Officials said the process better ensures that 

The Services Use Certain 

Management Practices as a 

Means of Obtaining 

Benefits from Fellowship 

and Training-with-Industry 

Programs
 

Page 39 GAO-12-367 Military Education

the right officer is selected for a given fellowship or training-withindustry program, which ultimately benefits the officer’s career as well 

as accomplishes DOD’s mission though the experience gained. In our 

review of the selection process, we found that the preferences of 

career field managers, senior leaders, and the officers themselves 

were considered, for many of the services, in the selection of officers 

for fellowship or training-with-industry programs.

• Orientation and ethics counseling: Service officials said that 

conducting orientation before the start of a fellowship helps to prepare 

fellows for their program by introducing them to key contacts, program 

requirements, and expectations for the year. In addition, officials 

stated, the ethics briefings given at orientation and availability of 

subsequent counseling provide assurance that fellows understand 

what is expected of them and are informed as to how to handle 

potential conflicts of interest. We reviewed seven ethics briefings and 

found them to contain essential elements, such as guidance on 

accepting gifts and information on contacting DOD legal officials with 

questions about ethics issues. (See app. IV for our review of these 

briefings.)

• Research: Service officials said they have assurances that they 

receive a benefit by requiring many of the fellows to conduct research 

and write papers on topics that are important to each respective 

service, as identified by senior leaders. At orientation, some of the 

services have senior leaders speak about emerging topics that could 

be better researched to benefit the service. For academic year 

2010-2011, for example, DOD fellows researched enhancing DOD’s 

acquisition and logistics processes, as well as countering irregular 

threats such as piracy.

Service obligations: Service officials informed us that they had general 

procedures to provide some measure of benefits obtained when 

officers complete their additional service obligation as required by 

statute or DOD guidance for participating in certain fellowships or 

training-with-industry programs—that is, that the fellow will serve in 

the military for a period at least three times the length of the period of 

the fellowship education or training-with-industry opportunity.66

 

66 As discussed earlier in this report, we found certain Army fellowship programs that were 

not in compliance with the statutory requirement; however, the Army still had a general 

process to provide assurances that officers complete the lesser service obligation agreed 

to by the servicemember.

 
 

Page 40 GAO-12-367 Military Education

We found that all of the services generally have (1) policies on the 

requirement; (2) special coding capabilities for personnel recordkeeping and monitoring; (3) a formalized waiver process to better 

ensure that servicemembers do not retire or separate without fulfilling 

service obligations; and (4) the potential ability to recoup certain 

educational costs. While many service officials asserted that these 

practices increase the likelihood that benefits are derived from 

fellowships and training-with-industry opportunities, some also said 

they could still improve upon these practices to have greater 

assurances that DOD derives benefits from these programs.

According to DOD, the intent for fellowships and training-with-industry 

programs is to help fulfill a present need, anticipated requirement, or 

future capability that contributes to the effectiveness of the department’s 

mission. DOD has used these programs for at least 1,797 mid- to seniorlevel officers across the services over the past 5 fiscal years. Even as the 

war in Afghanistan is winding down and reductions in personnel endstrengths occur, servicemembers will still be deployed globally, and DOD 

will have to carefully balance operational assignments with identified 

needs for professional military education, both within DOD’s professional 

military educational system and outside of DOD, in fellowship and training 

with industry programs. However, until OSD gains improved visibility into 

these programs and the military services are better positioned to know 

that they achieve their intended benefits and are cost-effective, DOD will 

continue to face challenges in ensuring that it is deriving sufficient value 

from these programs.

To improve oversight and management of DOD’s fellowship and trainingwith-industry programs, we are making 11 recommendations to the 

Secretary of Defense.

To help ensure compliance with DOD Instruction 1322.06 and thus 

enhance DOD’s visibility over all of the fellowship and training-withindustry programs, and to promote a shared understanding across the 

military services of what is expected in meeting the instruction, the 

Secretary of Defense should direct the Under Secretary of Defense for 

Personnel and Readiness to take the following five actions:

(1) develop a mission statement that clearly defines the respective 

purposes of the legislative and nonlegislative fellowship and training-withConclusions 

Recommendations for 

Executive Action
 

Page 41 GAO-12-367 Military Education

industry programs to be in a better position to know the extent to which 

desired program outcomes are being achieved;

(2) more consistently enforce the DOD instruction’s requirement on the 

submission of annual reviews from the military services on these 

programs; and

(3) collaborate with the military departments to ensure that each service 

has designated an office to be responsible for compiling information on 

the legislative and nonlegislative fellowship and training-with-industry 

programs for the annual reports required in the DOD instruction.

In addition, to enable DOD to develop a more reliable inventory for these 

programs, the Under Secretary of Defense for Personnel and Readiness 

should:

(4) clarify in the DOD instruction the definition of a fellowship; and

(5) specify in the DOD instruction common reporting requirements for the 

annual report, and clarify which fellowship and training-with-industry 

opportunities should be included in this report, to facilitate the collection of 

consistent information on these programs across the military services.

Additionally, to facilitate OSD’s ability to perform its oversight 

responsibility for the legislative fellowship program and to better ensure 

consistency in the department’s dealings with interested committees and 

members of Congress, the Secretary of Defense should direct the 

Assistant Secretary of Defense for Legislative Affairs to take the following 

two actions:

(6) clearly delineate in the DOD instruction the roles and responsibilities 

for overseeing DOD’s Legislative Fellowship Program, and

(7) develop documented placement criteria for legislative fellows.

Finally, to better position DOD to determine the extent of the benefits it 

derives from legislative and nonlegislative fellowship and training-withindustry programs and better assess whether fellowship and training-withindustry programs offer the best venues for developing needed personnel 

skills, the Secretary of Defense should direct the Secretaries of the 

Department of the Army, the Department of the Navy, and the 

Department of the Air Force to take the following four actions:
 

Page 42 GAO-12-367 Military Education

(8) perform periodic and comprehensive program reviews that assess the 

progress using quantifiable measures, validate that programs continue to 

meet current or emerging needs, incorporate feedback from program 

participants and host organizations, and document the results of reviews;

(9) clarify guidance for determining what qualifies as a follow-on utilization 

tour, and establish criteria to determine when a utilization tour is needed 

or, conversely, when it can be postponed or waived;

(10) determine the direct costs of these programs by periodically 

obtaining and analyzing overall direct program costs, and explore the 

feasibility of estimating indirect program costs; and

(11) establish and periodically review fellowship written agreements or 

memoranda of understanding to document key information and 

expectations between the services and the host organizations, such as 

fellowship objectives, criteria for evaluating the appropriateness of fees or 

tuition charged to the military departments , and criteria for evaluating the 

appropriateness of the projects involved.

In written comments on a draft of this report, DOD concurred with the 

11 recommendations we made to improve OSD oversight and strengthen 

the military services’ management of its fellowships and training-withindustry programs. DOD also outlined actions that it plans to take for each 

recommendation, which it stated will improve the issues we identified in 

the report. DOD’s comments appear in their entirety in appendix V. 

We are encouraged by the department’s action plans that carry the intent 

to implement our recommendations. For example, we made 

7 recommendations to OSD designed to enhance OSD’s oversight and 

visibility over these programs, for which OSD provided its intended 

actions such as making planned revisions to its instruction governing 

these programs by including a mission statement, a standard format for 

the military services to follow when completing the required annual report, 

and a date when this report is due to OSD—all actions we believe meet 

the intent of these recommendations. We also made 4 recommendations 

to the military service secretaries to strengthen its management of these 

programs, which again OSD provided a series of steps it plans to take in 

response to our recommendations. OSD’s action plans included such 

steps as working with the military services to develop qualitative or 

quantitative measures that the department believes will best meet the 

services needs for these programs. Again, we are encouraged by the 

department’s action plans as stated in OSD’s comments to our draft 

Agency Comments 

and Our Evaluation
 

Page 43 GAO-12-367 Military Education

report in meeting the intent of our recommended actions to strengthen 

these fellowship and training-with-industry programs. Finally, DOD 

provided technical comments, which we considered and incorporated 

where appropriate.

We are sending copies of this report to the appropriate congressional 

committees. We are also sending copies to the Secretary of Defense; the 

Under Secretary of Defense (Comptroller); the Under Secretary of 

Defense for Personnel and Readiness; the Secretaries of the Army, Navy, 

and Air Force; and the Commandant of the Marine Corps. This report will 

also be available at no charge on our website at http://www.gao.gov.

Should you or your staff have any questions concerning this report, 

please contact me at (202) 512-3604 or farrellb@gao.gov. Contact points 

for our Offices of Congressional Relations and Public Affairs may be 

found on the last page of this report. Key contributors are listed in 

appendix VI.

Brenda S. Farrell

Director, Defense Capabilities and Management
 

Page 44 GAO-12-367 Military Education

List of Committees

The Honorable Carl Levin

Chairman

The Honorable John McCain

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Daniel K. Inouye

Chairman

The Honorable Thad Cochran

Ranking Member

Subcommittee on Defense

Committee on Appropriations

United States Senate

The Honorable Howard P. “Buck” McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable C.W. Bill Young

Chairman

The Honorable Norman D. Dicks

Ranking Member

Subcommittee on Defense

Committee on Appropriations

House of Representatives
Appendix I: Scope and Methodology

Page 45 GAO-12-367 Military Education

To determine the statutory provisions that authorize the Department of 

Defense (DOD) fellowship and training-with-industry programs, we 

reviewed and assessed relevant laws and regulations that authorize and 

govern these programs. We also interviewed officials with the Office of 

the Under Secretary of Defense for Personnel and Readiness (USD P&R) 

and attorneys from OSD’s Office of General Counsel for their 

perspectives on laws and regulations governing these programs and 

obtained written responses from OSD General Counsel on these 

authorities.

To determine the extent of OSD’s visibility over these programs, we 

obtained and assessed DOD instructions and service guidance governing 

its fellowship and training-with-industry programs to determine the policy 

oversight responsibility and other requirements. We interviewed officials 

from USD P&R and the Office of the Assistant Secretary of Legislative 

Affairs to obtain information about their roles and responsibilities with 

respect to the Legislative Fellowship Program. We also interviewed 

officials from USD P&R with knowledge of the service reporting 

requirements from the DOD instruction on fellowships and training-withindustry programs. We collected available service reports that 

corresponded to these requirements, and assessed the extent to which 

USD P&R has established guidelines for information to include in these 

reports. We obtained information on the extent to which USD P&R was 

aware of the services’ compliance with statutory and regulatory 

requirements, such as the service obligation commitments and reporting 

requirements. Also, we assessed the extent to which USD P&R had a 

complete inventory of its fellowship and training-with-industry programs.

We collected data on the number of military officers1

 

1 We focused on military officers because many of the fellowship programs were only 

eligible to officers, and we excluded civilians participating in fellowship and training-withindustry programs because Senate Report 111-201 accompanying the National Defense 

Authorization Act for Fiscal Year 2011 directed us to focus on servicemembers.

and the types of 

fellowship and training-with-industry programs from each of the military 

services and from OSD. We relied primarily on data from the military 

services, as they were able to provide more detailed information on these 

programs. To assess the reliability of each of the military services’ 

program data, we obtained information on (1) the systems used to 

maintain their data and these systems’ ability to record and report on 

these data, and (2) the quality control measures in place to ensure that 

the data were reliable for our reporting purposes. We also interviewed 

Appendix I: Scope and Methodology
Appendix I: Scope and Methodology

Page 46 GAO-12-367 Military Education

some service officials who were responsible for compiling these data. We 

identified some data limitations within these data and cross referenced 

with other documentation where available. We found the fellowship and 

training-with-industry data provided to us by the services to be sufficiently 

reliable for providing contextual information on the minimum number of

participants; however, these data do not allow us to provide the actual 

totals.

To determine the extent to which the military services are able to 

determine that they derive benefits from these programs, we obtained 

and assessed service guidance, collected and reviewed information on 

service processes and practices used to manage their programs, and 

interviewed service officials. We collected and analyzed information on 

the extent to which the services reviewed their programs, including 

completion of periodic program reviews and whether the reviews 

assessed the program against program goals using quantifiable 

performance measures; validated that the program continued to address 

current or emerging mission requirements; incorporated feedback from 

program participants or host organizations; and documented the results of 

the review. We collected data and information on utilization tours and on 

the extent to which the fellows are assigned to them. We also collected 

information on the extent to which the services tracked the costs of these 

programs and established and maintained memoranda of understanding 

with host organizations. We obtained information from each of the military 

services on the tuition or fee paid to fellowship host organizations for 

fellowships in academic year 2010-2011.2 We also obtained and 

evaluated seven ethics briefings that DOD provided to fellows and 

training-with-industry participants prior to the start of their selected 

program with a non-DOD host organization. We identified the key 

elements in these briefings and evaluated them for comprehensiveness.

In doing so, our Office of General Counsel staff from the Ethics Office—

an office that provides guidance to our employees on ethics, conflicts of 

interest, impairments to independence, and related conduct rules and 

issues—reviewed and assessed the briefings we obtained from the 

military services. We also selected and interviewed a non-probability 

sample of four legislative fellows and six think tank fellows3

 

2 For the legislative fellowship program, we used data on the cost for legislative 

fellowships in calendar year 2011.

to obtain a 

3 We also interviewed a fellow at a graduate school—the Institute of World Politics—

because we initially understood it to be a think tank. 
Appendix I: Scope and Methodology

Page 47 GAO-12-367 Military Education

firsthand understanding about the benefits of these educational and 

training opportunities from the perspective of the officer. We selected 

fellows from each service who were either current or had recently 

completed the fellowship at the time of our interviews, who were available 

for interviews; and who were situated in proximity to the Washington, 

D.C., area.

We selected fellows from all four services and from a variety of different 

host organizations, focusing on think tanks and on legislative fellows in 

response to the interest expressed by Senate Armed Services Committee 

staff. In addition, we interviewed a non-probability sample of nine nonDOD host organizations to obtain their perspectives on the educational 

benefits provided to military officers. We selected host organizations that 

were hosting a fellow at the time of our interviews; that were available for 

interviews; and that were situated in proximity to the Washington, D.C., 

area. To provide more in-depth examples of think tank fellowships, we 

selected three of the host organizations that hosted a fellow from each of 

the services and reported on the fees associated with the fellowships, and 

on the extent to which the services established memoranda of 

understanding with those organizations.

We visited or contacted the following organizations during our review:

Office of the Secretary of Defense

• Under Secretary of Defense for Personnel and Readiness

• Office of the Deputy General Counsel

• Assistant Secretary of Defense for Legislative Affairs

• National Defense University

Department of the Army

• Manpower and Reserve Affairs, Military Personnel Policy

• Congressional Operations Division

• Combined Arms Center

• Department of Academic Affairs, Army War college

• Interagency Student Division

• Leadership Development Division

• Senior Leaders Division

• Strategic Leadership Division

• Retirements and Separations Division
Appendix I: Scope and Methodology

Page 48 GAO-12-367 Military Education

Department of the Navy

• Manpower and Reserve Affairs, Military Personnel Policy

• Education Branch

• Distribution Management

• Graduate Education and Training Placement

• Information Dominance Corp

• Legislative Liaison Office

• Office of Supply Corps Personnel

United States Marine Corps

• Congressional Fellows Program Office

• Marine Corps University

• Officer Assignments Branch

Department of the Air Force

• Congressional Support Branch

• Colonel Management Office

• Force Development

• Fellowships Program Office

• Developmental Education Branch

• Officer Promotions, Appointments, and Selective Continuation Branch

• Learning Division

• Acquisitions Career Management

• Air Force Research Institute, Air University

Host Organizations

• American Enterprise Institute

• Atlantic Council

• Brookings Institution

• Center for New American Security

• Center for Strategic and International Studies.

• Council on Foreign Relations.

• Institute of World Politics

• Joint Center for Political and Economic Studies

• Washington Institute for Near East Studies

We conducted this performance review from March 2011 through April 

2012 in accordance with generally accepted government auditing 
Appendix I: Scope and Methodology

Page 49 GAO-12-367 Military Education

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives.
Appendix II: Life-cycle Phases of a Fellowship 

Program

Page 50 GAO-12-367 Military Education

For each DOD fellowship program, there are various phases that 

comprise the program, depending on its life-cycle as shown in figure 2.

Figure 2: Fellowship Program Life-cycle

Typical phases of a life-cycle for fellowships are as follows:

1. Different organizations within each service identify present and 

emerging needs of the service that the officers should be educated in 

and trained on. For example, a service identifies an emerging need for 

more cyber security based on recent events.

2. The service policy or program offices establish the fellowship 

opportunity that provides the training and skills to meet the identified 

need. For example, once the cyber security emerging need was 

identified, the Navy policy office established a fellowship program with 

leading organizations in that field outside of DOD.

Appendix II: Life-cycle Phases of a 

Fellowship Program
Appendix II: Life-cycle Phases of a Fellowship 

Program

Page 51 GAO-12-367 Military Education

3. Generally, the personnel command or center selects officers to 

participate in the fellowships through a competitive selection process 

that ranks eligible officers for selection.

4. The fellows start their fellowship with a university, think tank, 

corporation, federal agency, or congressional committee or member 

office, generally with DOD or the service providing orientation and 

ethics counseling.

5. During the fellowship, the program office with primary responsibility for 

the fellowship monitors the fellows’ progress, assisting them, when 

applicable, with research associated with the fellowship.

6. At the completion of some fellowships, the fellows are generally 

required to submit a research paper or article. After completion, the 

fellow’s personnel command or center is responsible for assigning the 

participant to the postfellowship utilization tour, and for ensuring the 

fellow does not separate or retire from the military before completing 

the service obligation.

7. Reviewing the fellowship program is generally conducted by either the 

policy office or the program office. The review considers whether 

there are any necessary changes to incorporate into the program for 

the upcoming year.

Although we discussed fellowships in terms of a life-cycle, the life-cycle 

for training-with-industry programs is similar to that of fellowships.
Appendix III: Military Service Guidance on 

Fellowship and Training-with-Industry 

Programs

Page 52 GAO-12-367 Military Education

The military services each have their own guidance or regulations that 

covers fellowships and training-with-industry programs, as shown in 

table 5.

Table 5: Military Service Guidance on Fellowships and Training-with-Industry Programs

Army

Army Regulation 621-7 Army Fellowships and Scholarships (Aug. 8 1997)

Army Regulation 1-202 Army Congressional Fellowship Program (May 26, 2000)

Army Regulation 621-1 Training of Military Personnel at Civilian Institutions (Aug. 28, 2007)

Navy 

Bureau of Navy Personnel Instruction 1560.21E Navy Legislative Fellows Program (Nov. 12, 2010)

Office of the Chief of Naval Operations Instruction 1500.72G Navy Politico-Military Fellowships, Graduate Education Programs and 

Community Sponsorship (June 22, 2010)

Office of the Chief of Naval Operations Instruction 1500.79A Cyber Federal Executive Fellowship (June 03, 2011)

Navy Supply System Command Instruction 1520.7 Training With Industry Program 

Marine Corps

Marine Corps Order 1520.28B Commandant of the Marine Corps Fellows Program (Oct. 22, 1996)

Air Force

Air Force Instruction 36-2301 Developmental Education (July 16, 2010)

Air Force Instruction 36-2302 Professional Development (Advanced Academic Degrees and 

Professional Continuing Education) (July 11, 2001)

Air Force Instruction 90-403 Air Force Legislative Fellows Program (Jan. 17, 2001)

Air Force Instruction 36-2639 Education with Industry Program (May 22, 2009)

Source: The military services.

Appendix III: Military Service Guidance on 

Fellowship and Training-with-Industry 

Programs
Appendix IV: Ethics Guidance Provided to 

Fellows

Page 53 GAO-12-367 Military Education

DOD legal officials presented ethics briefings to fellows during their 

orientation to the fellowship program. Each service provided a multipleday orientation to fellows prior to the start of the fellowship and included a 

segment that covered ethics issues. Some services provided a general 

ethics briefing to all fellowship program participants at one time, and other 

services provided the ethics briefing separately to each fellowship 

program. Fellows participating in the Secretary of Defense Corporate 

Fellowship Program received two ethics briefings, one from their service 

and the other at the Secretary of Defense Corporate Fellowship Program 

orientation.

In consultation with GAO’s Ethics Office, we identified key elements that 

would provide fellows with guidance on potential ethical issues and 

conflicts of interest they may face during their fellowship with a non-DOD 

host organization. We obtained seven examples of ethics briefings: two 

from the Army, two from the Navy, one from the Air Force, one from the 

Marine Corps, and one from the Secretary of Defense Corporate 

Fellowship Program. The key elements in the ethics briefings included:

• Relevant laws and DOD policies, including the Joint Ethics Regulation 

(JER), DOD 5500.7-R, the Standards of Ethical Conduct for Executive 

Branch Employees 5 C.F.R. Part 2635, and relevant sections of 18 

United States Code , Chapter 11, Bribery, Graft, and Conflicts of 

Interest.

• Standards of Ethical Conduct for Executive Branch Employees 5 

C.F.R. Part 2635 include

• Conflicts of interest

• Acceptance of gifts

• Unauthorized commitments purporting to bind the government

• Using public office for private gain

• Seeking outside employment

Some of the briefings provided guidance on teaching, speaking, and 

writing, such as guidance on the proper use of disclaimers in those 

activities for which the opinions of the fellow do not represent DOD, and 

guidance on being compensated for those activities. For example, fellows 

were instructed not to take compensation for teaching, speaking, and 

writing if the activity was undertaken as part the fellow’s official position, 

or if the topic dealt with an ongoing or announced policy, program, or 

operation of DOD. In addition, some briefings provided guidance on 

engaging in political activities. For example, fellows were instructed that 

they were not permitted to use official authority or influence for interfering 

Appendix IV: Ethics Guidance Provided to 

Fellows
Appendix IV: Ethics Guidance Provided to 

Fellows

Page 54 GAO-12-367 Military Education

with an election; to be a candidate for civil office except as authorized; to 

participate in partisan political management, campaigns, speeches, 

articles, or conventions; or to promote or attend political dinners or 

fundraising events as an official representative of the Armed Forces. 

Furthermore, DOD provided the fellows with a point of contact for future 

questions and advice.
Appendix V: Comments from the Department 

of Defense

Page 55 GAO-12-367 Military Education

Appendix V: Comments from the Department 

of Defense
Appendix V: Comments from the Department 

of Defense

Page 56 GAO-12-367 Military Education
Appendix V: Comments from the Department 

of Defense

Page 57 GAO-12-367 Military Education
Appendix V: Comments from the Department 

of Defense

Page 58 GAO-12-367 Military Education
Appendix V: Comments from the Department 

of Defense

Page 59 GAO-12-367 Military Education
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 60 GAO-12-367 Military Education

Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov

In addition to the contact above, Laura Talbott, Assistant Director; 

Darreisha Bates; Maria McCollester; Erin Preston; Sara Olds; Terry 

Richardson; Amie Steele; Cheryl Weissman; Allen Westheimer; and 

Michael Willems made key contributions to this report.

Appendix VI: GAO Contact and Staff 

Acknowledgments 

Contact 

Acknowledgments 

(351606)
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