MILITARY 

DEPENDENT 

STUDENTS

Better Oversight 

Needed to Improve 

Services for Children 

with Special Needs

Report to the Committee on Armed 

Services, U.S. Senate

September 2012

GAO-12-680

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-680, a report to the 

Committee on Armed Services, U.S. Senate

September 2012

MILITARY DEPENDENT STUDENTS

Better Oversight Needed to Improve Services for 

Children with Special Needs

Why GAO Did This Study

DOD operates a worldwide school 

system to meet the educational needs 

of military dependents. Questions have 

arisen about whether DOD is meeting 

the special needs of some of these 

children, such as those with learning 

disabilities. In response to a mandate 

in the National Defense Authorization 

Act for Fiscal Year 2011, GAO 

reviewed (1) how DOD provides 

special education services; (2) how 

DOD entities coordinate to assign 

families overseas and how schools 

might be affected; (3) what challenges, 

if any, families face in accessing DOD 

services for their children with special 

educational needs and obtaining 

related information; and (4) what steps, 

if any, DOD is taking to enhance 

screening and overseas assignment 

for families with children with special 

educational needs. GAO reviewed 

relevant federal laws and regulations, 

analyzed DOD documents and data, 

and conducted interviews with officials 

from multiple DOD entities, including 

schools. GAO also held 22 focus 

groups with parents of children with 

special needs during site visits and 

phone interviews at eight military 

installations worldwide. 

What GAO Recommends

GAO recommends that the Secretary 

of Defense (1) ensure the military 

branches medically and educationally 

screen all school-age children before 

relocation overseas; (2) direct OSN to 

establish benchmarks and 

performance goals for the EFM 

program; and (3) direct OSN to 

develop and implement a process for 

ensuring the branches’ compliance 

with EFM program requirements. DOD 

generally agreed with the 

recommendations.

What GAO Found

The Department of Defense (DOD) provides special education services through 

a complex system that varies by location. Domestically, DOD provides special 

education mainly within DOD schools. In contrast, DOD schools overseas vary in 

the types and levels of disabilities they are readily equipped to serve. For 

example, DOD schools in Ramstein, Germany, are equipped to serve children 

with severe disabilities of any type, whereas schools in some other overseas 

installations have no pre-established special education programs of any kind.

Overseas assignment of servicemembers with children with special educational 

needs requires coordination between the military branches through their 

Exceptional Family Member (EFM) programs and the DOD Education Activity—

the office that oversees education of military dependent children in DOD schools. 

Each branch implements its own processes for screening military families and 

assigning servicemembers to locations where there are school services that can 

meet their families’ needs. However, impediments to effective placements may 

strain school resources. More specifically, ineffective screenings may result in 

families being placed in locations where schools are not readily equipped to 

serve certain needs. For example, we found one case in which a school that only 

had programs in place for students with mild disabilities received a student with 

severe needs who had not been educationally screened.

Families in many of GAO’s focus groups were generally satisfied with the 

services DOD provided their children with special needs once they received 

them, but they felt that the limited availability of special education and medical 

specialists overseas presented challenges. Some parents were concerned their 

children were not receiving all the services they needed, partly due to difficulties 

DOD schools encounter hiring and retaining special education staff, especially 

overseas. While the military branches provide family support services, parents in 

our focus groups also indicated they lacked information about obtaining special 

education and related medical services. DOD is taking some steps to provide 

better information to families, but the extent to which these efforts are helping 

them is unclear.

DOD’s recently established Office of Special Needs (OSN) is responsible for 

enhancing and monitoring support for military families with special needs. OSN 

and the military branches have initiated efforts to improve screening and 

overseas assignment of military families with special needs. However, it is 

unclear when some of these efforts will be completed. Moreover, while OSN was 

established in part to enhance and monitor the military branches’ support for 

families with special needs, it has limited enforcement authority and oversight 

over the branches’ EFM programs. Specifically, it is limited in the extent to which 

it can compel the branches to comply with DOD or service-level program 

requirements, and it has no direct means by which to hold them accountable if 

they fail to do so. In addition, DOD currently lacks agencywide benchmarks and 

performance goals for all components of the EFM program. As a result, it cannot 

assess the effectiveness of the branches’ EFM programs and ensure that 

improvements are made when needed. Without overall performance information 

to proactively identify emerging problem areas, some of the branches have had 

to conduct investigations to address problems after they have arisen.

View GAO-12-680. For more information, 

contact George Scott at (202) 512-7215 or 

scottg@gao.gov.
Page i GAO-12-680 Military Dependent Students

Letter 1 

Background 3

DOD Provides Special Education Services through a Complex 

System That Varies by Location 11

Military Branches Screen Families and Consult with DODEA to 

Assign Families to Overseas Locations, but Ineffective Processes 

May Strain School Resources 15

Families Generally Satisfied with Special Education Services, but 

Face Challenges Obtaining Them 20

DOD Is Taking Steps to Improve EFM Programs, but Limited 

Oversight Hinders Its Ability to Assess and Ensure Program 

Effectiveness 25

Conclusions 29

Recommendations for Executive Action 30

Agency Comments and Our Evaluation 31

Appendix I Scope and Methodology 34

Appendix II DODEA Categories and Definitions of Disabilities 38

Appendix III Comments from the Department of Defense 42

Appendix IV GAO Contact and Staff Acknowledgments 45

Related GAO Products 46

Table

Table 1: Site Visit Installation and School Selection 35

Contents
Page ii GAO-12-680 Military Dependent Students

Figures

Figure 1: Location of DOD Schools and Number of Students 

Receiving Special Education Services, January 2012 4

Figure 2: Primary Type of Disability of Children Enrolled in DOD 

Schools, January 2012 6

Figure 3: IEP Process for DOD Schools 8

Figure 4: DOD Entities That Provide Special Education Services 11

Figure 5: Examples of Variation in Levels of Services Available at 

DOD Schools Overseas 13

Abbreviations

DOD Department of Defense

DODEA Department of Defense Education Activity

EDIS Educational and Developmental Intervention 

 Services

EFM (Program) Exceptional Family Member Program

IDEA Individuals with Disabilities Education Act 

IEP Individualized Education Program

NDAA National Defense Authorization Act

OSN Office of Special Needs

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-12-680 Military Dependent Students

United States Government Accountability Office

Washington, DC 20548

September 10, 2012

The Honorable Carl Levin

Chairman

The Honorable John S. McCain

Ranking Member

Committee on Armed Services

United States Senate

Military families who have children with special needs, such as 

communication impairments or learning disabilities, face a unique set of 

challenges, in part due to their frequent moves within the United States 

and to overseas installations.1

About 12 percent of the approximately 85,000 children enrolled in 

Department of Defense (DOD) schools worldwide received special 

education services in the 2011-12 school year, and over half of these 

students were in schools overseas.

Recent executive branch, congressional, 

and advocacy group initiatives have focused on increasing support for 

these families. For example, in 2011 the White House issued a report 

making the care and support of military families a top national security 

policy priority, including ensuring excellence in military children’s 

education and development.

2 DOD is required to provide special 

education and related services for children with disabilities who attend 

DOD schools, as prescribed in the Individuals with Disabilities Education 

Act (IDEA).3

Given the important role DOD schools play in serving highly mobile 

military families, questions have arisen regarding whether DOD is 

meeting the complex needs of students with special needs.4

 

1

For the purpose of this report, the terms “special needs” and “disabilities” will be used 

interchangeably, unless indicated otherwise.

In response 

2

Data are as of January 2012.

3

Codified at 20 U.S.C. §§ 1400 to 1482. 

4

The term “special needs” encompasses both children with disabilities that receive special 

education services as well as children that meet the definition of special needs under the 

military branches’ Exceptional Family Member programs, both of which are discussed 

later in this report.

 
 

Page 2 GAO-12-680 Military Dependent Students

to a mandate in the Senate report accompanying the National Defense 

Authorization Act (NDAA) for Fiscal Year 2011,5

To address these questions, we reviewed relevant federal laws and 

regulations and analyzed DOD policy and guidance documents. We also

obtained data from the DOD Education Activity (DODEA)—the office that

oversees the education of military dependent children in DOD schools—

on the number and characteristics of students in DOD schools receiving 

special education services in the United States and overseas, as well as 

quantitative and qualitative data on educational screenings and family 

assignment concerns. We determined these data to be reliable for the 

purpose of describing the population of children with disabilities in DOD 

schools and reporting information about screenings and assignment 

concerns. We conducted site visits to five military installations in Europe 

and two in the United States, as well as telephone interviews with agency 

officials at one military installation in the Pacific. We selected these 

locations based on several criteria, including the number of children with 

disabilities enrolled in DOD schools, the level of special education 

services schools were equipped to provide, variation in urban and remote 

areas, and variation among the four military branches. During our site 

visits and Pacific teleconference, we conducted meetings with officials 

from 15 schools and held 22 focus groups with the parents of students 

receiving special education services to discuss their perceptions of the 

services their children have received. While the results of these focus 

groups cannot be generalized to all parents of children with disabilities, 

nor are they representative of the population of parents, common 

responses across groups and recurring themes provide some degree of 

validation. We also interviewed DODEA officials in the United States and 

overseas, including district and school officials, such as principals, special 

education coordinators, and teachers. In addition, we interviewed officials 

GAO examined (1) how 

DOD provides special education services; (2) how DOD entities 

coordinate to assign servicemembers accompanied by their families to 

overseas locations and how schools might be affected; (3) what 

challenges, if any, families face in accessing DOD services for their 

children with special educational needs and obtaining related information; 

and (4) what steps, if any, DOD is taking to enhance assignment 

coordination for servicemembers who have children with special 

educational needs.

 

5

S. Rep. No. 111-201, at 138 (2010).
 

Page 3 GAO-12-680 Military Dependent Students

from DOD’s Office of Special Needs (OSN), the military branches, subject 

matter experts, and advocacy groups. Finally, we met with 

representatives from other DOD entities, including the military branches’ 

Educational and Developmental Intervention Services (EDIS) and the 

Exceptional Family Member (EFM) programs involved in screening and 

supporting this population. Appendix I provides a detailed description of 

our scope and methodology.

We conducted this performance audit from May 2011 through September 

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.

DOD operates a worldwide school system to meet the educational needs 

of military dependent students and others, such as the children of DOD’s 

civilian employees overseas. DODEA oversees the management and 

operation of 196 schools in seven states; Puerto Rico and Guam; and 12 

foreign countries. DODEA has organized its schools into three areas—the 

United States, Europe, and the Pacific—and multiple districts within each 

area. About 66 percent (130 of 196) of DOD schools are located overseas 

serving about 68 percent of the student population (approximately 58,000 

of 85,000 children) (see fig. 1). The overseas schools are mainly 

concentrated in Germany and Japan, where the United States built 

military installations after World War II. Almost all the domestic schools 

are in the southeastern United States.

Background 

DOD Schools and Students 

with Disabilities
 

Page 4 GAO-12-680 Military Dependent Students

Figure 1: Location of DOD Schools and Number of Students Receiving Special Education Services, January 2012

DOD schools provide a comprehensive kindergarten through 12th grade 

curriculum.6

 

6

DOD also provides pre-kindergarten programs for children between the ages of 3 and 5 

in its domestic schools. However, the overseas schools only provide pre-kindergarten 

programs for children with disabilities.

Approximately 12 percent (or about 10,200 students) of all 

students received special education services in the 2011-12 school year. 
 

Page 5 GAO-12-680 Military Dependent Students

As of January 2012, the most prevalent disabilities among children 

enrolled in DOD schools were communication impairments (such as 

speech and language impairments), specific learning disabilities, and 

developmental delays, cumulatively representing about 71 percent of this 

population (see fig. 2).7 Appendix II provides DOD’s categories and 

definitions of disabilities. While some children may have more than one 

type of disability, DODEA bases its criteria for determining eligibility for 

receiving special education services on the primary type of disability that 

has the greatest educational impact.

 

7

The total number of children used as the basis for these calculations is about 9,200, 

rather than the 10,200 reported above. This is primarily because, at any given point in 

time, some children’s special education eligibility is under review, and DODEA’s database 

does not capture their disability type.
 

Page 6 GAO-12-680 Military Dependent Students

Figure 2: Primary Type of Disability of Children Enrolled in DOD Schools, January 2012

Although DOD schools do not receive IDEA funding, DOD is required to 

provide in its educational programs the substantive rights, protections, 

and procedural safeguards for students with disabilities under IDEA.8

 

8

10 U.S.C. § 2164(f), 20 U.S.C. § 927(c).

Specifically, DOD is required to provide these children early intervention 

services, and special education and related services. For children ages 3 

to 21, this includes identifying and evaluating eligible children; developing 

and implementing an individualized education program (IEP) for such 

students (see fig. 3); and providing the students special education and 
 

Page 7 GAO-12-680 Military Dependent Students

related services.9

 

9

DOD Instruction 1342.12, Provision of Early Intervention and Special Education Services 

to Eligible DoD Dependents, April 11, 2005. Special education is specially designed 

instruction which is provided at no cost to parents to meet the unique needs of a child with 

a disability. Related services include speech-language pathology and audiology, 

psychological services, physical and occupational therapy, early identification and 

assessment of disabilities in children, and other services. In this report we refer to special 

education and related services as special education services.

The military medical departments—through their EDIS 

programs—are responsible for providing selected related services as well 

as completing evaluations for certain disabilities, such as autism or visual 

or hearing impairments, that may require medical expertise.
 

Page 8 GAO-12-680 Military Dependent Students

Figure 3: IEP Process for DOD Schools

a

The Case Study Committee is a multidisciplinary team of special educators, regular educators, 

related services personnel, administrators, and parents, where appropriate.
 

Page 9 GAO-12-680 Military Dependent Students

To implement DOD’s policy regarding overseas travel for eligible military 

dependents with special needs, each branch is required to establish its 

own EFM program for active duty servicemembers.10

• Identification and Enrollment. Active duty servicemembers with 

eligible family members are required to enroll in the EFM program for 

their branch to document dependents’ special needs, so that medical 

and educational personnel can review the availability of medical and 

educational resources in planned assignment locations.

The Army set up the 

first EFM program in 1979; since that time, the Air Force, Marine Corps, 

and Navy have also established EFM programs. EFM programs have 

three components—identification and enrollment, assignment 

coordination, and family support services.

11

• Assignment Coordination. Each military branch is required to 

identify, document, and consider a military family member’s special 

needs during the process of assigning servicemembers to a particular 

installation. Screening and assignment coordination occur when the 

branch’s personnel command requests that medical and/or 

educational professionals review a family member’s documented 

needs to determine the availability of DOD’s specialized medical and 

educational services at a planned location.

• Family Support. Each military branch’s EFM program is required to 

include a family support component. EFM program family support 

personnel assist families with special needs by helping them identify 

and access programs and services. Services may include information 

and referrals for military and community services, education and 

training about issues related to the special needs, local school 

 

10Department of Defense Instruction 1315.19, Authorizing Special Needs Family Members 

Travel Overseas at Government Expense (Dec. 20, 2005). DOD officials stated that while 

this guidance was intended for overseas travel, DOD also uses it to identify family 

members with special medical needs within the United States. 

11An eligible family member is generally defined as (1) a spouse, child, or dependent adult 

who, regardless of age, has special medical needs and requires medical services for a 

chronic condition such as asthma, attention deficit disorder, diabetes, multiple sclerosis, 

etc.; receives ongoing services from a medical specialist; or has significant behavioral 

health concerns; or (2) a child (birth through 21 years) with special educational needs who 

is eligible for, or receives, special education services through an IEP; or Early Intervention 

Services through an Individualized Family Service Plan. Civilian families are not eligible 

for EFM programs.

Exceptional Family 

Member Program
 

Page 10 GAO-12-680 Military Dependent Students

information, nonclinical case management, and assistance 

transitioning between installations.

The NDAA for Fiscal Year 2010 expanded support for military families 

with special needs.12

• developing and implementing a comprehensive policy for the support 

of military families with special needs,

While initial EFM program requirements only 

included identification and enrollment and assignment coordination, the 

Act requires DOD to develop and implement a comprehensive policy on 

family support. While the Army and Marine Corps incorporated family 

support programs into their EFM programs prior to this requirement, the 

Air Force and Navy began incorporating family support programs in 2010. 

The Act also created the Office of Community Support for Military 

Families with Special Needs, referred to as OSN, and specified its 

responsibilities to include

• establishing and overseeing associated programs,

• identifying gaps in DOD services for military families with special 

needs,

• developing plans to address gaps in DOD services through 

appropriate mechanisms such as enhancing resources and training, 

and ensuring the provision of special assistance,

• monitoring the programs of the military departments for the 

assignment of servicemembers who are members of families with 

special needs and the programs in support of such families, and

• advising the Secretary of Defense on the adequacy of such programs 

in conjunction with DOD budgeting and planning activities.

 

12National Defense Authorization Act for Fiscal Year 2010, Pub. L. No. 111-84, § 563, 123 

Stat. 2190, 2304 (2009). 
 

Page 11 GAO-12-680 Military Dependent Students

Like public schools in the United States, DOD is required to provide 

special education and related services necessary to meet the unique 

needs of eligible students. As needed, DOD schools provide special 

education services in all schools worldwide and related services (such as 

occupational and physical therapy) in its domestic schools only. 

Overseas, each branch’s medical department provides related services to 

eligible students through its EDIS program. A child with a disability may 

receive services from some or all of the DOD entities shown in figure 4, 

depending on the family’s location.

Figure 4: DOD Entities That Provide Special Education Services

Services for children with disabilities in DOD schools may include 

consultation by special educators to general classroom teachers or 

instruction in a special education classroom for part or all of the school 

day. In addition to special and general education teachers, DOD schools 

employ paraprofessionals—who assist and support teachers— and 

specialists, such as speech and language therapists. DOD schools in the 

United States also provide related services, such as physical and 

occupational therapy.

The military branches’ medical departments provide different types of 

services for children with disabilities through their EDIS programs. EDIS 

helps identify children with disabilities and delivers early intervention 

services to eligible infants and toddlers, from birth through age 2. EDIS 

also provides medical assessments necessary to determine children’s 

eligibility for special education services. For example, in order to provide 

special education services for children with emotional impairments or 

autism spectrum disorders, DODEA requires medical evaluations and 

diagnoses by qualified medical professionals, such as developmental 

pediatricians, psychologists, or psychiatrists. Although military families 

may use civilian providers in the United States, when stationed overseas, 

DOD Provides Special 

Education Services 

through a Complex 

System That Varies by 

Location 
 

Page 12 GAO-12-680 Military Dependent Students

only military providers may provide these diagnoses for children attending 

DOD schools. Overseas, EDIS also provides related services for children 

enrolled in DOD schools.

Domestic DOD schools provide special education for all types and levels 

of disabilities, mainly within DOD schools. However, according to DOD, in 

certain cases students may receive services from external service 

providers that DOD contracts with or they may be placed in local public 

schools. Overseas, the military branches and DODEA have implemented 

a system of specific, pre-established programs for different types of 

disabilities and levels of services in each school. For example, schools in 

Ramstein, Germany, have programs designed to serve children with all 

types of disabilities, whereas schools in Iwakuni, Japan, have programs 

that serve only a few types of disabilities, and the Seville Elementary 

School in Spain has no programs for any type of disability. Agency 

officials explained that this variation is a function of the size of the military 

community and the needs of the military. To help facilitate intra-agency 

communication about these differences, DOD developed a directory that 

indicates which pre-established programs are available in each school 

overseas. (See figure 5 for an excerpt of this directory.)
 

Page 13 GAO-12-680 Military Dependent Students

Figure 5: Examples of Variation in Levels of Services Available at DOD Schools 

Overseas

Notes: All disabilities reflect a continuum of severity, ranging from mild to moderate to severe. The 

types of services provided and the levels of disabilities are described in detail in the DOD Services 

Directory for overseas locations. Below are some examples of the types of services provided for each 

level. However, the descriptions are neither complete nor representative of all disability types.

a

Developmental delay is a disability category for children from birth through age 7. Therefore, the 

classification of a developmental delay does not apply in intermediate, middle, or high schools.
 

Page 14 GAO-12-680 Military Dependent Students

b

For mild disabilities, children are typically accommodated in the general education classroom setting 

and receive needed services through school resources or itinerant specialists. There are no schools 

with pre-established programs for mild Autism Spectrum Disorder, Emotional Impairment, or 

Intellectual Disability.

c

For most types of moderate disabilities, students receive the majority of their instruction in the 

general education classroom and may also receive supplemental instruction in a resource room.

d

For severe disabilities, children may receive instruction in a variety of settings, including the general 

education classroom and a self-contained environment.

Moreover, DOD schools provide different levels of service for each type of 

disability, as indicated by the circles in the DOD directory excerpt shown 

in figure 5. For example, Garmisch Elementary School in Germany has a 

program to provide services in the general education classroom for 

children with the mildest forms of specific learning disabilities. In contrast, 

Naples Elementary School in Italy is equipped to provide individualized 

instruction in a separate classroom setting for children with the most 

severe types of specific learning disabilities. Schools in Ramstein, 

Germany, are equipped to serve children with severe disabilities of any 

type. Nonetheless, consistent with IDEA requirements, it is DOD policy 

that all schools must provide special education services to all students 

with such needs, regardless of the types or severity of students’ needs or 

the school’s location.
 

Page 15 GAO-12-680 Military Dependent Students

Because DOD schools in overseas communities are designated to serve 

children with certain types and levels of disabilities, the military branches 

and DODEA are required to coordinate the overseas assignment of 

servicemembers with families with special needs, including all children 

with IEPs.13

Each branch implements its EFM program differently, and the branches’ 

screening and assignment coordination processes also vary somewhat. 

Generally, through a process referred to as EFM program assignment 

coordination, the servicemember’s personnel office coordinates with the 

medical department to verify the availability of medical services in the 

planned location overseas. During this process, the military branch is also 

required to coordinate with DODEA about the educational programs 

available. DODEA makes a recommendation based on the services 

available at the schools, and the branch’s medical department makes a 

recommendation about the availability of medical services. The military 

branch then determines whether the servicemember and his or her family 

should proceed to the planned location. Depending on the 

recommendations of both medical and educational reviewers, the 

servicemember may be approved for travel accompanied by family 

All family members who are seeking a move overseas must 

be screened by the relevant branch’s medical department for medical and 

educational needs in addition to other factors that might inhibit travel 

overseas, such as financial problems. If the medical screening identifies 

an EFM program-enrollable condition, the servicemember is referred for 

EFM program enrollment.

 

13Sections 5.4.3, E4.1 and E4.2 of Department of Defense Instruction 1315.19.

Military Branches 

Screen Families and 

Consult with DODEA 

to Assign Families to 

Overseas Locations, 

but Ineffective 

Processes May Strain 

School Resources

Military Branches’ 

Processes to Coordinate 

Overseas Assignment of 

Servicemembers with 

Families with Special 

Needs Are Not Always 

Effective 
 

Page 16 GAO-12-680 Military Dependent Students

members, recommended to relocate to a different location, or allowed to 

take an unaccompanied tour. However, according to DODEA and one 

branch’s military officials, the installation’s command personnel may 

override a recommendation for an unaccompanied tour and allow the 

servicemember to bring the family if he or she has special skills that are 

needed at an installation.

Each year, some military families with children with special educational 

needs are sent to locations that are not prepared to serve their children’s 

needs upon arrival. This may occur either due to a “screening failure” 

(i.e., when an educational screening did not occur) or an “assignment 

concern” (i.e., when the family was screened but the child was 

nonetheless enrolled in a school unequipped to meet his or her needs). 

DODEA records the number of screenings completed and assignment 

concerns, as well as the reasons for such concerns. DODEA data show 

that since school year 2008-09, there have been 93 instances when 

children were educationally screened, but still arrived at a school that did 

not have programs in place to meet their needs.14

 

14According to a DODEA official, the office does not maintain data on the number of 

children with special needs who should have been educationally screened. DODEA data 

show that over 5,000 children were educationally screened during this same time frame. 

Data reported are as of April 2012.

This may have 

occurred because (1) the student’s needs were more severe than the 

educational or medical screening indicated, (2) the military overrode 

DODEA’s assignment recommendation, or (3) the servicemember was 

approved for one location but was reassigned to another. Moreover, 

several DODEA and school officials we interviewed confirmed that a 

number of children with special educational needs who were not 

screened have enrolled in their schools. For example, school officials in 

Naples said that a few years ago, the school received 44 incoming 

students with IEPs, but only four of those students had been 

educationally screened through the EFM program. According to OSN 

officials, schools are generally able to accommodate children with mild 

disabilities regardless of the location, and such cases would not be 

recorded as assignment concerns. However, DODEA officials overseas 

also stated that when children with severe disabilities are sent to locations 

that do not have appropriate pre-existing programs, even a very small 

number of these cases can require substantial additional resources. 

According to a Navy EFM program official at an installation we visited, 
 

Page 17 GAO-12-680 Military Dependent Students

screening and assignment coordination failures could cost the military up 

to $100,000 per incident.

Although all four branches require EFM program enrollment for eligible 

servicemembers, underenrollment in and circumvention of EFM programs 

were cited repeatedly as concerns during our interviews and site visits. 

Senior OSN officials estimated that about half the families with children 

with special needs who are eligible to enroll in the EFM program have not 

done so. They attributed underenrollment to several factors, including that 

some families having children with very mild disabilities may think they 

are not eligible for the program or may not be aware it exists. DODEA’s 

Europe area and military officials at three of the eight installations 

included in our study explained that more families are eligible to enroll in 

EFM programs than have done so. OSN and military officials at three 

installations also explained that families with special needs may not 

realize they are required to enroll in EFM programs. DOD officials also 

explained that a family might be using an off-base medical provider who 

is not aware of the program. An EFM program official from one installation 

added that families who rarely relocate may not understand why it is 

important to enroll. Another EFM program official from a different 

installation acknowledged that more work needs to be done to raise 

awareness and enroll families in EFM programs.

Servicemembers may also intentionally circumvent educational screening 

and EFM enrollment. More specifically, servicemembers sometimes avoid 

identifying their children’s special educational needs by declining special 

education services or inaccurately completing relevant forms, according 

to DODEA officials in Europe and the Pacific, as well as other DOD 

entities we interviewed. Senior OSN officials believe that a fair number of 

families intentionally opt not to enroll in the EFM program because some 

are concerned that enrollment may adversely affect servicemembers’ 

careers. They noted that there is a perceived stigma associated with EFM 

enrollment among servicemembers. Some servicemembers have also 

been known to travel with their families against recommendation and 

once on base, request approval from the installation leadership for the 

family to stay, according to DODEA and military officials at one

installation. In seven of our focus groups, parents said they felt that 

enrolling in EFM would hurt their chances of being assigned to a position 

or location they desire. However, DOD policy states that servicemembers 

with children with special educational needs should be assigned to 

appropriate locations overseas consistent with the needs of the military 

and the career of the servicemember. According to senior OSN and 

Underenrollment and 

Circumvention of EFM 

Procedures Hinder 

Program Effectiveness
 

Page 18 GAO-12-680 Military Dependent Students

military officials at two installations, EFM enrollment does not limit 

servicemembers’ career opportunities. They noted that servicemembers 

can accept an unaccompanied tour to the desired location or seek a 

different assignment that would better support the family’s needs if the 

initially planned location is not suitable.

EFM programs may not be as effective as they could be due to 

inconsistent policy enforcement regarding enrollment. DOD policy 

provides that a servicemember who fails or refuses to provide the 

information required for overseas screening and assignment or knowingly 

provides false information may be subject to disciplinary action and 

administrative sanctions, including denial of command sponsorship.15

Medical screening failures may also contribute to underenrollment in EFM 

programs. More specifically, some special educational needs are 

identified when families complete medical screenings for overseas 

assignments. However, officials from OSN and a military branch 

explained that sometimes these needs are not identified during 

screenings, resulting in families not being enrolled in EFM programs. For 

example, if a servicemember’s child is diagnosed with autism by a civilian 

provider, the military’s overseas screening personnel may not be aware of 

it—since, according to officials from this branch and DODEA, they only 

have access to records from military hospitals or treatment facilities—

unless families disclose this information. Senior DOD officials stated that 

they believe such failures are uncommon and have minimal impact on 

EFM program enrollment.

However, OSN and military officials we spoke to at two installations 

indicated that installation commanders rarely take such disciplinary 

actions.

In addition, some branches’ EFM programs face administrative 

challenges that may contribute to underenrollment of families with special 

needs. A military official from one installation observed that EFM program 

staff often do not complete the EFM program paperwork or they take a 

significant amount of time to do so because other duties take priority. For 

example, officials from two installations said that ideally enrollment should 

occur within 4 to 6 weeks, but can sometimes take several months for the 

process to be completed. Moreover, officials at two installations from one 

 

15Section E5.2.3 of Department of Defense Instruction 1315.19.
 

Page 19 GAO-12-680 Military Dependent Students

military branch told us that enrollment forms were not always forwarded to 

the receiving installation for review.

When screening and assignment processes are ineffective, students may 

arrive at schools that are not immediately equipped to meet their needs. 

Officials at some schools we visited told us it can be difficult to 

accommodate students whose needs they are not structured to serve. 

DODEA district and area office officials concurred, and noted that this is 

one of the most significant challenges that schools overseas face. To 

meet the needs of students, schools may need to reallocate or increase 

staff and other resources, which can be difficult with limited resources.

According to a senior DODEA official, the local district or area 

administrative offices will first attempt to shift existing resources to meet 

the needs of students. Typically, a school might bus a student to another 

location or hire a paraprofessional. However, if necessary, DODEA will 

purchase new equipment or hire a teacher, a process that can be lengthy 

in some instances. For example, during our review of DODEA’s screening 

and assignment concern database, we found one case in which a school 

overseas that did not have pre-existing programs in place for students 

with severe cognitive disabilities received such a student. The student’s 

family had not gone through EFM program screening before the 

servicemember’s authorization to travel was approved. Once the child’s 

educational records were reviewed, travel was not recommended for the 

family, but the family arrived nonetheless. As a result, the school had to 

expend additional resources to meet the student’s needs.

In contrast to military personnel, civilian families are not required to enroll 

in EFM programs or to undergo medical screenings prior to relocating 

overseas. According to DOD officials, under federal law16

 

16The Genetic Information Nondiscrimination Act (Pub. L. No. 110-233, 122 Stat. 881) 

prohibits employers from requesting genetic information, including family medical history, 

from their employees.

human 

resource offices are prohibited from asking civilian employees whether 

their family members have certain medical conditions or other special 

needs and cannot bar employment or relocation to overseas installations 

based on such factors. However, according to DOD policy, DOD human 

resource offices are responsible for providing information to civilian 

employees regarding the educational and medical services available at 

Failures to Screen and 

Coordinate Assignments 

May Strain School 

Resources
 

Page 20 GAO-12-680 Military Dependent Students

overseas installations, so that the civilian employee or selectee may 

make an informed choice regarding whether to accept the overseas 

position. DOD human resource offices are also required to provide a point 

of contact to answer applicants’ questions.

Officials from two schools we visited also said that because civilian 

families do not undergo any systematic screening before transferring 

overseas, they tend to have the most severe needs. Senior DOD officials, 

however, told us they do not maintain data on whether civilian families 

have more severe needs than active duty families. A school official at an 

installation in Europe told us that the majority of students with severe 

special needs enrolled in schools on that installation are civilians, and that 

military dependents with similar needs would have been identified and 

likely prevented from transferring there during the screening and 

assignment process. According to data provided by DOD, as of January 

2012, there were approximately 1,100 children with special needs from 

civilian families enrolled in DODEA schools.

Families in 21 out of the 22 focus groups we held told us they were 

generally satisfied with the special education services their children 

received in DOD schools once they received them. Further, participants in 

10 focus groups said that special education services in DOD schools 

were superior to those in the non-DOD schools their children had 

attended. In fact, one focus group participant in Germany was so pleased 

with the special education services her children had received at DOD 

schools that she wanted to remain on the installation for several 

additional years so her children could graduate from them.

Despite families’ general satisfaction with services once their children 

received them, participants in 16 out of 22 focus groups we held reported 

facing challenges obtaining these services due to the limited availability of 

related service providers available on military installations, particularly 

overseas. More specifically, participants in seven focus groups said they 

Families Generally 

Satisfied with Special 

Education Services, 

but Face Challenges 

Obtaining Them

Limited Educational and 

Medical Specialists in 

Some Locations Pose 

Challenges for Families, 

and Schools Struggle to 

Hire and Retain Staff
 

Page 21 GAO-12-680 Military Dependent Students

believe that there are shortages of occupational therapists or physical 

therapists at certain schools. For example, a parent in one focus group 

believed her child was not receiving necessary services as often as she 

felt was warranted. In the 2008-09 school year, DODEA issued 285 

reports of unavailability of medically related services for military 

dependents in the Pacific region due to the number of vacancies at Navy 

EDIS clinics and delays in filling positions.17 According to these reports, 

unavailable services included diagnostic evaluations, social work 

services, as well as occupational and physical therapy. Since 2009, many 

of these cases have been resolved.18

In addition, participants in six of our focus groups expressed concern with 

perceived shortages of paraprofessionals to assist special education 

teachers, and participants in four focus groups also stated that they 

believed there was high turnover among them. Officials from three 

schools we spoke with and DODEA officials from one district indicated 

that there are shortages of paraprofessionals or high turnover among 

them. The high turnover rate among paraprofessionals can be especially 

disruptive for children with special needs, who thrive on consistency, 

according to parents in three of our focus groups.

In school years 2009-10 and 2011-

12, there were 41 reports of unavailability of medically related services.

Participants in seven focus groups told us it has been difficult for them to 

obtain medical services for their children. Since IEPs require medical 

diagnoses for some conditions, limited medical services can directly affect 

students’ educational progress. According to DODEA guidelines, certain 

impairments require medical reports from appropriate specialists, which 

can include developmental pediatricians, psychologists, autism clinicians, 

and audiologists, among others. Some school, DODEA, and EFM 

program officials we met with confirmed that it can be difficult for families 

to obtain medical services on base. For example, while DOD officials told 

us that military families have greater access to developmental 

 

17Reports of unavailability of medically related services are filed when a DOD school 

determines that children with disabilities have unmet medical needs. 

18According to DODEA’s Annual Compliance Report for 2009, several of the cases were 

resolved and make-up services were provided to many students in the summer of 2009. In 

addition, DODEA’s Annual Compliance Report for 2010 states that the number of reports 

on unavailability of medically related services was substantially reduced in the 2009-10 

school year as a result of ongoing oversight and corrective actions implemented by the 

Navy.
 

Page 22 GAO-12-680 Military Dependent Students

pediatricians than civilians, officials at a domestic school we visited said 

that waiting lists for developmental pediatricians at the military medical 

treatment facilities are so long that families frequently seek care from 

private providers. Further, a senior military official at another domestic 

installation told us that the local military treatment facility does not have a 

permanent developmental psychologist and as a result, some families 

have to wait almost 2 months for appointments. In addition, participants in 

five focus groups told us it has been difficult for them to obtain a particular 

type of autism therapy for their children, especially overseas. For 

example, one focus group participant in Germany told us there is a long 

waiting list to receive Applied Behavioral Analysis (ABA) therapy in 

Germany.19

Moreover, officials from many DOD schools we visited said it is difficult to 

fill and retain key positions, including special education teachers, 

paraprofessionals, and specialists. When a school needs additional staff 

to fill vacant teacher or specialist positions, candidates are first recruited 

from the local area. If they cannot be recruited locally, candidates are 

hired from the United States through a process that can take several 

months. Hiring delays may create staffing challenges for schools, and 

they may need to rely on substitutes or reallocate existing staff. For 

example, officials from one overseas school said that they began the 

school year with long-term substitutes in special education classrooms 

because teachers were not yet in place. In addition, officials from the 

same school stated that although the school began the process of filling a 

projected speech and language therapist vacancy in April 2011, the 

position was not filled until late September of that year, several weeks 

after the school year had begun. As a result, school officials stated they 

had to divide the workload among existing staff and some students 

received fewer services in the meantime. Officials from two additional 

schools noted their speech and language therapists’ caseloads exceeded 

the DODEA standard of 30 to 50 students. Officials from one of these 

schools said it is unclear when they will receive another speech and 

While the military does not provide ABA therapy in military 

treatment facilities, according to DOD officials, many families have 

become accustomed to receiving this service in the United States. Some 

DODEA area and school officials we spoke with acknowledged a 

shortage of autism specialists overseas.

 

19Applied Behavioral Analysis therapy involves the use of certain principles and 

techniques to bring about changes in behavior. 
 

Page 23 GAO-12-680 Military Dependent Students

language therapist to reduce their large caseloads. DODEA area officials 

also noted the difficulties in hiring speech and language therapists and 

other special education staff. Overall, parents in seven focus groups 

stated that they believed their children did not always receive all the 

speech and language therapy they needed, and some of these parents 

felt that there were shortages of these therapists. Likewise, DODEA 

district officials in Europe and a few school officials we spoke with 

overseas also acknowledged that hiring and retaining special education 

paraprofessionals can be difficult, citing low pay and the fact that the 

hiring pool—typically spouses from the local community—is a small and

highly mobile population.

The family support components of each of the military branches’ EFM 

programs are responsible for supporting military families with special 

needs by providing information and referral and nonclinical case 

management services. For example, EFM case managers at military 

installations may identify families’ needs, provide relevant information and 

referrals, assist families in accessing resources, and coordinate among 

various resources and services. EFM family support services are 

available to all military families with special needs, including those with 

children with special educational needs. However, the support military 

branches offer through their EFM programs vary. For example, an EFM 

program official at an Army installation in Germany told us that every 

incoming family is provided informational materials, including those on 

special education, and a meeting with a case manager is scheduled to 

discuss the family’s needs. In contrast, an EFM program official at a Navy 

installation in Italy said that families are expected to reach out to EFM 

family support staff to obtain information when they arrive.

School Liaison Officers and DODEA may also provide some information 

to families. School Liaison Officers generally support military leadership in 

coordinating with and advising parents of school-aged children on all 

educational issues. According to a senior DODEA official, DODEA also 

provides families information on special education services and 

processes, including documents on parental rights and responsibilities 

and a special education handbook.

Despite the existing support available and their general satisfaction with 

services once receiving them, families in 16 of our 22 focus groups said 

they felt the information they received about obtaining services was 

insufficient for their needs. Participants in four focus groups noted they 

faced challenges navigating DOD’s complex system in order to obtain 

Families Lack Information 

about Obtaining Services
 

Page 24 GAO-12-680 Military Dependent Students

special education and medical services. Seventy of the 92 active duty 

servicemembers and spouses who attended our focus groups reported 

having one or more children enrolled in their respective branch’s EFM 

program. While families in three of our focus groups reported they were 

satisfied with their respective branches’ EFM programs, parents in 21of 

the 22 focus groups told us that the program played little to no role in 

helping them learn about or access special education and medical 

services. Further, while each of the military branches’ EFM programs 

have case managers to assist military families in learning about and 

obtaining special education and medical services for their children, 

families in seven of our focus groups told us they lacked a central point of 

contact to assist them in doing so. As a result, a participant in one focus 

group reported feeling “lost” when trying to learn about and access such 

services, while another noted feeling “frustrated.” Families in three of our 

focus groups indicated they had to be proactive and obtain information on 

their own, while participants in three focus groups also stated they 

primarily received information from other families with children with 

disabilities. In addition, participants in three focus groups were not aware 

that the EFM program provided support in learning about or accessing 

services. Focus group participants at one installation overseas said they 

did not receive any information from EFM programs regarding what types 

of special education services and specialists were available on base 

before they relocated. Officials at two schools we visited, as well as 

military officials at one installation, confirmed that families sometimes face 

challenges obtaining information and navigating the system for accessing 

special education and medical services. 

At the DOD headquarters level, OSN has taken some steps to provide 

better information to families and identify their concerns, including 

developing outreach and marketing materials and updating website 

information on EFM programs for families. For example, OSN has 

provided resources to help strengthen education and awareness in the 

Army EFM program community. Further, OSN, in collaboration with the 

military branches, is in the process of developing online learning modules, 

including an overview of the EFM program. OSN has also developed a 

reference guide for EFM program case managers to help them access 

and network with community support systems. However, the extent to 

which these efforts are helping families obtain information and access 

services for their children remains unclear.
 

Page 25 GAO-12-680 Military Dependent Students

OSN and the military branches are taking actions to improve assignment 

coordination processes for military families with special needs. These 

efforts include, but are not limited to, families with children with disabilities 

who require special education services. DOD provided $5 million in fiscal 

year 2010 and $10 million in fiscal year 2011 to the military branches, 

based on their needs, to hire and train an additional 120 EFM program 

family support personnel to assist military families with identifying and 

accessing programs and services. The military branches also hired staff 

or identified a point of contact at all installations to support military 

families with special needs and trained all EFM program family support 

staff. As of fiscal year 2012, the branches allocated funding to maintain 

these additional staff.

Since its establishment in late 2010, OSN has begun several initiatives to 

improve EFM programs, including revising DOD policy to establish 

minimum requirements for the three components of the program. OSN is 

revising the policy in response to the 2010 NDAA in order to reflect 

requirements included in the legislation. Under the new policy, currently in 

draft, each military branch will be expected to revise and implement 

branch-specific guidance. According to a senior OSN official, the draft 

policy will include reporting requirements for the branches, such as the 

number of EFM families identified and screened and the number of 

assignment concerns. OSN officials indicated the draft policy revisions 

are currently undergoing internal review and could take a year or more to 

be finalized. OSN is also working with the Council on Accreditation to 

develop performance goals for the family support component of the EFM 

DOD Is Taking Steps 

to Improve EFM 

Programs, but Limited 

Oversight Hinders Its 

Ability to Assess and 

Ensure Program 

Effectiveness 

DOD Has Taken Recent 

Steps to Improve 

Screening Processes
 

Page 26 GAO-12-680 Military Dependent Students

programs.20

OSN is also undertaking another initiative, working with a contractor to 

conduct an analysis of each branch’s current EFM program databases 

and case management systems. According to officials, this analysis is a 

first step in a long-term project to determine the feasibility of developing a 

joint database that would network all three components of the EFM 

program. If a joint database is developed, OSN officials noted that a 

range of relevant program officials—including DODEA staff, medical 

providers, and EFM case managers—would have access to components 

of the joint database to obtain information necessary to assist families 

with special needs. As of May 2012, the first phase of the analysis is 

complete and provides information on all the information sources and 

databases for each of the military branches’ EFM programs, according to 

a senior OSN official. As a next step, OSN expects to develop common 

definitions and explore ways to merge or network existing databases, 

which officials anticipate will be completed by October 2013. However, an 

OSN official stated that developing a joint database will require significant 

buy-in from each military branch. As such, this process is anticipated to 

take several years, according to officials.

According to agency officials, this effort is based on the 

requirements set forth in the 2010 NDAA. These performance goals are 

intended to address the resource and referral aspects of family support 

services, among other things.

Although OSN was established to enhance and monitor the military 

branches’ support for military families with special needs, it lacks a strong 

oversight role and enforcement authority. Because the military branches 

are responsible for implementing and enforcing EFM program 

requirements, OSN currently has limited authority to enforce these 

requirements if a military branch does not follow or effectively implement 

them. According to DOD policy, each military branch is required to 

maintain records and report annually to the Deputy Under Secretary of 

Defense for Military Community and Family Policy on the current number 

 

20The Council on Accreditation is an international, independent, not-for-profit, child- and 

family-service and behavioral healthcare accrediting organization. It was founded in 1977 

by the Child Welfare League of America and Family Service America (now the Alliance for 

Children and Families). Originally known as an accrediting body for family and children’s 

agencies, the Council on Accreditation currently accredits over 45 different service areas. 

Among the service areas are substance abuse treatment, adult day care, services for the 

homeless, foster care, and inter-country adoption.

Office of Special Needs’ 

Oversight of Screening 

Processes and Family 

Support Programs Is 

Limited
 

Page 27 GAO-12-680 Military Dependent Students

of family members identified with special needs and the effectiveness of 

its processes for implementing EFM program guidance.21

DOD also currently lacks comprehensive agencywide benchmarks and 

performance goals with which to measure the effectiveness of the 

branches’ EFM programs. As noted previously, OSN is in the process of 

developing performance goals for the family support function of the EFM 

program in response to requirements set forth in the 2010 NDAA. 

However, OSN does not currently have benchmarks and performance 

goals for the two other components of the program—

identification/enrollment and assignment coordination. Our prior work has 

noted that establishing performance goals and measuring progress is a 

key element of effective oversight.

However, 

officials from at least one branch’s EFM program acknowledged they had 

not provided the required reports, and OSN is limited in the extent to 

which it can compel them to do so. DOD officials noted that while OSN 

does not have direct enforcement authority over the branches’ EFM 

programs, high-level responsibility for ensuring compliance with program 

requirements rests with the Under Secretary of Defense for Personnel 

and Readiness. For example OSN, through the Under Secretary of 

Defense of Personnel and Readiness, may submit a report to DODEA or 

the secretaries of the military branches citing noncompliance. However, 

only the branches have the ability to take corrective action based on such 

letters. Further, some DOD officials expressed concern about the lack of 

military leadership’s sustained attention and commitment to EFM 

programs.

22

 

21DOD Instruction 1315.19(5.4.15) and DOD Instruction 1315.19(E5.1.3).

At least one military branch has 

included performance goals and standards in its EFM program policy. 

Specifically, the Air Force’s EFM program instruction includes targets and 

benchmarks for relocations due to assignment concerns. For example, 

according to these benchmarks, less than 0.5 percent of families who 

relocate each calendar year should be relocated again as the result of 

unavailable educational or medical services at the initial location. Another 

Air Force target stipulates that 5 percent or less of EFM program 

reassignments in each calendar year will be due to screening failures.

22See, for example GAO, Preventing Sexual Harassment: DOD Needs Greater 

Leadership Commitment and an Oversight Framework, GAO-11-809 (Washington, D.C.: 

Sept. 21, 2011) and Military Personnel: DOD’s and the Coast Guard’s Sexual Assault 

Prevention and Response Programs Face Implementation and Oversight Challenges, 

GAO-08-924 (Washington, D.C.: Aug. 29, 2008). 
 

Page 28 GAO-12-680 Military Dependent Students

Because DOD currently lacks performance goals and benchmarks, it 

cannot assess the effectiveness of the branches’ EFM programs and 

ensure that improvements are made when needed. Without overall 

performance information to proactively identify emerging problem areas, 

some of the branches have only been able to react to specific problems 

after they have arisen. For example, entities within the Air Force and 

Navy have conducted internal audits or investigations in response to 

concerns regarding special education services and EFM programs. In 

December 2009, the Inspector General of the Air Force initiated an 

investigation of the Air Force’s EFM program in response to complaints 

from a number of Air Force families with special needs.23 The 

investigation substantiated many of the complaints from families, 

including allegations that installations did not follow required assignment 

coordination procedures. As of June 2012, the Air Force has not 

determined its plans to respond to the investigation findings. Similarly, in 

April 2009, the Naval Audit Service initiated an audit of the Marine Corps’ 

EFM program.24 While this audit focused on children’s access to special 

education services in public schools in the United States, the Naval Audit 

Service identified areas for improvement in the Marine Corps’ oversight 

and provision of EFM program services. The Marine Corps concurred 

with the audit’s recommendations. As of June 2012, Marine Corps 

officials stated that most of the audit’s recommendations have been 

addressed. They added that the remaining open recommendations are 

related to ongoing efforts currently being implemented, such as those 

intended to improve case manager training processes. Finally, in April 

2010, the Naval Audit Service initiated an audit of the Navy’s EDIS 

program to verify that the program effectively provides special education 

services to school-aged children overseas.25

 

23Inspector General of the Air Force: Report of Investigation (ROI) - Category 1, 

December 2, 2009 – January 12, 2010.

The audit focused on 

services for school-aged children enrolled in the Navy’s EDIS program in 

the Mediterranean area. It found that there was inadequate centralized 

oversight over local programs as well as inadequate educational 

screening for families being assigned to overseas locations. The Navy 

Bureau of Medicine and Surgery concurred with the audit’s 

24Naval Audit Service: Marine Corps Exceptional Family Member Program, January 14, 

2011.

25Naval Audit Service: Department of the Navy Educational and Developmental 

Intervention Services, March 29, 2012.
 

Page 29 GAO-12-680 Military Dependent Students

recommendations and agreed to take actions to address them with a 

target completion date of October 2012.

In 2011, the Administration made the care and support of military families 

a top national security policy priority. In the 2011 White House report, the 

heads of 16 executive branch agencies, including the Secretary of 

Defense, committed to making the well-being of military families one of 

their highest priorities and to improve their access to services and 

support. Further, the Administration emphasized the importance of 

ensuring that military children are provided a quality education. Due to 

their frequent relocations, accessing educational services may be 

particularly difficult for military families—especially for those with children 

with special educational needs. DODEA and the military branches provide 

special education services to eligible families thorough a complex system 

that varies by location. While families in our focus groups were generally 

satisfied once their children received special education services, they 

faced challenges obtaining these services, in part due to the limited 

availability of medical and related service providers at overseas 

installations. In addition, families may lack sufficient information about 

accessing special education and related medical services. The 

challenges families and schools face in obtaining and providing special 

education services are not unique to DOD schools. However, the 

complexity of DOD’s system for providing services—especially 

overseas—along with the high mobility of military families is unique. 

Consequently, effective overseas assignment and family support 

processes are essential for meeting the needs of families with children 

with special needs. Impediments to effective assignment coordination, 

such as ineffective screening processes, can result in families being 

assigned to overseas installations that are unable to readily meet their 

children’s educational and medical needs. As such, it is important that the 

branches’ screening and assignment processes for children with special 

needs are consistently conducted in a thorough manner.

OSN has recently taken some steps to enhance the military branches’ 

EFM programs. However, it is unclear when some of these efforts will be 

completed or if they will be effectively implemented. While OSN was 

established in part to monitor the military branches’ support for families 

with special needs, it has limited enforcement authority over the 

branches’ EFM programs. Specifically, it is limited in the extent to which it 

can compel the branches to comply with DOD or service-level program 

requirements, and it has no direct means by which to hold them 

accountable if they fail to do so. As such, it is important that OSN develop 

Conclusions 
 

Page 30 GAO-12-680 Military Dependent Students

processes to strengthen its oversight of the branches’ EFM programs to 

ensure that they are operating effectively.

Moreover, DOD currently lacks uniform performance goals and 

benchmarks for all aspects of the EFM program. Because OSN is 

charged with monitoring EFM programs and is developing benchmarks 

and performance goals for the family support component of the program, 

it is well positioned to develop them for the other two components of the 

program—identification/enrollment and assignment coordination. Such an 

effort would give DOD the information it needs to determine whether the 

branches are complying with program policies and requirements. Without 

clear benchmarks and performance goals, DOD is limited in the extent to 

which it can determine the effectiveness of the branches’ EFM programs 

and improve these programs for families with special needs. As a result, 

families may continue to be assigned to installations that cannot readily 

meet their children’s special educational and medical needs.

Based on our review, we are making three recommendations.

To ensure that military families are assigned to overseas installations that 

can readily meet their children’s special educational and medical needs, 

we recommend that the Secretary of Defense direct the secretaries of 

each branch to ensure that all military dependent children of school age 

are medically and educationally screened in accordance with each 

branch’s policies and that all required educational screening forms are 

forwarded to DODEA for educational assignment recommendations prior 

to families’ relocations.

To improve oversight of the military branches’ programs for families with 

special needs, we recommend that the Secretary of Defense direct OSN 

to establish uniform benchmarks and performance goals for the 

identification/enrollment and assignment coordination components of the 

military branches’ EFM programs. These goals can be used to determine 

whether EFM programs are achieving desired outcomes across DOD and 

identify areas for improvement. For example, such performance goals 

could include specific targets and benchmarks for reducing screening 

failures over time and reassigning families who have been sent to 

locations that are unable to meet their children’s educational or medical 

needs.

To strengthen OSN’s oversight over the military branches’ EFM 

programs, we recommend that the Secretary of Defense direct OSN to 

Recommendations for 

Executive Action
 

Page 31 GAO-12-680 Military Dependent Students

develop and implement a process to assess the branches’ compliance 

with DOD-level EFM program policies and requirements, and to identify 

and report any issues related to noncompliance to senior leadership for 

corrective action. For example, OSN could consider conducting periodic, 

unannounced site visits to select military installations on a periodic basis 

to monitor implementation of their EFM programs.

We provided a draft of this report to the Department of Defense (DOD) for 

review and comment. DOD’s comments are reproduced in appendix III. 

DOD also provided technical comments that we incorporated in the report 

as appropriate.

DOD concurred with our recommendation that all school-age military 

dependent children be medically and educationally screened and that all 

screening forms be forwarded to DODEA for placement 

recommendations before families relocate. DOD noted that it has a policy 

that requires the military branches to identify and refer school-age 

children with special educational needs to the appropriate DODEA 

reviewer for educational placement recommendations.

DOD partially concurred with our recommendation to direct OSN to 

establish uniform benchmarks and performance goals for two elements of 

the branches’ EFM programs—the identification/enrollment and 

assignment coordination components. In its comments, DOD said it has 

completed the first year of an analysis of the branches’ EFM programs 

that will provide uniform benchmarks and performance goals for these 

components of the program. In a subsequent discussion with DOD to 

clarify their written comments, a senior official confirmed that these 

benchmarks and performance goals are currently not in place and are still 

in the process of being developed. While there is no specific deadline for 

their completion, DOD anticipates that they will be finalized in mid-2013.

Since the primary intent of this effort is to develop a joint database that 

will network all three components of the EFM program, it is unclear 

whether any benchmarks and goals resulting from the analysis will 

include all the elements necessary for effective oversight of the programs.

DOD partially concurred with our recommendation to provide OSN with 

the authority to require the branches to comply with DOD and branchlevel EFM program policies and requirements. DOD said its current 

policies assign responsibility for ensuring compliance to senior leadership 

within the Office of the Secretary of Defense. In addition, DOD said the 

responsibility for ensuring the branches’ compliance with its forthcoming 

Agency Comments 

and Our Evaluation
 

Page 32 GAO-12-680 Military Dependent Students

revised policy on EFM program compliance will be assigned to the 

Assistant Secretary of Defense for Readiness and Force Management to 

whom OSN will report any issues regarding noncompliance. When this 

occurs, DOD said the Assistant Secretary will direct the branches to take 

corrective action. We revised our report to clarify that high-level 

responsibility for ensuring the branches’ compliance with EFM program 

requirements rests with the Under Secretary of Defense for Personnel 

and Readiness. We also modified our recommendation to direct DOD to 

require OSN to develop and implement a process to assess the branches’ 

compliance with EFM program policies and requirements and to report 

any issues related to noncompliance to senior leadership for corrective 

action. We believe this would allow OSN to better evaluate the extent to 

which the branches are complying with the revised policy.

In overall comments on our report, DOD said that despite some families’ 

comments in our focus groups that their children lacked services such as 

speech and language therapy, its monitoring reports over the past 10 

years have indicated no lack of services due to an inadequate number of 

special education teachers or specialists. In our report, we noted that 

families’ comments about challenges obtaining special education services 

were generally corroborated by DODEA administrative offices and 

individual schools overseas. For example, officials from DOD schools we 

visited told us they have difficulties filling and retaining key positions, such 

as special education teachers, paraprofessionals, and specialists. In 

addition, some officials said that caseloads for certain special education 

service providers can exceed accepted standards.

In addition, DOD said the perspectives obtained from families during our 

focus groups are presented as facts in our report, and noted that caution 

must be exercised when drawing conclusions about the accessibility of 

services based on a sample of individual opinions. In our report, we 

acknowledged that our focus groups cannot be generalized to all parents 

of children with special needs, nor are they representative of the entire 

population of parents. Because common responses and recurring themes 

across focus groups provide some degree of validation that experiences 

are not limited to specific individuals, we identified throughout the report 

the number of focus groups where particular perspectives were 

discussed. In addition, we did not rely entirely on focus groups for 

evidence in the report, but rather used several different methods to 

support our conclusions. For example, we interviewed officials from 

DODEA administrative offices, military branches, and individual schools 

who corroborated many themes that emerged during our focus groups.
 

Page 33 GAO-12-680 Military Dependent Students

We are sending copies of this report to the appropriate congressional 

committees, the Secretary of Defense, and other interested parties. The 

report also is available at no charge on the GAO website at 

http://www.gao.gov. 

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

contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

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

this report are listed in appendix IV.

George A. Scott

Director, Education, Workforce,

 and Income Security Issues
Appendix I: Scope and Methodology

Page 34 GAO-12-680 Military Dependent Students

The objectives of this report were to determine (1) how the Department of 

Defense (DOD) provides special education services, and any associated 

challenges for families and schools; (2) how DOD entities coordinate to 

assign families to overseas locations, and how schools might be affected; 

(3) what challenges, if any, families face in obtaining DOD services for 

their children with special educational needs and accessing related 

information; and (4) what steps, if any, DOD is taking to enhance 

screening and overseas assignment for families with children with special 

educational needs.

In order to obtain information on how DOD schools provide special 

education services, and to identify challenges families face in obtaining 

these services and schools face in providing them, we conducted site 

visits to five military installations in Europe and in two states. During these 

site visits, we visited nine schools on four military installations in 

Germany, and two schools on a military installation in Italy. Domestically, 

we also visited three schools on an installation in North Carolina and two 

schools on an installation in South Carolina. We also held telephone 

interviews with school and other officials from a military installation in 

Japan. (See table 1 for more information on the installations and schools 

we visited.) During our school visits we conducted 22 focus groups with 

parents of children with special education needs enrolled in these 

schools. We also interviewed school officials, including principals, 

teachers, and specialists, at 15 of the 17 schools included in our study to 

learn about the challenges schools face in providing special education 

services, and the strategies they employ to respond to those challenges. 

We also toured schools and obtained documents. In addition, we 

interviewed Department of Defense Education Activity (DODEA) area and 

district officials, and officials from the Exceptional Family Member (EFM) 

program and the Educational and Developmental Intervention Services 

(EDIS) programs on each of the installations we visited. Site visit 

locations were selected to obtain ranges in the number of students with 

special education needs enrolled in DOD schools in particular districts 

and the severity of needs the schools overseas were equipped to serve. 

We also strove to achieve variation in urban and remote areas, as well as 

the four armed service branches. In addition, we considered 

recommendations from DODEA and subject matter experts in our 

selection of site visit locations.

Appendix I: Scope and Methodology

Site Visits to Selected 

Military Installations and 

DOD Schools
Appendix I: Scope and Methodology

Page 35 GAO-12-680 Military Dependent Students

Table 1: Site Visit Installation and School Selection

Selected district Selected military installation Number and type of school

South Carolina/Fort Stewart/Cuba Marine Corps/Navy Tri-Command (South Carolina) 1 Elementary School

1 Elementary/Middle School

North Carolina Fort Bragg (Army) (North Carolina) 2 Elementary Schools

1 Intermediate School

Mediterranean Naval Support Activity Naples (Italy) 1 Elementary School

1 Middle/High School

Kaiserslautern Ramstein Air Base (Germany) 1 Elementary School

1 Intermediate School

Spangdahlem Air Base/Eifel community (Germany) 2 Elementary Schools

U.S. Army Garrison Kaiserslautern (Germany) 1 Elementary School

1 Elementary/Middle School

1 Middle School

1 High School

U.S. Army Garrison Baumholder (Germany) 1 Elementary School

Japan (by video teleconference) Commander Fleet Activities Yokosuka (Naval Base, Japan) 1 Elementary School 

Source: GAO.

We conducted 22 focus groups at all of the schools included in our study, 

including 17 at overseas locations and five at domestic locations, 

covering over 100 service members, their spouses, and DOD civilians 

across all four branches of the military, in order to obtain the views of 

parents regarding the challenges they face in learning about and 

obtaining special education services for their children with special needs. 

One of our overseas focus groups was conducted via video 

teleconference, rather than in person, to mitigate travel costs. We are 

confident that using this method did not substantially impact our findings. 

For each location, all parents of children with an individualized education 

program (IEP) were invited to participate. A list of sites we spoke with can 

be found in table 1.

A focus group protocol was developed to help the moderator gather 

information from these parents about their experiences with special 

education services at DODEA schools. The protocol contained questions 

about the types of services their children received, degree of satisfaction 

with those services, experiences with the Exceptional Family Member 

(EFM) program and with the screening process for obtaining special 

education services, and a comparison to services provided at other 

Focus Groups with Parents 

of Children with Special 

Education Needs Enrolled 

in DOD Schools
Appendix I: Scope and Methodology

Page 36 GAO-12-680 Military Dependent Students

locations. In addition, it included questions on any complaints that may 

have been communicated to DODEA, and the resolution of those 

complaints. Notes were taken by at least one, but usually multiple, GAO 

note-takers. These notes were integrated into transcripts of the focus 

groups, which were then organized by question. For each question, a 

GAO analyst reviewed notes from all the focus groups to identify themes 

across the different groups, in order to provide insights into the range of 

concerns and support for these topics. While the results of these focus 

groups cannot be generalized to all parents of children with special 

needs, nor are they representative of the population of parents, common 

responses across groups and recurring themes provide some degree of 

validation. Because of these limitations, our study was supported by 

several methodologies, of which the focus groups were one part, to 

support our conclusions.

To address all of the report’s objectives, we interviewed relevant officials 

from DODEA, the Office of Special Needs, and the military services’ EFM 

program headquarters offices. We also met with individual subject matter 

experts and representatives from the National Council on Disability and 

the Specialized Training of Military Parents, an organization focused on 

providing support and advice to military families with special needs. In 

addition, we reviewed relevant federal laws and regulations. We also 

reviewed agency documents and program guidance, such as DODEA’s 

directory of special education services in overseas communities, 

DODEA’s special education procedural guide, service-level EFM program 

instructions, and DOD instructions for the provision of special education 

and related services. We also reviewed prior GAO reports on military 

dependents and elementary and secondary education.

To obtain information about the number and characteristics of children 

with special needs who attend DOD schools, we reviewed data from 

DODEA’s Excent and Aspen databases, including enrollment by disability 

type, location, and military branch or other governmental affiliation, as of 

January 2012. As part of our data request, we asked questions about the 

reliability of the data, such as whether there are audits of the data or 

routine quality control procedures in place. We found limitations with the 

enrollment data resulting from the transition between systems, but 

determined that the data provided by DOD were sufficiently reliable to 

accurately provide an approximation of enrollment figures as of January 

2012. We also examined data from DODEA’s Screening and Assignment 

Concerns database to determine the number of screenings and 

Interviews with Agency 

Officials and Other 

Organizations

Data Collection and 

Analysis
Appendix I: Scope and Methodology

Page 37 GAO-12-680 Military Dependent Students

assignment concerns reported between 2005 and 2012, as well as the 

nature of the assignment concerns from the most recent school year. We 

tested the screening and assignment concerns database for errors and 

found the data to be sufficiently reliable for the purposes of reporting the 

number of screenings and the number and nature of assignment 

concerns.
Appendix II: DODEA Categories and 

Definitions of Disabilities

Page 38 GAO-12-680 Military Dependent Students

Students whose educational performance is adversely affected by a 

physical impairment that requires environmental and/or academic 

modifications including, but not limited to, the following: visually impaired, 

hearing impaired, orthopedically impaired, and other health impaired.

This term includes Pervasive Developmental Disorder, Asperger’s 

syndrome, as well as the diagnosis of autism. It is a developmental 

disability significantly affecting verbal and nonverbal communication and 

social interaction, generally evident before age 3 that adversely affects 

educational performance. The term does not include students with 

characteristics of the disability “serious emotional disturbance.” 

A hearing loss or deficit so severe that the student is impaired in 

processing linguistic information through hearing, with or without 

amplification, to the extent that his or her educational performance is 

adversely affected.

Concomitant hearing and visual impairments. This disability causes such 

severe communication, developmental, and educational problems that 

they cannot be accommodated in special education programs solely for 

students with deafness or students with blindness.

An impairment in hearing, whether permanent or fluctuating that

adversely affects a student’s educational performance, but is not included 

under the definition of deafness.

Though not exhaustive, OHI may include limited strength, vitality, or 

alertness due to chronic or acute health problems that adversely affect a 

student’s educational performance, including but not limited to heart 

condition, tuberculosis, rheumatic fever, nephritis, asthma, sickle cell 

anemia, hemophilia, epilepsy, lead poisoning, leukemia, diabetes or 

attention deficit disorder with or without hyperactivity.

A severe physical impairment that adversely affects a student’s 

educational performance. The term includes congenital impairments, 

impairments caused by disease (e.g., poliomyelitis, bone tuberculosis, 

etc.), and impairments from other causes such as cerebral palsy, 

amputations, and fractures or burns causing contractures.

An acquired injury to the brain caused by an external physical force, 

resulting in total or partial functional disability or psychosocial impairment, 

or both, that adversely affects a student’s educational performance. The 

term applies to open or closed head injuries resulting in impairments in 

Appendix II: DODEA Categories and 

Definitions of Disabilities

1. Physical Impairments 

Autism Spectrum Disorder

Deaf

Deaf-Blindness

Hearing Impairment

Other Health Impairment (OHI)

Orthopedic Impairment

Traumatic Brain Injury
Appendix II: DODEA Categories and 

Definitions of Disabilities

Page 39 GAO-12-680 Military Dependent Students

one or more areas, such as cognition, language, memory, attention, 

reasoning, abstract thinking, judgment, or problem-solving; sensory, 

perceptual, and motor abilities; psychosocial behavior; physical functions; 

information processing, and speech. The term does not apply to brain 

injuries that are congenital or degenerative, or brain injuries induced by 

birth trauma.

Impairment in vision that, even with correction, adversely affects a 

student’s educational performance. The term includes both partial sight 

and blindness.

A condition that has been confirmed by clinical evaluation and diagnosis 

and that, over a long period of time and to a marked degree, adversely 

affects educational performance and that exhibits one or more of the 

following characteristics:

1. An inability to learn that cannot be explained by intellectual, 

sensory, or health factors.

1. An inability to build or maintain satisfactory interpersonal 

relationships with peers and teachers.

2. Inappropriate types of behavior under normal circumstances.

3. A tendency to develop physical symptoms or fears associated with 

personal or school problems.

4. A general pervasive mood of unhappiness or depression.

This includes students who are schizophrenic, but does not include 

students who are socially maladjusted, unless it is determined that they 

are seriously emotionally disturbed. The term emotional impairment does 

not usually include (a) antisocial behavior, (b) parent-child problems, (c) 

conduct disorders, (d) interpersonal problems, or (e) other problems that 

are not the result of a severe mental disorder.

Communication Impairment includes two disabilities: speech disorders 

and language disorders. Students whose educational performance is 

adversely affected by a developmental or acquired communication 

disorder to include voice, fluency, articulation, receptive, and/or 

expressive language.

Visual Impairment, including 

Blindness

2. Emotional Impairments

3. Communication 

Impairments
Appendix II: DODEA Categories and 

Definitions of Disabilities

Page 40 GAO-12-680 Military Dependent Students

Language/phonological disorders are characterized by an 

impairment/delay in receptive and/or expressive language including 

semantics, orphology/syntax, phonology and/or pragmatics. This 

impairment does not include students whose language problems are due 

to English as a second language or dialect difference.

1. Articulation disorder is characterized by substitutions, distortions, 

and/or omissions of phonemes that are not commensurate with 

expected developmental age norms, that are not the result of limited 

English proficiency or dialect difference, and that may cause 

unintelligible conversational speech. 

2. Fluency disorder is characterized by atypical rate, rhythm, repetitions, 

and/or secondary behavior(s) that interferes with communication or is 

inconsistent with age/development.

3. Voice disorder is characterized by abnormal pitch, intensity, 

resonance, duration, and/or quality that is inappropriate for 

chronological age or gender.

Learning Impairment includes two disabilities: specific learning disability 

and intellectual disability.

Specific learning disability is a disorder in one or more of the basic 

psychological processes involved in understanding or in using spoken or 

written language that may manifest itself as an imperfect ability to listen, 

think, speak, read, write, spell, remember, or do mathematical 

calculations. The term includes such conditions as perceptual disabilities, 

brain injury, minimal brain dysfunction, dyslexia, and developmental 

aphasia. The term does not include learning problems that are primarily 

the result of visual, hearing, or motor disabilities; of mental retardation or 

emotional disturbance; or of environmental, cultural, or economic 

disadvantage.

Intellectual disability is significantly sub-average intellectual functioning 

existing concurrently with deficits in adaptive behavior and manifested 

during the developmental period that adversely affects a student’s 

educational performance. Significant sub-average general intellectual 

functioning is documented by a comprehensive intelligence test score that 

is two or more standard deviations below the mean.

Language/Phonological 

Disorders

Speech Disorders

4. Learning Impairments

Specific Learning Disability

Intellectual Disability
Appendix II: DODEA Categories and 

Definitions of Disabilities

Page 41 GAO-12-680 Military Dependent Students

The term developmental delay refers to a significant discrepancy in the 

actual functioning of an infant, toddler, or child birth through age 7, when 

compared with the functioning of a nondisabled infant, toddler, or child of 

the same chronological age in the following areas: physical, cognitive, 

communication, social or emotional, and adaptive development as 

measured using standardized evaluation instruments and confirmed by 

clinical observation and judgment. A child classified with a developmental 

delay before age 7 may maintain that eligibility classification through age 

10. Developmental delay does not refer to a condition in which a child is 

slightly or momentarily lagging in development. The presence of a 

developmental delay is an indication that the developmental processes 

are significantly affected and that, without special intervention, it is likely 

that the educational performance will be affected when the child reaches 

school age.

There are five developmental areas of concern in the definition of 

developmental delay:

1. Physical Development - Fine/gross motor skills used for 

coordinated use of muscles and body control in actions such as 

balance, standing, walking, climbing, object manipulation, cutting, 

and pre-writing activities.

2. Communication Development - Ability to understand and use 

language and the phonological processes.

3. Cognitive Development - Ability to receive information, process 

relationships, and apply knowledge.

4. Social/Emotional Development - Ability to develop and maintain 

functional interpersonal relationships and to exhibit social and 

emotional behaviors appropriate to the setting.

5. Adaptive/Self-Help Development - Ability to deal with 

environmental expectations and use functional daily living skills.

5. Developmental Delay
Appendix III: Comments from the Department 

of Defense

Page 42 GAO-12-680 Military Dependent Students

Appendix III: Comments from the 

Department of Defense
Appendix III: Comments from the Department 

of Defense

Page 43 GAO-12-680 Military Dependent Students
Appendix III: Comments from the Department 

of Defense

Page 44 GAO-12-680 Military Dependent Students
Appendix IV: GAO Contact and Staff 

Acknowledgments

Page 45 GAO-12-680 Military Dependent Students

George Scott, 202-512-7215 or scottg@gao.gov

In addition to the contact named above, Elizabeth Sirois, Assistant 

Director; Divya Bali, Jennifer Cook, and Charlene J. Lindsay made 

significant contributions to this report. Also contributing to this report were 

Deborah Bland, Kate van Gelder, Mimi Nguyen, Steven Putansu, James 

Rebbe, Michael Silver, and Rachael Valliere. 

Appendix IV: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 
Related GAO Products

Page 46 GAO-12-680 Military Dependent Students

Education of Military Dependent Students: Better Information Needed to 

Assess Student Performance. GAO-11-231. Washington, D.C.: March 1, 

2011.

DOD Schools: Additional Reporting Could Improve Accountability for 

Academic Achievement of Students with Dyslexia. GAO-08-70. 

Washington, D.C.: December 6, 2007.

Military Personnel: Medical, Family Support, and Educational Services 

Are Available for Exceptional Family Members. GAO-07-317R. 

Washington, D.C.: March 16, 2007.

DOD Schools: Limitations in DOD-Sponsored Study on Transfer 

Alternatives Underscore Need for Additional Assessment. GAO-05-469. 

Washington, D.C.: April 26, 2005.

Related GAO Products

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