GAO 

United States Government Accountability Office

Report to the Subcommittee on Military 

Personnel, Committee on Armed 

Services, House of Representatives 

MILITARY 

RECRUITING 

Clarified Reporting 

Requirements and 

Increased 

Transparency Could 

Strengthen Oversight 

over Recruiter 

Irregularities 

January 2010 

GAO-10-254 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

January 2010

MILITARY RECRUITING

Clarified Reporting Requirements and Increased 

Transparency Could Strengthen Oversight over 

Highlights of GAO-10-254, a report to the Recruiter Irregularities

Subcommittee on Military Personnel, 

Committee on Armed Services, House of 

Representatives 

To sustain a viable military force, 

the Department of Defense (DOD) 

depends on recruiting several 

hundred thousand qualified 

individuals into the military each 

year. The service components rely 

on their recruiters to act with the 

utmost integrity because even a 

single incident of wrongdoing on 

the part of a recruiter—a recruiter 

irregularity—can adversely affect 

the service components’ ability to 

recruit qualified individuals. GAO 

was asked to (1) analyze data on 

reported cases of recruiter 

irregularities across the service 

components, (2) review the extent 

to which the service components 

have guidance and procedures to 

address recruiter irregularities, and 

(3) review the extent to which the 

Office of the Secretary of Defense 

(OSD) has oversight over recruiter 

irregularities. GAO analyzed the 

data on recruiter irregularities 

reported to OSD by the service 

components; reviewed the service 

components’ recruiter irregularity 

case files; examined relevant 

guidance and procedures from the 

service components; and 

interviewed service components’ 

recruiting command personnel, 

recruiters, and OSD officials. 

What GAO Recommends

GAO is making several 

recommendations to improve the 

service components’ sharing of 

recruiter irregularity data, the 

clarity of OSD’s reporting guidance, 

and the transparency of the data 

reported to OSD. In commenting on 

a draft of this report, DOD 

concurred with GAO’s 

recommendations. 

From fiscal year 2006 through 2008, the total number of substantiated cases of 

recruiter irregularities across the service components represented a small 

percentage of overall accessions (i.e., number of individuals entering military 

service), and the service components have taken various actions against the 

recruiters responsible for these irregularities. Specifically, the number of 

substantiated cases of recruiter irregularities as a percentage of overall 

accessions was 0.26 percent in fiscal year 2006, 0.22 percent in fiscal year 

2007, and 0.18 percent in fiscal year 2008. The most common types of recruiter 

irregularity reported involved concealment or falsification of documents or 

information, sexual misconduct, and quality control measures (e.g., valid 

parental signatures). The action most commonly applied against recruiters 

who committed irregularities varied by service component. Removal from 

recruiting was the most commonly applied action in the Marine Corps while 

adverse administrative action (e.g., a letter of reprimand in the recruiter’s 

personnel file) was most commonly applied in the Army. 

All service components have guidance and procedures on addressing recruiter 

irregularities and have improved oversight over them, but the manner in 

which data on recruiter irregularities are shared within the service 

components varied. Although some differences exist, the service components 

are similar in how they identify, investigate, and adjudicate recruiter 

irregularities. In addition, the service components have taken steps to identify 

and prevent recruiter irregularities, including establishing quality control 

checks to help identify recruiter irregularities and providing training for 

recruiters to help prevent recruiter irregularities. However, in most service 

components, not all levels of command have regular access to information on 

recruiter irregularities that occur. Without regular access to information, 

commanders may not be able to take full advantage of servicewide recruiter 

irregularity data and opportunities to learn from their peers. 

Although OSD has implemented requirements for the service components to 

regularly report on recruiter irregularities, it does not have complete oversight 

over the recruiter irregularities that occur. In December 2006, OSD issued a 

memorandum for the service components on tracking and reporting recruiter 

irregularities, and the service components have been providing recruiter 

irregularity data to OSD. However, because some of the reporting 

requirements lack clarity, the service components do not interpret the 

reporting requirements in the same way. Further, the data provided to OSD by 

the National Guard are incomplete and the relevant offices within the National 

Guard Bureau do not provide appropriate caveats regarding these data, such 

as including information on the States and Territories that did not submit 

recruiter irregularity data. Unless OSD clarifies the reporting requirements in 

its memorandum and directs the service components to provide transparency 

in the data they report, it will be unable to maintain complete oversight over 

the extent to which recruiter irregularities are occurring and make 

determinations on whether corrective action is needed. 

View GAO-10-254 or key components.

For more information, contact Brenda S. 

Farrell at (202) 512-3604 or farrellb@gao.gov. 
Page i GAO-10-254 

Contents 

Letter 1

Results in Brief 5 

Background 8 

Substantiated Cases of Irregularities Represent a Small Percentage 

of Accessions, and Actions Have Been Taken against the 

Recruiters Responsible 14 

The Service Components Have Developed Guidance and 

Procedures to Address Recruiter Irregularities, but Not All 

Service Components Share Recruiter Irregularity Data 

throughout All Levels of Command 22 

OSD Implemented Recruiter Irregularity Reporting Requirements, 

but Lacks Complete Oversight over Irregularities 32 

Conclusions 41 

Recommendations for Executive Action 42 

Agency Comments and Our Evaluation 42 

Appendix I Scope and Methodology 44 

Appendix II Examples of Recruiter Irregularities in Fiscal 

Year 2008 50 

Appendix III Examples of Dispositions in Fiscal Year 2008 51 

Appendix IV Comments from the Department of Defense 52 

Appendix V GAO Contact and Staff Acknowledgments 55 

 

Tables 

Table 1: Number of Recruiters in Fiscal Years 2006 through 2009, 

by Service Component 9 

Table 2: Enlisted Accessions for Each Service Component in Fiscal 

Years 2006 through 2009 11 

 Military Recruiting 
Table 3: Total Number of Substantiated Recruiter Irregularities, 

Accessions, and Irregularities as a Percentage of 

Accessions, Fiscal Years 2006 through 2008 15 

Table 4: Cases of Substantiated Recruiter Irregularities as a 

Percentage of All Cases of Reported Recruiter 

Irregularities, Fiscal Years 2006 through 2008 16 

Table 5: Most Commonly Reported Types of Recruiter 

Irregularities as a Percentage of All Reported Recruiter 

Irregularities in Fiscal Year 2008, by Service Component 17 

Table 6: Examples of Substantiated Recruiter Irregularities by 

Type, Fiscal Year 2008 18 

Table 7: Most Commonly Reported Actions Taken against 

Recruiters as a Percentage of All Actions Taken, Fiscal 

Year 2008 19 

Table 8: Examples of Actions Taken against Recruiters Who 

Committed Recruiter Irregularities, Fiscal Year 2008 20 

Table 9: Organizations and Offices Contacted 45 

Table 10: Examples of Substantiated Recruiter Irregularities by 

Type, Fiscal Year 2008 50 

Table 11: Examples of Dispositions, Fiscal Year 2008 51 

Figures 

Figure 1: Organization of the Service Recruiting Commands 10 

Figure 2: Overview of the Enlistment Process 13 

Figure 3: The Service Components’ Process for Addressing 

Recruiter Irregularities 25 

Figure 4: The Service Components’ Processes for Reporting of the 

Recruiter Irregularity Data 30 

Figure 5: Army National Guard States and Territories Reporting 

Recruiter Irregularity Data for Fiscal Year 2008 during the 

January 2009 Reporting Cycle 39 

Page ii GAO-10-254 Military Recruiting
Abbreviations 

ASVAB Armed Forces Vocational Aptitude Battery 

DOD Department of Defense 

MEPCOM Military Entrance Processing Command 

MEPS Military Entrance Processing Station 

OSD Office of the Secretary of Defense 

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Page iii GAO-10-254 Military Recruiting
Page 1 GAO-10-254 

 

United States Government Accountability Office

Washington, DC 20548 

 

January 28, 2010 

The Honorable Susan A. Davis 

Chairwoman 

The Honorable Joe Wilson 

Ranking Member 

Subcommittee on Military Personnel 

Committee on Armed Services 

House of Representatives

To sustain a viable all-volunteer military force, the Department of Defense 

(DOD) depends on recruiting several hundred thousand qualified 

individuals into the military each year. Although DOD’s service 

components have generally met their recruiting goals in recent years,1

 the 

recruiting environment continues to present challenges, partly due to the 

length, frequency, and difficult nature of deployments expected of 

servicemembers. While the present economic downturn has increased the 

number of individuals expressing an interest in military service, DOD 

estimates that only 3 out of 10 American youth ages 17 to 24 are qualified 

to join the military. If economic conditions improve, it may become more 

difficult for the military to find qualified recruits to carry out its 

challenging mission. 

The service components have assigned 30,000 recruiting personnel to 

carry out DOD’s goal of recruiting high-quality individuals into the military. 

Recruiters serve as the military’s representatives in communities 

throughout the United States, and the service components rely on them to 

act with the utmost integrity in order to win and maintain the public’s 

trust. DOD recognizes that even a single incident of wrongdoing on the 

part of a recruiter can erode public confidence in the recruiting process 

and damage a service component’s reputation. To prevent such incidents 

from occurring, the service components’ recruiting commands have 

developed guidance that governs recruiter irregularities, and instituted 

procedures for (1) reporting allegations of recruiter irregularities and (2) 

conducting an investigation to determine whether a case is substantiated 

or unsubstantiated. Substantiated cases of recruiter wrongdoing are those 

1

“Service components” refers to the Army, the Army Reserve, the Marine Corps, the Marine 

Corps Reserve, the Navy, the Navy Reserve, the Air Force, and the Air Force Reserve. 

 Military Recruiting 
 

cases in which the service components determine that a recruiter violated 

recruiting guidance based on a review of the facts in the case. 

Oversight of the service components’ recruiting programs is the 

responsibility of the Office of the Secretary of Defense (OSD), Under 

Secretary of Defense for Personnel and Readiness. That office is 

responsible for policy development, planning, resource management, and 

program evaluation specific to the readiness of the force, including those 

affecting the recruiting force. In establishing oversight over recruiter 

irregularities, OSD issued a directive-type memorandum defining recruiter 

irregularities as those willful and unwillful acts of omission and 

improprieties that are perpetrated or alleged to be perpetrated by a 

recruiter to facilitate the recruiting process for an applicant.2

 Recruiter 

irregularities encompass a range of actions including, for example, 

administrative paperwork errors, instructing applicants not to reveal 

certain disqualifying conditions, and criminal misconduct.3

 

In 2006, we reported that substantiated cases of recruiter irregularities 

were low relative to overall accessions (i.e., the number of individuals 

entering military service)—less than 1 percent.4

 However, we found at that 

time that the service components and OSD were not able to determine the 

full extent to which recruiter irregularities were occurring within their 

command structures, thus preventing them from fully addressing the 

problem. For example, we determined that none of the service 

components could provide a comprehensive and accurate report on 

recruiter irregularities within its own organization because the service 

components used multiple data systems that were not integrated and 

maintained the data in different formats; lacked standardized procedures 

for recording the data; and did not account for all allegations of recruiter 

irregularities. As a result, we recommended that OSD establish an 

oversight framework to assess recruiter irregularities to include 

developing criteria and common definitions across the services for 

 

2

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

Tracking and Reporting of Recruiter Irregularities (Dec. 21, 2006). 

3

OSD groups recruiter irregularities into the following eight categories: criminal 

misconduct; sexual misconduct; sexual harassment; fraternization or unauthorized 

relationship with an applicant; concealment or falsification; testing irregularity; false 

promise or coercion; and quality control measures, which are irregularities resulting from 

administrative oversight. 

4

GAO, Military Recruiting: DOD and Services Need Better Data to Enhance Visibility 

over Recruiter Irregularities, GAO-06-846 (Washington, D.C.: August 8, 2006). 

Page 2 GAO-10-254 Military Recruiting
 

maintaining recruiter irregularity data, implementing a reporting 

requirement across the services, directing the services to develop internal 

systems and processes that better capture and integrate data on recruiter 

irregularities, and directing the commander of DOD’s Military Entrance 

Processing Command (MEPCOM) to track and report allegations and 

service-identified incidents of recruiter irregularities to OSD. In providing 

comments on our report, OSD agreed to establish a standardized 

framework allowing for a fair and accurate assessment of recruiter 

irregularities across the services, including establishing the criteria and 

common definitions for maintaining data on recruiter irregularities, and 

for the services to develop internal processes that better capture and 

integrate these data. OSD partially concurred with the recommendation to 

establish a reporting requirement across the services, but disagreed with 

the recommendation for MEPCOM to track and report allegations and 

incidents of recruiter irregularities to OSD because it said such a 

requirement would duplicate the reporting performed by the service 

components.5

 Following our report, OSD issued the memorandum in 

December 2006 setting the definitions of recruiter irregularities and the 

requirements for the service components to track and report on all cases 

of recruiter irregularities. 

In this context, you asked us to examine the service components’ policies 

and procedures for addressing recruiter irregularities and OSD’s oversight 

framework for assessing recruiter irregularities. This report addresses the 

following questions: 

1. What have the data shown on the incidence and types of reported 

cases of recruiter irregularities across the service components and 

what actions have the service components taken in substantiated cases 

of recruiter irregularities? 

2. To what extent have the service components developed guidance and 

procedures to address recruiter irregularities, what progress have they 

made in increasing their oversight over recruiter irregularities, and to 

what extent is information on recruiter irregularities shared within the 

service components? 

 

5

An OSD official also told us that MEPCOM only receives information on a subset of 

recruiter irregularities that are identified while the applicants are being processed at one of 

its military entrance processing stations, and would not know about irregularities that may 

come to light through other sources. MEPCOM has no direct command and control 

authority over the service components’ recruiters, but is required to refer any allegations of 

recruiter irregularities that it identifies to the recruiter’s commanders within the 

appropriate service component. 

Page 3 GAO-10-254 Military Recruiting
 

3. To what extent does OSD have oversight over recruiter irregularities 

that occur across the service components? 

In conducting this review, we focused our scope on recruiter irregularities 

that affect the active, reserve, and National Guard components of DOD’s 

military services that occurred from fiscal year 2006 through fiscal year 

2008. To provide information on the number and type of recruiter 

irregularities, we analyzed recruiter irregularity data that OSD received 

from the service components for that period. However, due to possible 

reporting errors in the 2006 data resulting from the new reporting 

requirement on recruiter irregularities issued by OSD in December 2006, 

we were unable to present trends in recruiter irregularities. Additionally, 

we did not include fiscal year 2009 data in our analysis of recruiter 

irregularities across the service components because the data covering the 

full fiscal year 2009 will not be reported to OSD by the service components 

in time to be included in our analysis. Although we found recruiter 

irregularity data for the active and reserve components to be sufficiently 

reliable for the purposes of this report, we could not present the data on 

recruiter irregularities reported by the National Guard because States and 

Territories do not report their data consistently and the different systems 

used by States and Territories for maintaining and reporting these data 

lead to data reliability issues. As part of our first objective, we also 

requested and reviewed case files from each of the active and reserve 

components for all substantiated cases of recruiter irregularities that 

occurred in fiscal year 2008 to provide illustrative examples of the types of 

recruiter irregularities that occur and the actions taken by the service 

components against recruiters responsible for committing recruiter 

irregularities. However, because the National Guard Bureau does not 

maintain centralized data on cases of recruiter irregularities, we selected 

and obtained case files from all seven States (Alabama, California, Indiana, 

Minnesota, Oklahoma, Pennsylvania, and Wisconsin) that reported more 

than four substantiated recruiter irregularities in fiscal year 2008. To 

assess the extent to which the service components’ have guidance and 

procedures in place to address recruiter irregularities, we obtained and 

reviewed the service components’ written guidance related to the 

enlistment process and recruiter conduct. To determine the extent to 

which OSD has oversight over recruiter irregularities, we interviewed 

officials from OSD and MEPCOM. We supplemented our work for all three 

objectives with site visits to the service components’ recruiting commands 

to interview recruiting command officials, staff from military entrance 

processing stations (MEPS), and recruiters. 

Page 4 GAO-10-254 Military Recruiting
 

We conducted this performance audit from February 2009 through January 

2010 in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. More information on our 

scope and methodology is available in appendix I. 

OSD data have shown that from fiscal year 2006 through fiscal year 2008, 

substantiated cases of recruiter irregularities across the service 

components represented a small percentage of overall accessions, and the 

service components have taken various actions against the recruiters 

responsible for these irregularities. The total number of substantiated 

cases of recruiter irregularities as a percentage of overall military 

accessions was 0.26 percent (616 cases out of 239,629 accessions) in fiscal 

year 2006, 0.22 percent (526 cases out of 242,602 accessions) in fiscal year 

2007, and 0.18 percent (450 cases out of 248,797 accessions) in fiscal year 

2008. The substantiated cases, however, represented less than one-quarter 

of all reported cases of recruiter irregularities. Of the 7,081 cases of 

recruiter irregularities reported by the service components during this 

time period, substantiated cases comprised 22.5 percent (or 1,592 cases). 

The types of recruiter irregularities most frequently reported from fiscal 

year 2006 through fiscal year 2008 varied by service component. For 

example, in fiscal year 2008, the most common type of recruiter 

irregularity reported by all service components except the Air Force 

Reserve involved the concealment or falsification of documents or 

information, such as when a recruiter omitted information concerning 

prior criminal violations in an applicant’s application packet. The 

incidence of other types of recruiter irregularities reported for fiscal year 

2008 varied by service component. For example, sexual misconduct 

constituted the second most commonly reported type of recruiter 

irregularity in the Marine Corps, while quality control measures, such as a 

recruiter failing to obtain parental signatures on an applicant’s application 

form, constituted the second most commonly reported type of recruiter 

irregularity in the Army. The types of actions taken against recruiters who 

committed irregularities in fiscal year 2008 also varied by service 

component. For example, the type of action most commonly applied in the 

Marine Corps was removal from recruiting. In contrast, the type of action 

most commonly applied in the Army was adverse administrative action, 

such as placing a letter of reprimand in the recruiter’s permanent 

personnel file. Within the National Guard, the types of actions taken 

against a recruiter who committed irregularities varied among the seven 

Results in Brief 

Page 5 GAO-10-254 Military Recruiting
 

States included in our review, likely due to the differences in state laws 

and guidance that govern how investigations are conducted and actions 

applied. 

The service components have developed guidance and procedures to 

address recruiter irregularities and have improved their oversight over 

them, but the manner in which information is shared within the service 

components varies.6

 All service components have guidance on recruiter 

irregularities and have instituted procedures for reporting allegations of 

recruiter irregularities, conducting investigations, and adjudicating cases 

of recruiter irregularities. In addition, the service components have taken 

steps to identify and prevent recruiter irregularities, including establishing 

quality control checks throughout the enlistment process and providing 

training for recruiters on issues related to recruiter irregularities. 

However, as we reported in prior work, in order to make improvements 

and promote knowledge sharing, leaders at all levels of an organization 

need to receive information on a continuous basis about problems that 

may be occurring across the organization.7 The Air Force has taken 

initiative to regularly share servicewide recruiter irregularity data, 

including information on the types of recruiter irregularities committed 

and the disposition of cases, with all levels of command within the Air 

Force Recruiting Service and all recruiting staff. Air Force officials 

explained that making this information available to all levels within the Air 

Force Recruiting Service provides commanders with examples of how 

others are addressing recruiter irregularities, promotes consistent 

application of such actions in substantiated cases of recruiter irregularities 

across the Air Force, and serves as a deterrent to future recruiter 

irregularities. However, while all service components regularly provide 

recruiter irregularity data to their recruiting command headquarters, in 

most service components outside of the Air Force, not all levels of 

command have regular access to information on the recruiter irregularities 

 

6

United States Army Recruiting Command Regulation 601-45, Recruiting Improprieties 

Policies and Procedures (July 13, 2009); Marine Corps Order 1130.65A, Total Force 

Recruiting Quality Control (Feb. 20, 1987); Navy Recruiting Command Instruction 1137.3, 

Investigating and Reporting of Allegations and Complaints (Apr. 3, 2009); Air Force 

Recruiting Service Instruction 36-2001, Recruiting Procedures for the Air Force (Apr.1, 

2005); Air Force Reserve Command Instruction 36-2001, Air Force Reserve Recruiting 

Procedures (June 1, 2009). 

7

GAO, Executive Guide: Effectively Implementing the Government Performance and 

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

Results: Enhancing Agency Use of Performance Information for Management Decision 

Making, GAO-05-927 (Washington, D.C.: September 9, 2005). 

Page 6 GAO-10-254 Military Recruiting
 

occurring. This is because the other service components do not have 

procedures for the data to regularly flow back to the commanders at levels 

below the recruiting headquarters to inform their efforts. Without 

continuous access to information on recruiter irregularities across their 

service component, commanders may not be able to take full advantage of 

servicewide recruiter irregularity data and opportunities to learn from 

their peers. We are recommending that the Secretary of Defense direct the 

Secretaries of the Army and Navy to identify mechanisms for the regular 

sharing of recruiter irregularity data within their service components. 

Although OSD requires the service components to report on cases of 

recruiter irregularities, OSD does not have complete oversight over the 

recruiter irregularities that have occurred across the service components 

because the reporting requirements lack clarity and the data are 

incomplete. In December 2006, OSD issued a memorandum that defines 

recruiter irregularities, establishes specific reporting categories to capture 

the types of recruiter irregularities that occur and the actions the service 

components take in response, and requires semiannual reporting of 

recruiter irregularities by the service components to OSD.8

 Although 

issuing the memorandum was an important first step in providing effective 

oversight over recruiter irregularities consistent with good management 

practices outlined in federal control standards, OSD still lacks 

comprehensive information on recruiter irregularities across the service 

components because some of the reporting requirements in the 

memorandum lack clarity and the data provided by the National Guard are 

incomplete.9

 For example, although most service components report only 

on cases involving applicants, at least one service component reported on 

all cases of infractions by recruiters, such as the use of a government 

vehicle for personal use or inappropriate relationship with other military 

personnel. In addition, recruiting officials with whom we spoke cited 

several problems with categorization, including reporting categories being 

too broad and lack of clarity on how to report cases in which more than 

one type of irregularity was committed or more than one action was taken 

against the recruiter. OSD officials said that the reporting requirements 

will be clarified when the 2006 memorandum is turned into an instruction 

for the service components to follow, but they have not developed the 

 

8

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

Tracking and Reporting of Recruiter Irregularities (Dec. 21, 2006). 

9

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

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

Page 7 GAO-10-254 Military Recruiting
 

instruction yet. With respect to the National Guard data, the data provided 

to OSD by the National Guard are incomplete. For example, our review of 

the recruiter irregularity data that the Army National Guard States and 

Territories provided to the Army National Guard Strength Maintenance 

Division in January 2009 showed that 18 of the 54 States and Territories 

did not provide the data for fiscal year 2008. The National Guard Bureau, 

in turn, has not provided the appropriate caveats in its reports to OSD 

about the States and Territories that did not provide their recruiter 

irregularity data, and OSD officials have not asked for such caveats. 

Unless OSD clarifies the reporting requirements in the memorandum and 

directs the service components to provide transparency in the data they 

report, it will be unable to maintain complete oversight over the extent to 

which recruiter irregularities are occurring across the service components 

and determine whether corrective action is needed. We are recommending 

that the Secretary of Defense direct the Under Secretary of Defense for 

Personnel and Readiness to (1) complete the instruction on tracking and 

reporting data on recruiter irregularities to clarify the requirements and 

categories for the types of recruiter irregularities to be reported and 

actions taken; (2) direct the National Guard Bureau to provide 

transparency in the data that it reports to OSD and disclose any limitations 

in these data; and (3) include the appropriate disclosures concerning data 

limitations in the recruiter irregularity reports that it produces on the basis 

of these data for the Congress and others. 

In commenting on a draft of this report, DOD stated that it concurred with 

our recommendations. DOD described the actions that it plans to take to 

work with the service components on addressing our recommendations 

and plans to complete these actions during fiscal year 2010. 

Subject to the authority, direction, and control of the Secretary of Defense, 

it is the responsibility of the services to recruit and train their forces. The 

service components depend on military recruiters to meet their annual 

recruiting missions. In fiscal year 2009, the service components utilized 

30,936 military recruiters. Of those, 26,381 were frontline recruiters 

assigned a monthly recruiting goal.10 The remaining recruiters held 

supervisory and staff positions throughout the services’ recruiting 

commands. (See table 1 for the number of recruiters for fiscal year 2006 

through fiscal year 2009.) 

Background 

 

10Frontline recruiters are those recruiting personnel who directly interact with applicants in 

the recruiting process. 

Page 8 GAO-10-254 Military Recruiting
 

Table 1: Number of Recruiters in Fiscal Years 2006 through 2009, by Service Component 

Army Navy 

Marine 

Corps Air Force 

Fiscal year 

Active and 

Reserve 

National 

Guard 

Active and 

Reserve

Active 

and 

Reserve Active Reserve 

National 

Guard DOD 

Total recruiters 

2006 11,410 6,313 5,133 3,388 2,284 412 464 29,404 

2007 11,347 7,558 5,261 3,633 2,259 411 464 30,933 

2008 12,232 7,893 5,499 4,033 1,992 424 464 32,537 

2009 11,171 7,042 5,670 4,033 2,033 429 558 30,936 

Frontline recruiters 

2006 10,381 4,919 4,796 3,388 1,624 339 464 25,911 

2007 10,281 5,027 5,027 3,633 1,580 342 464 26,354 

2008 11,190 4,970 5,321 4,033 1,320 347 464 27,645 

2009 10,283 4,456 5,348 4,033 1,346 357 558 26,381 

Source: Office of the Under Secretary of Defense for Personnel and Readiness. 

Note: Unlike the Air Force, the Army, Navy, and Marine Corps recruiters recruit for both active and 

reserve components of their services. 

Each of the military services has its own recruiting command, which is 

responsible for the service’s recruiting mission and functions.11 The role 

of the recruiting command is to provide support to the recruiting force an

guidance for the recruitment and enlistment process. In addition, the 

recruiting command plays a role in developing the recruiting goals. The 

commands are structured similarly across the services with some variation 

in organizational structure, as noted in figure 1. The recruiting command 

is the recruiting headquarters for each service, with subordinate 

commands between the headquarters level and recruiting stations or 

substations where frontline recruiters work to reach out to prospective 

applicants and communicate to them the benefits of joining the military. 

d 

 

11The Army Recruiting Command is located at Fort Knox, Kentucky; the Navy Recruiting 

Command is located in Millington, Tennessee; the Marine Corps Recruiting Command is 

located at Quantico, Virginia; the Air Force Recruiting Service is located at Randolph Air 

Force Base, Texas; and the Air Force Reserve Command Recruiting Service is located at 

Warner Robins, Georgia. 

Page 9 GAO-10-254 Military Recruiting
 

Figure 1: Organization of the Service Recruiting Commands 

Source: GAO analysis of information from the service components.

Service Recruiting Commands Headquarters

Army

Battalions

(43)

Districts

(26)

Districts

(6)

Squadrons

(24)

Flights

(182)

Zones

(259)

Companies

(260)

Recruiting

stations

(1724)

Recruiting

stations

(1468)

Recruiting

stations

(988)

Recruiting

stations

(271)

Recruiting

substations

(636)

Recruiting

stations

(48)

Brigades

(6)

Region (East) 

Region (West)

Region (Eastern) 

Region (Western)

Groups

(3) Squadrons

(3) 

 

Navy Marine Corps Air Forcea Air Force

Reservea

a

The Department of the Air Force is the only military department in which the recruiting commands for 

the active and reserve components are separate. 

Note: The Army National Guard and the Air National Guard have recruiting entities that are separate 

from the recruiting commands for the Army and the Air Force. Recruiting in the Army National Guard 

is overseen by the Army National Guard Strength Maintenance Division within the National Guard 

Bureau. Recruiting in the Air National Guard is overseen by the Air National Guard Recruiting and 

Retention Service within the National Guard Bureau. 

Since 2006, most of the service components have been able to achieve 

their recruiting goals, and all service components met their recruiting 

goals in fiscal years 2008 and 2009. (See table 2 for accession goals and 

achievements from fiscal year 2006 through fiscal year 2009.) Service 

Page 10 GAO-10-254 Military Recruiting
 

component officials and recruiters alike have attributed the high rate of 

recruiting success to the conditions of the economy and the services’ 

competitive advantage over the civilian job market, particularly given the 

rising unemployment rate. DOD found that more youth are willing to 

consider military service during periods of high unemployment. 

Recruiters reported, however, that while they have seen an increase in the 

number of individuals interested in military service, many of them do not 

meet the military’s qualification requirements. DOD estimated that 

approximately 7 out of 10 youth ages 17 to 24 do not meet the military’s 

entrance standards for reasons including medical conditions, prior 

criminal records, and existence of young dependents. 

Table 2: Enlisted Accessions for Each Service Component in Fiscal Years 2006 through 2009 

Fiscal year 2006 Fiscal year 2007 Fiscal year 2008 Fiscal year 2009 

 Service 

component 

Accessions 

achieved 

Percentage 

of goal 

achieved 

Accessions 

achieved

Percentage 

of goal 

achieved

Accessions 

achieved

Percentage 

of goal 

achieved 

Accessions 

achieved

 Percentage 

of goal 

achieved

Army 80,635 101 80,407 101 80,517 101 70,045 108 

Army 

National 

Guard 

69,042 99 66,652 95 65,192 103 56,071 100

Army 

Reserve 

34,379 95 35,734 101 39,870 106 36,189 105 

Navy 36,679 100 37,361 101 38,485 100 35,527 100

Navy 

Reserve 

9,722 87 10,627 100 9,134 100 7,793 101

Marine 

Corps 

32,337 100 35,603 100 37,991 100 31,413 100

Marine 

Corps 

Reserve 

8,056 100 7,959 110 7,629 100 8,805 122

Air Force 30,889 100 27,801 100 27,848 100 31,983 100

Air Force 

Reserve 

6,932 105 7,110 104 7,323 105 8,604 109

Air National 

Guard 

9,138 97 9,975 93 10,749 126 10,075 106

DOD 317,809 99 319,229 99 324,738 102 296,505 103 

Source: Office of the Under Secretary of Defense for Personnel and Readiness. 

Even in this favorable recruiting environment, irregularities can occur and 

checks have been built into the enlistment process that may help minimize 

recruiter irregularities. These checks begin with the initial prescreening of 

Page 11 GAO-10-254 Military Recruiting
 

the applicant conducted by the recruiter and involve a background review, 

an initial determination of physical eligibility, and a review of education 

credentials. After the initial prescreening, the military pays the applicant to 

travel to 1 of the 65 military entrance processing stations (MEPS) located 

throughout the country.12 Each MEPS station is staffed with military and 

civilian personnel, including liaisons representing each service component 

and MEPS staff who are responsible for quality control checks that are 

designed to prevent anyone not qualified for their service component from 

entering. Upon arrival at the MEPS, applicants meet with their service 

component’s liaison who reviews their qualifications. Applicants are also 

administered the Armed Services Vocational Aptitude Battery (ASVAB) 

that determines the applicant’s qualifications for enlistment and for a 

specific military job.13 In addition, a MEPS doctor conducts a medical 

examination to determine whether the applicant meets the physical 

entrance standards. When the applicant has met the qualifications for 

military enlistment, the applicant signs an enlistment contract and is 

sworn into the service before entering into the delayed entry program.14 In 

this program, applicants become members of the Individual Ready Reserve 

in an unpaid status until they receive orders to report for basic training. 

Prior to shipping to basic training, the applicant must return to the MEPS 

to undergo a brief physical examination that ascertains that the applicant 

continues to meet the physical fitness standards for entering the military. 

Upon successful completion of this final exam, the applicant is sworn into 

the military and shipped to basic training. Figure 2 illustrates the steps in 

the enlistment process. 

 

12The MEPS are under the direction and control of MEPCOM, which is under the direct 

operational authority of the Deputy Under Secretary of Defense for Military Personnel 

Policy within the Office of the Under Secretary of Defense for Personnel and Readiness. 

MEPCOM’s role is to ensure that all service applicants meet DOD standards for enlistment. 

13The ASVAB test can also be administered to applicants at their high school or a Military 

Entrance Test site. 

14The Army National Guard refers to its delayed entry program as the Recruit Sustainment 

Program. 

Page 12 GAO-10-254 Military Recruiting
 

Figure 2: Overview of the Enlistment Process 

Source: GAO analysis of information from the service components; Art Explosion (clip art).

DAVISH

JAMES

SMITH

ARMY

ARMY

Applicants

Army MEPS

• MEPS liaison

 interview

• ASVAB test

• Physical exam

• First enlistment 

 oath

MEPS

• Physical exam

• Second enlistment

 oath

Service basic

training

Delayed

Entry 

Program

Navy

Marine Corps

Air Force

Recruiting stations/

substations

Recruiter prescreening

Page 13 GAO-10-254 Military Recruiting
 

Substantiated Cases 

of Irregularities 

Represent a Small 

Percentage of 

Accessions, and 

Actions Have Been 

Taken against the 

Recruiters 

Responsible 

Substantiated Cases of 

Recruiter Irregularities 

across the Service 

Components Comprise a 

Small Percentage of 

Overall Accessions 

From fiscal year 2006 through fiscal year 2008, the total number of 

substantiated cases of recruiter irregularities across the service 

components comprised a small percentage of overall accessions.15 As table 

3 shows, the total number of substantiated cases of recruiter irregularities 

comprised less than 0.4 percent of accessions in every service component 

during this period. For example, there were 321 substantiated recruiter 

irregularity cases in the Army in fiscal year 2006, comprising 0.28 percent 

of the Army’s accessions. 

 

15The determination of whether a reported recruiter irregularity within the service 

components is substantiated or unsubstantiated is made by commanders within a 

recruiter’s chain of command based on a review of the facts of an investigation. 

Page 14 GAO-10-254 Military Recruiting
 

Table 3: Total Number of Substantiated Recruiter Irregularities, Accessions, and Irregularities as a Percentage of Accessions, 

Fiscal Years 2006 through 2008 

Service component 

Army Navy Marine Corps Air Force 

Air Force 

Reserve Total

Fiscal year 2006 

Substantiated irregularities 321 159 102 14 20 616

Accessions 115,014 46,401 40,393 30,889 6,932 239,629

Substantiated irregularities as percentage of 

accessions 0.28 0.34 0.25 0.05 0.29 0.26

Fiscal year 2007 

Substantiated irregularities 278 93 119 25 11 526

Accessions 116,141 47,988 43,562 27,801 7,110 242,602

Substantiated irregularities as percentage of 

accessions 0.24 0.19 0.27 0.09 0.15 0.22

Fiscal year 2008 

Substantiated irregularities 253 101 71 17 8 450

Accessions 120,387 47,619 45,620 27,848 7,323 248,797

Substantiated irregularities as percentage of 

accessions 0.21 0.21 0.16 0.06 0.11 0.18

Source: GAO analysis of data provided by the Office of the Under Secretary of Defense for Personnel and Readiness. 

Notes: Accessions numbers for the Army, Navy, and the Marine Corps include both active and 

reserve component accessions. 

We did not present the number of cases of recruiter irregularities for the National Guard because not 

all States and Territories consistently report data and because of concerns about the reliability of the 

data reported. 

We did not present fiscal year 2009 recruiter irregularity data because full fiscal year 2009 data will 

not be available in time to include in our analysis. 

From fiscal year 2006 through fiscal year 2008, less than 25 percent of the 

total reported cases of recruiter irregularities were found to be 

substantiated, as shown in table 4. However, the proportion of recruiter 

irregularities reported during that period that were found to be 

substantiated varied—both among the service components and within 

individual service components. For example, of the cases of recruiter 

irregularities reported in the Army during fiscal year 2008, 15 percent were 

found to be substantiated by commanders based on a review of the facts 

of an investigation; during the same period, 71 percent of the Air Force’s 

reported cases were substantiated. 

Page 15 GAO-10-254 Military Recruiting
 

Table 4: Cases of Substantiated Recruiter Irregularities as a Percentage of All Cases of Reported Recruiter Irregularities, 

Fiscal Years 2006 through 2008 

Service component Fiscal year 2006 (total) Fiscal year 2007 (total) Fiscal year 2008 (total) 

Average, fiscal years 

2006-2008 (total)

Army 18.8 (1,710) 15.9 (1,747) 15.1 (1,681) 16.6 (5,138)

Navy 33.8 (471) 36.3 (256) 27.4 (369) 32.2 (1,096)

Marine Corps 53.1 (192) 56.4 (211) 60.2 (118) 56.0 (521)

Air Force 9.0 (155) 62.5 (40) 70.8 (24) 25.6 (219)

Air Force Reserve 51.3 (39) 28.9 (38) 26.7 (30) 36.4 (107)

Total 24.0 ( 2,567) 22.9 (2,292) 20.3 (2,222) 22.5 (7,081)

Source: GAO analysis of data provided by the Office of the Under Secretary of Defense for Personnel and Readiness. 

Note: We did not present the number of cases of recruiter irregularities for the National Guard 

because not all States and Territories consistently report data and because of concerns about the 

reliability of the data reported. 

We did not present fiscal year 2009 recruiter irregularity data because full fiscal year 2009 data will 

not be available in time to include in our analysis. 

Concealment or 

Falsification of Documents 

or Information Was the 

Most Commonly Reported 

Irregularity 

From fiscal year 2006 through fiscal year 2008, recruiter irregularities 

involving concealment or falsification, such as when a recruiter omitted 

information concerning prior criminal violations in an applicant’s 

application packet, constituted the most commonly reported type of 

recruiter irregularity by all service components except the Air Force 

Reserve. For the Air Force Reserve, quality control measures, such as a 

recruiter failing to obtain parental signatures on an applicant’s application 

form, were the most common type of recruiter irregularity reported. The 

second most commonly reported type of recruiter irregularity varied 

among the service components. For example, in fiscal year 2008, it 

involved quality control measures in the Army, while during the same 

fiscal year, it involved sexual misconduct in the Marine Corps. (See table 

5 for the types of recruiter irregularities most commonly reported by the 

service components in fiscal year 2008.) 

Page 16 GAO-10-254 Military Recruiting
 

Table 5: Most Commonly Reported Types of Recruiter Irregularities as a Percentage 

of All Reported Recruiter Irregularities in Fiscal Year 2008, by Service Component 

Service 

component n= 

Most common 

(percentage) 

Second most common 

(percentage) 

Army 1681 Concealment/falsification 

(50.7%) 

Quality control measures 

(41.8%) 

Navy 369 Concealment/falsification 

(64.8%) 

Fraternization or unauthorized 

relationship with an applicant 

(10.6%) 

Marine 

Corps 

118 Concealment/falsification 

(44.9%) 

Sexual misconduct (22.9%) 

Air Force 24 Concealment/falsification 

(50.0%) 

Fraternization or unauthorized 

relationship with an applicant 

(41.7%) 

Air Force 

Reserve 

30 Quality control measures 

(53.3%) 

Concealment/falsification 

(33.3%) 

Source: GAO analysis of data provided by the Office of the Under Secretary of Defense for Personnel and Readiness. 

Note: We did not present the most commonly reported types of recruiter irregularities for the National 

Guard because not all States and Territories consistently report data and because of concerns about 

the reliability of the data reported. 

Our review of the service components’ case files of recruiter irregularities 

reported in fiscal year 2008 identified examples of recruiter irregularities 

illustrating each of the eight recruiter irregularity categories established in 

OSD’s memorandum.16 As the examples in table 6 show, recruiters across 

the service components committed a range of recruiter irregularities, from 

administrative or paperwork errors to inappropriate relationships with 

applicants or recruits. (Additional examples can be found in appendix II.) 

 

16OSD’s memorandum groups recruiter irregularities into the following eight categories: 

criminal misconduct; sexual misconduct; sexual harassment; fraternization or unauthorized 

relationship with an applicant; concealment or falsification; testing irregularity; false 

promise or coercion; and quality control measures, which are irregularities resulting from 

administrative oversight. 

Page 17 GAO-10-254 Military Recruiting
 

Table 6: Examples of Substantiated Recruiter Irregularities by Type, Fiscal Year 

2008 

Criminal misconduct 

A recruiter in charge of a recruiting station was involved in 

the purchasing of illegal drugs with a recruit (Navy). 

Sexual misconduct A recruiter impregnated a 17 year-old student in a high 

school in which he was responsible for recruiting (Marine 

Corps). 

Sexual harassment A recruiter sent sexually suggestive jokes to an applicant 

via e-mail, made inappropriate comments to the applicant, 

and refused to leave the applicant’s place of employment 

(Air Force Reserve). 

Fraternization or 

unauthorized relationship 

with an applicant 

A recruiter requested inappropriate pictures from a recruit, 

exchanged inappropriate personal text messages with the 

recruit, and engaged in a sexual relationship with the 

recruit (Army). 

Concealment or falsification A recruiter omitted a driving under the influence violation 

from an applicant’s application packet (Air Force). 

False promise/coercion A recruiter misled an applicant about the length of reserve 

service the applicant’s contract would require (Army 

National Guard). 

Testing irregularity A recruiter attempted to have a recent recruit take the 

ASVAB for an applicant (Marine Corps). 

Quality control measures A recruiter did not obtain the signature of both parents on 

the parental consent form required for enlistment (Army). 

Source: GAO analysis of recruiter irregularity case files provided by the service components. 

Actions Taken against 

Recruiters in Substantiated 

Cases of Recruiter 

Irregularities Varied by 

Service Component 

From fiscal year 2006 through fiscal year 2008, all service components 

took actions against recruiters who committed irregularities, but the 

service components varied in the types of actions that they most 

commonly took against these recruiters during these fiscal years. For 

example, as can be seen in table 7, in fiscal year 2008, the most common 

type of action taken by the Army involved adverse administrative action, 

such as placing a letter of reprimand in the recruiter’s permanent 

personnel file, while the most common type of action taken in the Marine 

Corps involved removal from recruiting. 

Page 18 GAO-10-254 Military Recruiting
 

Table 7: Most Commonly Reported Actions Taken against Recruiters as a 

Percentage of All Actions Taken, Fiscal Year 2008 

Service 

component n= Most common (percentage) 

Second most common 

(percentage) 

Army 253 Adverse administrative action 

(65.6%) 

Article 15 Non-Judicial 

Punishment (16.2%) 

Navy 101 Non-adverse administrative action 

(42.6%) 

Article 15 Non-Judicial 

Punishment (35.6%) 

Marine 

Corps 

71 Removed from recruiting (49.3%) Removed from service and 

adverse administrative action 

(16.9% each) 

Air Force 17 Non-adverse administrative action 

(29.4%) 

Article 15 Non-Judicial 

Punishment (23.5%) 

Air Force 

Reserve 

8 Removed from recruiting, nonadverse administrative action, and 

administrative or processing error 

(25.0% each) 

Adverse administrative action 

and Article 15 Non-Judicial 

Punishment (12.5%) 

Source: GAO analysis of data provided by the Office of the Under Secretary of Defense for Personnel and Readiness. 

Note: We did not present the most commonly reported actions for the National Guard because not all 

States and Territories consistently report data and because of concerns about the reliability of the 

data reported. 

The OSD memorandum provides the service components with specific 

categories to use when reporting on the status of cases, including 

categories for cases in which action has been taken, cases that are still 

ongoing, and cases that were determined to be unsubstantiated.17 Our 

review of the service components’ case files of recruiter irregularities 

reported in fiscal year 2008 identified examples illustrating each of OSD’s 

reporting categories. As can be seen in table 8, the service components 

sometimes take different actions against recruiters who committed similar 

types of recruiter irregularities. For instance, an Air Force recruiter was 

court-martialed for fraternizing with an applicant, while a Navy recruiter 

received an Article 15 Non-Judicial Punishment for a similar type of 

offense. (Additional examples can be found in appendix III.)

 

17The categories established by OSD for the service components to use in reporting are: 

court-martial/civil conviction, removed from service, removed from recruiting, Article 15 

Non-Judicial Punishment, adverse administrative action, non-adverse administrative action, 

administrative or processing error, unsubstantiated, action pending, and an on-going 

investigation. 

Page 19 GAO-10-254 Military Recruiting
 

Table 8: Examples of Actions Taken against Recruiters Who Committed Recruiter 

Irregularities, Fiscal Year 2008 

Court martial/civil conviction 

For fraternizing with an applicant, a recruiter was courtmartialed and was reduced in rank, confined for 30 days, 

and made to forfeit two-thirds of a month’s pay for 2 

months (Air Force). 

Removed from service For sexual misconduct, a recruiter was removed from 

service (Marine Corps). 

Removed from recruiting For fraternizing with an applicant, a recruiter was reduced 

in rank and transferred to a non-recruiting unit (Army 

National Guard). 

Article 15 Non-Judicial 

Punishment 

For fraternizing with an applicant, a recruiter was reduced 

in rank, received restriction and extra duties, and was 

made to forfeit pay (Navy). 

Adverse administrative action For failing to ensure that an applicant’s enlistment 

documents were completed correctly, a recruiter was 

given a letter of reprimand by his battalion commander 

(Army). 

Non-adverse administrative 

action 

For failing to perform adequate quality control checks on 

an applicant’s application packet; thereby allowing the 

wrong ASVAB score to be filed in an applicant’s 

application packet, a recruiter received counseling, which 

directed him to perform quality control checks on other 

application packets (Air Force Reserve). 

Administrative or processing 

error 

For failing to conduct a thorough prequalification interview 

of an applicant, a recruiter was judged to have committed 

a recruiter error. The recruiter was not punished, but his 

battalion commander used the error as an example in 

teaching his recruiters how to properly document 

information (Army). 

Source: GAO analysis of recruiter irregularity case files provided by the service components. 

For all service components, the determination of the action to apply in 

cases of recruiter irregularities is vested with the recruiting unit, and the 

commanders of the responsible recruiting units take a variety of factors 

into consideration when deciding on the actions to take against recruiters 

who commit irregularities. Several service component officials we 

interviewed reported that these commanders generally decide on the 

appropriate action to take against a recruiter on a case-by-case basis. For 

example, a Marine Corps Recruiting Command official told us that the 

commanders who are ultimately responsible for taking action against a 

recruiter can take into account how a particular action will affect a 

recruiter’s family before deciding upon the appropriate level of action. 

This can lead to different actions taken in cases that fall into similar 

recruiter irregularity categories. While the Army National Guard States 

and Territories follow states’ and territories’ laws and guidance that 

Page 20 GAO-10-254 Military Recruiting
 

govern how actions are applied, our review of selected recruiter 

irregularity case files from the Army National Guard also showed that the 

actions taken against recruiters who committed irregularities varied 

among States. For example, we found that different actions were taken 

against the recruiters from different States who engaged in irregularities 

falling into the sexual misconduct category, ranging from non-adverse 

administrative action to removal from service. A recruiter in one State who 

admitted to a sexual relationship with an applicant received non-adverse 

administrative action, which included counseling, a 12-month suspended 

reduction in rank, and a 12-month suspension from favorable personnel 

actions, such as the ability to be promoted, be reassigned, or receive 

awards or bonuses. However, a recruiter in another State who provided 

alcohol to and engaged in a sexual relationship with an applicant was 

removed from service. 

In the view of the recruiting command officials and recruiters with whom 

we spoke, the actions taken against recruiters who committed 

irregularities have generally been fair and sufficiently strict to act as 

deterrents against future recruiter irregularities. Further, they said that the 

ongoing training that recruiters receive includes examples of the actions 

taken against other recruiters who committed irregularities, thereby 

reinforcing the seriousness of committing a recruiter irregularity. For 

example, an Air Force recruiter told us that he realizes that he stands to 

receive strict punishment, such as a reduction in rank or removal from the 

Air Force, if he commits a recruiter irregularity. 

Page 21 GAO-10-254 Military Recruiting
 

The Service 

Components Have 

Developed Guidance 

and Procedures to 

Address Recruiter 

Irregularities, but Not 

All Service 

Components Share 

Recruiter Irregularity 

Data throughout All 

Levels of Command 

The Service Components 

Have Developed Guidance 

to Address Recruiter 

Irregularities 

All of the service components have developed guidance on recruiter 

irregularities and have instituted procedures for reporting allegations of 

recruiter irregularities, conducting an investigation, and adjudicating 

cases.18 Some service components have guidance specifically focused on 

recruiter irregularities. For example, the U.S. Army Recruiting Command 

developed a regulation that specifically focuses on recruiter 

irregularities—Regulation 601-45, Recruiting Improprieties Policies and

Procedures—which covers the definitions of recruiter irregularities, the 

process of reporting irregularities up the chain of command, and the 

investigation and adjudication of recruiter irregularity cases.19 Other 

service components, such as the Marine Corps, address recruiter 

irregularities within their existing framework of recruiting guidance. For 

example, the Marine Corps uses Marine Corps Order 1130.65A, Total Force 

 

18United States Army Recruiting Command Regulation 601-45, Recruiting Improprieties 

Policies and Procedures (July 13, 2009); Marine Corps Order 1130.65A, Total Force 

Recruiting Quality Control (Feb. 20, 1987); Navy Recruiting Command Instruction 1137.3, 

Investigating and Reporting of Allegations and Complaints (Apr. 3, 2009); Air Force 

Recruiting Service Instruction 36-2001, Recruiting Procedures for the Air Force (Apr. 1, 

2005); Air Force Reserve Command Instruction 36-2001, Air Force Reserve Recruiting 

Procedures (June 1, 2009). 

19United States Army Recruiting Command Regulation 601-45, Recruiting Improprieties 

Policies and Procedures (July 13, 2009). 

Page 22 GAO-10-254 Military Recruiting
 

Recruiting Quality Control, which covers recruiting in general, but 

includes provisions that apply to the reporting of recruiter irregularities 

and the actions that should be taken against recruiters who commit 

irregularities.20 

The Army National Guard Strength Maintenance Division and the Air 

National Guard Recruiting and Retention Service within the National 

Guard Bureau21 have also issued guidance providing the Army and Air 

National Guards of the 54 States and Territories with a broad framework 

for addressing recruiter irregularities.22 This guidance supplements laws 

and guidance that the Army National Guard and Air National Guard from 

each State and Territory follow. However, the implementation of National 

Guard Bureau guidance is at the discretion of the individual States and 

Territories. State National Guard recruiters typically operate under Title 32 

of the U.S. Code through which they are federally funded but under state 

control. Therefore, State National Guard recruiters are subject to state 

laws and guidance unlike active duty recruiters operating under Title 10 of 

the U.S. Code who are subject to the Uniform Code of Military Justice and 

service component guidance in the event they commit a recruiter 

irregularity.23 The Secretary of Defense issued a model code of military 

justice to recommend to the states for use with respect to the National 

Guard when not in federal service.24 According to an official within the 

Office of the Chief Counsel within the National Guard Bureau, many states 

have partially adopted this model military code while others have not 

adopted it at all. 

 

20Marine Corps Order 1130.65A, Total Force Recruiting Quality Control (Feb. 20, 1987). 

21According to 10 U.S.C. §10501, the National Guard Bureau is a joint activity of the 

Department of Defense, and is a channel of communication on all matters pertaining to the 

National Guard between the Departments of the Army and the Air Force and the states. 

22National Guard Regulation 601-1, Personnel-Procurement: Army National Guard 

Strength Maintenance Program (Apr. 28, 2006); Air National Guard Instruction 36-2602, 

Air National Guard Recruiting Expenditures and Management of Recruiting and 

Retention Programs (Mar. 28, 1997). 

23National Guard recruiters that recruit under Title 10—such as Reserve Component Career 

Counselors who recruit servicemen and servicewomen that are separating from active 

duty—are subject to the Uniform Code of Military Justice and service component guidance 

in the event they commit a recruiter irregularity. 

24The Bob Stump National Defense Authorization Act for Fiscal Year 2003, Pub. L. No. 107-

314, §512 (2002), directed the Secretary of Defense to prepare a model state code of 

military justice and a model state manual for courts-martial to recommend to the states for 

use with respect to the National Guard when not in federal service. 

Page 23 GAO-10-254 Military Recruiting
 

The service components have similar procedures for identifying, 

investigating, and adjudicating recruiter irregularities. As figure 3 shows, 

recruiter irregularity allegations can be brought to light through a variety 

of sources, such as complaints submitted through congressional 

representatives, service component hotlines, and recruiting staff reporting 

on the suspicious behavior of a fellow recruiter. Once an allegation is 

brought to the attention of the service component, all service components 

follow several steps, including the appointment of the investigating officer, 

the investigation process, and the review of the report produced by the 

investigating officer. The investigation report and the recommendations 

therein are used by the appropriate unit commander to determine whether 

the allegation can be substantiated. 25 When it is determined that an 

allegation is substantiated, the commander also determines the 

appropriate action and provides the recruiter with the opportunity to 

present additional information and appeal the decision. The service 

components’ recruiting command headquarters are notified of all final 

decisions in recruiter irregularity cases. 

 

25The determination of the appropriate unit commander can be based on a number of 

factors, to include where the recruiter irregularity investigation was initiated, the 

seriousness of the allegation, and the type of action that is recommended. The following 

service component recruiting command levels can be involved in the investigation review 

and adjudication process: Army—recruiting command, recruiting brigade, or recruiting 

battalion; Navy—recruiting region or recruiting district; Marine Corps—recruiting 

command, recruiting region, recruiting district, or recruiting station; Air Force—recruiting 

command, recruiting group, or recruiting squadron; and Air Force Reserve— recruiting 

command, recruiting squadron, or recruiting station. 

Page 24 GAO-10-254 Military Recruiting
 

Figure 3: The Service Components’ Process for Addressing Recruiter Irregularities 

Source: GAO analysis of information from the service components; Art Explosion (clip art).

Allegation of

recruiter 

irregularity

reported to 

service 

component

Recruiting 

staff

Military entrance

processing station

Congressional 

inquiry

Hotline 

Sources Of Allegations

Basic training Investigating

officer

appointed

Investigation

conducted 

Investigation 

report

produced 

Unsubstantiated 

allegations

fowarded to 

recruiting 

command

headquarters

(Case is closed) 

Commanding

officer

determines

appropriate

actions

Recruiting 

headquarters

are notified of 

final outcome

(Case is closed)

Substantiated

Unsubstantiated

Although the procedures for investigating and adjudicating cases of 

recruiter irregularities are generally similar across the service 

components, some differences exist. For example, the Army and the Air 

Force require that all recruiter irregularity investigations undergo a legal 

review—a review of the investigation report findings by the service 

component’s Judge Advocate’s office—while the Navy, Marine Corps, and 

Air Force Reserve do not have such a requirement. 

Service component officials we interviewed generally agreed that the 

existing service component guidance on recruiter irregularities is 

sufficient and informs those involved on how to handle recruiter 

irregularities that come to light. Further, recruiters we interviewed 

generally agreed that service component guidance they receive on 

recruiter irregularities is sufficient and that they know how to report any 

cases of recruiter irregularities that they may come across. 

Page 25 GAO-10-254 Military Recruiting
 

The service components have instituted a number of quality control 

checks to help identify recruiter irregularities, including the use of a 

hotline for individuals to report recruiter irregularities, periodic 

inspections of recruiting stations, and opportunities for recruits to reveal 

any potential recruiter irregularities committed by their recruiter during 

the enlistment process.26 The service components use the following 

mechanisms to ensure that recruiters are abiding by recruiting standards 

and verify the accuracy of information in applicant packets: 

The Service Components 

Have Taken Steps to 

Identify and Prevent 

Recruiter Irregularities 

• Hotline. Most service components make telephone numbers available 

to applicants and parents for reporting any suspected cases of recruiter 

irregularities by posting a notice in recruiting stations with a hotline 

listed or providing a card to applicants with the service component’s 

hotline number listed. For example, Navy recruiters provide applicants 

with hotline cards that list recruiter and applicant rights, activities that 

recruiters are prohibited from doing, and a hotline number that 

applicants can call to report any alleged recruiter irregularities to the 

Navy Recruiting Command Inspector General’s office. 

• Periodic inspections. All of the service components conduct periodic 

inspections and command visits to recruiting stations. For example, the 

Marine Corps Recruiting Command’s inspection program includes 

monthly visits and annual inspections by recruiting station 

commanders of the recruiting substations for which they are 

responsible. While these inspections do not focus specifically on 

identifying recruiter irregularities, recruiting command officials told us 

that some recruiter irregularities are identified in the course of the 

inspections process. 

• Opportunities to reveal irregularities. All of the service 

components provide recruits with an opportunity to disclose any 

information about themselves that could disqualify them from 

enlistment, such as medical issues or criminal history, and also allow 

applicants to bring up any inappropriate behavior displayed by their 

recruiter, such as a recruiter telling an applicant to conceal a medical 

problem in order to facilitate the enlistment process. Officials we 

interviewed generally agreed that such opportunities for disclosure, 

commonly known as a “moment of truth,” provide a powerful tool for 

identifying recruiter irregularities. 

 

26The service components’ quality control checks are further complemented by the checks 

done at the MEPS to identify any discrepancies in the enlistment paperwork, such as 

signature verification and the use of biometrics (i.e., technologies that automate the 

identification of people by distinct physical or behavioral characteristics, such as 

fingerprint recognition). 

Page 26 GAO-10-254 Military Recruiting
 

All of the service components have programs in place to help prevent 

recruiter irregularities, including recruiter screening programs and 

recruiter training. In addition, the Army and Army National Guard have 

established policies requiring more than one person to be present when a 

recruiter interacts with an applicant of the opposite gender.27 

• Screening programs. All service components have recruiter screening 

programs to screen their recruiter candidates. For example, the Air 

Force Recruiting Service’s screening program includes face-to-face 

interviews with recruiter candidates, reviews of the candidates’ history 

of meeting physical standards, reviews of performance reports from 

the previous 3 years, and a credit check. Recruiting command officials 

acknowledged that recruiting is a stressful job and said that the 

rigorous screening of individuals interested in becoming recruiters 

helps ensure that only those individuals who are most qualified; are 

sufficiently motivated; have a high level of integrity; and are not 

burdened by additional external stressors, such as financial debt or 

ongoing divorce proceedings, are selected to receive training at the 

recruiter schools. Recruiting command officials also stated that these 

programs help screen out individuals who may be more susceptible to 

committing recruiter irregularities. 

• Recruiter training. Once individuals are selected to become 

recruiters, they are required to attend the service component’s or the 

National Guard’s recruiter school, as appropriate, for initial recruiter 

training.28 The service components’ recruiting school officials and 

recruiters interviewed said that topics on ethical behavior, prohibited 

practices, fraternization, and sexual harassment are covered during the 

initial training. Additionally, they said that instructors share examples 

of actual recruiter irregularities with the new recruiters in order to 

inform them of situations to avoid. After graduating from the service 

component’s recruiter school, recruiters receive ongoing training, 

covering topics such as sexual harassment and the reporting of 

suspected recruiter irregularities. For example, the Marine Corps 

 

27This policy is referred to as the “buddy” policy by the Army’s active and reserve 

components and as the “no one alone” policy by the Army National Guard. 

28The Army Recruiting and Retention School is located at Fort Jackson, South Carolina; the 

Navy Recruiting Orientation Unit is located at Naval Air Station Pensacola, Pensacola, 

Florida; the Marine Corps Recruiters School is located at Marine Corps Recruit Depot, San 

Diego, California; the Air Force Recruiting School is located at Lackland Air Force Base, 

Texas; and the Army National Guard Strength Maintenance Training Center is located at 

Camp Robinson, Arkansas. Air Force Reserve and Air National Guard recruiters attend the 

Air Force Recruiting School in Texas. 

Page 27 GAO-10-254 Military Recruiting
 

Recruiting Command developed a new course that all recruiters are 

required to take annually, covering ethical and unethical behavior and 

case studies of actual recruiter irregularity cases. Officials stated that 

the course, once implemented, will help recruiters identify situations 

that can lead to recruiter irregularities and ways they can avoid those 

situations. Service component officials and recruiters we interviewed 

generally agreed that existing training on recruiter irregularities is 

sufficient to help prevent future recruiter irregularities. 

• “Buddy” or “no one alone” policies. The Army has implemented a 

policy requiring that whenever a recruiter comes in contact with a 

prospect, applicant, or future soldier of the opposite gender, at least 

one other qualifying person of any gender be present.29 Also, according 

to the Chief of the Army National Guard Strength Maintenance 

Division, the Army National Guard in 26 states have implemented the 

same policy. 

The Service Components’ 

Oversight and Data 

Sharing Have Improved, 

but Not All Service 

Components Share Data 

throughout All Levels of 

Command 

Since we reported in our prior work that the service components’ 

recruiting commands did not have oversight over recruiter irregularities, 

the service components have improved oversight.30 In our prior work, we 

reported that the service components had limited oversight over recruiter 

irregularities because multiple data systems for collecting and tracking 

recruiter irregularity data were being used. Because these systems were 

not integrated, the service components did not have oversight over all 

recruiter irregularities. Since then, the service components have made 

progress in establishing systems that have allowed for more consistent 

tracking and reporting of the recruiter irregularity data. We found that 

local recruiting units responsible for gathering and tracking recruiter 

irregularity data have systems and processes in place for passing the data 

up the chain of command to the service components’ recruiting command 

headquarters on a regular basis. Each service component’s recruiting 

command has an office at the headquarters level that is responsible for 

entering the data received from the local recruiting units into the service 

components’ database or spreadsheet and consolidating and reporting 

these data to OSD on a semiannual basis. 

 

29The Army includes, among others, the following individuals in its definition of a qualifying 

person: a family member (18 or older), recruiter, applicant (male or female, 18 or older), 

and future soldier (male or female). 

30GAO, Military Recruiting: DOD and Services Need Better Data to Enhance Visibility 

Over Recruiter Irregularities, GAO-06-846 (Washington, D.C.: August 8, 2006). 

Page 28 GAO-10-254 Military Recruiting
 

Although the reporting process is generally similar across the service 

components, some differences exist, as shown in figure 4. For example, 

most of the service components have only one recruiting command office 

in place that is responsible for gathering and tracking recruiter irregularity 

data; however, the U.S. Army Recruiting Command has two offices that 

are responsible for gathering and tracking recruiter irregularities—the 

Recruiting Standards Division and the Staff Judge Advocate’s office. The 

Recruiting Standards Division provides its consolidated recruiter 

irregularity data to the Staff Judge Advocate’s office, which then 

consolidates the data from both offices for the purpose of reporting to 

OSD. In addition, while the local recruiting units provide recruiter 

irregularity updates to the recruiting command on a daily basis in the 

Army and on a weekly basis in the Air Force, they do so on a monthly 

basis in the other service components. 

Some of the service components are continuing to refine their systems for 

tracking and reporting recruiter irregularity data. For example, the Navy is 

in the process of procuring a new data system that will allow for functions 

such as trend analysis and advanced querying of recruiter irregularity data. 

In addition, the Air Force Reserve has recently updated its instruction to 

require recruiting personnel to report all actual or suspected recruiter 

irregularities to their senior recruiter and to inform the Air Force Reserve 

Command Recruiting Service Inspector General of all allegations.31 

 

31Air Force Reserve Command Instruction 36-2001, Air Force Reserve Recruiting 

Procedures (June 1, 2009). 

Page 29 GAO-10-254 Military Recruiting
 

Figure 4: The Service Components’ Processes for Reporting of the Recruiter Irregularity Data 

Source: GAO analysis of information from the service components.

Recruiting

Brigades

(Report daily)

U.S. Army Recruiting Command U.S. Navy Recruiting Command

U.S. Marine Corps Recruiting Command

U.S. Air Force Recruiting Service

Recruiting 

Standards

Division

Staff Judge

Advocate’s

Office

Staff Judge

Advocate’s

Office

Recruiting

Districts

(Report 

monthly)

Recruiting

Squadrons

(Report weekly)

U.S. Air Force Reserve Command Recruiting Service

Inspector

General’s

Office

Recruiting

Squadrons

(Report monthly)

Recruiting Service

Operations Office

(Report monthly)

Recruiting

Regions

(Report 

monthly)

Recruiting

Districts

(Report 

monthly)

Recruiting

Regions

(Report 

monthly)

Manpower

Division

Inspector

General’s

Office

Staff Judge

Advocate’s

Office

Naval Criminal

Investigative 

Service

(Report as

cases arise)

Recruiting Regions’

Judge Advocates

(Report as

cases arise)

Recruiting Brigades’

Judge Advocates

(Report weekly)

While all service components regularly provide recruiter irregularity data 

to the recruiting command headquarters, with the exception of the Air 

Force, they do not regularly make recruiter irregularity data available to 

all levels of command. This is because most of the service components do 

not have procedures in place to disseminate recruiter irregularity data to 

the commanders at levels below the recruiting headquarters. In contrast, 

the Air Force Recruiting Service shares recruiter irregularity data with 

leadership at all levels of command within the Air Force Recruiting 

Service and all recruiting staff through monthly and quarterly reports and 

newsletters. These reports contain information on the circumstances of 

the recruiter irregularity committed and the actions taken against the 

Page 30 GAO-10-254 Military Recruiting
 

recruiter. 32 Air Force officials we interviewed explained that making this 

information available to personnel at all levels within the Air Force 

Recruiting Service provides commanders with examples of how others are 

addressing recruiter irregularities, promotes consistent application of 

actions in substantiated cases of recruiter irregularities across the Air 

Force, and serves as a deterrent to committing recruiter irregularities. Air 

Force recruiters we interviewed also generally agreed that the recruiter 

irregularity reports shared by the recruiting command have a strong 

deterring effect because everyone knows what will happen if they commit 

an irregularity. 

In order to make improvements and promote knowledge sharing, leaders 

at all levels of an organization need to receive information on a regular 

basis about the problems that may be occurring across the organization.33

Although the other service components have some efforts in place to 

communicate and share limited information on recruiter irregularities that 

occur within their service component, information on the range of 

recruiter irregularities occurring is not included or consistently shared 

with all levels within the recruiting command. For example, according to 

recruiting command officials, the U.S. Army Recruiting Command holds a 

quarterly meeting for headquarters officials, including the Commanding 

General and representatives from the Staff Judge Advocate’s office, the 

Recruiting Standards Division, and the Inspector General’s office to review 

and discuss trends in recruiter irregularities across the recruiting 

command and determine if there is a need for additional training or 

changes in policies to address any issues found. We also found that all 

service components, at a minimum, occasionally share examples of 

serious recruiter irregularities that have occurred or have been showcased 

by the media as part of the continuous training provided to recruiters on 

 

32The Air Force Recruiting Service develops and distributes the following reports on 

recruiter irregularities with personally identifying information left out: a monthly report to 

the Commander of the Air Force Recruiting Service, recruiting squadron commanders, and 

recruiting group commanders, which covers recruiter irregularities that resulted or may 

potentially result in a courts-martial; a monthly newsletter to all recruiting personnel, 

which covers recruiter irregularities that resulted in courts-martial, removal from 

recruiting, or removal from service; a quarterly report to all recruiting personnel, which 

covers recruiter irregularities that resulted in a letter of reprimand or a more serious 

action. 

33GAO, Executive Guide: Effectively Implementing the Government Performance and 

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

Results: Enhancing Agency Use of Performance Information for Management Decision 

Making, GAO-05-927 (Washington, D.C.: September 9, 2005). 

Page 31 GAO-10-254 Military Recruiting
 

recruiter irregularity issues. However, without processes that allow for the 

regular flow of recruiter irregularity data from the headquarters to all 

command levels, commanders may not be able to take full advantage of 

servicewide recruiter irregularity data that would enable them to improve 

their operations. Further, commanders may not be able to seize 

opportunities to learn from their peers about shared experiences on 

handling recruiter irregularities. 

OSD Implemented 

Recruiter Irregularity 

Reporting 

Requirements, but 

Lacks Complete 

Oversight over 

Irregularities 

OSD Has Implemented 

Recruiter Irregularity 

Reporting Requirements, 

Sponsored Research, and 

Provided InformationSharing Opportunities on 

Recruiter Irregularity 

Issues 

In December 2006, OSD issued the memorandum regarding the tracking 

and reporting of recruiter irregularities by the service components.34 The 

issuance of the memorandum constituted OSD’s response to our 2006 

recommendation for OSD to establish an oversight framework to assess 

recruiter irregularities, including criteria and common definitions across 

the service components. Such oversight is needed for OSD to have the 

tools for assessing and evaluating recruiting programs to assure itself that 

program objectives are being met—consistent with good management 

practices outlined in federal internal control standards.35 The 

memorandum defined recruiter irregularities, established specific 

categories for classifying irregularities and dispositions, and included a 

reporting template for the service components to use when providing 

recruiter irregularity data to OSD on a semiannual basis—in January and 

July of each year. OSD involved the service components in the 

development of the memorandum by convening a meeting of 

 

34Office of the Under Secretary of Defense for Personnel and Readiness Memorandum, 

Tracking and Reporting of Recruiter Irregularities (Dec. 21, 2006). 

35GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1 

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

Page 32 GAO-10-254 Military Recruiting
 

representatives from each of the service components to obtain their input 

on this guidance, including input on the proposed terminology and the 

reporting categories. OSD officials said that the issuance of the 

memorandum was important to their oversight over recruiter irregularities 

because it enabled them to monitor recruiter irregularities across the 

service components over time. 

Recruiting command officials we contacted reported familiarity with the 

memorandum, and the service components have been providing recruiter 

irregularity data to OSD semiannually, as required. Recruiting command 

officials we interviewed reported using the definitions in the memorandum 

when submitting their recruiter irregularity data to OSD. In our review of 

the service components’ data compiled by OSD, we found that since the 

memorandum was issued, all of the service components have been 

submitting semiannual reports following the memorandum’s reporting 

format. Recruiting command officials we interviewed also reported 

updating data submitted to OSD to reflect recently closed cases in 

accordance with the requirements set forth in the memorandum. 

In addition to obtaining and reviewing the recruiter irregularity data 

submitted by the service components, OSD contracted with RAND to 

conduct an analysis of recruiter irregularities across the service 

components. Among the issues that RAND is examining are the effects of 

recruiter irregularities on military readiness, public perceptions of the 

military, and the effect that factors, such as deployment history and 

recruiter incentives, have on the occurrence of recruiter irregularities. 

RAND is expected to produce its report in February 2010. OSD officials 

said that once they obtain the results of both RAND’s and GAO’s reviews, 

they will convene another meeting of stakeholders from each of the 

service components to discuss recruiter irregularity issues, including the 

service components’ experiences with reporting data on recruiter 

irregularities. Following this meeting, OSD officials stated that a DOD 

instruction for the reporting of recruiter irregularity data will be issued.36 

OSD also provides several opportunities for the sharing of information on 

recruiter irregularities. For example, MEPCOM holds an annual 

Commanders’ Conference for representatives from the service 

components to discuss a variety of issues, including recruiter irregularity 

 

36The memorandum states that the guidance that it contains shall be incorporated into a 

DOD instruction, but does not specify when such an instruction should be issued. 

Page 33 GAO-10-254 Military Recruiting
 

issues.37 Another example is the annual Leadership Conference, which 

brings together recruiting command officials to discuss various recruitingrelated issues. Although OSD officials explained that recruiter 

irregularities is not the only topic addressed at these events and not every 

conference or meeting will have recruiter irregularities on the agenda, 

these events provide opportunities for officials from the service 

components to share their experiences in addressing recruiter 

irregularities. Some recruiting command officials said that they would like 

additional information on what others are doing with respect to recruiter 

irregularities. For example, Navy officials said that they would like OSD to 

share lessons learned in addressing recruiter irregularities among the 

service components, and Air Force officials also said that it would help if 

OSD regularly provided the service components with DOD-wide recruiter 

irregularity data to enable them to see if the other service components are 

experiencing similar problems.38 

OSD Lacks Complete 

Oversight over Recruiter 

Irregularities Due to a 

Lack of Clarity in the 

Memorandum 

Although issuing the memorandum was an important first step in 

providing effective oversight over recruiter irregularities and establishing 

the means for assessing OSD’s programs related to recruiter irregularities, 

OSD still lacks complete oversight over the recruiter irregularities that are 

occurring because of inconsistencies in what is reported to OSD and how 

reports are prepared. We found that the inconsistencies in reporting were 

the result of differences in how the service components interpreted the 

requirements in the memorandum, interpreted the reporting categories in 

the memorandum, and reported cases involving more than one type of 

irregularity or disposition. Without more clarity, the service components 

may not be reporting the recruiter irregularity data in the same manner, 

precluding meaningful comparisons among them. 

We found that the service components and the National Guard states do 

not all interpret the requirements of the memorandum in the same manner; 

specifically, some recruiting officials were uncertain about the types of 

issues involving recruiters to include in the reporting. For example, while 

the majority of the service components reported only on irregularities 

 

37MEPCOM is overseen by the Office of the Under Secretary of Defense for Military 

Personnel Policy, which is one of the offices within OSD. 

38OSD officials said that they shared the data on recruiter irregularities with the service 

components. However, they said that the recruiting command personnel change frequently 

as existing personnel are reassigned to other posts, which may necessitate more frequent 

sharing of information. 

Page 34 GAO-10-254 Military Recruiting
 

committed by a recruiter when dealing with an applicant or a recruit, the 

Air Force Reserve, the Air National Guard States,39 and five out of seven 

Army National Guard States whose files we reviewed reported on all cases 

of recruiter irregularities,40 including cases in which no applicant or recruit 

was involved. Examples of these cases included recruiters committing 

offenses such as adultery with a non-applicant, inappropriate relationship 

with other military personnel, use of a government vehicle for personal 

benefit, or submission of fraudulent receipts for travel. OSD officials said 

that the memorandum is clear on the need to report only those recruiter 

irregularities in which an applicant is involved and the memorandum 

defines recruiter irregularities as those willful and unwillful acts of 

omission and improprieties that are perpetrated or alleged to be 

perpetrated by a recruiter to facilitate the recruiting process for an 

applicant. However, in some of our interviews with recruiting command 

officials, we found that they were not clear about the need to report only 

irregularities in which an applicant or a new recruit was involved. Some 

officials explained that they included all cases of recruiter irregularities 

because they wanted to be as transparent as possible in reporting every 

case of a recruiter irregularity to OSD. In addition, we identified at least 

one instance in which a state Air National Guard unit was not reporting 

any recruiter irregularity cases that were unsubstantiated, even though the 

memorandum specifically includes a category for unsubstantiated cases. 

In our discussions with officials in that location, they explained that they 

did not believe that those cases should be reported to anyone at the 

National Guard Bureau, and that it would help if OSD, through the 

National Guard Bureau, provided clear guidance to the States and 

Territories on the reporting of unsubstantiated cases. 

We also found that the reporting categories in the memorandum were seen 

as too broad and that the service components did not interpret these 

categories in the same manner. First, some recruiting officials said that 

the reporting categories in the memorandum are too broad to provide 

them with a clear picture of the types of recruiter irregularities that are 

occurring. For example, officials at the Recruiting Standards Division of 

 

39An official from the Air National Guard Recruiting and Retention Service did not know 

whether all Air National Guard States and Territories were reporting on cases of recruiter 

irregularities that did not involve applicants or recruits. 

40One of the Army National Guard States whose case files we reviewed only included cases 

involving applicants; however, an official with that State indicated that he would generally 

include all cases of recruiter irregularities in his report to the Army National Guard 

Strength Maintenance Division, even those not involving applicants or recruits. 

Page 35 GAO-10-254 Military Recruiting
 

the U.S. Army Recruiting Command and officials at the Navy Recruiting 

Command said that while they use the memorandum’s categories for 

reporting to OSD, they continue to rely on their own internal reporting 

categories. The Recruiting Standards Division has 12 categories and the 

Navy has more than 20 categories that are used internally to provide a 

picture of the recruiter irregularities that are occurring within their service 

components. For example, while the memorandum has a single category 

for all types of concealment or falsification, the Recruiting Standards 

Division distinguishes among the specific types of information concealed, 

such as medical information, prior police records, information on 

dependents, or history of prior service. Likewise, while the memorandum’s 

categories do not specifically address cases where the recruiter did not 

obtain appropriate parental consent for applicants under the age of 18, the 

Navy has a specific category for parental consent issues. Second, officials 

associated with the service components that continue to use their internal 

reporting categories acknowledged that decisions on how to place cases 

into one of the eight reporting categories as required by the memorandum 

can be subjective. For example, Navy officials told us that it is generally up 

to the individual who compiles the service component’s data for OSD to 

decide how cases should be transferred from the Navy categories into the 

broader categories outlined in the memorandum. Furthermore, an official 

with the Inspector General’s office of the Navy Recruiting Command told 

us that the office’s staff found the definitions and the reporting categories 

in the memorandum confusing and that the Navy’s interpretation of these 

categories would likely differ from that of the other service components. 

Some recruiting officials said that the memorandum also lacks clarity on 

how to report cases involving more than one type of irregularity or more 

than one type of disposition. OSD officials said that they expect the 

service components to report the more serious recruiter irregularity 

category when more than one category applies, and although we found 

that the service components generally did that, this was not clearly 

communicated in the memorandum. For example, Army and Air Force 

officials said that while they would handle such situations by reporting the 

most egregious type in cases involving more than one type of recruiter 

irregularity committed by the same recruiter, they have not received 

guidance from OSD on this. Additionally, such determinations will likely 

be made subjectively. For example, reasonable officials may differ in their 

opinion on whether falsification of documents is a more or less egregious 

case of a recruiter irregularity than a false promise made to an applicant. 

Similarly, some recruiting officials reported lack of clarity on how to 

report cases involving more than one type of disposition. OSD officials 

told us they expect the service components to report the final disposition 

Page 36 GAO-10-254 Military Recruiting
 

of a case. However, several recruiting officials said that this has not been 

clearly communicated to them. For example, officials from one of the 

Marine Corps recruiting districts that we visited said that the 

memorandum is not clear on the reporting of cases where more then one 

type of disposition applies, such as a recruiter first receiving punishment 

under Article 15 of the Uniform Code of Military Justice and then being 

removed from recruiting. Several recruiting officials responsible for 

reporting said that they are reporting preliminary actions against the 

recruiter even if the data would later need to be changed once the final 

action in the case is determined. For example, a Marine Corps recruiting 

official and an official with the U.S. Army Recruiting Command’s Staff 

Judge Advocate Office explained that they would report the preliminary 

actions at the time of required reporting. In fact, two Army case files that 

we reviewed showed that while the cases were ultimately found to be 

unsubstantiated, they were initially reported to OSD as having resulted in 

non-adverse administrative action because recruiters were temporarily 

suspended from recruiting while charges of inappropriate sexual 

relationship and sexual assault against them were investigated.41 

However, other service components may not be approaching this situati

in the same manner. For example, Air Force recruiting officials told us that

they only report the final disposition to OSD and not the preliminary 

actions. The memorandum does not explicitly address how such 

situations should be hand

on 

led in reporting. 

 

OSD officials acknowledged that the service components may have 

questions related to reporting, particularly given the relative newness of 

the memorandum. OSD officials told us that after the memorandum was 

issued in December 2006, their plan was to monitor the service 

components’ experiences with reporting and issue a DOD instruction that 

would incorporate the guidance in the memorandum and clarify any 

reporting issues that the service components might be experiencing. 

However, 3 years after its issuance, the memorandum has not been turned 

into a DOD instruction for the service components to follow when 

reporting to OSD. At the time of this reporting, OSD officials told us that 

they plan to wait for the issuance of this report and the RAND study before 

issuing the instruction. However, the continuing absence of definitive 

guidance may result in poor data quality that would prevent OSD from 

41Both soldiers were then reinstated to their recruiting duties after allegations against them 

were found to be unsubstantiated, and the disposition was updated in the subsequent 

report to OSD. 

Page 37 GAO-10-254 Military Recruiting
 

having complete and consistent information on recruiter irregularities 

across the service components and the National Guard and compromise 

its ability to maintain appropriate oversight over this important issue. 

OSD Also Lacks Complete 

National Guard Data 

OSD does not receive complete information from the National Guard. The 

memorandum applies to all service components, including the Army and 

Air National Guards. Officials with the Army National Guard Strength 

Maintenance Division and Air National Guard Recruiting and Retention 

Service told us that following the issuance of the memorandum, they 

began to request recruiter irregularity data from all States and Territories, 

and provided them with the definitions and the reporting template from 

the memorandum. The data from individual States and Territories are then 

aggregated by the Army and Air National Guard officials and forwarded to 

OSD.42 However, not all States and Territories in the Army National Guard 

report their recruiter irregularity data. As seen in figure 5, our review of 

the recruiter irregularity data that the Army National Guard States and 

Territories provided to the Army National Guard Strength Maintenance 

Division in January 2009 showed that 18 of the 54 States and Territories 

did not provide the data for fiscal year 2008.43 During the July 2009 

reporting cycle, 16 of the 54 States and Territories did not report their 

recruiter irregularity data. Of the 38 that reported data, the reporting 

period identified by the States and Territories on their reports varied from 

State to State. For example, some reports submitted in August 2009 

covered the first 3 quarters of fiscal year 2009, others covered only the 2nd 

and 3rd quarter of fiscal year 2009, and others only covered the 3rd quarter 

of fiscal year 2009. Moreover, two reports were not labeled, making it 

unclear what reporting period they covered. Army National Guard officials 

acknowledged problems with State reporting, but said that although they 

provide guidance based on the memorandum to the States and Territories, 

they rely on them to submit their data in accordance with that guidance. 

 

42Unless otherwise noted, Army and Air National Guard officials refer to officials from the 

Army National Guard Strength Maintenance Division and the Air National Guard Recruiting 

and Retention Service within the National Guard Bureau. 

43Another State submitted a report for fiscal year 2008 in August 2009, 6 months after it was 

due in January 2009. 

Page 38 GAO-10-254 Military Recruiting
 

Figure 5: Army National Guard States and Territories Reporting Recruiter Irregularity Data for Fiscal Year 2008 during the 

January 2009 Reporting Cycle 

Source: GAO analysis of recruiter irregularity data submitted to the Army National Guard Strength Maintenance Division by the States

and Territories.

Provided data for fiscal year 2008

Did not provide data for fiscal year 2008

ME

NH

VT

NY

PA

VA

NC

SC

GA

FL

PR

VI

AL

MS

LA TX

OK AR

TN

KY

WV

OH

MI

WI

MN

SD

MT ND

WY

CO

NM AZ

UT

ID

WA

OR

NV

AK

CA

HI

GU

IN IL

MO KS

NE

IA

MA

RI

CT

NJ

DE

MD

DC

Note: Of the 36 States and Territories that reported their recruiter irregularity data during the January 

2009 reporting cycle, 3 only provided the data for part of fiscal year 2008, and 4 did not provide 

documentation of whether their data cover the full fiscal year 2008. 

OSD also lacks a complete picture of the total number of recruiter 

irregularities occurring in the Air National Guard because of concerns 

regarding the quality of the data. Although, according to the Air National 

Guard, all States and Territories report their recruiter irregularity data, 

OSD has raised questions about the quality of the Air National Guard data. 

For example, when the Air National Guard initially reported zero 

Page 39 GAO-10-254 Military Recruiting
 

irregularities for both fiscal years 2007 and 2008, OSD officials expr

doubts about the absence of even a single allegation of a recruiter 

irregularity in the Air National Guard, particularly given that the rep

should include not only substantiated cases but also those tha

ultimately found to be unsubstantiated. Following electronic 

communication from OSD regarding this issue, the Air National G

reported two cases of recruiter irregularities for fiscal year 2008. 

Moreover, Air National Guard officials have not maintained supporting 

documentation for the information reported by each State and Territo

For example, one Territory did not submit a report (either by mail or 

electronically) during the January 2009 reporting cycle. An Air National 

Guard official at the Air National Guard Recruiting and Retention Service

told us that this Territory reported having no recruiter irregularitie

telephone conversation with his office, but documentation of this 

conversation does not exist. The absence of such documentation raises 

questions about the accuracy and completeness of the data t

essed 

ort 

t are 

uard 

ry. 

s in a 

hat the Air 

National Guard Recruiting and Retention Service receives. 

ch 

mitted. 

 has 

e, 

n direct 

t they have no 

mechanism to force States and Territories to comply. 

ities 

d 

mation 

Both Army and Air National Guard officials told us that although they

follow up with the States and Territories, they cannot force them to 

comply. Officials said that they follow up with States and Territories via email or telephone if the reports appear to contain obvious mistakes, su

as the totals not adding up to the numbers reported in each individual 

reporting category. They also follow up if no reports have been sub

However, they said that it is ultimately up to individual States and 

Territories to submit their reports because the National Guard Bureau

no command and control authority over them. Specifically, while the 

National Guard Bureau personnel operate under Title 10 of the U.S. Cod

the National Guard personnel at the state level typically operate under 

Title 32. Consequently, even though the National Guard Bureau ca

States and Territories to submit their recruiter irregularity data in 

accordance with the memorandum, officials told us tha

While the National Guard Bureau cannot force States and Territories to 

comply with the reporting requirements in the memorandum, it has not 

been transparent with respect to the total numbers reported to OSD, thus 

preventing OSD from having a complete picture of recruiter irregular

that occur in the National Guard. The Army and Air National Guar

officials aggregate the data that they receive from the States and 

Territories and report the total numbers to OSD. However, no infor

is provided on how many States or Territories did not submit their 

recruiter irregularity reports or whether any of these reports failed to 

Page 40 GAO-10-254 Military Recruiting
 

cover the full reporting period. OSD officials acknowledged that the Army 

National Guard Strength Maintenance Division and the Air National Guard 

Recruiting and Retention Service within the National Guard Bureau obta

recruiter irregularity data from the States and Territories and that each 

State and Territory maintains its own processes for collecting these da

However, while aware of this, OSD does not request that the National 

Guard officials provide caveats or any other explanatory notes on the 

limitations of the recruiter irregularity data when submitting these 

OSD. Consequently, OSD’s own reports summarizing the recruiter 

irregularity data received from the service components and the National 

in 

ta. 

data to 

Guard do not disclose any limitations of the data on which they are based. 

ed to 

y, 

ly with 

cruiter 

s, in 

ms 

bout 

Conclusions Recruiters work in a challenging environment and play a critical role in 

providing the military services with qualified men and women prepar

serve their country. Although instances of recruiter wrongdoing are 

infrequent, even a single case can undermine the trust that the American 

public has in its military. The service components recognize this realit

and all have made substantial progress since 2006 in increasing their 

oversight over recruiter irregularities. In particular, all service components

have established procedures for reporting cases of recruiter irregularities 

up the chain of command. While these systems assure that their recruiting 

command headquarters receive regular reports on recruiter irregularities, 

the Air Force is unique in sharing recruiter irregularity data regular

all of the different levels of command to provide opportunities for 

commanders at all levels to compare their progress in addressing re

irregularities with the other recruiting units and to learn from their 

experiences. The Army, Navy, and Marine Corps could benefit from doing 

likewise. OSD has also taken steps to increase its oversight over recruiter

irregularities occurring across the service components by implementing 

semiannual reporting requirements and establishing common definitions 

for the service components to use. While these are important first step

order for the reporting requirements to have a meaningful effect, it is 

critical that the services fully understand them and uniformly report 

accurate data. Without OSD monitoring and promptly addressing proble

that the service components may experience with respect to reporting 

their recruiter irregularity data, the quality of the data received by OSD 

from the service components could be compromised. Furthermore, OSD’s 

ability to rely on the data provided will be significantly diminished if OSD

does not receive complete information on which National Guard States 

and Territories submit the data and how complete their data are. While the 

National Guard Bureau cannot force States and Territories to comply with

the reporting requirements, at the very least it must be transparent a

the completeness of the data that it provides to OSD. Without such 

Page 41 GAO-10-254 Military Recruiting
 

transparency from the National Guard Bureau, OSD will not be able t

meaningfully analyze recruiter irregularity trends across the service 

o 

components and identify areas where corrective action may be needed. 

mend that the Secretary of Defense take the following four 

actions: 

 for 

 recruiter irregularity data throughout all 

irect the Under Secretary of Defense for Personnel and Readiness to: 

on 

ruiter 

rency in the 

e 

 the basis of the 

National Guard data for the Congress and others. 

f 

h. 

e 

inue 

lished 

 for 

Military Recruiting

We recom Recommendations

Executive Action 

1. direct the Secretaries of the Army and Navy to identify mechanisms

the regular sharing of the

levels of command, and 

2. d

• complete and issue the instruction on tracking and reporting data 

recruiter irregularities to clarify the requirements for the types of 

recruiter irregularities to be reported and the placement of rec

irregularity cases and actions taken into reporting categories; 

• direct the relevant offices within the National Guard Bureau to adjust 

their reporting procedures in ways that will provide transpa

data reported to OSD and any limitations on the data; and 

• include the appropriate disclosures concerning data limitations in th

recruiter irregularity reports that OSD produces on

In written comments on a draft of the report, DOD concurred with each o

our four recommendations. Specifically, DOD stated that it will address 

these recommendations through a DOD instruction that it plans to publis

Regarding our recommendation that the Secretary of Defense direct th

Secretaries of the Army and the Navy to identify mechanisms for the

regular sharing of recruiter irregularity data throughout all levels of 

command, DOD stated that the sharing of these data already occurs, and

that the Army and the Navy have clarified their reporting processes. We

agree that the service components have made progress in establishing 

systems that have allowed for more consistent tracking and reporting of 

the recruiter irregularity data, and our report highlighted instances of such

data being shared within the service components. However, we cont

to believe that in order for commanders to continually evaluate and 

improve their recruiting operations, processes must be in place for the 

regular flow of such information. DOD said that its soon-to-be-pub

instruction will require the service components to formalize their

processes for disseminating the recruiter irregularity data to the 

appropriate levels of command. We believe that these formal processes

will constitute an important step in ensuring that recruiter irregularity 

information is shared in a consistent and timely manner. DOD also agreed 

Agency Comments 

and Our Evaluation 

Page 42 GAO-10-254 
 

with our recommendations that the Secretary of Defense direct the Und

Secretary of Defense for Personnel and Readiness to (1) complete and 

issue the instruction on tracking and reporting recruiter irregularity dat

that clarifies the reporting requirements, (2) direct the relevant offices 

within the National Guard Bureau to adjust their reporting procedures in 

order to provide greater transparency in the data reported, and (3) in

the appropriate disclosures concerning any limitations in the data it 

receives. DOD said that it decided to wait to issue the instruction until this 

GAO study is complete, in order to incorporate our recommendatio

that it plans to publish the instruction during fiscal year 2010 after 

reconvening representatives from the service components to discuss t

reporting processes and procedures for the tracking and reporting of 

recruiter irreg

er 

a 

clude 

ns, and 

heir 

ularity data. DOD’s comments in their entirety appear in 

appendix IV. 

ir 

be 

available at no charge on GAO’s Web site at http://www.gao.gov. 

e 

e 

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

report are listed in appendix V. 

Brenda S. Farrell, Director 

nagement 

We are sending copies of this report to interested congressional 

committees; the Secretaries of Defense, the Army, the Navy, and the A

Force; and the Commandant of the Marine Corps. This report will 

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

at (202) 512-3604 or by e-mail at farrellb@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on th

Defense Capabilities and Ma

Page 43 GAO-10-254 Military Recruiting
Appendix I: Scope and Methodology Appendix I: Scope and Methodology 

For this review, we analyzed recruiter irregularities across all of the 

service components: the Army and Army Reserve, the Navy and Navy 

Reserve, the Marine Corps and Marine Corps Reserve, and the Air Force 

and Air Force Reserve. In addition, we analyzed recruiter irregularities in 

the Army National Guard and the Air National Guard. For the purposes of 

this review, the term recruiter irregularity is defined according to the 

memorandum issued by the Office of the Secretary of Defense (OSD) as 

those willful and unwillful acts of omission and improprieties that are 

perpetrated by a recruiter or alleged to be perpetrated by a recruiter to 

facilitate the recruiting process for an applicant. 

To conduct our work, we examined relevant guidance issued by OSD, the 

service components, the Army National Guard, and the Air National 

Guard; reviewed and analyzed data on recruiter irregularities reported by 

the service components to OSD from fiscal year 2006 through fiscal year 

2009; and reviewed reports issued by GAO and the Department of Defense 

(DOD) related to recruiting and recruiter irregularities, including surveys 

conducted by DOD on recruiters’ quality of life across the service 

components.1

 In addition, we conducted a case file review of all 

substantiated cases of recruiter irregularities reported by the service 

components for fiscal year 2008, and a case file review of all substantiated 

cases of recruiter irregularities reported by seven States on recruiter 

irregularities committed by recruiters in the Army National Guard for 

fiscal year 2008.2

 We interviewed OSD officials in the Washington, D.C. 

metropolitan area and conducted site visits to service components’ 

recruiting commands and the Military Entrance Processing Command 

(MEPCOM) to interview recruiting command officials and recruiters from 

all the service components. We selected our interviews with 24 recruiters 

using a nonprobability convenience sample to accommodate our 10 site 

visits.3

 In the course of our work, we contacted or visited the 

organizations and offices listed in table 9. 

 

1

Joint Advertising, Market Research and Studies, 2008 Recruiter Quality of Life Survey 

Topline Report (August 2008); and Joint Advertising, Market Research and Studies, 2005 

Recruiter Quality of Life Survey Topline Report (February 2006). 

2

The Air National Guard was excluded from the case file review as they had reported zero 

recruiter irregularities for fiscal year 2008 at the time of our case file review. The Air 

National Guard later reported two recruiter irregularities for fiscal year 2008 after the case 

file review had been completed. 

3

Out of the 24 recruiters that we interviewed, 8 held supervisory positions, such as 

recruiting station commander and flight chief. 

Page 44 GAO-10-254 Military Recruiting 
Appendix I: Scope and Methodology 

Table 9: Organizations and Offices Contacted 

Name of organization or office Location 

Air Force 

Air Force Recruiting Service Randolph Air Force Base, TX 

Air Force Recruiting School Lackland Air Force Base, TX 

Air Force 369th Recruiting Group Lackland Air Force Base, TX 

Air Force 341st Recruiting Squadron Lackland Air Force Base, TX 

Air Force Recruiting B-Flight San Antonio, TXa

Air Force Recruiting Stations Schaumberg, IL 

 Louisville, KY 

 Mira Mesa, CA 

 Washington, D.C. 

Air Force Reserve 

Air Force Reserve Command Recruiting Service Warner Robins, GA 

Air Force Reserve Recruiting Station San Antonio, TX 

Air National Guard 

National Guard Bureau–Air National Guard Recruiting and Retention Service Arlington, VA 

Air National Guard Recruiting Station 149th Fighter Wing Lackland Air Force Base, TX 

Army 

Army Recruiting Command Fort Knox, KY 

Army Recruiting and Retention School Fort Jackson, SC 

Army 1st Recruiting Brigade Fort Meade, MD 

Army 3rd Medical Recruiting Brigade Fort Knox, KY 

Army Baltimore Recruiting Battalion Fort Meade, MD 

Army Recruiting Stations Elizabethtown, KY 

 Lemon Grove, CA 

 Radcliff, KY 

 Washington, D.C. 

 Chicago, ILa

Army National Guard 

National Guard Bureau–Army National Guard Strength Maintenance Division Arlington, VA 

Army National Guard Strength Maintenance Training Center Little Rock, AR 

Illinois Army National Guard, Recruiting Chicago, ILa

Army National Guard Recruiting Station Chicago, ILa

Marine Corps 

Marine Corps Recruiting Command Quantico, VA 

Marine Corps Recruiters School San Diego, CA 

Page 45 GAO-10-254 Military Recruiting
Appendix I: Scope and Methodology 

Name of organization or office Location 

Marine Corps Western Recruiting Region San Diego, CA 

12th Marine Corps Recruiting District San Diego, CA 

4th Marine Corps Recruiting District New Cumberland, PA 

Marine Corps Recruiting Stations Frederick, MD 

 San Diego, CA 

Marine Corps Recruiting Substations Louisville, KY 

 Chicago, ILa

 Poway, CA 

 Washington, D.C. 

Navy 

Navy Recruiting Command Millington, TN 

Navy Recruiting Command, Recruit Quality Assurance Team Great Lakes, IL 

Navy Recruiting District Chicago North Chicago, IL 

Navy Recruiting Stations Escondido, CA 

 Louisville, KY 

 Washington, D.C. 

National Guard Bureau 

Office of the Chief Counsel Arlington, VA 

Office of the Secretary of Defense 

Office of the Under Secretary of Defense for Personnel and Readiness Washington, D.C. 

Military Entrance Processing Command North Chicago, IL 

Military Entrance Processing Stations Fort Meade, MD 

 Des Plaines, IL 

 Louisville, KY 

 San Diego, CA 

Source: GAO. 

a

For cases where we interviewed recruiters away from their recruiting station location, the 

metropolitan location is indicated. 

To assess the number and types of recruiter irregularities occurring in the 

service components, we obtained and reviewed recruiter irregularity data 

reported by the service components to OSD from fiscal year 2006 through 

fiscal year 2009, and the service components’ accessions data for the same 

time period. We were unable to present trends in recruiter irregularities 

from fiscal year 2006 through fiscal year 2009 and decided not to present 

data for fiscal year 2009 because (1) the memorandum issued by OSD in 

December 2006 required the service components to retroactively collect 

recruiter irregularity data for fiscal year 2006 to report to OSD, which may 

have resulted in the fiscal year 2006 data being less complete than the data 

Page 46 GAO-10-254 Military Recruiting
Appendix I: Scope and Methodology 

in subsequent fiscal years and (2) recruiter irregularity data reported by 

the service components for fiscal year 2009 do not include data from the 

fourth quarter of the fiscal year, which will not be reported until January 

2010. We interviewed officials within the Army National Guard Strength 

Maintenance Division and the Air National Guard Recruiting and Retention 

Service about their data system for tracking and maintaining recruiter 

irregularity data and determined that these data were not reliable. 

Specifically, we were unable to present data on recruiter irregularities 

reported by the National Guard because recruiter irregularity data are 

maintained at the state level of command and we did not review each 

state’s processes and procedures for collecting and maintaining these data. 

Furthermore, while some States and Territories reported their recruiter 

irregularity data to the Army National Guard Strength Maintenance 

Division and the Air National Guard Recruiting and Retention Service 

within the National Guard Bureau in accordance with the memorandum, 

others did not consistently report their data or did not report them at all. 

In addition, we assessed the reliability of each service component’s 

recruiter irregularity data system, including the systems’ ability to track 

and maintain recruiter irregularities. For each service component, we also 

interviewed personnel responsible for maintaining and overseeing these 

data systems. Additionally, we assessed the quality control measures in 

place to ensure that the data are reliable for reporting purposes. We found 

the recruiter irregularity data reported by the service components to be 

sufficiently reliable for the purposes of this review. 

To provide illustrative examples of the types of recruiter irregularities that 

occur across the service components and the actions taken against 

recruiters involved in recruiter irregularities, we conducted a case file 

review of all substantiated cases of recruiter irregularities reported by 

each of the service components and closed in fiscal year 2008. We 

reviewed a total of 346 case files for all the service components: Air Force 

(16), Air Force Reserve (7), Army (138), Army National Guard (53), Marine 

Corps (69), and Navy (63). The number of case files that we reviewed for 

fiscal year 2008 did not always reflect the total number of cases reported 

to OSD for the same year because some cases may have been closed and 

reported to OSD following our review of the case files. Although we 

included the Army National Guard in our case file review, we selected a 

nongeneralizeable sample of States for our case file review because the 

National Guard Bureau does not maintain centralized data on cases of 

recruiter irregularities. We selected States that reported more than four 

substantiated recruiter irregularities for fiscal year 2008. These States and 

their corresponding number of substantiated cases of recruiter 

irregularities as reported for fiscal year 2008 are: Alabama (10), California 

Page 47 GAO-10-254 Military Recruiting
Appendix I: Scope and Methodology 

(20), Indiana (7), Minnesota (6), Oklahoma (8), Pennsylvania (5), and 

Wisconsin (7).4

To assess the extent to which the service components have guidance in 

place to identify and address recruiter irregularities, we reviewed the 

guidance issued by the service components on recruiter irregularities and 

their procedures for reporting allegations, conducting investigations, and 

adjudicating cases of recruiter irregularities within the recruiting 

commands. We interviewed recruiting command officials and recruiters 

from the service components to gain their perspective on the causes of 

recruiter irregularities, the guidance in place to address them, and training 

and prevention programs aimed at reducing them. We also obtained their 

views on the fairness of the actions taken against recruiters as a result of 

their involvement in recruiter irregularity incidents, the deterring effect of 

those actions taken, and the consistency with which actions are applied. 

To determine the extent to which the relevant offices within the National 

Guard Bureau maintain oversight over recruiter irregularities occurring in 

the Army and Air National Guards, we examined the guidance issued by 

the Army National Guard Strength Maintenance Division and the Air 

National Guard Recruiting and Retention Service. However, we did not 

review National Guard guidance issued by the 54 individual National 

Guard States and Territories due to time and staffing limitations. 

To assess the extent to which OSD maintains oversight of recruiter 

irregularities occurring across the service components, we reviewed the 

December 2006 memorandum issued by OSD that requires each service 

component to submit a semiannual report to OSD on recruiter 

irregularities. We conducted interviews with officials from OSD’s Office of 

the Under Secretary of Defense for Personnel and Readiness, as well as 

officials from MEPCOM and 4 military entrance processing stations. We 

also interviewed service component officials to obtain their perspective on 

the memorandum and their experiences in addressing the reporting 

requirements it sets forth. We also interviewed OSD and National Guard 

officials on reporting issues within the National Guard. 

 

4

Although the total number of substantiated recruiter irregularities reported by these States 

was 63 in fiscal year 2008, we received and reviewed 53 case files. This is because in some 

case files, there was more than one recruiter involved in the recruiter irregularity incident. 

While the service components may maintain a single case file for a case involving multiple 

recruiters, they report to OSD on each individual recruiter who committed or was alleged 

to have committed a recruiter irregularity. 

Page 48 GAO-10-254 Military Recruiting
Appendix I: Scope and Methodology 

We conducted this performance audit from February 2009 through January 

2010 in accordance with generally accepted government auditing 

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

obtain sufficient, appropriate evidence to provide a reasonable basis for 

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

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on our audit objectives. 

Page 49 GAO-10-254 Military Recruiting
Appendix II: Examples of Recruiter Appendix II: Examples of Recruiter Irregularities in Fiscal Year 2008 

Irregularities in Fiscal Year 2008 

Table 10 provides examples that we identified in the course of our review 

of the service components’ files of recruiter irregularities for fiscal year 

2008—in addition to those provided in table 6 of this report—illustrating 

each recruiter irregularity category in the Office of the Secretary of 

Defense’s memorandum. 

Table 10: Examples of Substantiated Recruiter Irregularities by Type, Fiscal Year 2008 

Recruiter irregularity category Example 

A recruiter became aggressive with a recruit and engaged in a verbal altercation with 

the recruit’s boyfriend (Navy). 

Criminal misconduct 

A recruiter committed multiple irregularities, which included sexually harassing a recruit 

and high school students, meeting with female recruits without adequate supervision, 

influencing a recruit to lie to recruiter irregularity investigators, and failing to safely 

transport applicants in a government vehicle (Army). 

A recruiter consumed alcohol with applicants and engaged in inappropriate sexual 

conduct (Air Force). 

Sexual misconduct 

A recruiter engaged in a sexual relationship with a 16 year-old applicant (Marine 

Corps). 

A recruiter inappropriately touched a recruit while taking an unsupervised body fat 

measurement of the recruit (Navy). 

Sexual harassment 

A recruiter made sexually suggestive comments to an applicant (Marine Corps). 

A recruiter visited an applicant’s home twice without supervision and kissed the 

applicant (Army National Guard). 

Fraternization or unauthorized relationship 

with an applicant 

A recruiter purchased alcohol for an underage recruit and consumed it with him 

(Marine Corps). 

Concealment or falsification A recruiter falsified the results of a required physical fitness test for two recruits (Army). 

A recruiter withheld medical documents from an applicant’s application packet; the 

applicant had been previously temporarily disqualified from service for a hairline 

fracture (Air Force). 

A recruiter employed a false document and an individual who impersonated a Navy 

officer to falsely assure a recruit that the recruit would be able to change her military 

occupation upon her arrival at basic training (Navy). 

False promise/coercion 

A recruiter conducted himself inappropriately with a recruit who expressed a reluctance 

to ship to basic training before he had cleared up a family issue (Army). 

A recruiter arranged for another individual to take the ASVAB for a recruit (Army 

National Guard). 

Testing irregularity 

A recruiter provided a recruit with an unauthorized ASVAB study guide (Marine Corps). 

A recruiter was found to have in his possession a template of a child custody form, 

despite this being a violation of Army regulations (Army). 

Quality control measures 

A recruiter authorized the enlistment of a recruit who was subsequently disqualified at 

the MEPS for testing positive on a drug test (Air Force Reserve). 

Source: GAO analysis of recruiter irregularity case files provided by the service components. 

Page 50 GAO-10-254 Military Recruiting 
Appendix III: Examples of Dispositions in Appendix III: Examples of Dispositions in Fiscal Year 2008 

Fiscal Year 2008 

Table 11 provides examples that we identified in the course of our review 

of the service components’ files of recruiter irregularities for fiscal year 

2008—in addition to those provided in table 8 of this report— illustrating 

the violation disposition categories set out in the Office of the Secretary of 

Defense’s memorandum. 

Table 11: Examples of Dispositions, Fiscal Year 2008 

Disposition category Example 

For engaging in an intimate relationship with an applicant, a recruiter was court-martialed, 

reduced in rank, confined for 30 days, given 30 days of hard labor, and made to forfeit 

$1,000 per month for 3 months (Air Force). 

Court martial/civil conviction 

For providing a recruit with the answers to the ASVAB, a recruiter was court-martialed, 

reduced in rank, and discharged with an “other than honorable discharge” (Army). 

For submitting false high school diplomas in order to fraudulently enlist five recruits who 

did not meet minimum educational enlistment qualifications, a recruiter was removed from 

service (Marine Corps) 

Removed from service 

For instructing two recruits to conceal their criminal records at their MEPS processing, a 

recruiter was removed from service (Navy). 

For allowing a recruit to use his government vehicle and government credit card, a 

recruiter was removed from recruiting duty (Marine Corps). 

Removed from recruiting 

For falsifying high school verification letters for five applicants, a recruiter was removed 

from recruiting (Army). 

For falsifying information about references on a recruit’s background investigation forms, a 

recruiter received article 15 Non-Judicial Punishment, whereby he was reduced in rank, 

made to forfeit $500 per month for 2 months, and reprimanded (Air Force). 

Article 15 Non-Judicial Punishment 

For forging multiple signatures in a recruit’s application packet, a recruiter received article 

15 Non-Judicial Punishment, whereby he was reduced in rank and made to forfeit half of 

one month’s pay for 2 months (Navy). 

For allowing a recruit to ship to basic training despite the recruit having an unresolved 

criminal violation on her record, a recruiter received a letter of reprimand from his recruiting 

battalion commander (Army). 

Adverse administrative action 

For failing to perform an adequate medical pre-screening of recruits, a recruiter received a 

letter of reprimand from his recruiting squadron commander (Air Force). 

Non-adverse administrative action For enlisting an applicant who was not eligible for enlistment, a recruiter received 

counseling. (Army National Guard). 

For failing to properly question an applicant, and thus failing to uncover that the applicant 

had not completed a legal probation sentence, a recruiter was judged to have committed a 

recruiter error (Army). 

Administrative or processing error 

For failing to conduct an initial fitness test for a recruit, a recruiter was judged to have 

committed a recruiter error. (Navy) 

Source: GAO analysis of recruiter irregularity case files provided by the service components. 

Page 51 GAO-10-254 Military Recruiting
Appendix IV: Comments from the Department Appendix IV: Comments from the of Defense 

Department of Defense 

Page 52 GAO-10-254 Military Recruiting
Appendix IV: Comments from the Department 

of Defense 

Page 53 GAO-10-254 Military Recruiting
Appendix IV: Comments from the Department 

of Defense 

Page 54 GAO-10-254 Military Recruiting
Appendix V: 

A

GAO Contact and Staff 

cknowledgments 

Page 55 GAO-10-254 

Appendix V: GAO Contact and Staff 

Acknowledgments 

Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov. 

In addition to the contact above, Elizabeth McNally, Assistant Director; 

Natalya Barden; Seth Carlson; K. Nicole Harms; Joanne Landesman; 

Katherine Lenane; Amber Lopez; Steven Putansu; Terry Richardson; and 

Daniel Webb made key contributions to this report. 

 Military Recruiting 

GAO Contact 

Staff 

Acknowledgments 

(351327) 
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