Military Dependent Students: Better Oversight Needed to Improve Services for Children with Special Needs
Published: 2012-09-10T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: DOD operates a worldwide school system to meet the educational needs of military dependents. Questions have arisen about whether DOD is meeting the special needs of some of these children, such as those with learning disabilities. In response to a mandate in the National Defense Authorization Act for Fiscal Year 2011, GAO reviewed (1) how DOD provides special education services; (2) how DOD entities coordinate to assign families overseas and how schools might be affected; (3) what challenges, if any, families face in accessing DOD services for their children with special educational needs and obtaining related information; and (4) what steps, if any, DOD is taking to enhance screening and overseas assignment for families with children with special educational needs. GAO reviewed relevant federal laws and regulations, analyzed DOD documents and data, and conducted interviews with officials from multiple DOD entities, including schools. GAO also held 22 focus groups with parents of children with special needs during site visits and phone interviews at eight military installations worldwide.
section_title: What GAO Found
paragraphs: The Department of Defense (DOD) provides special education services through a complex system that varies by location. Domestically, DOD provides special education mainly within DOD schools. In contrast, DOD schools overseas vary in the types and levels of disabilities they are readily equipped to serve. For example, DOD schools in Ramstein, Germany, are equipped to serve children with severe disabilities of any type, whereas schools in some other overseas installations have no pre-established special education programs of any kind.
Overseas assignment of servicemembers with children with special educational needs requires coordination between the military branches through their Exceptional Family Member (EFM) programs and the DOD Education Activity--the office that oversees education of military dependent children in DOD schools. Each branch implements its own processes for screening military families and assigning servicemembers to locations where there are school services that can meet their families' needs. However, impediments to effective placements may strain school resources. More specifically, ineffective screenings may result in families being placed in locations where schools are not readily equipped to serve certain needs. For example, we found one case in which a school that only had programs in place for students with mild disabilities received a student with severe needs who had not been educationally screened.
Families in many of GAO's focus groups were generally satisfied with the services DOD provided their children with special needs once they received them, but they felt that the limited availability of special education and medical specialists overseas presented challenges. Some parents were concerned their children were not receiving all the services they needed, partly due to difficulties DOD schools encounter hiring and retaining special education staff, especially overseas. While the military branches provide family support services, parents in our focus groups also indicated they lacked information about obtaining special education and related medical services. DOD is taking some steps to provide better information to families, but the extent to which these efforts are helping them is unclear.
DOD's recently established Office of Special Needs (OSN) is responsible for enhancing and monitoring support for military families with special needs. OSN and the military branches have initiated efforts to improve screening and overseas assignment of military families with special needs. However, it is unclear when some of these efforts will be completed. Moreover, while OSN was established in part to enhance and monitor the military branches' support for families with special needs, it has limited enforcement authority and oversight over the branches' EFM programs. Specifically, it is limited in the extent to which it can compel the branches to comply with DOD or service-level program requirements, and it has no direct means by which to hold them accountable if they fail to do so. In addition, DOD currently lacks agencywide benchmarks and performance goals for all components of the EFM program. As a result, it cannot assess the effectiveness of the branches' EFM programs and ensure that improvements are made when needed. Without overall performance information to proactively identify emerging problem areas, some of the branches have had to conduct investigations to address problems after they have arisen.
section_title: What GAO Recommends
paragraphs: GAO recommends that the Secretary of Defense (1) ensure the military branches medically and educationally screen all school-age children before relocation overseas; (2) direct OSN to establish benchmarks and performance goals for the EFM program; and (3) direct OSN to develop and implement a process for ensuring the branches' compliance with EFM program requirements. DOD generally agreed with the recommendations.

section_title: Letter
paragraphs: Military families who have children with special needs, such as  communication impairments or learning disabilities, face a unique set of  challenges, in part due to their frequent moves within the United States   Recent executive branch, congressional,  and to overseas installations.and advocacy group initiatives have focused on increasing support for  these families. For example, in 2011 the White House issued a report  making the care and support of military families a top national security  policy priority, including ensuring excellence in military children’s  education and development.
About 12 percent of the approximately 85,000 children enrolled in  Department of Defense (DOD) schools worldwide received special  education services in the 2011-12 school year, and over half of these  students were in schools overseas. education and related services for children with disabilities who attend  DOD schools, as prescribed in the Individuals with Disabilities Education  Act (IDEA).
DOD is required to provide special  Given the important role DOD schools play in serving highly mobile  military families, questions have arisen regarding whether DOD is  meeting the complex needs of students with special needs.
Data are as of January 2012. to a mandate in the Senate report accompanying the National Defense  Authorization Act (NDAA) for Fiscal Year 2011, GAO examined (1) how  DOD provides special education services; (2) how DOD entities  coordinate to assign servicemembers accompanied by their families to  overseas locations and how schools might be affected; (3) what  challenges, if any, families face in accessing DOD services for their  children with special educational needs and obtaining related information;  and (4) what steps, if any, DOD is taking to enhance assignment  coordination for servicemembers who have children with special  educational needs.
To address these questions, we reviewed relevant federal laws and  regulations and analyzed DOD policy and guidance documents. We also  obtained data from the DOD Education Activity (DODEA)—the office that  oversees the education of military dependent children in DOD schools— on the number and characteristics of students in DOD schools receiving  special education services in the United States and overseas, as well as  quantitative and qualitative data on educational screenings and family  assignment concerns. We determined these data to be reliable for the  purpose of describing the population of children with disabilities in DOD  schools and reporting information about screenings and assignment  concerns. We conducted site visits to five military installations in Europe  and two in the United States, as well as telephone interviews with agency  officials at one military installation in the Pacific. We selected these  locations based on several criteria, including the number of children with  disabilities enrolled in DOD schools, the level of special education  services schools were equipped to provide, variation in urban and remote  areas, and variation among the four military branches. During our site  visits and Pacific teleconference, we conducted meetings with officials  from 15 schools and held 22 focus groups with the parents of students  receiving special education services to discuss their perceptions of the  services their children have received. While the results of these focus  groups cannot be generalized to all parents of children with disabilities,  nor are they representative of the population of parents, common  responses across groups and recurring themes provide some degree of  validation. We also interviewed DODEA officials in the United States and  overseas, including district and school officials, such as principals, special  education coordinators, and teachers. In addition, we interviewed officials  from DOD’s Office of Special Needs (OSN), the military branches, subject  matter experts, and advocacy groups. Finally, we met with  representatives from other DOD entities, including the military branches’  Educational and Developmental Intervention Services (EDIS) and the  Exceptional Family Member (EFM) programs involved in screening and  supporting this population. Appendix I provides a detailed description of  our scope and methodology.
We conducted this performance audit from May 2011 through September  2012 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
subsections: section_title: Background
subsections: section_title: DOD Schools and Students with Disabilities
paragraphs: DOD operates a worldwide school system to meet the educational needs  of military dependent students and others, such as the children of DOD’s  civilian employees overseas. DODEA oversees the management and  operation of 196 schools in seven states; Puerto Rico and Guam; and 12  foreign countries. DODEA has organized its schools into three areas—the  United States, Europe, and the Pacific—and multiple districts within each  area. About 66 percent (130 of 196) of DOD schools are located overseas  serving about 68 percent of the student population (approximately 58,000  of 85,000 children) (see fig. 1). The overseas schools are mainly  concentrated in Germany and Japan, where the United States built  military installations after World War II. Almost all the domestic schools  are in the southeastern United States.
DOD schools provide a comprehensive kindergarten through 12th grade  curriculum.students received special education services in the 2011-12 school year.
Approximately 12 percent (or about 10,200 students) of all  As of January 2012, the most prevalent disabilities among children  enrolled in DOD schools were communication impairments (such as  speech and language impairments), specific learning disabilities, and  developmental delays, cumulatively representing about 71 percent of this  population (see fig. 2). Appendix II provides DOD’s categories and  definitions of disabilities. While some children may have more than one  type of disability, DODEA bases its criteria for determining eligibility for  receiving special education services on the primary type of disability that  has the greatest educational impact.
Although DOD schools do not receive IDEA funding, DOD is required to  provide in its educational programs the substantive rights, protections,  and procedural safeguards for students with disabilities under IDEA.Specifically, DOD is required to provide these children early intervention  services, and special education and related services. For children ages 3  to 21, this includes identifying and evaluating eligible children; developing  and implementing an individualized education program (IEP) for such  students (see fig. 3); and providing the students special education and  related services.programs—are responsible for providing selected related services as well  as completing evaluations for certain disabilities, such as autism or visual  or hearing impairments, that may require medical expertise.
section_title: DOD Provides Special Education Services through a Complex System That Varies by Location
paragraphs: Like public schools in the United States, DOD is required to provide  special education and related services necessary to meet the unique  needs of eligible students. As needed, DOD schools provide special  education services in all schools worldwide and related services (such as  occupational and physical therapy) in its domestic schools only.  Overseas, each branch’s medical department provides related services to  eligible students through its EDIS program. A child with a disability may  receive services from some or all of the DOD entities shown in figure 4,  depending on the family’s location.
Services for children with disabilities in DOD schools may include  consultation by special educators to general classroom teachers or  instruction in a special education classroom for part or all of the school  day. In addition to special and general education teachers, DOD schools  employ paraprofessionals—who assist and support teachers— and  specialists, such as speech and language therapists. DOD schools in the  United States also provide related services, such as physical and  occupational therapy.
The military branches’ medical departments provide different types of  services for children with disabilities through their EDIS programs. EDIS  helps identify children with disabilities and delivers early intervention  services to eligible infants and toddlers, from birth through age 2. EDIS  also provides medical assessments necessary to determine children’s  eligibility for special education services. For example, in order to provide  special education services for children with emotional impairments or  autism spectrum disorders, DODEA requires medical evaluations and  diagnoses by qualified medical professionals, such as developmental  pediatricians, psychologists, or psychiatrists. Although military families  may use civilian providers in the United States, when stationed overseas,  only military providers may provide these diagnoses for children attending  DOD schools. Overseas, EDIS also provides related services for children  enrolled in DOD schools.
Domestic DOD schools provide special education for all types and levels  of disabilities, mainly within DOD schools. However, according to DOD, in  certain cases students may receive services from external service  providers that DOD contracts with or they may be placed in local public  schools. Overseas, the military branches and DODEA have implemented  a system of specific, pre-established programs for different types of  disabilities and levels of services in each school. For example, schools in  Ramstein, Germany, have programs designed to serve children with all  types of disabilities, whereas schools in Iwakuni, Japan, have programs  that serve only a few types of disabilities, and the Seville Elementary  School in Spain has no programs for any type of disability. Agency  officials explained that this variation is a function of the size of the military  community and the needs of the military. To help facilitate intra-agency  communication about these differences, DOD developed a directory that  indicates which pre-established programs are available in each school  overseas. (See figure 5 for an excerpt of this directory.)
Moreover, DOD schools provide different levels of service for each type of  disability, as indicated by the circles in the DOD directory excerpt shown  in figure 5. For example, Garmisch Elementary School in Germany has a  program to provide services in the general education classroom for  children with the mildest forms of specific learning disabilities. In contrast,  Naples Elementary School in Italy is equipped to provide individualized  instruction in a separate classroom setting for children with the most  severe types of specific learning disabilities. Schools in Ramstein,  Germany, are equipped to serve children with severe disabilities of any  type. Nonetheless, consistent with IDEA requirements, it is DOD policy  that all schools must provide special education services to all students  with such needs, regardless of the types or severity of students’ needs or  the school’s location.
section_title: Military Branches Screen Families and Consult with DODEA to Assign Families to Overseas Locations, but Ineffective Processes May Strain School Resources
subsections: section_title: Military Branches’ Processes to Coordinate Overseas Assignment of Servicemembers with Families with Special Needs Are Not Always Effective
paragraphs: Because DOD schools in overseas communities are designated to serve  children with certain types and levels of disabilities, the military branches  and DODEA are required to coordinate the overseas assignment of  servicemembers with families with special needs, including all children  with IEPs. All family members who are seeking a move overseas must  be screened by the relevant branch’s medical department for medical and  educational needs in addition to other factors that might inhibit travel  overseas, such as financial problems. If the medical screening identifies  an EFM program-enrollable condition, the servicemember is referred for  EFM program enrollment.
Each branch implements its EFM program differently, and the branches’  screening and assignment coordination processes also vary somewhat.  Generally, through a process referred to as EFM program assignment  coordination, the servicemember’s personnel office coordinates with the  medical department to verify the availability of medical services in the  planned location overseas. During this process, the military branch is also  required to coordinate with DODEA about the educational programs  available. DODEA makes a recommendation based on the services  available at the schools, and the branch’s medical department makes a  recommendation about the availability of medical services. The military  branch then determines whether the servicemember and his or her family  should proceed to the planned location. Depending on the  recommendations of both medical and educational reviewers, the  servicemember may be approved for travel accompanied by family  members, recommended to relocate to a different location, or allowed to  take an unaccompanied tour. However, according to DODEA and one  branch’s military officials, the installation’s command personnel may  override a recommendation for an unaccompanied tour and allow the  servicemember to bring the family if he or she has special skills that are  needed at an installation.
Each year, some military families with children with special educational  needs are sent to locations that are not prepared to serve their children’s  needs upon arrival. This may occur either due to a “screening failure”  (i.e., when an educational screening did not occur) or an “assignment  concern” (i.e., when the family was screened but the child was  nonetheless enrolled in a school unequipped to meet his or her needs).  DODEA records the number of screenings completed and assignment  concerns, as well as the reasons for such concerns. DODEA data show  that since school year 2008-09, there have been 93 instances when  children were educationally screened, but still arrived at a school that did  not have programs in place to meet their needs. This may have  occurred because (1) the student’s needs were more severe than the  educational or medical screening indicated, (2) the military overrode  DODEA’s assignment recommendation, or (3) the servicemember was  approved for one location but was reassigned to another. Moreover,  several DODEA and school officials we interviewed confirmed that a  number of children with special educational needs who were not  screened have enrolled in their schools. For example, school officials in  Naples said that a few years ago, the school received 44 incoming  students with IEPs, but only four of those students had been  educationally screened through the EFM program. According to OSN  officials, schools are generally able to accommodate children with mild  disabilities regardless of the location, and such cases would not be  recorded as assignment concerns. However, DODEA officials overseas  also stated that when children with severe disabilities are sent to locations  that do not have appropriate pre-existing programs, even a very small  number of these cases can require substantial additional resources.  According to a Navy EFM program official at an installation we visited,  screening and assignment coordination failures could cost the military up  to $100,000 per incident.
section_title: Underenrollment and Circumvention of EFM Procedures Hinder Program Effectiveness
paragraphs: Although all four branches require EFM program enrollment for eligible  servicemembers, underenrollment in and circumvention of EFM programs  were cited repeatedly as concerns during our interviews and site visits.  Senior OSN officials estimated that about half the families with children  with special needs who are eligible to enroll in the EFM program have not  done so. They attributed underenrollment to several factors, including that  some families having children with very mild disabilities may think they  are not eligible for the program or may not be aware it exists. DODEA’s  Europe area and military officials at three of the eight installations  included in our study explained that more families are eligible to enroll in  EFM programs than have done so. OSN and military officials at three  installations also explained that families with special needs may not  realize they are required to enroll in EFM programs. DOD officials also  explained that a family might be using an off-base medical provider who  is not aware of the program. An EFM program official from one installation  added that families who rarely relocate may not understand why it is  important to enroll. Another EFM program official from a different  installation acknowledged that more work needs to be done to raise  awareness and enroll families in EFM programs.
Servicemembers may also intentionally circumvent educational screening  and EFM enrollment. More specifically, servicemembers sometimes avoid  identifying their children’s special educational needs by declining special  education services or inaccurately completing relevant forms, according  to DODEA officials in Europe and the Pacific, as well as other DOD  entities we interviewed. Senior OSN officials believe that a fair number of  families intentionally opt not to enroll in the EFM program because some  are concerned that enrollment may adversely affect servicemembers’  careers. They noted that there is a perceived stigma associated with EFM  enrollment among servicemembers. Some servicemembers have also  been known to travel with their families against recommendation and  once on base, request approval from the installation leadership for the  family to stay, according to DODEA and military officials at one  installation. In seven of our focus groups, parents said they felt that  enrolling in EFM would hurt their chances of being assigned to a position  or location they desire. However, DOD policy states that servicemembers  with children with special educational needs should be assigned to  appropriate locations overseas consistent with the needs of the military  and the career of the servicemember. According to senior OSN and  military officials at two installations, EFM enrollment does not limit  servicemembers’ career opportunities. They noted that servicemembers  can accept an unaccompanied tour to the desired location or seek a  different assignment that would better support the family’s needs if the  initially planned location is not suitable.
EFM programs may not be as effective as they could be due to  inconsistent policy enforcement regarding enrollment. DOD policy  provides that a servicemember who fails or refuses to provide the  information required for overseas screening and assignment or knowingly  provides false information may be subject to disciplinary action and  administrative sanctions, including denial of command sponsorship.  However, OSN and military officials we spoke to at two installations  indicated that installation commanders rarely take such disciplinary  actions.
Medical screening failures may also contribute to underenrollment in EFM  programs. More specifically, some special educational needs are  identified when families complete medical screenings for overseas  assignments. However, officials from OSN and a military branch  explained that sometimes these needs are not identified during  screenings, resulting in families not being enrolled in EFM programs. For  example, if a servicemember’s child is diagnosed with autism by a civilian  provider, the military’s overseas screening personnel may not be aware of  it—since, according to officials from this branch and DODEA, they only  have access to records from military hospitals or treatment facilities— unless families disclose this information. Senior DOD officials stated that  they believe such failures are uncommon and have minimal impact on  EFM program enrollment.
In addition, some branches’ EFM programs face administrative  challenges that may contribute to underenrollment of families with special  needs. A military official from one installation observed that EFM program  staff often do not complete the EFM program paperwork or they take a  significant amount of time to do so because other duties take priority. For  example, officials from two installations said that ideally enrollment should  occur within 4 to 6 weeks, but can sometimes take several months for the  process to be completed. Moreover, officials at two installations from one  military branch told us that enrollment forms were not always forwarded to  the receiving installation for review.
section_title: Failures to Screen and Coordinate Assignments May Strain School Resources
paragraphs: When screening and assignment processes are ineffective, students may  arrive at schools that are not immediately equipped to meet their needs.  Officials at some schools we visited told us it can be difficult to  accommodate students whose needs they are not structured to serve.  DODEA district and area office officials concurred, and noted that this is  one of the most significant challenges that schools overseas face. To  meet the needs of students, schools may need to reallocate or increase  staff and other resources, which can be difficult with limited resources.
According to a senior DODEA official, the local district or area  administrative offices will first attempt to shift existing resources to meet  the needs of students. Typically, a school might bus a student to another  location or hire a paraprofessional. However, if necessary, DODEA will  purchase new equipment or hire a teacher, a process that can be lengthy  in some instances. For example, during our review of DODEA’s screening  and assignment concern database, we found one case in which a school  overseas that did not have pre-existing programs in place for students  with severe cognitive disabilities received such a student. The student’s  family had not gone through EFM program screening before the  servicemember’s authorization to travel was approved. Once the child’s  educational records were reviewed, travel was not recommended for the  family, but the family arrived nonetheless. As a result, the school had to  expend additional resources to meet the student’s needs.
In contrast to military personnel, civilian families are not required to enroll  in EFM programs or to undergo medical screenings prior to relocating  overseas. According to DOD officials, under federal law human  resource offices are prohibited from asking civilian employees whether  their family members have certain medical conditions or other special  needs and cannot bar employment or relocation to overseas installations  based on such factors. However, according to DOD policy, DOD human  resource offices are responsible for providing information to civilian  employees regarding the educational and medical services available at  overseas installations, so that the civilian employee or selectee may  make an informed choice regarding whether to accept the overseas  position. DOD human resource offices are also required to provide a point  of contact to answer applicants’ questions.
Officials from two schools we visited also said that because civilian  families do not undergo any systematic screening before transferring  overseas, they tend to have the most severe needs. Senior DOD officials,  however, told us they do not maintain data on whether civilian families  have more severe needs than active duty families. A school official at an  installation in Europe told us that the majority of students with severe  special needs enrolled in schools on that installation are civilians, and that  military dependents with similar needs would have been identified and  likely prevented from transferring there during the screening and  assignment process. According to data provided by DOD, as of January  2012, there were approximately 1,100 children with special needs from  civilian families enrolled in DODEA schools.
section_title: Families Generally Satisfied with Special Education Services, but Face Challenges Obtaining Them
subsections: section_title: Limited Educational and Medical Specialists in Some Locations Pose Challenges for Families, and Schools Struggle to Hire and Retain Staff
paragraphs: Families in 21 out of the 22 focus groups we held told us they were  generally satisfied with the special education services their children  received in DOD schools once they received them. Further, participants in  10 focus groups said that special education services in DOD schools  were superior to those in the non-DOD schools their children had  attended. In fact, one focus group participant in Germany was so pleased  with the special education services her children had received at DOD  schools that she wanted to remain on the installation for several  additional years so her children could graduate from them.
Despite families’ general satisfaction with services once their children  received them, participants in 16 out of 22 focus groups we held reported  facing challenges obtaining these services due to the limited availability of  related service providers available on military installations, particularly  overseas. More specifically, participants in seven focus groups said they  believe that there are shortages of occupational therapists or physical  therapists at certain schools. For example, a parent in one focus group  believed her child was not receiving necessary services as often as she  felt was warranted. In the 2008-09 school year, DODEA issued 285  reports of unavailability of medically related services for military  dependents in the Pacific region due to the number of vacancies at Navy  EDIS clinics and delays in filling positions. According to these reports,  unavailable services included diagnostic evaluations, social work  services, as well as occupational and physical therapy. Since 2009, many  of these cases have been resolved. In school years 2009-10 and 2011- 12, there were 41 reports of unavailability of medically related services.
In addition, participants in six of our focus groups expressed concern with  perceived shortages of paraprofessionals to assist special education  teachers, and participants in four focus groups also stated that they  believed there was high turnover among them. Officials from three  schools we spoke with and DODEA officials from one district indicated  that there are shortages of paraprofessionals or high turnover among  them. The high turnover rate among paraprofessionals can be especially  disruptive for children with special needs, who thrive on consistency,  according to parents in three of our focus groups.
Participants in seven focus groups told us it has been difficult for them to  obtain medical services for their children. Since IEPs require medical  diagnoses for some conditions, limited medical services can directly affect  students’ educational progress. According to DODEA guidelines, certain  impairments require medical reports from appropriate specialists, which  can include developmental pediatricians, psychologists, autism clinicians,  and audiologists, among others. Some school, DODEA, and EFM  program officials we met with confirmed that it can be difficult for families  to obtain medical services on base. For example, while DOD officials told  us that military families have greater access to developmental  pediatricians than civilians, officials at a domestic school we visited said  that waiting lists for developmental pediatricians at the military medical  treatment facilities are so long that families frequently seek care from  private providers. Further, a senior military official at another domestic  installation told us that the local military treatment facility does not have a  permanent developmental psychologist and as a result, some families  have to wait almost 2 months for appointments. In addition, participants in  five focus groups told us it has been difficult for them to obtain a particular  type of autism therapy for their children, especially overseas. For  example, one focus group participant in Germany told us there is a long  waiting list to receive Applied Behavioral Analysis (ABA) therapy in  Germany. While the military does not provide ABA therapy in military  treatment facilities, according to DOD officials, many families have  become accustomed to receiving this service in the United States. Some  DODEA area and school officials we spoke with acknowledged a  shortage of autism specialists overseas.
Moreover, officials from many DOD schools we visited said it is difficult to  fill and retain key positions, including special education teachers,  paraprofessionals, and specialists. When a school needs additional staff  to fill vacant teacher or specialist positions, candidates are first recruited  from the local area. If they cannot be recruited locally, candidates are  hired from the United States through a process that can take several  months. Hiring delays may create staffing challenges for schools, and  they may need to rely on substitutes or reallocate existing staff. For  example, officials from one overseas school said that they began the  school year with long-term substitutes in special education classrooms  because teachers were not yet in place. In addition, officials from the  same school stated that although the school began the process of filling a  projected speech and language therapist vacancy in April 2011, the  position was not filled until late September of that year, several weeks  after the school year had begun. As a result, school officials stated they  had to divide the workload among existing staff and some students  received fewer services in the meantime. Officials from two additional  schools noted their speech and language therapists’ caseloads exceeded  the DODEA standard of 30 to 50 students. Officials from one of these  schools said it is unclear when they will receive another speech and  language therapist to reduce their large caseloads. DODEA area officials  also noted the difficulties in hiring speech and language therapists and  other special education staff. Overall, parents in seven focus groups  stated that they believed their children did not always receive all the  speech and language therapy they needed, and some of these parents  felt that there were shortages of these therapists. Likewise, DODEA  district officials in Europe and a few school officials we spoke with  overseas also acknowledged that hiring and retaining special education  paraprofessionals can be difficult, citing low pay and the fact that the  hiring pool—typically spouses from the local community—is a small and  highly mobile population.
section_title: Families Lack Information about Obtaining Services
paragraphs: The family support components of each of the military branches’ EFM  programs are responsible for supporting military families with special  needs by providing information and referral and nonclinical case  management services. For example, EFM case managers at military  installations may identify families’ needs, provide relevant information and  referrals, assist families in accessing resources, and coordinate among  various resources and services. EFM family support services are  available to all military families with special needs, including those with  children with special educational needs. However, the support military  branches offer through their EFM programs vary. For example, an EFM  program official at an Army installation in Germany told us that every  incoming family is provided informational materials, including those on  special education, and a meeting with a case manager is scheduled to  discuss the family’s needs. In contrast, an EFM program official at a Navy  installation in Italy said that families are expected to reach out to EFM  family support staff to obtain information when they arrive.
School Liaison Officers and DODEA may also provide some information  to families. School Liaison Officers generally support military leadership in  coordinating with and advising parents of school-aged children on all  educational issues. According to a senior DODEA official, DODEA also  provides families information on special education services and  processes, including documents on parental rights and responsibilities  and a special education handbook.
Despite the existing support available and their general satisfaction with  services once receiving them, families in 16 of our 22 focus groups said  they felt the information they received about obtaining services was  insufficient for their needs. Participants in four focus groups noted they  faced challenges navigating DOD’s complex system in order to obtain  special education and medical services. Seventy of the 92 active duty  servicemembers and spouses who attended our focus groups reported  having one or more children enrolled in their respective branch’s EFM  program. While families in three of our focus groups reported they were  satisfied with their respective branches’ EFM programs, parents in 21of  the 22 focus groups told us that the program played little to no role in  helping them learn about or access special education and medical  services. Further, while each of the military branches’ EFM programs  have case managers to assist military families in learning about and  obtaining special education and medical services for their children,  families in seven of our focus groups told us they lacked a central point of  contact to assist them in doing so. As a result, a participant in one focus  group reported feeling “lost” when trying to learn about and access such  services, while another noted feeling “frustrated.” Families in three of our  focus groups indicated they had to be proactive and obtain information on  their own, while participants in three focus groups also stated they  primarily received information from other families with children with  disabilities. In addition, participants in three focus groups were not aware  that the EFM program provided support in learning about or accessing  services. Focus group participants at one installation overseas said they  did not receive any information from EFM programs regarding what types  of special education services and specialists were available on base  before they relocated. Officials at two schools we visited, as well as  military officials at one installation, confirmed that families sometimes face  challenges obtaining information and navigating the system for accessing  special education and medical services.
At the DOD headquarters level, OSN has taken some steps to provide  better information to families and identify their concerns, including  developing outreach and marketing materials and updating website  information on EFM programs for families. For example, OSN has  provided resources to help strengthen education and awareness in the  Army EFM program community. Further, OSN, in collaboration with the  military branches, is in the process of developing online learning modules,  including an overview of the EFM program. OSN has also developed a  reference guide for EFM program case managers to help them access  and network with community support systems. However, the extent to  which these efforts are helping families obtain information and access  services for their children remains unclear.
section_title: DOD Is Taking Steps to Improve EFM Programs, but Limited Oversight Hinders Its Ability to Assess and Ensure Program Effectiveness
subsections: section_title: DOD Has Taken Recent Steps to Improve Screening Processes
paragraphs: OSN and the military branches are taking actions to improve assignment  coordination processes for military families with special needs. These  efforts include, but are not limited to, families with children with disabilities  who require special education services. DOD provided $5 million in fiscal  year 2010 and $10 million in fiscal year 2011 to the military branches,  based on their needs, to hire and train an additional 120 EFM program  family support personnel to assist military families with identifying and  accessing programs and services. The military branches also hired staff  or identified a point of contact at all installations to support military  families with special needs and trained all EFM program family support  staff. As of fiscal year 2012, the branches allocated funding to maintain  these additional staff.
Since its establishment in late 2010, OSN has begun several initiatives to  improve EFM programs, including revising DOD policy to establish  minimum requirements for the three components of the program. OSN is  revising the policy in response to the 2010 NDAA in order to reflect  requirements included in the legislation. Under the new policy, currently in  draft, each military branch will be expected to revise and implement  branch-specific guidance. According to a senior OSN official, the draft  policy will include reporting requirements for the branches, such as the  number of EFM families identified and screened and the number of  assignment concerns. OSN officials indicated the draft policy revisions  are currently undergoing internal review and could take a year or more to  be finalized. OSN is also working with the Council on Accreditation to  develop performance goals for the family support component of the EFM  programs.requirements set forth in the 2010 NDAA. These performance goals are  intended to address the resource and referral aspects of family support  services, among other things.
According to agency officials, this effort is based on the  OSN is also undertaking another initiative, working with a contractor to  conduct an analysis of each branch’s current EFM program databases  and case management systems. According to officials, this analysis is a  first step in a long-term project to determine the feasibility of developing a  joint database that would network all three components of the EFM  program. If a joint database is developed, OSN officials noted that a  range of relevant program officials—including DODEA staff, medical  providers, and EFM case managers—would have access to components  of the joint database to obtain information necessary to assist families  with special needs. As of May 2012, the first phase of the analysis is  complete and provides information on all the information sources and  databases for each of the military branches’ EFM programs, according to  a senior OSN official. As a next step, OSN expects to develop common  definitions and explore ways to merge or network existing databases,  which officials anticipate will be completed by October 2013. However, an  OSN official stated that developing a joint database will require significant  buy-in from each military branch. As such, this process is anticipated to  take several years, according to officials.
section_title: Office of Special Needs’ Oversight of Screening Processes and Family Support Programs Is Limited
paragraphs: Although OSN was established to enhance and monitor the military  branches’ support for military families with special needs, it lacks a strong  oversight role and enforcement authority. Because the military branches  are responsible for implementing and enforcing EFM program  requirements, OSN currently has limited authority to enforce these  requirements if a military branch does not follow or effectively implement  them. According to DOD policy, each military branch is required to  maintain records and report annually to the Deputy Under Secretary of  Defense for Military Community and Family Policy on the current number  of family members identified with special needs and the effectiveness of  its processes for implementing EFM program guidance. However,  officials from at least one branch’s EFM program acknowledged they had  not provided the required reports, and OSN is limited in the extent to  which it can compel them to do so. DOD officials noted that while OSN  does not have direct enforcement authority over the branches’ EFM  programs, high-level responsibility for ensuring compliance with program  requirements rests with the Under Secretary of Defense for Personnel  and Readiness. For example OSN, through the Under Secretary of  Defense of Personnel and Readiness, may submit a report to DODEA or  the secretaries of the military branches citing noncompliance. However,  only the branches have the ability to take corrective action based on such  letters. Further, some DOD officials expressed concern about the lack of  military leadership’s sustained attention and commitment to EFM  programs.
DOD also currently lacks comprehensive agencywide benchmarks and  performance goals with which to measure the effectiveness of the  branches’ EFM programs. As noted previously, OSN is in the process of  developing performance goals for the family support function of the EFM  program in response to requirements set forth in the 2010 NDAA.  However, OSN does not currently have benchmarks and performance  goals for the two other components of the program— identification/enrollment and assignment coordination. Our prior work has  noted that establishing performance goals and measuring progress is a  key element of effective oversight.included performance goals and standards in its EFM program policy.  Specifically, the Air Force’s EFM program instruction includes targets and  benchmarks for relocations due to assignment concerns. For example,  according to these benchmarks, less than 0.5 percent of families who  relocate each calendar year should be relocated again as the result of  unavailable educational or medical services at the initial location. Another  Air Force target stipulates that 5 percent or less of EFM program  reassignments in each calendar year will be due to screening failures.
At least one military branch has  Because DOD currently lacks performance goals and benchmarks, it  cannot assess the effectiveness of the branches’ EFM programs and  ensure that improvements are made when needed. Without overall  performance information to proactively identify emerging problem areas,  some of the branches have only been able to react to specific problems  after they have arisen. For example, entities within the Air Force and  Navy have conducted internal audits or investigations in response to  concerns regarding special education services and EFM programs. In  December 2009, the Inspector General of the Air Force initiated an  investigation of the Air Force’s EFM program in response to complaints  from a number of Air Force families with special needs. The  investigation substantiated many of the complaints from families,  including allegations that installations did not follow required assignment  coordination procedures. As of June 2012, the Air Force has not  determined its plans to respond to the investigation findings. Similarly, in  April 2009, the Naval Audit Service initiated an audit of the Marine Corps’  EFM program. While this audit focused on children’s access to special  education services in public schools in the United States, the Naval Audit  Service identified areas for improvement in the Marine Corps’ oversight  and provision of EFM program services. The Marine Corps concurred  with the audit’s recommendations. As of June 2012, Marine Corps  officials stated that most of the audit’s recommendations have been  addressed. They added that the remaining open recommendations are  related to ongoing efforts currently being implemented, such as those  intended to improve case manager training processes. Finally, in April  2010, the Naval Audit Service initiated an audit of the Navy’s EDIS  program to verify that the program effectively provides special education  services to school-aged children overseas. The audit focused on  services for school-aged children enrolled in the Navy’s EDIS program in  the Mediterranean area. It found that there was inadequate centralized  oversight over local programs as well as inadequate educational  screening for families being assigned to overseas locations. The Navy  Bureau of Medicine and Surgery concurred with the audit’s  recommendations and agreed to take actions to address them with a  target completion date of October 2012.
section_title: Conclusions
paragraphs: In 2011, the Administration made the care and support of military families  a top national security policy priority. In the 2011 White House report, the  heads of 16 executive branch agencies, including the Secretary of  Defense, committed to making the well-being of military families one of  their highest priorities and to improve their access to services and  support. Further, the Administration emphasized the importance of  ensuring that military children are provided a quality education. Due to  their frequent relocations, accessing educational services may be  particularly difficult for military families—especially for those with children  with special educational needs. DODEA and the military branches provide  special education services to eligible families thorough a complex system  that varies by location. While families in our focus groups were generally  satisfied once their children received special education services, they  faced challenges obtaining these services, in part due to the limited  availability of medical and related service providers at overseas  installations. In addition, families may lack sufficient information about  accessing special education and related medical services. The  challenges families and schools face in obtaining and providing special  education services are not unique to DOD schools. However, the  complexity of DOD’s system for providing services—especially  overseas—along with the high mobility of military families is unique.  Consequently, effective overseas assignment and family support  processes are essential for meeting the needs of families with children  with special needs. Impediments to effective assignment coordination,  such as ineffective screening processes, can result in families being  assigned to overseas installations that are unable to readily meet their  children’s educational and medical needs. As such, it is important that the  branches’ screening and assignment processes for children with special  needs are consistently conducted in a thorough manner.
OSN has recently taken some steps to enhance the military branches’  EFM programs. However, it is unclear when some of these efforts will be  completed or if they will be effectively implemented. While OSN was  established in part to monitor the military branches’ support for families  with special needs, it has limited enforcement authority over the  branches’ EFM programs. Specifically, it is limited in the extent to which it  can compel the branches to comply with DOD or service-level program  requirements, and it has no direct means by which to hold them  accountable if they fail to do so. As such, it is important that OSN develop  processes to strengthen its oversight of the branches’ EFM programs to  ensure that they are operating effectively.
Moreover, DOD currently lacks uniform performance goals and  benchmarks for all aspects of the EFM program. Because OSN is  charged with monitoring EFM programs and is developing benchmarks  and performance goals for the family support component of the program,  it is well positioned to develop them for the other two components of the  program—identification/enrollment and assignment coordination. Such an  effort would give DOD the information it needs to determine whether the  branches are complying with program policies and requirements. Without  clear benchmarks and performance goals, DOD is limited in the extent to  which it can determine the effectiveness of the branches’ EFM programs  and improve these programs for families with special needs. As a result,  families may continue to be assigned to installations that cannot readily  meet their children’s special educational and medical needs.
section_title: Recommendations for Executive Action
paragraphs: Based on our review, we are making three recommendations.
To ensure that military families are assigned to overseas installations that  can readily meet their children’s special educational and medical needs,  we recommend that the Secretary of Defense direct the secretaries of  each branch to ensure that all military dependent children of school age  are medically and educationally screened in accordance with each  branch’s policies and that all required educational screening forms are  forwarded to DODEA for educational assignment recommendations prior  to families’ relocations.
To improve oversight of the military branches’ programs for families with  special needs, we recommend that the Secretary of Defense direct OSN  to establish uniform benchmarks and performance goals for the  identification/enrollment and assignment coordination components of the  military branches’ EFM programs. These goals can be used to determine  whether EFM programs are achieving desired outcomes across DOD and  identify areas for improvement. For example, such performance goals  could include specific targets and benchmarks for reducing screening  failures over time and reassigning families who have been sent to  locations that are unable to meet their children’s educational or medical  needs.
To strengthen OSN’s oversight over the military branches’ EFM  programs, we recommend that the Secretary of Defense direct OSN to  develop and implement a process to assess the branches’ compliance  with DOD-level EFM program policies and requirements, and to identify  and report any issues related to noncompliance to senior leadership for  corrective action. For example, OSN could consider conducting periodic,  unannounced site visits to select military installations on a periodic basis  to monitor implementation of their EFM programs.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to the Department of Defense (DOD) for  review and comment. DOD’s comments are reproduced in appendix III.  DOD also provided technical comments that we incorporated in the report  as appropriate.
DOD concurred with our recommendation that all school-age military  dependent children be medically and educationally screened and that all  screening forms be forwarded to DODEA for placement  recommendations before families relocate. DOD noted that it has a policy  that requires the military branches to identify and refer school-age  children with special educational needs to the appropriate DODEA  reviewer for educational placement recommendations.
DOD partially concurred with our recommendation to direct OSN to  establish uniform benchmarks and performance goals for two elements of  the branches’ EFM programs—the identification/enrollment and  assignment coordination components. In its comments, DOD said it has  completed the first year of an analysis of the branches’ EFM programs  that will provide uniform benchmarks and performance goals for these  components of the program. In a subsequent discussion with DOD to  clarify their written comments, a senior official confirmed that these  benchmarks and performance goals are currently not in place and are still  in the process of being developed. While there is no specific deadline for  their completion, DOD anticipates that they will be finalized in mid-2013.  Since the primary intent of this effort is to develop a joint database that  will network all three components of the EFM program, it is unclear  whether any benchmarks and goals resulting from the analysis will  include all the elements necessary for effective oversight of the programs.
DOD partially concurred with our recommendation to provide OSN with  the authority to require the branches to comply with DOD and branch- level EFM program policies and requirements. DOD said its current  policies assign responsibility for ensuring compliance to senior leadership  within the Office of the Secretary of Defense. In addition, DOD said the  responsibility for ensuring the branches’ compliance with its forthcoming  revised policy on EFM program compliance will be assigned to the  Assistant Secretary of Defense for Readiness and Force Management to  whom OSN will report any issues regarding noncompliance. When this  occurs, DOD said the Assistant Secretary will direct the branches to take  corrective action. We revised our report to clarify that high-level  responsibility for ensuring the branches’ compliance with EFM program  requirements rests with the Under Secretary of Defense for Personnel  and Readiness. We also modified our recommendation to direct DOD to  require OSN to develop and implement a process to assess the branches’  compliance with EFM program policies and requirements and to report  any issues related to noncompliance to senior leadership for corrective  action. We believe this would allow OSN to better evaluate the extent to  which the branches are complying with the revised policy.
In overall comments on our report, DOD said that despite some families’  comments in our focus groups that their children lacked services such as  speech and language therapy, its monitoring reports over the past 10  years have indicated no lack of services due to an inadequate number of  special education teachers or specialists. In our report, we noted that  families’ comments about challenges obtaining special education services  were generally corroborated by DODEA administrative offices and  individual schools overseas. For example, officials from DOD schools we  visited told us they have difficulties filling and retaining key positions, such  as special education teachers, paraprofessionals, and specialists. In  addition, some officials said that caseloads for certain special education  service providers can exceed accepted standards.
In addition, DOD said the perspectives obtained from families during our  focus groups are presented as facts in our report, and noted that caution  must be exercised when drawing conclusions about the accessibility of  services based on a sample of individual opinions. In our report, we  acknowledged that our focus groups cannot be generalized to all parents  of children with special needs, nor are they representative of the entire  population of parents. Because common responses and recurring themes  across focus groups provide some degree of validation that experiences  are not limited to specific individuals, we identified throughout the report  the number of focus groups where particular perspectives were  discussed. In addition, we did not rely entirely on focus groups for  evidence in the report, but rather used several different methods to  support our conclusions. For example, we interviewed officials from  DODEA administrative offices, military branches, and individual schools  who corroborated many themes that emerged during our focus groups.
We are sending copies of this report to the appropriate congressional  committees, the Secretary of Defense, and other interested parties. The  report also is available at no charge on the GAO website at  http://www.gao.gov.
If you or your staff members have any questions about this report, please  contact me at (202) 512-7215 or scottg@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made major contributions to  this report are listed in appendix IV.
section_title: Appendix I: Scope and Methodology
paragraphs: The objectives of this report were to determine (1) how the Department of  Defense (DOD) provides special education services, and any associated  challenges for families and schools; (2) how DOD entities coordinate to  assign families to overseas locations, and how schools might be affected;  (3) what challenges, if any, families face in obtaining DOD services for  their children with special educational needs and accessing related  information; and (4) what steps, if any, DOD is taking to enhance  screening and overseas assignment for families with children with special  educational needs.
subsections: section_title: Site Visits to Selected Military Installations and DOD Schools
paragraphs: In order to obtain information on how DOD schools provide special  education services, and to identify challenges families face in obtaining  these services and schools face in providing them, we conducted site  visits to five military installations in Europe and in two states. During these  site visits, we visited nine schools on four military installations in  Germany, and two schools on a military installation in Italy. Domestically,  we also visited three schools on an installation in North Carolina and two  schools on an installation in South Carolina. We also held telephone  interviews with school and other officials from a military installation in  Japan. (See table 1 for more information on the installations and schools  we visited.) During our school visits we conducted 22 focus groups with  parents of children with special education needs enrolled in these  schools. We also interviewed school officials, including principals,  teachers, and specialists, at 15 of the 17 schools included in our study to  learn about the challenges schools face in providing special education  services, and the strategies they employ to respond to those challenges.  We also toured schools and obtained documents. In addition, we  interviewed Department of Defense Education Activity (DODEA) area and  district officials, and officials from the Exceptional Family Member (EFM)  program and the Educational and Developmental Intervention Services  (EDIS) programs on each of the installations we visited. Site visit  locations were selected to obtain ranges in the number of students with  special education needs enrolled in DOD schools in particular districts  and the severity of needs the schools overseas were equipped to serve.  We also strove to achieve variation in urban and remote areas, as well as  the four armed service branches. In addition, we considered  recommendations from DODEA and subject matter experts in our  selection of site visit locations.
We conducted 22 focus groups at all of the schools included in our study,  including 17 at overseas locations and five at domestic locations,  covering over 100 service members, their spouses, and DOD civilians  across all four branches of the military, in order to obtain the views of  parents regarding the challenges they face in learning about and  obtaining special education services for their children with special needs.  One of our overseas focus groups was conducted via video  teleconference, rather than in person, to mitigate travel costs. We are  confident that using this method did not substantially impact our findings.  For each location, all parents of children with an individualized education  program (IEP) were invited to participate. A list of sites we spoke with can  be found in table 1.
A focus group protocol was developed to help the moderator gather  information from these parents about their experiences with special  education services at DODEA schools. The protocol contained questions  about the types of services their children received, degree of satisfaction  with those services, experiences with the Exceptional Family Member  (EFM) program and with the screening process for obtaining special  education services, and a comparison to services provided at other  locations. In addition, it included questions on any complaints that may  have been communicated to DODEA, and the resolution of those  complaints. Notes were taken by at least one, but usually multiple, GAO  note-takers. These notes were integrated into transcripts of the focus  groups, which were then organized by question. For each question, a  GAO analyst reviewed notes from all the focus groups to identify themes  across the different groups, in order to provide insights into the range of  concerns and support for these topics. While the results of these focus  groups cannot be generalized to all parents of children with special  needs, nor are they representative of the population of parents, common  responses across groups and recurring themes provide some degree of  validation. Because of these limitations, our study was supported by  several methodologies, of which the focus groups were one part, to  support our conclusions.
section_title: Interviews with Agency Officials and Other Organizations
paragraphs: To address all of the report’s objectives, we interviewed relevant officials  from DODEA, the Office of Special Needs, and the military services’ EFM  program headquarters offices. We also met with individual subject matter  experts and representatives from the National Council on Disability and  the Specialized Training of Military Parents, an organization focused on  providing support and advice to military families with special needs. In  addition, we reviewed relevant federal laws and regulations. We also  reviewed agency documents and program guidance, such as DODEA’s  directory of special education services in overseas communities,  DODEA’s special education procedural guide, service-level EFM program  instructions, and DOD instructions for the provision of special education  and related services. We also reviewed prior GAO reports on military  dependents and elementary and secondary education.
section_title: Data Collection and Analysis
paragraphs: To obtain information about the number and characteristics of children  with special needs who attend DOD schools, we reviewed data from  DODEA’s Excent and Aspen databases, including enrollment by disability  type, location, and military branch or other governmental affiliation, as of  January 2012. As part of our data request, we asked questions about the  reliability of the data, such as whether there are audits of the data or  routine quality control procedures in place. We found limitations with the  enrollment data resulting from the transition between systems, but  determined that the data provided by DOD were sufficiently reliable to  accurately provide an approximation of enrollment figures as of January  2012. We also examined data from DODEA’s Screening and Assignment  Concerns database to determine the number of screenings and  assignment concerns reported between 2005 and 2012, as well as the  nature of the assignment concerns from the most recent school year. We  tested the screening and assignment concerns database for errors and  found the data to be sufficiently reliable for the purposes of reporting the  number of screenings and the number and nature of assignment  concerns.
section_title: Appendix II: DODEA Categories and Definitions of Disabilities
subsections: section_title: 1. Physical Impairments
paragraphs: Students whose educational performance is adversely affected by a  physical impairment that requires environmental and/or academic  modifications including, but not limited to, the following: visually impaired,  hearing impaired, orthopedically impaired, and other health impaired.
This term includes Pervasive Developmental Disorder, Asperger’s  syndrome, as well as the diagnosis of autism. It is a developmental  disability significantly affecting verbal and nonverbal communication and  social interaction, generally evident before age 3 that adversely affects  educational performance. The term does not include students with  characteristics of the disability “serious emotional disturbance.”
A hearing loss or deficit so severe that the student is impaired in  processing linguistic information through hearing, with or without  amplification, to the extent that his or her educational performance is  adversely affected.
Concomitant hearing and visual impairments. This disability causes such  severe communication, developmental, and educational problems that  they cannot be accommodated in special education programs solely for  students with deafness or students with blindness.
An impairment in hearing, whether permanent or fluctuating that  adversely affects a student’s educational performance, but is not included  under the definition of deafness.
Other Health Impairment (OHI)
Though not exhaustive, OHI may include limited strength, vitality, or  alertness due to chronic or acute health problems that adversely affect a  student’s educational performance, including but not limited to heart  condition, tuberculosis, rheumatic fever, nephritis, asthma, sickle cell  anemia, hemophilia, epilepsy, lead poisoning, leukemia, diabetes or  attention deficit disorder with or without hyperactivity.
A severe physical impairment that adversely affects a student’s  educational performance. The term includes congenital impairments,  impairments caused by disease (e.g., poliomyelitis, bone tuberculosis,  etc.), and impairments from other causes such as cerebral palsy,  amputations, and fractures or burns causing contractures.
An acquired injury to the brain caused by an external physical force,  resulting in total or partial functional disability or psychosocial impairment,  or both, that adversely affects a student’s educational performance. The  term applies to open or closed head injuries resulting in impairments in  one or more areas, such as cognition, language, memory, attention,  reasoning, abstract thinking, judgment, or problem-solving; sensory,  perceptual, and motor abilities; psychosocial behavior; physical functions;  information processing, and speech. The term does not apply to brain  injuries that are congenital or degenerative, or brain injuries induced by  birth trauma.
Impairment in vision that, even with correction, adversely affects a  student’s educational performance. The term includes both partial sight  and blindness.
section_title: 2. Emotional Impairments
paragraphs: A condition that has been confirmed by clinical evaluation and diagnosis  and that, over a long period of time and to a marked degree, adversely  affects educational performance and that exhibits one or more of the  following characteristics: 1.  An inability to learn that cannot be explained by intellectual,  sensory, or health factors. 1.  An inability to build or maintain satisfactory interpersonal  relationships with peers and teachers. 2.  Inappropriate types of behavior under normal circumstances.  3.  A tendency to develop physical symptoms or fears associated with  personal or school problems. 4.  A general pervasive mood of unhappiness or depression.
This includes students who are schizophrenic, but does not include  students who are socially maladjusted, unless it is determined that they  are seriously emotionally disturbed. The term emotional impairment does  not usually include (a) antisocial behavior, (b) parent-child problems, (c)  conduct disorders, (d) interpersonal problems, or (e) other problems that  are not the result of a severe mental disorder.
section_title: 3. Communication Impairments
paragraphs: Communication Impairment includes two disabilities: speech disorders  and language disorders. Students whose educational performance is  adversely affected by a developmental or acquired communication  disorder to include voice, fluency, articulation, receptive, and/or  expressive language.
Language/phonological disorders are characterized by an  impairment/delay in receptive and/or expressive language including  semantics, orphology/syntax, phonology and/or pragmatics. This  impairment does not include students whose language problems are due  to English as a second language or dialect difference. 1.  Articulation disorder is characterized by substitutions, distortions,  and/or omissions of phonemes that are not commensurate with  expected developmental age norms, that are not the result of limited  English proficiency or dialect difference, and that may cause  unintelligible conversational speech. 2.  Fluency disorder is characterized by atypical rate, rhythm, repetitions,  and/or secondary behavior(s) that interferes with communication or is  inconsistent with age/development. 3.  Voice disorder is characterized by abnormal pitch, intensity,  resonance, duration, and/or quality that is inappropriate for  chronological age or gender.
section_title: 4. Learning Impairments
paragraphs: Learning Impairment includes two disabilities: specific learning disability  and intellectual disability.
Specific learning disability is a disorder in one or more of the basic  psychological processes involved in understanding or in using spoken or  written language that may manifest itself as an imperfect ability to listen,  think, speak, read, write, spell, remember, or do mathematical  calculations. The term includes such conditions as perceptual disabilities,  brain injury, minimal brain dysfunction, dyslexia, and developmental  aphasia. The term does not include learning problems that are primarily  the result of visual, hearing, or motor disabilities; of mental retardation or  emotional disturbance; or of environmental, cultural, or economic  disadvantage.
Intellectual disability is significantly sub-average intellectual functioning  existing concurrently with deficits in adaptive behavior and manifested  during the developmental period that adversely affects a student’s  educational performance. Significant sub-average general intellectual  functioning is documented by a comprehensive intelligence test score that  is two or more standard deviations below the mean.
section_title: 5. Developmental Delay
paragraphs: The term developmental delay refers to a significant discrepancy in the  actual functioning of an infant, toddler, or child birth through age 7, when  compared with the functioning of a nondisabled infant, toddler, or child of  the same chronological age in the following areas: physical, cognitive,  communication, social or emotional, and adaptive development as  measured using standardized evaluation instruments and confirmed by  clinical observation and judgment. A child classified with a developmental  delay before age 7 may maintain that eligibility classification through age  10. Developmental delay does not refer to a condition in which a child is  slightly or momentarily lagging in development. The presence of a  developmental delay is an indication that the developmental processes  are significantly affected and that, without special intervention, it is likely  that the educational performance will be affected when the child reaches  school age.
There are five developmental areas of concern in the definition of  developmental delay: 1.  Physical Development - Fine/gross motor skills used for  coordinated use of muscles and body control in actions such as  balance, standing, walking, climbing, object manipulation, cutting,  and pre-writing activities. 2.  Communication Development - Ability to understand and use  language and the phonological processes. 3.  Cognitive Development - Ability to receive information, process  relationships, and apply knowledge. 4.  Social/Emotional Development - Ability to develop and maintain  functional interpersonal relationships and to exhibit social and  emotional behaviors appropriate to the setting. 5.  Adaptive/Self-Help Development - Ability to deal with  environmental expectations and use functional daily living skills.
section_title: Appendix III: Comments from the Department of Defense
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the contact named above, Elizabeth Sirois, Assistant  Director; Divya Bali, Jennifer Cook, and Charlene J. Lindsay made  significant contributions to this report. Also contributing to this report were  Deborah Bland, Kate van Gelder, Mimi Nguyen, Steven Putansu, James  Rebbe, Michael Silver, and Rachael Valliere.
section_title: Related GAO Products
paragraphs: Education of Military Dependent Students: Better Information Needed to  Assess Student Performance. GAO-11-231. Washington, D.C.: March 1,  2011.
DOD Schools: Additional Reporting Could Improve Accountability for  Academic Achievement of Students with Dyslexia. GAO-08-70.  Washington, D.C.: December 6, 2007.
Military Personnel: Medical, Family Support, and Educational Services  Are Available for Exceptional Family Members. GAO-07-317R.  Washington, D.C.: March 16, 2007.
DOD Schools: Limitations in DOD-Sponsored Study on Transfer  Alternatives Underscore Need for Additional Assessment. GAO-05-469.  Washington, D.C.: April 26, 2005.