Military Recruiting: Clarified Reporting Requirements and Increased Transparency Could Strengthen Oversight over Recruiter Irregularities
Published: 2010-01-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.

section_title: Letter
paragraphs: 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, 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  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.  Recruiter  irregularities encompass a range of actions including, for example,  administrative paperwork errors, instructing applicants not to reveal  certain disqualifying conditions, and criminal misconduct.
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. 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  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. 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?    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.
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.
subsections: section_title: Background
paragraphs: 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. 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.)
Each of the military services has its own recruiting command, which is  responsible for the service’s recruiting mission and functions.  The role  of the recruiting command is to provide support to the recruiting force and  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.
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  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.
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  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. 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.  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. 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.
section_title: Substantiated Cases of Irregularities Represent a Small Percentage of Accessions, and Actions Have Been Taken against the Recruiters Responsible
subsections: section_title: Substantiated Cases of Recruiter Irregularities across the Service Components Comprise a Small Percentage of Overall Accessions
paragraphs: 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. 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.
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.
section_title: Concealment or Falsification of Documents or Information Was the Most Commonly Reported Irregularity
paragraphs: 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.)
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.  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.)
section_title: Actions Taken against Recruiters in Substantiated Cases of Recruiter Irregularities Varied by Service Component
paragraphs: 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.
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. 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.)
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  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.
section_title: 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
subsections: section_title: The Service Components Have Developed Guidance to Address Recruiter Irregularities
paragraphs: 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. 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.  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  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.
The Army National Guard Strength Maintenance Division and the Air  National Guard Recruiting and Retention Service within the National  Guard Bureau 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.  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. 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. 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.
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.  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.
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.
section_title: The Service Components Have Taken Steps to Identify and Prevent Recruiter Irregularities
paragraphs: 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. 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:    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.
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.
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. 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  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. 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.
section_title: The Service Components’ Oversight and Data Sharing Have Improved, but Not All Service Components Share Data throughout All Levels of Command
paragraphs: 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. 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.
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.
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  recruiter. 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.  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  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.
section_title: OSD Implemented Recruiter Irregularity Reporting Requirements, but Lacks Complete Oversight over Irregularities
subsections: section_title: OSD Has Implemented Recruiter Irregularity Reporting Requirements, Sponsored Research, and Provided Information- Sharing Opportunities on Recruiter Irregularity Issues
paragraphs: In December 2006, OSD issued the memorandum regarding the tracking  and reporting of recruiter irregularities by the service components.  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. 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  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.
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  issues. Another example is the annual Leadership Conference, which  brings together recruiting command officials to discuss various recruiting- related 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.
section_title: OSD Lacks Complete Oversight over Recruiter Irregularities Due to a Lack of Clarity in the Memorandum
paragraphs: 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  committed by a recruiter when dealing with an applicant or a recruit, the  Air Force Reserve, the Air National Guard States, and five out of seven  Army National Guard States whose files we reviewed reported on all cases  of recruiter irregularities, 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  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  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.   on  However, other service components may not be approaching this situati in the same manner. For example, Air Force recruiting officials told us thatthey only report the final disposition to OSD and not the preliminary  actions.  The memorandum does not explicitly address how such  situations should be hand 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  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.
section_title: OSD Also Lacks Complete National Guard Data
paragraphs: 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. 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. 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.
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  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 hat the Air  National Guard Recruiting and Retention Service receives.   ry.
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 e- mail or telephone if the reports appear to contain obvious mistakes, su ch  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 mechanism to force States and Territories to comply.   mitted.
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  ities  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  mation  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 in  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  Guard do not disclose any limitations of the data on which they are based.    ta.
section_title: Conclusions
paragraphs: Recruiters work in a challenging environment and play a critical role in  providing the military services with qualified men and women prepared to  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 ly with  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 recruiterirregularities 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 withthe reporting requirements, at the very least it must be transparent a the completeness of the data that it provides to OSD. Without such  bout  transparency from the National Guard Bureau, OSD will not be able t meaningfully analyze recruiter irregularity trends across the service  components and identify areas where corrective action may be needed.
section_title: Recommendations Executive Action
paragraphs: mend that the Secretary of Defense take the following four  1.  direct the Secretaries of the Army and Navy to identify mechanisms the regular sharing of the levels of command, and   recruiter irregularity data throughout all  irect the Under Secretary of Defense for Personnel and Readiness to:    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 the basis of the  National Guard data for the Congress and others.
section_title: Agency Comments and Our Evaluation
paragraphs: 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 the  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 h. 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  lished  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 ns, and  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 appendix IV.  ularity data. DOD’s comments in their entirety appear in  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 be  available at no charge on GAO’s Web site at http://www.gao.gov.
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 last page of this report. GAO staff who made major contributions to the  report are listed in appendix V.
section_title: Appendix I: Scope and Methodology
paragraphs: 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. 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. 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. In the course of our work, we contacted or visited the  organizations and offices listed in table 9.
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  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  (20), Indiana (7), Minnesota (6), Oklahoma (8), Pennsylvania (5), and  Wisconsin (7).
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.
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.
section_title: Appendix II: Examples of Recruiter Irregularities in Fiscal Year 2008
paragraphs: 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.
A recruiter became aggressive with a recruit and engaged in a verbal altercation with  the recruit’s boyfriend (Navy).
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).
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).
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).
A recruiter purchased alcohol for an underage recruit and consumed it with him  (Marine Corps).
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).
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).
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).
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).
section_title: Appendix III: Examples of Dispositions in Fiscal Year 2008
paragraphs: 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.
section_title: Appendix IV: Comments from the Department of Defense
section_title: Appendix V: GAO Contact and Staff Acknowledgments
paragraphs: Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov.
subsections: section_title: Staff Acknowledgments
paragraphs: 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.