Defense Health Care: Additional Efforts Needed to Ensure Compliance with Personality Disorder Separation Requirements
Published: 2008-10-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: At DOD, a personality disorder can render a servicemember unsuitable for service. GAO was required to report on personality disorder separations and examined (1) the extent that selected military installations complied with DOD's separation requirements and (2) how DOD ensures compliance with these requirements. GAO reviewed a sample of 312 servicemembers' records from four installations, representing the Army, Air Force, and Marine Corps, that had the highest or second highest number of Operation Enduring Freedom or Operation Iraqi Freedom servicemembers separated because of a personality disorder. The review is generalizable to the installations, but not to the services. GAO also reviewed 59 Navy servicemembers' records, but this review is not generalizable to the installation or the Navy because parts of the separation process could have been completed at multiple locations.
section_title: What GAO Found
paragraphs: GAO's review of enlisted servicemembers' records found that the selected military installations GAO visited varied in their documented compliance with DOD's requirements for personality disorder separations. DOD has requirements for separations because of a personality disorder, which is defined as an enduring pattern of behavior that deviates markedly from expected behavior and has an onset in adolescence or early adulthood. The three key requirements established by DOD are that enlisted servicemembers (1) must be notified of their impending separation because of a personality disorder, (2) must be diagnosed with a personality disorder by a psychiatrist or psychologist who determines that servicemembers' personality disorder interferes with their ability to function in the military, and (3) must receive formal counseling about their problem with functioning in the military. For the four installations, compliance with the notification requirement was at or above 98 percent. The compliance rates for the requirement related to the personality disorder diagnosis ranged from 40 to 78 percent. For the requirement for formal counseling, compliance ranged from 40 to 99 percent. GAO's review of the documentation in the enlisted Navy servicemembers' records found that compliance varied by requirement. Ninety-five percent of enlisted Navy servicemembers' records had documentation indicating that enlisted servicemembers had been notified of their impending separation because of a personality disorder. Eighty-two percent had documentation that indicated compliance with the requirement that enlisted servicemembers must be diagnosed with a personality disorder by a psychiatrist or psychologist who determines that the personality disorder interferes with servicemembers' ability to function in the military. Seventy-seven percent had documentation indicating compliance with the requirement for formal counseling. DOD does not have reasonable assurance that its key personality disorder separation requirements have been followed. DOD policy directs the military services to implement and ensure consistent administration of DOD's requirements for separating enlisted servicemembers because of a personality disorder. According to military service officials, the military services delegate to commanders with separation authority at military installations sole responsibility for ensuring that the separation requirements are followed for enlisted servicemembers under their command. When asked about the low rates of compliance for some of the separation requirements that GAO found, military officials responsible for reviewing the servicemembers' records with whom GAO spoke could not explain why these separations were approved if compliance with the separation requirements was not documented in the servicemembers' records. The military services have not established a way to determine whether the commanders with separation authority are ensuring that DOD's key separation requirements are met, and DOD does not have reasonable assurance that its requirements have been followed.

section_title: Letter
paragraphs: The Department of Defense (DOD) requires that all servicemembers,  including those who serve in Operation Enduring Freedom (OEF) and  Operation Iraqi Freedom (OIF), be physically and psychologically suitable  for military service. Enlisted servicemembers who fail to meet this  standard may be separated from the military. One psychological condition  that can render a servicemember unsuitable for military service is a  personality disorder, which is defined as a long-standing, inflexible pattern  of behavior that deviates markedly from expected behavior, has an onset  in adolescence or early adulthood, and leads to distress or impairment.  Such a condition may make one unable to work within a military  environment. DOD data show that from November 1, 2001, through   June 30, 2007, about 26,000 enlisted servicemembers were separated from  the military because of a personality disorder. Of these 26,000, about 2,800  had deployed at least once in support of OEF/OIF.
Accurately diagnosing OEF/OIF servicemembers with a personality  disorder can be challenging. Specifically, some of the symptoms of a  personality disorder—irritability, feelings of detachment or estrangement  from others, and aggressiveness—are similar to the symptoms of post- traumatic stress disorder (PTSD), a condition for which some OEF/OIF  servicemembers may also be at risk. However, according to mental health  experts and military mental health providers, one important difference  between a personality disorder and PTSD is that a personality disorder is a  long-standing condition, whereas PTSD is a condition that follows  exposure to a traumatic event. Although servicemembers with personality  disorders may have symptoms that first appear during their military duty,  DOD does not consider this to be a condition caused by military service. A  separation from the military because of a personality disorder can be  stigmatizing and can have adverse consequences for servicemembers,  such as limiting employment opportunities after servicemembers leave the  military.
DOD has established three key requirements that the military services— Army, Air Force, Navy, and Marine Corps—must follow when separating  enlisted servicemembers because of a personality disorder. Specifically,  before they are separated because of a personality disorder, enlisted  servicemembers    must receive notification of their impending separation because of a    must receive, prior to the notification, a diagnosis of personality disorder  by a psychiatrist or psychologist who determines that the personality  disorder interferes with servicemembers’ ability to function in the military;  and   must receive formal counseling about their problem with functioning in  the military.
Typically, an enlisted servicemember’s commander initiates the separation  process. This commander, as well as a psychiatrist or psychologist, must  follow the requirements established by DOD when separating a  servicemember because of a personality disorder. Additionally,  servicemembers undergoing the separation process have various  protections available to them. For example, servicemembers may meet  with a military attorney to discuss their rights during the separation  process.
Congress included provisions in the National Defense Authorization Act  for Fiscal Year 2008 that require us to review and report on OEF/OIF  servicemembers’ separations from military service because of a  personality disorder, and 11 senators also expressed interest in this work.  For our review, we examined (1) the extent to which selected military  installations complied with DOD requirements for separating enlisted  servicemembers because of a personality disorder, (2) how DOD ensures  compliance by the military services with personality disorder separation  requirements, and (3) the extent to which enlisted servicemembers  selected the protections available to them.
To determine the extent to which selected military installations complied  with DOD’s personality disorder separation requirements, we reviewed  DOD and the military services’ separation regulations and instructions to  identify the key requirements for separating enlisted servicemembers  because of a personality disorder. We included only enlisted  servicemembers because officers generally are able to resign at any time  rather than be involuntarily separated. We obtained DOD data for enlisted  OEF/OIF servicemembers separated because of a personality disorder  from November 1, 2001, through June 30, 2007, which we determined to be  sufficiently reliable for our purposes by corroborating these data with  information in the servicemembers’ personnel records. We analyzed these  data to determine which installations across the military services had the  highest number of enlisted OEF/OIF servicemembers separated because of  a personality disorder. We selected four installations to visit—Fort Carson  (Army), Fort Hood (Army), Davis-Monthan Air Force Base (Air Force),  and Camp Pendleton (Marine Corps)—because these installations  accounted for the highest or second highest number of enlisted OEF/OIF  servicemembers separated because of a personality disorder from  November 1, 2001, through June 30, 2007, among their military service’s   installations. For three of the installations we visited, we obtained and  reviewed personnel records for a random sample of enlisted  servicemembers whose certificates of release indicated that they were  separated from these installations because of a personality disorder. For  the fourth installation, we obtained and reviewed personnel records for all  of the enlisted servicemembers whose certificates of release indicated that  they were separated from that installation because of a personality  disorder. We reviewed all of these enlisted servicemembers’ records  because the total number of servicemembers separated from this  installation was too small to draw a random, generalizable sample. Our  findings based on our compliance review can be generalized to each of the  four installations but cannot be generalized to the military services.
In addition to the four military installations from the Army, Air Force, and  Marine Corps, we visited Naval Base San Diego. We obtained and reviewed  personnel records for enlisted Navy servicemembers whose certificates of  release indicated that they were separated because of a personality  disorder. During the course of our review, Navy officials at this base told  us that enlisted Navy servicemembers selected for our review were  transferred to the transient personnel unit at Naval Base San Diego from a  Navy ship at various points in the separation process. According to a  Navy official, most enlisted Navy servicemembers were diagnosed,  formally counseled, and notified of their impending separation while on  board a Navy ship and were transferred to the transient personnel unit at  Naval Base San Diego to receive their certificates of release. Other enlisted  Navy servicemembers were diagnosed, formally counseled, and notified of  their impending separation while at Naval Base San Diego. We could not  generalize our findings to Naval Base San Diego because some of the  elements of the separation process could have been completed while these  servicemembers were on board a Navy ship. We also could not generalize  to the Navy. Therefore, we have reported the results of our review of  enlisted Navy servicemembers’ records separately from our presentation  of findings based on our review of the other four military installations.
For our compliance review, we examined 312 personnel records for  enlisted servicemembers from the Army, Air Force, and Marine Corps  installations and 59 records for enlisted servicemembers from the Navy— 371 records in total. We obtained these records from each military  service’s central repository, where the personnel records of  servicemembers who have been separated from the military are stored. In  each of these records, we reviewed what is known as a separation packet,  which is required to contain documents related to a servicemember’s  separation. According to military service officials responsible for the  separation policy, the separation packet is required to include  documentation demonstrating that DOD’s three key requirements for a  personality disorder separation have been met.
To complete our compliance review, we reviewed servicemembers’  separation packets first to see if the packets contained documentation that  servicemembers had been notified of their impending separation because  of a personality disorder. If the servicemembers’ separation packets  lacked such documentation, we did not assess compliance for the other  two key separation requirements. If the packets did include such  documentation, we reviewed the packets to determine whether they  contained documentation required by the military services demonstrating  that the other two key requirements had been met. Table 1 describes the  criteria we used to determine compliance.
To determine how DOD ensures compliance with its personality disorder  separation requirements by the military services, we reviewed DOD  regulations and interviewed officials from DOD and the military services.  To determine the extent to which enlisted servicemembers selected the  protections available to them, such as consulting legal counsel prior to  being separated, we reviewed the same 371 enlisted servicemembers’  separation packets as we reviewed to determine compliance with DOD’s  personality disorder separation requirements—312 separation packets for  enlisted servicemembers from the Army, Air Force, and Marine Corps  installations and 59 separation packets for enlisted servicemembers from  the Navy. For the 371 enlisted servicemembers whose separation packets  we reviewed, we also obtained information from the military services to  determine whether any of these servicemembers appealed the reason for  their separation. Appendix I provides more detailed information on our  methodology. We conducted this performance audit from May 2007  through August 2008 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
paragraphs: Enlisted servicemembers can be separated from the military when they are  found to be unsuitable for continued military service. According to DOD  regulations, enlisted servicemembers can be separated for reasons such as  misconduct, failure to overcome substance abuse, and certain mental  health conditions, including a personality disorder. A personality disorder  by itself does not make enlisted servicemembers unsuitable for military  service. DOD requires that the disorder be severe enough that it interferes  with an enlisted servicemember’s ability to function in the military.
DOD and the military services require that to diagnose a personality  disorder a psychiatrist or psychologist use criteria established in the  Diagnostic and Statistical Manual of Mental Disorders (DSM), which  was developed by the American Psychiatric Association. Similarly, in the  private sector, clinicians use criteria in the DSM to diagnose a personality  disorder, but in some instances, clinicians other than psychiatrists or  psychologists, such as licensed clinical social workers, may make this  diagnosis.
Diagnosing a personality disorder in a servicemember who has served in  combat can be complicated by the fact that some symptoms of a  personality disorder may be similar to symptoms of combat-related mental  health conditions. For example, both personality disorder and PTSD have  similar symptoms of feelings of detachment or estrangement from others,  and irritability. According to the American Psychiatric Association and the  American Psychological Association, the only way to distinguish a  personality disorder from a combat-related mental health condition, such  as PTSD, is by getting an in-depth medical and personal history from the  servicemember that is corroborated, if possible, by family and friends.
According to DOD officials, the three key requirements that the military  services must follow when separating an enlisted servicemember are  designed to help ensure that enlisted servicemembers are separated for  the appropriate reason. Documentation of compliance with these  requirements is to be included in the separation packet found in the  enlisted servicemember’s personnel record, as required by the military  services. The separation packet is required to contain other documents  related to the enlisted servicemember’s separation. According to officials  from the military services, the servicemember’s immediate commander  gives the separation packet to an installation official who is to review the  packet to verify that the requirements for the personality disorder  separation have been met. If this review verifies that the requirements  have been met, the separation packet is then sent to a commander at the  installation who has authority for approving a personality disorder  separation for that enlisted servicemember. This commander is a higher- level officer than the enlisted servicemember’s immediate commander. A  military installation may have more than one commander who has the  authority to approve separations because of a personality disorder.  However, each commander with separation authority approves  separations only for enlisted servicemembers under his or her command.
Once enlisted servicemembers have been separated from military service,  they receive certificates of release from the military, which include  information on the reason for separation and an official characterization  of their time in the service. For enlisted servicemembers separated  because of a personality disorder, their certificates of release would state  that the reason for their separation was a personality disorder. Employers  may request to see separated servicemembers’ certificates of release to  verify their military service, and employers may make employment  decisions based on the information they see on servicemembers’  certificates of release.
Enlisted servicemembers have protections available to them when going  through the separation process. All enlisted servicemembers can submit  statements on their own behalf to the commander with separation  authority, consult with legal counsel prior to separation, and obtain copies  of the separation packet that is sent to the commander with separation  authority. In addition, enlisted servicemembers with 6 or more years of  military service are eligible to request a hearing before an administrative  board. An administrative board hearing allows enlisted servicemembers  to have legal representation, call witnesses, and speak on their own behalf  in defending against the recommended separation. The board includes at  least three members who, following a hearing, make a recommendation to  the commander with separation authority as to whether the enlisted  servicemember should be separated.
Enlisted servicemembers also have protections available to them after  they have been separated. They may challenge the reasons given for their  separations after they have been separated from the military. Within 15  years after separation from the military, enlisted servicemembers may  appeal their separation to a discharge review board. Further, enlisted  servicemembers may appeal the discharge review board’s decision by  applying to a board for the correction of military records.
section_title: Selected Military Installations’ Compliance with Three Key Personality Disorder Separation Requirements Varied
paragraphs: The four military installations we visited varied in their compliance with  DOD’s three key requirements for personality disorder separations. For  the four installations, compliance with the first requirement—to notify  enlisted servicemembers of their impending separation because of a  personality disorder—was at or above 98 percent. For the second  requirement, that enlisted servicemembers must be diagnosed with a  personality disorder by a psychiatrist or psychologist who determines that  the personality disorder interferes with servicemembers’ ability to  function in the military, the compliance rates ranged from 40 to 78 percent.  Compliance ranged from 40 to 99 percent for the third requirement, that  enlisted servicemembers receive formal counseling about their problem  with functioning in the military. Our review of the documentation in the  enlisted Navy servicemembers’ separation packets found that compliance  varied by requirement.
subsections: section_title: Compliance with the Notification Requirement Ranged from 98 to 100 Percent
paragraphs: Across the four installations, the percentage of enlisted servicemembers’  separation packets that documented compliance with the notification  requirement ranged from 98 to 100 percent. Of the 312 enlisted  servicemembers’ separation packets included in our review, only 4 did not  contain documentation that the servicemembers received notification that  they were being separated because of a personality disorder. We did not  assess whether the separation packets for these 4 servicemembers had  documentation that indicated compliance for the remaining two key  separation requirements.
section_title: Compliance with the Requirement Related to the Personality Disorder Diagnosis Ranged from 40 to 78 Percent
paragraphs: Across the four installations, the percentage of enlisted servicemembers’  separation packets that had documentation indicating compliance with all  three parts of the second requirement—that enlisted servicemembers  separated because of a personality disorder (1) be diagnosed with a  personality disorder (2) by a psychiatrist or psychologist who   (3) determines that the personality disorder interferes with  servicemembers’ ability to function in the military—ranged from 40 to   78 percent. Noncompliance with this requirement occurred in two ways:  enlisted servicemembers’ separation packets did not contain the medical  form used to document the three parts of this requirement or  servicemembers’ separation packets contained the medical form but  documentation on the form for one or more of the three parts of this  requirement was missing or incorrect. Figure 1 summarizes the four  installations’ compliance rates for this requirement.
We found that 34 enlisted servicemembers’ separation packets did not  contain a medical form, which is used to document compliance with the  three parts of this requirement. We also found that of the enlisted  servicemembers’ separation packets that contained a medical form, the  medical form in 66 of these packets did not contain information needed to  fulfill all three parts of the requirement. For example, 27 of these 66  enlisted servicemembers’ medical forms had documentation indicating  that the servicemember had been diagnosed with a personality disorder,  but there was also information in the medical form indicating that the  diagnosis was not made by a psychiatrist or psychologist. In some of these  cases, we found that the diagnosis of a personality disorder was made by a  licensed clinical social worker or other type of provider, such as a  battalion surgeon.
section_title: Compliance with the Requirement for Formal Counseling Ranged from 40 to 99 Percent
paragraphs: We found that compliance with the requirement that enlisted  servicemembers receive formal counseling about their problem with  functioning in the military ranged from 40 to 99 percent. Across the four  installations, we found that 42 enlisted servicemembers’ separation  packets did not contain a counseling form documenting that  servicemembers received formal counseling as required. As a result, these  42 servicemembers’ separation packets were noncompliant with this  requirement. Figure 2 summarizes the four installations’ compliance rates  for this requirement.
section_title: Documented Compliance with the Three Key Personality Disorder Separation Requirements Varied for Enlisted Navy Servicemembers’ Separation Packets That We Reviewed
paragraphs: Our review of the documentation in 59 enlisted Navy servicemembers’  separation packets found that compliance varied by requirement. Of the  separation packets that we reviewed, 95 percent had documentation  indicating that enlisted servicemembers had been notified of their  impending separation because of a personality disorder. (Three enlisted  servicemembers’ separation packets did not contain documentation of this  requirement, and as a result, we did not assess compliance with the  remaining two requirements for these three servicemembers’ separation  packets.) The requirement that enlisted servicemembers be diagnosed  with a personality disorder by a psychiatrist or psychologist who  determines that the personality disorder interferes with servicemembers’  ability to function in the military had a compliance rate of 82 percent for  the 56 remaining enlisted Navy servicemembers’ separation packets that  we reviewed. Of the 56, we found that 1 enlisted Navy servicemember’s  separation packet did not contain a medical form, which is used to  document compliance with the three parts of this requirement. We also  found that 9 of the 56 enlisted Navy servicemembers’ separation packets  contained a medical form, but did not have documentation indicating  compliance with all three parts of this requirement. Most of these—6—did  not have documentation indicating that the diagnosis of a personality  disorder was made by a psychiatrist or psychologist. For the requirement  for formal counseling, 77 percent of the 56 enlisted Navy servicemembers’  separation packets contained documentation that enlisted  servicemembers received formal counseling about their problem with  functioning in the military.
section_title: DOD Does Not Have Reasonable Assurance That Its Separation Requirements Have Been Followed
paragraphs: DOD does not have reasonable assurance that its key personality disorder  separation requirements have been followed. DOD policy directs the  military services to implement and ensure consistent administration of  DOD’s requirements for separating enlisted servicemembers because of a  personality disorder. In turn, according to officials in each of the military  services, the military services delegate to commanders with separation  authority at the military installations sole responsibility for ensuring that  the requirements are followed for enlisted servicemembers under their  command.
According to military officials at the installations we visited, to ensure  compliance with DOD’s key separation requirements, the commander with  separation authority has an official at the installation examine the enlisted  servicemember’s separation packet prior to the separation to determine  that all requirements have been met. Military officials responsible for  reviewing the separation packets at the installations we visited explained  that when the official who is reviewing the separation packet discovers  that a requirement for separation has not been documented, the reviewing  official is supposed to take steps to resolve the situation. For example, if  the official reviewing the separation packets does not find documentation  that enlisted servicemembers have been formally counseled about their  problem with functioning in the military, the reviewing official would  verify that the formal counseling had occurred and then obtain  documentation of that counseling session. Similarly, a Navy legal official  told us that enlisted servicemembers’ separation packets should be  reviewed to make sure that DOD’s key separation requirements have been  met before the separations are approved. When we asked about the low  rates of compliance for some of the separation requirements that we found  at the Army, Air Force, and Marine Corps installations we visited and for  the enlisted Navy servicemembers’ records that we reviewed, the military  officials responsible for reviewing the separation packets with whom we  spoke could not explain why these separations were approved if  compliance with the separation requirements was not documented in the  separation packet.
Having given sole responsibility to the commanders with separation  authority to ensure compliance, the military services have not established  a way to determine whether these commanders are ensuring that DOD’s  key requirements are met. Furthermore, DOD does not have reasonable  assurance that its requirements for separating enlisted servicemembers  because of a personality disorder have been followed.
section_title: Enlisted Servicemembers’ Selection of Protections Available During and After Separation Varied
paragraphs: At the four installations we visited, enlisted servicemembers who were  separated because of a personality disorder varied in the extent to which  they selected the protections available to them during the separation  process, depending on the specific protection. Based on our review of  separation packets in the enlisted servicemembers’ personnel records, we  found that a small proportion of enlisted servicemembers—12 percent— stated that they wanted to submit statements on their own behalf to the  commander with separation authority. Of these servicemembers who  submitted a statement, 18 percent submitted a statement that either  questioned whether the diagnosis of a personality disorder was an  accurate diagnosis or requested not to be separated. All of these  servicemembers were separated. We also found that 38 percent of enlisted  servicemembers at the installations we visited stated that they wanted to  consult with legal counsel prior to their separation. According to legal  officials at the installations we visited, enlisted servicemembers may seek  legal counsel to discuss the implications of a personality disorder  separation, seek advice on how to stay in the military, or obtain  information on their eligibility for Department of Veterans Affairs’  benefits, such as health and educational benefits, after separation. For  enlisted Navy servicemembers whose separation packets we reviewed,   5 percent selected to submit statements and 5 percent selected to consult  with counsel prior to separation.
Based on our review of enlisted servicemembers’ separation packets for  the installations we visited, we found that the majority of servicemembers  requested copies of their separation packets, which are sent to the  commander with separation authority. Specifically, 289 of 312 enlisted  servicemembers in our review at the four installations—93 percent— requested copies of their separation packets, while 66 percent of enlisted  Navy servicemembers in our review requested copies of their separation  packets. We also found that no enlisted servicemembers—either at the  installations we visited or among the enlisted Navy servicemembers whose  separation packets we reviewed—requested a hearing before an  administrative board prior to their separation.
Enlisted servicemembers may challenge the reason given for their  separation to a discharge review board after the separation has been  completed. For the four installations we visited and for enlisted Navy  servicemembers, we found that three enlisted servicemembers applied to  their military service’s discharge review board to challenge the reason for  their separation. Of these three, one servicemember received a change to  the reason for separation because the discharge review board found that  the separation because of a personality disorder was unjust. For this  servicemember, the reason for separation was changed from personality  disorder to the reason of secretarial authority of that military service. The  other two servicemembers who applied for a change to their reason for  separation did not receive a change because the discharge review board  found that the documentation present in the personnel record supported  the personality disorder separation. The two servicemembers who were  unsuccessful in their appeal to the discharge review board did not choose  to appeal the discharge review board’s decision to the board for the  correction of military records.
section_title: Conclusions
paragraphs: DOD has established requirements that are intended to help ensure that  enlisted servicemembers separated because of a personality disorder are  separated appropriately. Failure to comply with these requirements  increases the risk of enlisted servicemembers being inappropriately  separated because of a personality disorder. For enlisted servicemembers,  the stakes are high because a personality disorder separation can carry a  long-term stigma in the civilian world. Because DOD relies on the military  services to ensure compliance with its key personality disorder separation  requirements, and because the military services rely solely on  commanders with separation authority to ensure compliance with these  requirements, there is a lack of reasonable assurance that the  requirements have been met. During our review of enlisted  servicemembers’ separation packets at the four military installations and  for enlisted Navy servicemembers’ separation packets we reviewed, the  low rates of compliance we found for some of the key personality disorder  separation requirements indicate that the military services need a system,  beyond relying on the commanders who are making separation decisions,  to ensure compliance with DOD’s personality disorder separation  requirements. Additionally, DOD needs to monitor the military services’  compliance with these requirements. Until this happens, DOD does not  have reasonable assurance that personality disorder separations of  enlisted servicemembers have been appropriate.
section_title: Recommendations for Executive Action
paragraphs: To help ensure that DOD’s requirements for personality disorder  separations are met and to help increase assurance that these separations  are appropriate, we recommend that the Secretary of Defense direct the  Under Secretary of Defense for Personnel and Readiness to  1.  direct the Secretaries of the Army, the Air Force, and the Navy and the  Commandant of the Marine Corps to develop a system to ensure that  personality disorder separations are conducted in accordance with  DOD’s requirements and  2.  ensure that DOD monitors the military services’ compliance with  DOD’s personality disorder separation requirements.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments on a draft of this report, DOD concurred with our  recommendation that the military services develop a system to ensure that  personality disorder separations are conducted in accordance with DOD’s  requirements. DOD partially concurred with our recommendation that  DOD monitor the military services’ compliance with DOD’s personality  disorder separation requirements. DOD stated that it will strengthen policy  guidance related to the military services’ standardized compliance  reporting, but that it is the responsibility of the military services to ensure  compliance with DOD policy. However, as we stated in our draft report,  DOD’s reliance on the military services to ensure compliance with its  separation requirements has not provided reasonable assurance that these  requirements will be followed. We believe that the low rates of compliance  we found for some of DOD’s key personality disorder separation  requirements suggest the need for another system to ensure compliance  with these requirements, as well as the need for DOD to monitor the  military services’ compliance.
DOD suggested that we change the title of our draft report to indicate that  our subject area was personnel management and not defense health care.  We have not changed the title. For an enlisted servicemember to be  separated because of a personality disorder, the servicemember must first  be diagnosed as having a personality disorder. Therefore, we consider our  review of DOD’s separation process for servicemembers with personality  disorders a review of a health care issue.
In its comments, DOD also identified two inaccuracies in our description  of DOD’s separation requirements. DOD pointed out that its policy does  not state that a servicemember’s written notification of the impending  separation has to come from a servicemember’s commander, as we  indicated in our draft report. According to DOD, the policy does not  specify who must provide this written notification. We revised our draft  report to clarify our discussion of this requirement. However, this change  did not affect the results of our compliance review because we determined  compliance based on whether servicemembers’ separation packets  contained a notification letter and not on who notified the servicemember.  DOD also pointed out that its policy does not state that servicemembers  must receive formal counseling from their supervisors about their problem  with functioning in the military, as we stated in our draft report. According  to DOD, the policy does not state who should provide the formal  counseling to the servicemember; however, we were told by a DOD  separation policy official that the counseling should be done by the  servicemember’s supervisor. We revised our draft report to clarify our  discussion of this requirement. This also did not change the results of our  compliance review because we assessed compliance based on whether  servicemembers’ separation packets contained a counseling form and not  on who counseled the servicemember.
DOD also provided technical comments, which we incorporated as  appropriate. DOD’s written comments are reprinted in appendix II.
We are sending copies of this report to the Secretary of Defense; the  Secretaries of the Army, the Air Force, and the Navy; the Commandant of  the Marine Corps; and appropriate congressional committees and  addressees. We will also provide copies to others upon request. In  addition, this report is available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staff have any questions about this report, please contact me  at (202) 512-7114 or williamsonr@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 III.
section_title: Appendix I: Scope and Methodology
paragraphs: To meet our objectives, we examined Department of Defense (DOD)  separation regulations that the military services are required to follow to  help ensure that enlisted servicemembers are separated for the  appropriate reasons. For our review, we examined (1) the extent to which  selected military installations complied with DOD requirements for  separating enlisted servicemembers because of a personality disorder,   (2) how DOD ensures compliance with personality disorder separation  requirements by the military services, and (3) the extent to which enlisted  servicemembers who are separated because of a personality disorder  selected protections available to them.
For this review, we included enlisted servicemembers from the Army, Air  Force, Navy, and Marine Corps. We included only enlisted  servicemembers because officers are able to resign at any time rather than  be involuntarily separated. We included enlisted servicemembers who  deployed at least once in support of Operation Enduring Freedom (OEF)  or Operation Iraqi Freedom (OIF). The Coast Guard was excluded because  it is under the direction of the Department of Homeland Security and  represents a very small portion of servicemembers deployed in support of  OEF and OIF. For this review, enlisted servicemembers are those in the  active duty component and Reserve component—reservists and National  Guard members—who were discharged or released from active duty from  November 1, 2001—the first full month of combat operations for OEF— through June 30, 2007—the latest date for which data were available from  DOD at the time of our review.
We obtained data from DOD’s Defense Manpower Data Center (DMDC) on  the number of enlisted servicemembers who had been separated from the  military because of a personality disorder from November 1, 2001, through  June 30, 2007. These data came from DMDC’s Active Duty Military  Personnel Transaction File and DMDC’s Reserve Components Common  Personnel Data Transaction File, which are databases that contain  servicemember-level data, such as Social Security number, education  level, date of birth, pay grade, separation program designator code, and  reenlistment eligibility. The Active Duty Military Personnel Transaction  File contains a transaction record for every individual entrance,  separation, or reenlistment in the Army, Air Force, Navy, and Marine  Corps within a specific time frame. The Reserve Components Common  Personnel Data Transaction File contains this information for every  individual entrance, separation, or reenlistment in the Army National  Guard, Army Reserve, Air National Guard, Air Force Reserve, Navy  Reserve, and Marine Corps Reserve within a specific time frame. We also  asked that DMDC indicate, from its Contingency Tracking System  Deployment File, if any enlisted servicemembers who were separated  because of a personality disorder were also deployed, for at least one tour  of duty, in support of OEF or OIF. The Contingency Tracking System  Deployment File is a database that includes data elements for all  servicemembers deployed in support of OEF/OIF. A contingency tracking  system deployment is defined as a servicemember being physically located  within the OEF or OIF combat zones/areas of operation, or specifically  identified by the military service as directly supporting the OEF/OIF  mission outside of the designated combat zone. We determined that the  DMDC data were sufficiently reliable because we corroborated these data  with information in the enlisted servicemembers’ personnel records.
Based on our analysis of the data provided by DMDC, we selected four  military installations across the Army, Air Force, and Marine Corps to visit  based on whether the installation had the highest or second highest  number of enlisted OEF/OIF servicemembers separated because of a  personality disorder for that service. We selected one installation each  from the Air Force and the Marine Corps. We selected two Army  installations because at the time of our review, the Army had the majority  of servicemembers deployed in support of OEF/OIF when compared with  the Air Force and the Marine Corps. Among Marine Corps installations, we  selected Camp Pendleton, in California, which had the second highest  number of enlisted servicemembers separated because of a personality  disorder during this time period. This installation was selected because the  Marine Corps installation with the highest number of enlisted  servicemembers separated because of a personality disorder was in the  midst of a deployment cycle and requested that we not visit. The other  military installations we selected were Fort Carson (Army), Colorado; Fort  Hood (Army), Texas; and Davis-Monthan Air Force Base (Air Force),  Arizona.
In addition to the four military installations we visited, we visited Naval  Base San Diego. We selected Naval Base San Diego based on DMDC’s data,  which identified this naval base as having the second highest number of  enlisted OEF/OIF Navy servicemembers separated because of a  personality disorder from November 1, 2001, through June 30, 2007.  During the course of our review, Navy officials at this base told us that  enlisted Navy servicemembers selected for our review were transferred to  the transient personnel unit at Naval Base San Diego from a Navy ship at  various points in the separation process. According to a Navy official,  most enlisted Navy servicemembers were diagnosed, formally counseled,  and notified of their impending separation while on board a Navy ship and  were transferred to the transient personnel unit at Naval Base San Diego  to receive their certificates of release. Other enlisted Navy  servicemembers were diagnosed, formally counseled, and notified of their  impending separation while at Naval Base San Diego. We could not  generalize our findings to Naval Base San Diego because some of the  elements of the separation process could have been completed while these  servicemembers were on board a Navy ship. Therefore, we have reported  the results of our review of enlisted Navy servicemembers’ records  separately from our presentation of findings based on our review of the  other four military installations.
To determine the extent to which the four military installations and  enlisted Navy servicemembers’ records that we reviewed complied with  DOD personality disorder separation requirements, we reviewed DOD’s  and the military services’ enlisted administrative separation regulations  and instructions to identify the key requirements for separating enlisted  servicemembers because of a personality disorder. We also interviewed  officials at each of the military services’ headquarters who are responsible  for overseeing separation policy. We interviewed additional officials at  each of the four selected installations and at Naval Base San Diego,  including mental health providers, staff judge advocates, legal counsel  with defense services, unit commanders, administrators of the Medical  Evaluation Board, and officials in the transition/separation offices, to  understand the administrative separation process.
Additionally, to determine whether the selected installations and enlisted  Navy servicemembers’ records that we reviewed complied with DOD’s  requirements for separating servicemembers because of a personality  disorder, we obtained and reviewed the personnel records of selected  servicemembers to verify that their certificates of release indicated that  they were separated because of a personality disorder. We obtained these  records from each military service’s central repository, where the  personnel records of servicemembers who have been separated from the  military are stored. According to military service officials responsible for  separation policy, the separation packet, which is found in the enlisted  servicemember’s personnel record, is required to contain documents  related to the separation, including documents indicating that DOD’s three  key requirements have been met.
For three of the installations we selected, we reviewed the personnel  records of a random, generalizable sample of enlisted servicemembers  who deployed at least once in support of OEF/OIF and who were  separated from that installation because of a personality disorder from  November 1, 2001, through June 30, 2007. For the other installation we  selected, we reviewed the personnel records of all enlisted  servicemembers who deployed at least once in support of OEF/OIF and  who were separated from that installation because of a personality  disorder from November 1, 2001, through June 30, 2007, because the  number of servicemembers separated from that installation was too small  to draw a random, generalizable sample. In total, we included 343 enlisted  servicemembers’ personnel records across the four installations. Of these  343 records, 312 enlisted servicemembers’ personnel records were  included in our documentation review because their personnel records  contained separation packets, which we needed to review to determine  compliance. Of the 31 servicemembers’ personnel records that were  excluded from our review, 3 had separation packets that were illegible.  The remaining 28 servicemembers’ personnel records did not have  separation packets available for our review.
We also obtained 94 enlisted Navy servicemembers’ personnel records  from the Navy’s central repository, where the personnel records of  servicemembers who have been separated are stored after they leave the  Navy. We reviewed the personnel records of all enlisted Navy  servicemembers who deployed at least once in support of OEF/OIF and  who were separated from Naval Base San Diego because of a personality  disorder from November 1, 2001, through June 30, 2007, because the  number of enlisted servicemembers separated from Naval Base San Diego  was too small to draw a random, generalizable sample. We reviewed these  personnel records to determine if they contained separation packets,  which are required by the Navy. Of the 94 enlisted Navy servicemembers,  59 servicemembers’ personnel records were included in our review  because their records contained separation packets, which were needed  for us to determine compliance. We excluded 35 enlisted Navy  servicemembers’ personnel records from our evaluation of compliance.  One enlisted servicemember’s separation packet was illegible and   34 enlisted servicemembers’ separation packets were not available for  review.
In our review, we determined compliance for each of the three key  personality disorder separation requirements by reviewing the  documentation in the enlisted servicemembers’ separation packets to see  if it indicated compliance with that requirement. If the enlisted  servicemember’s separation packet did not include documentation that  the servicemember had been notified of the impending separation because  of a personality disorder—one of the key requirements for a personality  disorder separation—we did not assess compliance with the other two key  requirements. Table 2 describes the criteria we used to determine  compliance.
Our review of compliance can be generalized to each of the four  installations we visited, but not to the military services. For enlisted Navy  servicemembers whose separation packets we reviewed, we cannot  generalize to Naval Base San Diego or to the Navy.
To determine how DOD ensures compliance by the military services with  requirements for separating enlisted servicemembers because of a  personality disorder, we reviewed DOD regulations and interviewed DOD  and the military services’ officials responsible for separation policy.  Additionally, we interviewed military officials responsible for legal  services at the installations we visited and at Naval Base San Diego about  how they ensure compliance with DOD’s key requirements for personality  disorder separations.
To determine the extent to which enlisted servicemembers at the four  installations we visited and enlisted Navy servicemembers selected the  protections available to them during the separation process, we reviewed  the same 371 enlisted servicemembers’ separation packets as we reviewed  to determine compliance with DOD’s personality disorder separation  requirements—312 separation packets for enlisted servicemembers from  the Army, Air Force, and Marine Corps installations and 59 separation  packets for enlisted servicemembers from the Navy. Enlisted  servicemembers are given a list of the protections available to them and  select protections from this list, which are included in servicemembers’  separation packets. From our review of the separation packets, we  determined whether enlisted servicemembers selected the protections  available, but did not determine whether servicemembers received the  protections that they selected. To determine the extent to which enlisted  servicemembers selected protections available after being separated, we  obtained information from each military service’s discharge review board  and board for the correction of military records. Using this information,  we determined whether the same 371 enlisted servicemembers, whose  separation packets we reviewed to determine compliance with DOD’s  personality disorder separation requirements, challenged the reason for  their separation.
We conducted this performance audit from May 2007 through August 2008  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: Comments from the Department of Defense
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Acknowledgments
paragraphs: In addition to the contact named above, Mary Ann Curran, Assistant  Director; Sarah Burton; Christie Enders; Krister Friday; Becky  Hendrickson; Martha R.W. Kelly; Lisa Motley; Jason Vassilicos; and  Suzanne Worth made key contributions to this report.