Military Personnel: Additional Actions Are Needed to Strengthen DOD's and the Coast Guard's Sexual Assault Prevention and Response Programs
Published: 2010-02-03T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Sexual assault is a crime with negative implications to military readiness and esprit de corps. In response to a congressional request, GAO, in 2008, reviewed Department of Defense (DOD) and U.S. Coast Guard sexual assault prevention and response programs and recommended a number of improvements. GAO was subsequently asked to evaluate the extent to which (1) DOD has addressed GAO's 2008 recommendations and further developed its programs, (2) DOD has established a sexual assault database, and (3) the Coast Guard has addressed GAO's 2008 recommendations and further developed its programs. To do so, GAO analyzed legislative requirements and program guidance, interviewed officials, and compared database implementation efforts to key information technology best practices.
section_title: What GAO Found
paragraphs: DOD has addressed four of GAO's nine recommendations from 2008 regarding the oversight and implementation of its sexual assault prevention and response programs. For example, the Office of the Secretary of Defense (OSD) evaluated department program guidance for joint and deployed environments, and it evaluated factors that may hinder access to health care following a sexual assault. But DOD's efforts to address the other recommendations reflect less progress. For example, GAO recommended that DOD develop an oversight framework, to include long-term goals and milestones, performance goals and strategies, and criteria for measuring progress. However, GAO found that the draft framework lacks key elements needed for comprehensive oversight of DOD's programs, such as criteria for measuring progress and an indication of how it will use the information derived from such measurement to improve its programs. Until OSD incorporates all key elements into its draft oversight framework, it will remain limited in its ability to effectively manage program development to help prevent and respond to sexual assault incidents. DOD acknowledges that more work remains in order to fully develop its oversight framework. DOD has taken steps to begin acquiring a centralized sexual assault database. However, it did not meet a legislative requirement to establish the database by January 2010, and it is unclear when the database will be established because DOD does not yet have a reliable schedule to guide its efforts. Also, key system acquisition best practices associated with successfully acquiring and deploying information technology systems, such as economically justifying the proposed system solution and effectively developing and managing requirements, have largely not been performed. OSD officials said they intend to employ these acquisition best practices. Until this is accomplished the program will be at increased risk of not delivering promised mission capabilities and benefits on time and within budget. While the Coast Guard has partially implemented one of GAO's two recommendations for further developing its sexual assault prevention and response program, it has not implemented the other. In June 2009, the Coast Guard began assessing its program staff's workload, which represents progress in addressing GAO's recommendation to evaluate its processes for staffing key installation-level positions in its program. However, it has not addressed GAO's recommendation to develop an oversight framework. Further, the Coast Guard lacks a systematic process for assembling, documenting, and maintaining sexual assault incident data, and lacks quality control procedures to ensure that the program data being collected are reliable. In fiscal year 2008, for example, different Coast Guard offices documented conflicting numbers of sexual assault reports: the Coast Guard Program Office documented 30, while the Investigative Office documented 78. The Coast Guard had to resolve this significant discrepancy before it could provide its data to DOD. Without a systematic process for tracking its data, the Coast Guard lacks reliable knowledge on the occurrence of sexual assaults.

section_title: Letter
paragraphs: Sexual assault is a crime that has a far-reaching negative impact on  communities, families, and individuals and has additional implications for  the military services because it undermines their core values, degrades  mission readiness and esprit de corps, subverts strategic goodwill, and  raises financial costs. Since we reported on these implications in 2008,  incidents of sexual assault have continued to occur; in fiscal year 2008, the  Department of Defense (DOD) reported nearly 3,000 alleged sexual assault  cases, and the U.S. Coast Guard reported about 80. However, it is  impossible to accurately analyze trends or to draw conclusions from these  data about the incidence of sexual assault in the military services because,  as we have previously reported, DOD and the Coast Guard have not been  using standardized reporting requirements.
Since 2004, Congress has repeatedly taken steps to address sexual assault  in the military, including passing legislation that directs the Secretary of  Defense to develop a comprehensive policy for DOD on the prevention of  and response to sexual assaults involving members of the Armed Forces.  The comprehensive policy is to include procedures for confidentially  reporting sexual assault incidents. Further, the Secretary of Defense is  required to submit an annual report to Congress on reported sexual  assault incidents involving servicemembers. In 2008, we issued two  reports that have helped inform congressional deliberations on sexual  assault in the military; the first, in January 2008, addressed sexual assault  at the DOD and Coast Guard academies, while the second, in August 2008,  addressed sexual assault in the military and Coast Guard services. Our  August 2008 report found that while DOD and the Coast Guard have taken  positive steps to prevent and respond to sexual assault, program  implementation was hindered by several issues, such as the lack of an  oversight framework—that is, a plan to improve the Office of the Secretary  of Defense’s (OSD) oversight of the programs; limited support from some  commanders; and training that was not consistently effective.  Accordingly, we made a number of recommendations to improve DOD and  Coast Guard programs, including recommending the development of an  oversight framework to assess program effectiveness and the evaluation of  program guidance, training, and installation-level staffing processes to  enhance program implementation. We also raised as a matter for  congressional consideration that the Coast Guard be required to annually  submit to Congress sexual assault incident and program data that are  methodologically comparable to those required of DOD. DOD and the  Coast Guard concurred with all of the recommendations in our August  2008 report, which are reprinted in the Background section of this report.  In addition, we testified twice before your Subcommittee: in July 2008, to  discuss our preliminary observations on DOD’s and the Coast Guard’s  sexual assault prevention and response programs, and in September 2008,  to discuss the findings and recommendations included in our August 2008  report.
In November 2008, you requested that we continue to monitor DOD and  Coast Guard efforts to strengthen the implementation and oversight of  their respective sexual assault prevention and response programs. This  report builds upon our previous work related to sexual assault in the  military services, and assesses the extent to which (1) DOD has taken  steps to implement our recommendations from 2008 and has further  developed its programs to prevent and respond to sexual assault; (2) DOD  has taken steps to address a congressional requirement to establish a  centralized, case-level sexual assault incident database; and (3) the Coast  Guard has taken steps to implement our recommendations from 2008 and  has further developed its programs to prevent and respond to sexual  assault.
To assess the extent to which DOD has implemented our previous  recommendations, we reviewed current DOD policies and programs and  compared them with our prior findings and recommendations. We also  interviewed DOD officials to supplement our analyses of program  modifications. To assess the extent to which DOD has addressed the  congressional requirement to establish a centralized, case-level sexual  assault database, we reviewed applicable legislation to identify statutory  provisions that direct DOD to make changes to its processes for collecting  and maintaining sexual assault data. We also reviewed applicable DOD  documentation, compared it to DOD, federal, and industry guidance and to  key system acquisition best practices; and interviewed DOD officials to  obtain information on the status of the department’s efforts to establish  the database. To assess the extent to which the Coast Guard has  implemented our previous recommendations, we reviewed current Coast  Guard policies and programs and compared them with our prior findings  and recommendations. We also interviewed Coast Guard officials to  supplement our analyses of program modifications. Further details about  our scope and methodology can be found in appendix I.
We conducted this performance audit from February 2009 to February  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.
subsections: section_title: Background
subsections: section_title: Department of Defense
paragraphs: In October 2004, Congress included a provision in the Ronald W. Reagan  National Defense Authorization Act for Fiscal Year 2005 that required the  Secretary of Defense to develop a comprehensive policy for DOD on the  prevention of and response to sexual assaults involving members of the  Armed Forces. The legislation required that the policy be based on the  recommendations of the Defense Task Force on Care for Victims of Sexual  Assaults and on other matters as the Secretary deemed appropriate.  Among other things, the legislation requires the Secretary to establish a  standardized departmentwide definition of sexual assault, and to develop  a policy, using the standardized definition, to address a number of issues,  including the confidential reporting of sexual assault incidents and the  uniform collection of data on the incidence of sexual assault. The law also  requires DOD to submit an annual report to Congress on reported sexual  assault incidents involving members of the Armed Forces.
In October 2005, DOD issued DOD Directive 6495.01, which contains its  policy for the prevention of and response to sexual assault. In June 2006,  DOD issued DOD Instruction 6495.02, which provides guidance for  implementing this policy. DOD’s directive defines sexual assault as  follows:  “intentional sexual contact, characterized by use of force, threats,  intimidation, abuse of authority, or when the victim does not or  cannot consent. Sexual assault includes rape, forcible sodomy  (oral or anal sex), and other unwanted sexual contact that is  aggravated, abusive or wrongful (to include unwanted and  inappropriate sexual contact), or attempts to commit these acts.  “Consent” means words or overt acts indicating a freely given  agreement to the sexual conduct at issue by a competent person.  An expression of lack of consent through words or conduct means  there is no consent. Lack of verbal or physical resistance or  submission resulting from the accused’s use of force, threat of  force, or placing another person in fear does not constitute  consent. A current or previous dating relationship by itself or the  manner of dress of the person involved with the accused in the  sexual conduct at issue shall not constitute consent.”
In October 2008, Congress passed the Duncan Hunter National Defense  Authorization Act for Fiscal Year 2009, which includes a provision  requiring the Secretary of Defense to implement a centralized, case-level  database for the collection and maintenance of information regarding  sexual assaults involving members of the Armed Forces. The law  specifies that the database include information, if available, about the  nature of the assault, the victim, the offender, and the outcome of any legal  proceedings associated with the assault, and requires DOD to implement  the database by January 2010—which is 15 months from the day of its  enactment.
In OSD, the Under Secretary of Defense for Personnel and Readiness has  the responsibility for developing the overall policy and guidance for the  department’s sexual assault prevention and response program. Under the  Office of the Under Secretary of Defense for Personnel and Readiness,  OSD’s Sexual Assault Prevention and Response Office (within the Office of  the Deputy Under Secretary of Defense for Plans) serves as the  department’s single point of responsibility for sexual assault policy  matters. These responsibilities include providing the military services  with guidance and technical support and facilitating the identification and  resolution of issues; developing programs, policies, and training standards  for the prevention of, reporting of, and response to sexual assault;  developing strategic program guidance and joint planning objectives;  overseeing the department’s collection and maintenance of data on  reported alleged sexual assaults involving servicemembers; establishing  mechanisms to measure the effectiveness of the department’s sexual  assault prevention and response program; and preparing the department’s  annual report to Congress. The Deputy Under Secretary of Defense for  Plans has the responsibility for programming, budgeting, and allocating  funds and other resources for the Sexual Assault Prevention and Response  Office.
Each military service has established a sexual assault prevention and  response office with responsibility for overseeing and managing its sexual  assault matters. Further, DOD’s instruction requires the military services  to establish Sexual Assault Response Coordinator positions and states that  at the services discretion, these positions may be staffed by members of  the military, civilian employees, or DOD contractors. Sexual Assault  Response Coordinators are generally responsible for implementing their  respective services’ sexual assault prevention and response programs,  including coordinating the response to and reporting of sexual assault  incidents. Other responders include victim advocates, judge advocates,  medical and mental health providers, criminal investigative personnel, law  enforcement personnel, and chaplains.
section_title: Coast Guard
paragraphs: The Coast Guard has had a sexual assault prevention and response  program in place since 1997, and in December 2007, the Coast Guard  updated its instruction to generally mirror DOD’s policy. According to  Coast Guard officials, in January 2009, they revised their instruction to  incorporate what officials have stated is a more comprehensive definition  of the term “sexual assault,” modify titles of certain program personnel to  better reflect their responsibility, and clarify processes for reporting a  sexual assault.
The Coast Guard’s Office of Work-Life (within the Health, Safety, and  Work-Life Directorate, which is under the Office of the Assistant  Commandant for Human Resources) is responsible for overseeing and  managing sexual assault matters. At the installation level, the Coast Guard  has established Employee Assistance Program Coordinators to manage the  response to and reporting of sexual assault incidents. Like DOD’s, the  Coast Guard’s sexual assault prevention and response program utilizes  other responders to manage sexual assault incidents, including victim  advocates, judge advocates, medical and mental health providers, criminal  investigative personnel, law enforcement personnel, and chaplains.
section_title: Recommendations from 2008 GAO Report
paragraphs: In August 2008, we issued a report containing nine recommendations to  DOD and two recommendations to the Coast Guard to improve program  implementation. With respect to DOD, we recommended that the  Secretary of Defense take the following actions:    Review and evaluate the department’s policies for the prevention of  and response to sexual assault to ensure that adequate guidance is  provided to effectively implement the program in deployed  environments and joint environments.
Direct the military service secretaries to emphasize to all levels of  command their responsibility for supporting the program, and review  the extent to which commanders support the program and resources  are available to raise servicemembers’ awareness of sexual assault  matters.
Systematically evaluate and develop an action plan to address any  factors that may prevent or discourage servicemembers from  accessing health services following a sexual assault.
Direct the Defense Task Force on Sexual Assault in the Military  Services to begin its examination immediately, now that all members  of the task force have been appointed, and to develop a detailed plan  with milestones to guide its work.
Require the Sexual Assault Prevention and Response Office to develop  an oversight framework to guide continued program implementation  and to evaluate program effectiveness. At a minimum, such a  framework should contain long-term goals, objectives, and milestones;  performance goals; strategies to be used to accomplish goals; and  criteria for measuring progress.
Review and evaluate sexual assault prevention and response training  to ensure that the military services are meeting training requirements  and to enhance the effectiveness of the training.
Evaluate the military services’ processes for staffing and designating  key installation-level program positions—such as coordinators—at  installations in the United States and overseas, to ensure that these  individuals have the ability and resources to fully carry out their  responsibilities.
Direct the military service secretaries to provide installation-level  incident data to the Sexual Assault Prevention and Response Office  annually or as requested to facilitate the analysis of sexual assault- related data and to better target resources over time.
Improve the usefulness of the department’s annual report as an  oversight tool both internally and for congressional decision makers by  establishing baseline data to permit the analysis of data over time and  to distinguish cases in which (1) evidence was insufficient to  substantiate an alleged assault, (2) a victim recanted, or (3) the  allegations of sexual assault were unfounded.
With respect to the Coast Guard, we recommended that the Commandant  of the Coast Guard take the following actions:    Evaluate the Coast Guard’s processes for staffing key installation-level  program positions—such as coordinators—to ensure that these  individuals have the ability and resources to fully carry out their  responsibilities.
Develop an oversight framework to guide continued program  implementation and to evaluate program effectiveness. At a minimum,  such a framework should contain long-term goals, objectives, and  milestones; performance goals; strategies to be used to accomplish  goals; and criteria for measuring progress.
We also suggested as a matter for congressional consideration that the  Coast Guard be required to annually submit to Congress sexual assault  incident and program data that are methodologically comparable to those  required of DOD. In commenting on a draft of that report, both DOD and  the Coast Guard concurred with all of our recommendations.
section_title: DOD’s Efforts to Address GAO’s Recommendations from 2008 Reflect Varying Levels of Progress
paragraphs: DOD has made varying levels of progress in implementing our  recommendations from 2008 to improve its sexual assault prevention and  response programs. To its credit, DOD has implemented four of the nine  recommendations in our August 2008 report. However, DOD’s efforts  toward implementing the other five recommendations reflect less  progress, which is likely to hinder the effectiveness of DOD’s efforts to  oversee its programs.
subsections: section_title: DOD Has Implemented Four of Our Recommendations from 2008
paragraphs: During fiscal years 2008 and 2009, DOD implemented four of the  recommendations in our August 2008 report on DOD and Coast Guard  sexual assault prevention and response programs. First, OSD established a  working group to address our recommendation to review and evaluate the  adequacy of DOD policies for implementing its sexual assault prevention  and response program in joint and deployed environments. Based on the  working group’s findings, OSD submitted a memorandum to the Joint Staff  in April 2009 detailing its suggested revisions to joint policy, which a Joint  Staff official told us they are using to modify related publications.  Additionally, according to a Joint Staff official, the Joint Staff has issued  interim guidance to support the implementation of sexual assault  prevention and response programs in joint and deployed environments  until the new joint publications are approved.
Second, the military service secretaries have taken a variety of steps to  address our recommendation to emphasize responsibility for program  support to all levels of command. For example, the military services’ top  leadership spoke at their respective services’ sexual assault prevention  summits, during which they emphasized the need for “ownership” of the  programs and commitment to the prevention of and response to sexual  assault. Specifically, in the spring of 2009, the Secretary of the Army spoke  to noncommissioned officers—the personnel responsible for program  implementation—on the importance of modifying the Army’s culture to  actively reject sexual assault and other inappropriate behavior. In the fall  of 2009, the Secretaries of the Air Force and Navy and the Commandant of  the Marine Corps gave similar presentations to their personnel, during  which they stressed their commitment to eradicating sexual assault in the  military services. The military services have taken even more far-reaching  steps to relay their support for and to commit resources to sexual assault  prevention and response programs. For example, the Secretary of the  Navy recently established the Navy’s Sexual Assault Prevention and  Response Office that reports directly to the Secretary, which Navy officials  assert will foster additional support and accountability for its sexual  assault program initiatives. The Marine Corps, following a review of its  program staffing, established full-time Sexual Assault Response  Coordinator positions at four installations with the highest troop  concentrations and is in the process of establishing full-time coordinator  positions at installations with at least 1,000 troops as a way to better  manage its sexual assault prevention and response programs. Additionally,  the Army has incorporated an assessment of sexual assault program  awareness into promotional boards for noncommissioned officers to  promote accountability for the implementation of prevention and response  initiatives.
DOD has also taken a variety of steps to emphasize support for and to  further develop its sexual assault prevention and response programs. For  example, in fiscal year 2008, representatives from OSD and the military  services visited selected military installations to assess, among other  things, the extent to which commanders—company and field grade  officers—support sexual assault prevention and response programs. OSD  found that while most program personnel had demonstrable support from  their command, command support of sexual assault prevention and  response programs varied from installation to installation, and stronger  command support of the program was required. OSD further reported that  it is working with its stakeholders to address its findings. Additionally,  each of the military services has incorporated interactive, scenario-based  training programs to promote increased involvement by participants and  to enhance the retention of the material being presented. For example, the  Army contracts with a company that offers a nationally recognized  presentation called “Sex Signals”—a 90-minute program that uses  interactive skits to address the topics of dating, rape, consent, and  intervention. The Air Force has implemented bystander intervention  training that incorporates techniques such as role-playing to motivate  servicemembers to take actions if they see, hear, or otherwise recognize  signs of an inappropriate or unsafe situation. The Marine Corps has  implemented and the Navy is in the process of adopting a program called  Mentors in Violence Prevention training. Like the Air Force’s program, this  consists of role-playing exercises that allow students to construct and  practice ways to respond or intervene in incidents of harassment, abuse,  or violence.
Third, OSD chartered the Health Affairs Sexual Assault Task Force to  address our recommendation to evaluate and develop an action plan to  address factors that may prevent or discourage servicemembers from  seeking health services. In March 2009, the task force made a number of  recommendations intended to improve the availability of health care, such  as (1) chartering a military health system Sexual Assault Health Care  Integrated Policy Team to review department-level policies regarding  clinical practice guidelines, standards of care, research gaps and  opportunities, personnel and staffing, training requirements and  responsibilities, continuity of care, and in-theater equipment and supplies;  (2) drafting model memorandums of understanding for use by all service  military treatment facilities as they establish continuity of care  relationships with local community providers; and (3) reviewing DOD  policy, including performing peer reviews of sexual assault cases to ensure  that they are aligned with civilian practices.
Fourth, in August 2008, the Defense Task Force on Sexual Assault in the  Military Services began its examination of matters relating to sexual  assault, as we recommended. According to task force staff, the task force  has conducted interviews and focus groups with sexual assault prevention  and response program personnel at approximately 60 locations throughout  the world. However, the task force did not meet its August 11, 2009,  reporting deadline. It was granted an extension, which it met by releasing  its report on December 1, 2009.
section_title: DOD’s Efforts toward Implementing the Five Other Recommendations from 2008 Reflect Less Progress
paragraphs: DOD’s efforts to implement the five other recommendations we made in  our report issued in August 2008 reflect less progress. Further, remaining  issues with OSD’s strategic planning efforts and DOD’s annual report to  Congress on alleged sexual assault incidents are likely to hinder the  effectiveness of DOD’s efforts to oversee its programs.
subsections: section_title: OSD’s Oversight Framework Has Been Drafted, but It Lacks Key Elements Necessary for Comprehensive Oversight
paragraphs: OSD recently drafted an oversight framework, but the framework only  partially satisfies our recommendation in that the framework does not  contain all the elements that we previously recommended as necessary for  effective strategic planning and program implementation. Further, the  draft oversight framework cannot be implemented until it is approved—a  step that OSD officials stated will occur once they have incorporated  revisions from and obtained the endorsements of the military service  secretaries. Based on our prior work on the importance of strategic  program planning guidance and our finding that OSD had not established  an oversight framework to guide the implementation of its programs, we  recommended in August 2008 that OSD develop an oversight framework  that includes, at a minimum, (1) long-term goals, objectives, and  milestones; (2) performance goals and strategies to be used to accomplish  goals; and (3) criteria for measuring progress.
To its credit, OSD, in October 2009, completed drafting and is preparing to  begin a 3-year implementation of its oversight framework to improve the  oversight and integration of the department’s sexual assault prevention  and response programs. This draft oversight framework contains long- term goals, objectives, and milestones for implementation. For example, it  identifies nine objective-like elements—called “improvement  opportunities”—to facilitate program oversight. Examples of the  improvement opportunities include defining core oversight roles and  responsibilities, standardizing performance measures and reports, and  improving communication with stakeholders. The draft framework also  identifies action-oriented steps that correspond with and are designed to  facilitate the achievement of these opportunities. For example, the draft  framework specifies that OSD will “define and document the policy  development, coordination, and approval process” and “define and  document the process to review alignment between policy and program  development” as specific steps toward the achievement of its objective of  defining core oversight roles and responsibilities. Table 1 details the nine  opportunities and selected steps for achieving them that are contained in  the draft framework.
OSD’s draft oversight framework is a positive step toward stronger  management of the department’s sexual assault prevention and response  programs. Further, OSD recently restructured its Sexual Assault Advisory  Council and established the Oversight Steering Committee to more  actively involve DOD’s top leadership in the development and  implementation of the department’s sexual assault prevention and  response initiatives. For example, DOD’s instruction specifies that the  Sexual Assault Advisory Council shall be chaired by the Under Secretary  of Defense for Personnel and Readiness and shall comprise top DOD  leadership, including the Deputy Under Secretary of Defense for Plans, the  military departments’ assistant secretaries for manpower and reserve  affairs, and the Vice Chairman of the Joint Chiefs of Staff. While the  establishment of such committees is an important step toward successful  implementation of the oversight framework, implementation will require  the personal involvement of top DOD leadership to maintain the long-term  focus on and accountability for program objectives.
Further, OSD’s draft oversight framework is missing key elements that are  needed to provide comprehensive oversight of DOD’s sexual assault  prevention and response programs. Specifically, OSD’s framework lacks  performance measures, does not identify how it will use or report the  results of its performance assessments, does not identify how OSD’s  budgeting of resources relates to its achievement of strategic program  objectives, and does not correlate with the program’s two strategic plans.
section_title: Draft Oversight Framework Lacks Performance Measures and Details on How Measures Will Be Used to Guide Program Improvements
paragraphs: OSD’s draft oversight framework does not satisfy our recommendation  from 2008 in that it does not yet contain performance measures, which are  needed to facilitate the evaluation of program performance and the  identification of areas needing improvement. Our prior work has shown  that managers can use performance information to identify problems and  develop solutions that will improve program results. Currently, OSD has  plans to develop a standardized set of performance measures and targets  by the second year of its 3-year plan for implementing its oversight  framework. We note that our prior work has highlighted the importance of  performance measures and that they should include quantifiable,  numerical targets or other measurable values for determining (1) whether  the desired performance results are being achieved and (2) overall  program progress. Until performance measures are established, OSD  cannot accurately assess the progress of the department’s initiatives or  correctly identify and implement actions to improve program  performance.
section_title: OSD’s Draft Oversight Framework Does Not Identify How Its Budgeting of Resources Relates to the Achievement of Strategic Objectives
paragraphs: In addition to its lack of performance measures, OSD’s framework does  not identify how OSD’s budgeting of resources relates to its achievement  of strategic program objectives, which limits the department’s ability to  inform budget formulation and execution decisions according to  performance considerations. Our prior work has demonstrated that by  linking program plans with budgets, organizations can more explicitly  guide budget discussions and can assist management by correlating total  resources consumed with actual results achieved. While these  correlations have not been made in the draft framework, OSD officials told  us that the process of developing the framework helped to identify the  need and gain approval for 21 full-time employees, which is three times the  number of staff originally approved for that office. However, until OSD  explicitly correlates its budgeting of resources to the achievement of  strategic program objectives, it will be challenged in its justification of  future budget requests.
section_title: Draft Oversight Framework Does Not Correlate with the Program’s Strategic Plans
paragraphs: OSD’s strategic planning documents do not correlate with the program’s  two strategic plans. Our prior work has shown that clear linkages among  long-term strategic goals, objectives, strategies, and day-to-day activities  are critical for enabling a strategic plan to drive an organization’s  operations. In addition to its draft oversight framework, OSD drafted an  internal strategic plan to guide the initiatives of DOD’s Sexual Assault  Prevention and Response Office, and a DOD-wide strategic plan to guide  initiatives across the larger DOD community. According to OSD officials,  the oversight framework, when approved, will support OSD’s ability to  meet the goals of its strategic plans, which were designed to serve as the  overarching program planning guidance.
However, the intended correlation among these three documents is not  clear because they do not use similar terminology to clearly link their  purposes. For example, OSD’s internal strategic plan is based on five  “strategic objectives” that are identical to the five “strategic sexual assault  prevention and response priorities” contained in the DOD-wide strategic  plan. In contrast, the draft oversight framework contains terminology that  is different from both strategic plans, and it refers to its nine objective-like  elements as “future state improvement opportunities.” As a result, the  correlation between these three documents is not clear. Further, the two  strategic plans and the draft oversight framework do not clearly illustrate  how each supports the achievement of the objectives and strategies  contained in the other two documents. In commenting on a draft of this  report, DOD further defined the relationship between the draft oversight  framework and its two strategic plans for sexual assault prevention and  response programs. DOD also noted that the objective-like elements in its  draft oversight framework were purposely not tied to the program  objectives in the two strategic plans. However, without consistent  terminology and clearly correlated objectives and strategies among these  three documents, the prioritization of and responsibility for these  initiatives will remain unclear. (See app. II for DOD’s comments)
section_title: Training Effectiveness Cannot Be Fully Determined without Performance Measures
paragraphs: While OSD has taken steps to evaluate the effectiveness of the sexual  assault prevention and response training provided to DOD  servicemembers, training programs cannot be assessed because OSD’s  strategic plans and draft oversight framework do not contain measures  against which to benchmark performance. As we reported in August 2008,  DOD’s sexual assault prevention and response training was not  consistently administered or evaluated for effectiveness. Accordingly, we  recommended that DOD undertake an evaluation of the department’s  training programs. To its credit, OSD’s training subcommittee reviewed  the military services’ training policies and found that they continue to  provide initial and refresher training for all personnel. However, it also  found that a greater level of detail was needed in policy to guide the  execution of training requirements. OSD’s training subcommittee  developed an action plan for fiscal year 2009 that included visits to  selected military installations to review sexual assault prevention and  response training programs.
Nevertheless, OSD’s draft oversight framework does not include  performance measures, thus limiting OSD’s ability to assess the  effectiveness of training programs and other initiatives. OSD officials, as  part of their recent strategic planning efforts, have acknowledged the need  for and are planning to develop a standard set of DOD-wide performance  measures over the next few years for DOD sexual assault prevention and  response programs. However, they have stated that these performance  measures will not be established until at least the second year of DOD’s 3- year implementation plan for the oversight framework. Until these  measures are established, we continue to assert that OSD cannot ensure  that the department’s sexual assault prevention and response training  effectively imparts an awareness of the subject matter to servicemembers.
section_title: Staffing of Key Installation- Level Program Positions Has Not Been Evaluated
paragraphs: DOD has not implemented our recommendation to evaluate the military  services’ processes for staffing key installation-level program positions to  ensure that they have the ability and resources to fully carry out their  responsibilities. In fiscal year 2008, OSD and the military services  examined program staffing processes during OSD’s assessments of  selected military installations, and similarly concluded that DOD’s policy  on selection criteria and scope of duty for key program personnel should  be further evaluated. However, OSD officials stated that they had not  taken action to address their findings because personnel from the  congressionally mandated Defense Task Force on Sexual Assault in the  Military Services advised OSD that they would be making related  recommendations in their December 2009 report to Congress. Until DOD  implements our 2008 recommendation, it cannot ensure that it is able to  adequately staff and resource its sexual assault prevention and response  programs.
section_title: Installation-Level Data Are Not Being Collected While Centralized Database Is under Development
paragraphs: While the military services have agreed to provide installation-level data  on sexual assault incidents, OSD officials told us that they will not collect  them until they have implemented the statutorily mandated centralized  database to maintain these data. (For a discussion of this database, see a  later section of this report.) As we reported in our August 2008 report,  OSD could not conduct a comprehensive cross-service trend analysis  because it did not have access to installation-level data on sexual assault  incidents from the military services. As such, we recommended that the  military services provide these data to OSD to facilitate the analysis of  sexual assault-related data and to better target resources over time.  However, OSD is not currently collecting these data, despite their  availability, because it has not yet completely standardized its data  definitions and data elements. OSD and its stakeholders have started to  create a standardized set of sexual assault data elements, thus delineating  the types of data to be provided by each of the services. However, OSD  officials told us that the process of developing and training the numerous  program personnel worldwide to collect and report standardized data  elements will be a very complex and time-consuming undertaking.  Further, OSD officials stated that they plan to finalize the data definitions  in the coming months, but added that similar to the data elements, they  will not require that the definitions be used by the military services until  the implementation of DOD’s sexual assault incident database, the date of  which is not yet known. Therefore, it is unknown when OSD will establish  baseline data, which are needed to conduct trend analyses of the military  services’ sexual assault data.
section_title: DOD’s Annual Report to Congress Is Not Comprehensive
paragraphs: While OSD introduced some changes in DOD’s annual report to Congress,  these changes have not sufficiently improved the report to ensure that  congressional stakeholders are better informed on DOD’s prevention of  and response to incidents of sexual assault. As we previously reported,  DOD’s annual report may not have been effectively characterizing  incidents of sexual assault in the military services, and thus we  recommended that the department improve the usefulness of its annual  report as an oversight tool. To its credit, OSD incorporated new charts  and graphics into DOD’s fiscal year 2008 annual report that more  specifically illustrated the demographics of individuals involved and the  locations in which sexual assaults in the military have been occurring.  Further, OSD and its stakeholders have started to create a standardized set  of sexual assault data elements and definitions. However, the  standardization is not yet complete, and as noted previously, OSD officials  told us that developing definitions and data elements for and training the  numerous program personnel worldwide on how to consistently report on  the data elements collected, is very complex and time-consuming. OSD  officials added that the standardization of data definitions is something  that they expect to accomplish in the near term, while standardizing data  elements will take longer since it is a task that will be completed in  conjunction with their development of a centralized sexual assault  database. Further, OSD has not provided its own analysis of the military  services’ reports and programs, and we do not believe that it will be able  to do so until it establishes performance measures with which it can  assess program effectiveness.
We believe that the format of the information provided in DOD’s annual  report to Congress continues to complicate the reader’s ability to establish  a comprehensive understanding of the department’s sexual assault  prevention and response programs. Our prior work shows that the  usefulness of data ultimately depends on the degree of confidence that  users have in the data being presented. Higher confidence can be achieved  by providing key information about the data being reported, including  efforts to validate data and the implications of the data limitations that  have been identified. However, we believe the sexual assault incident  data are not qualified at the outset of DOD’s annual report to disclose that  incident data may include an alleged sexual assault that occurred prior to  the victim’s or perpetrator’s military service or outside of the year in which  it was reported. Our prior work shows that standardized data with  common definitions are critical to ensuring that comparable information  from multiple sources is accurately represented. However, the military  services’ sections in the annual report contain similar but not comparable  types of information. For example, the Army and Air Force structure their  respective reports according to the category of program information, and  the Navy and Marine Corps structure their report according to the  responses received from program personnel involved in their sexual  assault prevention and response initiatives. While we do not advocate for  one military service’s approach over another’s, the dissimilar report  formats make it difficult, if not impossible, to compare program efforts.
OSD officials told us that they have taken initial steps to address some  data inconsistencies by providing the military services with a data  collection template to begin the process of standardizing the collection  and reporting of sexual assault program information in DOD’s fiscal year  2009 annual report to Congress. This is an important first step; however, it  does not fully address our concerns in that the military services may still  be reporting data that are based on different criteria. Further, while we  recognize that the complete standardization of the type, amount, and  format of the military services’ data will be a significant undertaking, OSD  will not be able to report consistent data on the status and condition of  DOD’s sexual assault prevention and response programs until these issues  are resolved. Until OSD and the military services reach consensus on the  data elements and begin disseminating the new data collection and  reporting requirements to program personnel, DOD will continue to lack  key information needed for oversight.
section_title: DOD Has Yet to Establish a Centralized Sexual Assault Database
paragraphs: DOD has taken preliminary steps to implement a centralized, case-level  sexual assault incident database. However, the database was not  implemented by the statutorily mandated deadline of January 2010.  Moreover, when the database will be implemented is uncertain because a  reliable schedule to guide acquisition and implementation tasks and  activities has yet to be developed. In addition, other key information  technology management practices that are essential to successfully  acquiring and implementing the database also remain to be accomplished.
DOD officials agreed that these key practices need to be implemented;  however, they have yet to develop plans or time frames for doing so.
The National Defense Authorization Act for Fiscal Year 2009 required DOD  to implement a centralized, case-level database for collecting and  maintaining information on sexual assaults involving members of the  Armed Forces, including information, if available, about the nature of the  assault, the victim, the offender, and the outcome of any legal proceedings  in connection with the assault. The law also required the Secretary of  Defense to submit a concept plan for this database to Congress by January  2009 and to implement the database by January 2010. In response to these  statutory requirements, the Under Secretary of Defense for Personnel and  Readiness instructed the Sexual Assault Prevention and Response Office  to develop the Defense Sexual Assault Incident Database. According to  OSD officials, this database is to generate congressionally mandated  annual reports, run ad hoc queries, track sexual assault victim support  services, support program administration, meet program reporting  requirements, and perform data analysis. Among other things, the database  is also to ensure the privacy and restricted reporting options of victims.
subsections: section_title: DOD Did Not Meet the Statutory Deadline for Implementing the Database, and It Does Not Have a Schedule with Reliable Time Frames for Doing So
paragraphs: DOD has established conceptual plans for acquiring and deploying a  centralized sexual assault incident database. According to these plans, the  database will be delivered in two increments, with the first increment  consisting of four phases. (See table 2 for a description of the increments  and phases.) However, these phases have not yet been decomposed into  meaningful work tasks, activities, and events, including timeframes and  resources needed to execute them. Moreover, other important practices  associated with creating a reliable schedule of when and how these phases  will be accomplished have yet to be satisfied. Specifically, our research  has identified nine practices associated with developing and maintaining a  reliable schedule. These practices are (1) capturing all key activities, (2)  sequencing all key activities, (3) assigning resources to all key activities,  (4) integrating all key activities horizontally and vertically, (5) establishing  the duration of all key activities, (6) establishing the critical path for all  key activities, (7) identifying float between key activities, (8) conducting a  schedule risk analysis, and (9) updating the schedule using logic and  durations to determine the dates for all key activities. According to  program officials, the steps and associated time frames for the increments  and phases identified in table 2 cannot be reliably determined until the  development and implementation contractor is hired, which will not occur  until sometime after March 31, 2010. This means that the program office  currently lacks the necessary means by which to execute a system  acquisition, gauge progress, identify and address potential problems, and  promote accountability.
In addition, DOD’s current plans include a few general milestones. For  example, OSD officials told us that the first phase of the initial increment  was to have been achieved when they provided a “proof-of-concept”  document to Congress in January 2010. However, this document has yet to  be approved. Further, they stated that they intend to release a Request for  Proposals for a database developer in the second quarter of fiscal year  2010. Based on these milestones and the absence of a reliable program  schedule, DOD did not meet its legislative mandate to implement the  database by January 2010, and when it will implement the database is  uncertain.
section_title: DOD’s Success in Acquiring and Implementing the Database Depends on Its Use of Key Management Practices
paragraphs: OSD program officials stated that they received milestone approval in July  2009 from the milestone decision authority, the Acting Deputy Under  Secretary of Defense for Program Integration, to conclude the Materiel  Solution Analysis (previously Concept Refinement) phase and begin the  Technology Development phase of DOD’s acquisition system. Associated  with this progression, DOD has taken steps to begin employing a number  of key information technology acquisition management disciplines that are  provided for in DOD and related guidance. Our research and evaluations  of information technology programs across the federal government have  shown that adhering to such disciplines is essential to delivering promised  system capabilities and benefits on time and within budget. Among other  things, these disciplines include assessing a program’s overlap with and  duplication of related programs through architecture compliance,  justifying investment in the proposed system solution on the basis of  reliable estimates of life cycle costs and benefits, effectively developing  and managing system requirements, adequately testing system capabilities,  and effectively managing program risks. However, DOD has yet to  progress to the point that it can demonstrate that these disciplines have  been fully implemented, as discussed below. Until it does, the chances of it  successfully delivering the database are reduced.
Architectural alignment: DOD’s guidance and other guidance  recognize the importance of investing in business systems within the  context of an enterprise architecture. Additionally, our experience in  reviewing federal agencies has shown that making investments  without the context of a well-defined enterprise architecture often  results in systems that are, among other things, duplicative of other  systems. Within DOD, the means for avoiding business system  duplication and overlap is the department’s process for assessing  compliance with DOD’s business enterprise architecture and its  associated investment review and decision-making processes. DOD  officials told us that the database was assessed for compliance with  the business enterprise architecture and received investment review  board approval as compliant in July 2009. However, a complete set of  system-level architecture products needed to perform a thorough and  meaningful compliance assessment are not yet available. As we have  previously reported, architecture compliance is not a onetime event  but rather a determination that needs to be made at key junctures in a  system’s acquisition life cycle. If it is not, unnecessary overlap and  duplication with other systems, as well as system interoperability  shortfalls, can occur.
Economic justification: Our prior work has shown that a reliable  cost estimate is critical to informed investment decision making,  realistic budget formulation and justification, program resourcing,  meaningful progress measurement, proactive course correction, and  accountability for results. Further, according to Office of Management  and Budget (OMB) guidance, justifications for an investment should  include an analysis of the investment’s total life cycle cost. DOD  developed a business case for the database in June 2009 that provides  the department’s proposal and justification for its database (i.e.,  system solution), and this business case includes a program cost  estimate of $12.6 million. While the cost estimate was derived in  accordance with some best practices identified in relevant cost  estimating guidance, such as estimating software costs with a  parametric tool that incorporates GAO cost estimating best practices  and relying on the costs of analogous existing systems, it was not done  in accordance with others. For example, it does not include all costs  over the system’s life cycle, and it has not been adjusted to account for  program risks. More specifically, program officials stated that the $12.6  million does not include program office and management costs,  relevant development costs (e.g., testing), or sustainment costs (i.e.,  operations and maintenance). OSD officials told us that they intend to  develop a reliable cost estimate once the development contract is  awarded. Without reliable estimates, a proposed system solution  cannot be adequately justified on the basis of costs and benefits, and  DOD may be at increased risk of experiencing cost overruns, schedule  slippages, and performance shortfalls.
Beyond not having a reliable cost estimate, DOD’s business case does  not comply with other OMB guidance. According to OMB, the  economic analysis used to justify an investment should meet certain  criteria to be considered reasonable, including comparing alternatives  on the basis of net present value and conducting an uncertainty  analysis of benefits. While the business case includes an explanation of  why the database is needed, it does not address the costs and benefits  associated with each of the four database alternatives that were  considered (i.e., commercial-off-the-shelf case management system  software product, custom-built system, enhancement of an existing  military service system, or maintenance of the status quo). Moreover,  the four alternatives were not assessed on the basis of net present  value, including using the proper discount rate to account for inflation.  Instead, only the selected alternative was evaluated quantitatively.  Without a meaningful analysis of alternatives, DOD lacks sufficient  assurance that it has selected the most cost-effective system solution.
Requirements development and management: Well-defined and  well-managed requirements are the cornerstone of effective system  development and acquisition. Effective requirements development  and management includes, among other things, (1) effectively eliciting  user needs early and continuously in the system life cycle process, (2)  establishing a stable baseline set of requirements and placing the  baseline under configuration management, (3) ensuring that system- level requirements can be traced back to higher-level business or  operational requirements (e.g., concept of operations) and forward to  system design documents (e.g., software requirements specification)  and test plans, and (4) controlling changes to baseline requirements.  DOD has begun to take steps to engage users in the development of  requirements. For example, it formed a working group composed of  representatives from each of the military services and the National  Guard to develop high-level system requirements. Further, program  officials stated that additional actions are planned or under way to  reach agreement on system interfaces, which is important given that  the database is to draw data from multiple systems to satisfy statutory  requirements. They also said that users will be further involved in  developing requirements. For example, DOD is working with the Air  Force and National Guard to define more specific functional,  performance, and data requirements, and has initiated discussions  with the Army, Navy, and Marine Corps to do the same. In addition,  program officials stated that once the high-level system requirements  are baselined, the Change Control Board, comprising representatives  from DOD and the user community, will be established to control  changes to the baseline requirements. While these ongoing and  planned actions are positive, they represent only the beginning of a  series of actions that are associated with effectively defining and  managing requirements over a system’s acquisition life cycle. To the  extent that this series of actions is not well detailed and implemented,  the risk of the database not performing as intended, and costing more  and taking longer to implement than necessary, is increased.
Test management: According to DOD and other relevant guidance,  system testing should be progressive, meaning that it should consist of  a series of test events that first focus on the performance of individual  system components, then on the performance of integrated system  components, followed by system-level tests that focus on whether the  system (or major system increments) are acceptable, interoperable  with related systems, and operationally suitable to users. Among  other things, effective testing should ensure that (1) all test events are  governed by a well-defined test management structure, (2) each test  event is executed in accordance with well-defined plans, and (3) the  results of each test event are captured and used to ensure that  problems discovered are disclosed and corrected. Program officials  stated that they plan to work with the development contractor to  establish an effective test management structure, develop test plans,  and capture and resolve problems found during testing. In addition,  they plan to engage an independent test organization. However, DOD  has not yet developed milestones for its testing plans or activities.
Unless adequate testing is performed and key test management  structures and controls are established, it is unlikely that the database  will meet user expectations and mission needs, and the risk of it  costing more and taking longer than planned is increased.
Risk management: Proactively managing program risks is a key  acquisition management control that if done properly, can increase the  chances of programs delivering promised capabilities and benefits on  time and within budget. Relevant guidance, including DOD’s Risk  Management Guide for DOD Acquisition, recognizes the importance  of conducting effective risk management. Among other things,  effective risk management includes (1) establishing and implementing  a written plan and defined process for risk identification, analysis, and  mitigation; (2) assigning responsibility for managing risks to key  stakeholders; (3) encouraging programwide participation in risk  management; and (4) examining the status of identified risks during  program milestone reviews. Program officials stated that they intend  to document and implement a risk management strategy that is  consistent with DOD’s Risk Management Guide. To its credit, the  program office has begun to identify key risks. For example, it cited  identified risks related to (1) what officials believed to be an  unattainable congressionally mandated database implementation date  of January 2010; (2) staffing shortages that complicate the office’s  ability to develop and gain approval of a large number of key  documents (e.g., privacy impact assessments, documentation required  for investment reviews, and updates of relevant DOD instructions,  etc.); (3) potential shortfalls in system development and maintenance  funding issues; (4) limitations of the military services’ systems, which  are expected to provide data to DOD’s database; and (5) the military  services’ competing priorities, which may jeopardize their support and  involvement. However, they have yet to begin proactively managing  these risks. Unless this is done, the risks could evolve into actual cost,  schedule, and performance shortfalls.
section_title: Coast Guard Has Partially Implemented One of Our Two Recommendations from 2008
paragraphs: The Coast Guard has partially implemented one of our recommendations  from 2008 to further develop its sexual assault prevention and response  program, but it has not addressed the other. To its credit, the Coast Guard  conducted an assessment of its processes for staffing key program  positions and has continued to develop, through a variety of initiatives,  other components of its sexual assault prevention and response program.  However, the Coast Guard has not addressed our recommendation to  develop an oversight framework, and its program is challenged by the lack  of a systematic process for collecting, documenting, and maintaining  sexual assault data and by the lack of training for program coordinators.
subsections: section_title: The Coast Guard Has Taken Steps to Implement One of Our Recommendations from 2008 and Has Continued Developing Its Programs
paragraphs: The Coast Guard has taken steps to implement our previous  recommendation to evaluate its processes for staffing key program  positions. As we previously reported, Coast Guard officials told us that its  Sexual Assault Response Coordinators do not have the time to effectively  implement a sexual assault prevention and response program. Thus we  recommended that the Coast Guard evaluate its processes for staffing key  program positions to ensure that they have the ability and resources to  fully carry out their responsibilities. Coast Guard officials told us that  current levels of full-time staffing continue to hinder their ability to  appropriately implement various components of their sexual assault  prevention and response program, adding that the continuity of care for  victims is negatively affected since its coordinators do not possess the  time or the training to provide consistent case management services. To  address this, the Coast Guard, in June 2009 initiated an assessment of the  current workload requirements and resource allocations for its Sexual  Assault Response Coordinators. Officials told us that they plan to use the  results of this assessment to determine whether the responsibilities of the  position or associated resource levels need to be revised. Coast Guard  officials also noted that the assessment is to be completed by December  2009, and that they hope to address any program recommendations within  2 years of the assessment’s completion. While these are positive first steps,  they do not fully address our findings and recommendation from 2008  because the Coast Guard has yet to complete its assessment and decide  what, if any, program modifications it will make. The Coast Guard also  established two new program positions in response to findings in our  previous report. Specifically, in September 2008, the Coast Guard  established a headquarters-level program manager position to oversee the  management of, training for, and evaluation of its sexual assault  prevention and response program. The Coast Guard also established a  Sexual Assault Response Coordinator position at its academy to manage  its sexual assault prevention and response program.
While the Coast Guard is not generally subject to the departmental  direction or statutory requirements that apply to DOD, it has developed an  instruction that charges responsible personnel with establishing policies  and procedures for its program. To the Coast Guard’s credit, Coast Guard  officials stated that they frequently leverage program information and  materials obtained through their regular participation in OSD’s Sexual  Assault Advisory Council subcommittees and working groups and the  military services’ conferences and summits. For example, the Coast Guard  recently modeled its victim advocate training after the Navy’s curriculum,  and it is revising its data collection requirements to mirror those of DOD.  The Coast Guard is also modifying its sexual assault prevention and  response program instruction to clarify its definition of sexual assault and  revise its description of selected program positions to better reflect  program responsibilities. Coast Guard officials stated that they plan to  issue the revised instruction in spring 2010.
section_title: The Coast Guard Has Not Implemented Our Second Recommendation from 2008, and Its Program Is Hindered by Accountability Issues
paragraphs: With respect to our second recommendation, the Coast Guard’s efforts to  establish a program oversight framework have been limited. Although the  Coast Guard has identified broad program objectives, it has not addressed  our recommendation to develop an oversight framework that provides  comprehensive and specific guidance for operating its programs. Further,  the Coast Guard’s program lacks a systematic process for assembling,  documenting, and maintaining sexual assault incident data, lacks quality  control procedures to ensure that the program data being collected are  reliable, and the Coast Guard has yet to complete the development and  implementation of training for key program personnel. As a result, the  Coast Guard’s program development efforts continue to be hindered by its  inability to evaluate program effectiveness, to accurately account for  sexual assault incidents, to prioritize program initiatives, and to help  ensure that program personnel are trained to properly execute their  responsibilities.
subsections: section_title: Coast Guard Has Not Developed an Oversight Framework
paragraphs: The Coast Guard has not developed an oversight framework to guide its  program development and implementation, despite its concurrence with  our August 2008 recommendation that it do so. Our prior work has  demonstrated the importance of results-oriented performance measures to  successful program oversight, and has shown that having an effective plan  for implementing initiatives and measuring progress can help decision  makers determine whether initiatives are achieving their desired result.  As we previously reported, the Coast Guard was not able to fully evaluate  the results achieved by its efforts, and thus we recommended that it  develop an oversight framework that at a minimum includes long-term  goals, objectives, and milestones; performance goals; strategies to be used  to accomplish goals; and criteria for measuring progress. The Coast  Guard revised its program instruction to clarify departmental oversight  roles, and it has developed an action plan that broadly defines program  goals, objectives, strategies, milestones, and criteria. However, based on  our prior work on developing and enhancing program oversight, the Coast  Guard’s efforts do not sufficiently encompass the key components of an  oversight framework. For example, the Coast Guard’s action plan does not  contain performance measures, nor does it identify how it plans to use the  results of its program evaluations to revise its future program objectives.  Furthermore, the strategies identified in its action plan are too vague to  enable an assessment of whether they would help achieve program goals  and objectives. For example, the Coast Guard’s action plan includes as one  of the long-term program objectives, “provide updated, consistent  information on program reporting options and resources,” and the  corresponding strategy is simply, “purchase and distribute marketing  materials to the field,” without specifying how or when it plans to achieve  this objective.
Further, the Coast Guard has not correlated program objectives and  strategies with its internal budget requests, which limits its ability to  effectively allocate and account for program resources. As we noted  previously, our prior work shows that having program plans clearly linked  with budgets allows an organization to more explicitly guide budget  discussions and can assist program management by connecting total  resources consumed with actual results achieved. Thus, we continue to  believe that our recommendation has merit, and that the Coast Guard will  remain limited in its ability to manage and evaluate its sexual assault  prevention and response program until it develops and implements an  oversight framework.
section_title: Coast Guard Does Not Have a Systematic Process to Collect, Document, and Maintain Sexual Assault Incident Information
paragraphs: The Coast Guard does not have a systematic process to collect, document,  and maintain its sexual assault data and related program information. The  Coast Guard’s instruction charges responsible program personnel with  establishing a reporting system to evaluate statistical data related to  sexual assault incidents, maintaining records to identify victims and track  services provided, and providing oversight of quality assurance review  processes to ensure the provision of quality services. Additionally, our  prior work has shown that organizations striving to meet program goals  must have information systems in place to meet the modern need for fast,  reliable, and accurate information. However, the Coast Guard’s sexual  assault program does not currently have a systematic process to collect,  document, and maintain its sexual assault incident data. One individual  maintains a hard copy log, informed by reports from coordinators in the  field, and if necessary, may call these coordinators to get additional  information. At the conclusion of our review, Coast Guard officials told us  that they are in the process of developing a prototype to enable personnel  to electronically manage sexual assault cases, and that they expect to  conduct an assessment of prototype capabilities in early 2010. However,  until the Coast Guard establishes a systematic process for the collection,  documentation, and maintenance of these data, it will be challenged in its  ability to efficiently retrieve data and its visibility over sexual assault  incidents will remain limited.
Additionally, the Coast Guard has not instituted quality control processes  to ensure the reliability of the sexual assault incident and program data  being collected. Our prior work has highlighted the importance of  organizations assessing the quality of their program data and ensuring that  these data are complete and reliable. However, the Coast Guard has not  established a process to periodically assess the sufficiency of the program  information it collects. For example, Coast Guard officials noted that in  fiscal year 2008, the Coast Guard Investigative Service, in the course of its  investigations, documented 78 reports of sexual assault, while Coast  Guard Headquarters, using the hard copy log of reports from its  coordinators, had documented only 30. Further, the Coast Guard’s sexual  assault prevention and response instruction requires that commanding  officers “ensure completion of mandatory annual training on sexual  assault prevention by all unit personnel.” However, officials told us that  the current system used to track training is designed to report training  compliance at the unit level, and while individual training compliance can  be discerned, the process to do so is overly cumbersome. As a result, this  practice complicates the Coast Guard’s ability to oversee whether  personnel are completing their required training. Officials added that unit  compliance with training is assessed during inspections that occur every 2  to 3 years, and the responsible command is notified if any problems are  identified. Further, Coast Guard officials told us that while there is no  systematic process for following up on the findings from these  inspections, they are confident that the issues are taken seriously and  appropriately addressed. However, we believe that until the Coast Guard  establishes a systematic process to assess the quality and reliability of its  data, it cannot be sure that the information it collects is relevant to and  sufficient for the achievement of its program goals.
section_title: The Coast Guard Has Not Trained Its Program Coordinators
paragraphs: The Coast Guard recently developed and is starting to conduct training for  its victim advocates however, it has not provided training for its Sexual  Assault Response Coordinators—the personnel who manage the victim  advocates. The Coast Guard’s instruction requires that all Coast Guard  Sexual Assault Response Coordinators be trained to perform relevant  duties, and prohibits them from accepting a restricted sexual assault  report until the training has been completed. However, Coast Guard  officials stated that they have not developed a curriculum or implemented  training for the Coast Guard’s 16 Sexual Assault Response Coordinators,  because, alternatively, they were developing and implementing a training  curriculum for victim advocates. Coast Guard officials initially told us that  it would likely take up to 2 years to develop a formalized curriculum for  Coast Guard Sexual Assault Response Coordinators, but that in the  meantime, they have scheduled a training session for coordinators in  January 2010 to review policy revisions and reporting processes. At the  conclusion of our review, Coast Guard officials stated that they have since  updated their plans to train Sexual Assault Response Coordinators, noting  that they plan to complete a formalized curriculum by May 2010 and have  scheduled training for the Coordinators during the week of May 4, 2010.
However, until such training is administered, Sexual Assault Response  Coordinators will lack formalized Coast Guard sexual assault prevention  and response training, and according to Coast Guard officials, they will  rely instead only on the general mandated training provided to all  personnel, their own professional experience, and their interpretation of  the Coast Guard’s sexual assault prevention and response policy.
Additionally, the Coast Guard’s Sexual Assault Program Manager plans to  travel to Coast Guard installations throughout the country to administer  annual victim advocate training, which will eventually be administered by  coordinators. However, this may not be the most effective use of  resources, as the training could be administered by trained Sexual Assault  Response Coordinators. Until a formal curriculum is developed and  implemented, the Coast Guard cannot be sure that it has effectively  imparted program responsibilities and requirements to its Sexual Assault  Response Coordinators.
section_title: Conclusions
paragraphs: Since the release of our August 2008 report, DOD has taken a number of  positive steps toward addressing our recommendations to further  strengthen its sexual assault prevention and response programs and to  develop the statutorily mandated sexual assault incident database.  Additionally, each service has proactively developed and implemented a  variety of initiatives—beyond what we recommended—to increase  program awareness and to improve prevention of and response to  occurrences of sexual assault. While such progress is noteworthy, DOD’s  efforts have not fully established a sound management framework, which  must build upon the foundation of a comprehensive strategic framework  that guides program development and implementation. Without such a  foundation, DOD’s programs lack the institutional support, long-term  perspective, and clear lines of accountability that are needed to withstand  the administrative, fiscal, and political pressures that confront federal  programs on a daily basis. Until OSD finalizes and fully implements its  oversight framework and strategic plans, it will continue to lack the ability  to synergize its prevention and response initiatives, and it may not be able  to effect the change in military culture that is needed to ensure that  programs are institutionalized. Additionally, successful implementation of  the oversight framework will require the personal involvement of top DOD  leadership to maintain the long-term focus on and accountability for  program objectives.
While the Coast Guard is not generally subject to the departmental  program direction or statutory requirements that apply to DOD, it  continues to proactively develop its sexual assault prevention and  response program. The Coast Guard has, however, experienced challenges  similar to those of DOD because it lacks the long-term strategic  perspective needed to structure its program development and  implementation. Until the Coast Guard develops an oversight framework  that includes specific management improvement steps, key milestones,  and performance measures, it will be unable to accurately demonstrate  that its programs are achieving its goals of establishing a culture of  prevention, sensitive response, and accountability. Further, the Coast  Guard may not be able to demonstrate that program elements, such as its  sexual assault prevention and response training, are being implemented in  a manner that most effectively ensures its achievement of program goals.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Secretary of Defense take the following 10  actions:    To improve the management, strategic planning, and  comprehensiveness of OSD’s oversight of the department’s sexual  assault prevention and response programs, direct the Under Secretary  of Defense for Personnel and Readiness to strengthen OSD’s oversight  framework by  identifying how the results of performance assessments  will be used to guide the development of future program  initiatives,  identifying how OSD’s program resources correlate to its  achievement of strategic program objectives, and  correlating its oversight framework to the program’s two  strategic plans so that program objectives, timelines, and  strategies for achieving objectives are synchronized.
To enhance visibility over the incidence of sexual assaults involving  DOD servicemembers, the department’s sexual assault prevention and  response programs, and the pending implementation of the Defense  Sexual Assault Incident Database, direct the Under Secretary of  Defense for Personnel and Readiness to standardize the type, amount,  and format of the data in the military services’ annual report  submissions.
To enhance the oversight of the sexual assault prevention and  response program in DOD, direct the Under Secretary of Defense for  Personnel and Readiness to ensure that the development and  implementation of the Defense Sexual Assault Incident Database  includes adherence to the following key system development and  acquisition management processes and controls developing a reliable integrated master schedule that  addresses the nine key practices discussed in this report,  adequately assessing the program’s overlap with and  duplication of related programs through architecture  compliance,  adequately justifying investment in the proposed approach  on the basis of reliable estimates of life cycle costs and  benefits,  effectively developing and managing system requirements,  adequately testing system capabilities, and  effectively managing program risks.
We are recommending that the Commandant of the Coast Guard take the  following three actions:    To improve the oversight and accountability of the Coast Guard’s  sexual assault prevention and response program  establish a systematic process for collecting, documenting,  and maintaining sexual assault incidence data, and  establish quality control processes to ensure that program  information collected is valid and reliable.
To improve execution of sexual assault prevention and response  programs, we recommend that the Commandant of the Coast Guard  establish and administer a curriculum for all key program personnel to  ensure that they can provide proper advice to Coast Guard personnel.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments on a draft of this report, both DOD and the Coast  Guard concurred with all of our recommendations. DOD noted in its  comments that our report contained technical inaccuracies, which we  addressed where appropriate, based on the technical comments received  from both DOD and the Coast Guard. Further, DOD asserted that the  report also contained misstatements that improperly diminished the  department’s efforts to address our recommendations. We believe that our  report accurately represents DOD’s progress to address our  recommendations from 2008. DOD’s comments are reprinted in appendix  II, and the Coast Guard’s comments are reprinted in appendix III.
In concurring with our recommendations aimed at improving the  management, strategic planning, and comprehensiveness of OSD’s  oversight of the department’s sexual assault prevention and response  programs—including that OSD should strengthen its oversight framework  by (1) identifying how the results of performance assessments will be used  to guide the development of future program initiatives, (2) identifying how  OSD’s program resources correlate with its achievement of strategic  program objectives, and (3) correlating its oversight framework with the  program’s two strategic plans—DOD commented that several efforts are  underway or are planned to address these issues. For example, DOD  stated that in the early part of 2010, it will have a plan in place that details  how it will track its progress toward the performance objectives laid out in  the DOD-wide strategic plan, and it will develop a procedure to report  back on progress toward objectives and any needed corrective steps. DOD  also stated that starting with the 2012 budget cycle, OSD plans to align its  budget categories with specific performance objectives laid out in its  strategic plan. Further, DOD noted that the process it plans to use to track  its progress toward performance objectives will also allow the department  to synchronize the objectives, timelines, and strategies of its two strategic  plans. We commend DOD for taking immediate steps in response to our  recommendations, and encourage the department to continue taking  positive actions toward fully implementing them.
In its concurrence with our recommendation that the department  standardize the type, amount, and format of the data in the military  services’ annual report submissions, DOD acknowledged that achieving  uniformity among the military services for all required data elements will  greatly enhance its oversight capabilities. DOD added that it recently  established definitions for case disposition data and developed a  standardized program report template, and that both are being used by the  military services to compile their respective data for the department’s  fiscal year 2009 report on sexual assault in the military services. DOD  stated that the comprehensive process of linking all of its data elements  will ultimately be accomplished through its development of the Defense  Sexual Assault Incident Database. Our report credits DOD with taking  initial steps toward developing standardized data elements and definitions,  and acknowledges the data template it developed and is using to collect a  more standardized set of data from the military services for the  department’s fiscal year 2009 annual report to Congress. However, as we  noted in our report, OSD officials stated that full standardization of data  elements and definitions will not be achieved until it implements the  Defense Sexual Assault Incident Database—for which DOD does not  currently have a reliable implementation schedule. While we recognize  that this will be a complex and time-consuming task, we continue to assert  that the full establishment and implementation of standardized data  elements and definitions will facilitate a more comprehensive  understanding of DOD’s sexual assault prevention and response programs.
In concurring with our recommendation to develop a reliable integrated  master schedule for the Defense Sexual Assault Incident Database, DOD  stated that it will give priority to doing so, and will follow GAO schedule  estimating guidance. However, it added that while the department has thus  far developed schedules that it characterized as capturing broader scope  key activities, it would not be able to capture key schedule activities or  estimate a timeframe for identifying key activities that are fundamental to  developing a reliable schedule until it acquired the assistance of the  system development contractor. DOD noted that this is because only the  contractor will know the steps and time required to adopt proprietary  materials to DOD’s requirements for the database. We understand the role  that the development contractor plays in developing a reliable integrated  master schedule, which is why our recommendation does not specify a  timeframe for developing the schedule, and thus allows DOD to first  acquire a contractor’s services. Further, while we agree with the  department’s comment that our report does not include an assessment of  the viability of a 15-month deadline contained in statute for the  database’s design, acquisition, and implementation, we note that we told  program officials during the course of our review that such an assessment  was not part of the scope of our work because the 15-month deadline was  a statutory requirement rather than a DOD schedule-driven milestone.
In concurring with our recommendation to adequately assess the  program’s overlap with related programs through architecture compliance,  the department stated that it acknowledges the benefits derived from  doing so. It added, however, that our report inaccurately asserts that DOD  has not complied with DOD guidance governing architecture compliance  by stating that a complete set of system-level architecture products are not  yet available to perform a thorough architecture compliance assessment.  In this regard, it stated that DOD guidance does not call for the  development of system-level architecture products until the Technology  Development Phase in the Defense Acquisition System. We agree with the  department’s comment as to the timing of system-level architecture  products, which is why we do not conclude that DOD has not assessed  architecture compliance. As stated in this report, architecture compliance  is not a onetime event but rather a determination that needs to be made at  key junctures in a system’s acquisition life cycle. Thus, the intent of our  statement and our recommendation is to emphasize the importance of  conducting compliance activities once a complete set of system-level  architecture products is available.
In concurring with our recommendation to adequately justify investment  in the proposed database approach on the basis of reliable estimates of life  cycle costs and benefits, the department stated that it agreed that the cost  estimate in the existing business case does not account for all life cycle  costs and risks. However, it added that DOD guidance does not require  comprehensive cost estimates in the business case and that the cost  estimate in the business case was derived using cost estimating best  practices. While we agree that DOD guidance does not explicitly state that  business case cost estimates must be comprehensive, both DOD guidance  and OMB guidance state that these cost estimates should include all costs  over the system’s life cycle, which is a recognized best practice. Further,  while the cost estimate was derived in accordance with some cost  estimating best practices, such as estimating software costs with a  parametric tool and relying on the costs of analogous existing systems, it  was not done in accordance with others. For example, it was not risk  adjusted. Further the business case did not include a comparison of  alternatives on the basis of net present value.
In concurring with our recommendation to effectively develop and manage  system requirements, DOD noted that it has continued to work with the  military services in developing system requirements and that its progress  in doing so is much greater than our report states. It also noted that since  the database was legislated, Congress expanded its annual sexual assault  reporting requirements, which in turn necessitated additional  requirements development work with stakeholders. Further, it stated that  it will institute a Change Control Board, which is a key requirements  management control mechanism, and is using a range of system life cycle  management tools that support requirements development and  management. We support DOD’s continued efforts to work with  stakeholders to further develop requirements and capture them in a range  of requirements documents, as such efforts are consistent with our  recommendation. Also consistent with our recommendation are its plans  to institute a Change Control Board and use relevant requirements-related  tools.
In concurring with our recommendation to adequately test system  capabilities, DOD stated that our report does not sufficiently describe its  efforts to develop a detailed test plan defining the program’s testing  approach and strategy, including the entrance and exit criteria for each  testing phase. We agree that our report does not cite the development of  this plan because no such plan was provided to us as part of the  documentation set submitted for the database’s milestone acquisition  approval, nor were we made aware of the existence of such a plan.  Moreover, program officials told us that a test plan would be developed  after the contractor was hired, and DOD’s comments on our draft report  acknowledge that a final test plan has yet to be created.
In concurring with our recommendation to effectively manage program  risks, DOD noted that our statement that risk management has yet to begin  is incorrect because key risks have been identified. We agree that risk  identification, which is the first step in risk management, has begun, as our  report recognizes. We also agree that the statement in our draft report that  risk management has yet to begin is not consistent with its recognition of  these risk identification efforts. As a result, we have modified the report to  note that many aspects of risk management have yet to begin, which DOD  also states in its comments on our draft report.
The Coast Guard also concurred with our recommendations aimed at  improving the oversight, accountability, and execution of its sexual assault  prevention and response programs, including (1) establishing a systematic  process for collecting, documenting, and maintaining sexual assault  incidence data; (2) establishing quality control processes to ensure that  program information collected is valid and reliable; and (3) establishing  and administering a curriculum for all key program personnel to ensure  that they can provide proper advice to Coast Guard personnel. In  commenting on our draft report, the Coast Guard noted that it has several  initiatives underway to continue developing its sexual assault prevention  and response program. For example, the Coast Guard stated that an  electronic database to track sexual assault reports is in the prototype  development phase, and based on current progress, it expects to complete  the database in 2010. Further, the Coast Guard noted that it has completed  an assessment of workload requirements and resource allocations for its  Sexual Assault Response Coordinators, and upon release of the final  report, the Coast Guard plans to review and analyze the recommendations  and, as appropriate, incorporate additional resource requirements into its  annual budget process. We commend the Coast Guard for the steps it has  taken and its plans for further developing its sexual assault prevention and  response program, and we encourage the service to continue taking  positive actions toward fully implementing our recommendations.
As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until thirty days from  the report date. At that time, we will send copies to interested members of  Congress; the Secretaries of Defense, Homeland Security, the Army, the  Navy, and the Air Force; the Commandant of the Marine Corps; and the  Commandant of the Coast Guard. The report also will be available at no  charge on the GAO Web site at http://www.gao.gov.
If you or your staff have any questions concerning this report, please  contact Brenda Farrell at (202) 512-3604 or farrellb@gao.gov or Randolph  Hite at (202) 512-3439 or hiter@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Key contributors to this report are listed in appendix IV.
section_title: Appendix I: Scope and Methodology
paragraphs: To determine the extent to which the Department of Defense (DOD) has  taken steps to address our previous recommendations in GAO-08-924  regarding programs to prevent and respond to sexual assault, we reviewed  relevant statutory requirements and obtained and analyzed DOD’s policies,  guidance, and procedures for the prevention of and response to sexual  assault incidents. We also interviewed officials in DOD, the Army, the Air  Force, the Navy, the Marine Corps, and the Defense Task Force on Sexual  Assault in the Military Services to gain a comprehensive understanding of  their efforts to address our previous recommendations. We also obtained  and analyzed the Office of the Secretary of Defense’s (OSD) strategic plans  and draft oversight framework for the department’s sexual assault  prevention and response efforts to determine whether they contained the  elements necessary for effective program implementation. In addition, we  obtained and analyzed DOD’s annual reports to Congress on sexual assault  in the military services for fiscal years 2007 and 2008 to assess the extent  to which OSD addressed our recommendation to improve the usefulness  of DOD’s annual report.
To determine the extent to which DOD has taken steps to address a  statutory requirement to establish a centralized, case-level sexual assault  incident database, we reviewed statutory provisions related to DOD’s  process for collecting and maintaining sexual assault data. We also  interviewed DOD officials to obtain information on the department’s  efforts to establish the database; reviewed documentation related to  database development; and compared this documentation to relevant  DOD, federal, GAO, and industry guidance.
To determine the extent to which the U.S. Coast Guard has taken steps to  address our previous recommendations regarding policies and programs  to prevent and respond to sexual assault, we identified relevant legislative  requirements and obtained and analyzed the Coast Guard’s policies,  guidance, and procedures for the prevention of and response to sexual  assault incidents. We also interviewed Coast Guard officials to gain a  comprehensive understanding of their efforts to address our previous  recommendations. We also obtained and analyzed the Coast Guard’s  action plan for sexual assault prevention and response to determine the  extent to which it consisted of the elements that we recommended be  included in an oversight framework.
We visited or contacted the following organizations during our review:    Defense Task Force on Sexual Assault in the Military Services,    Sexual Assault Prevention and Response Office, Arlington, Virginia    Office of the Assistant Secretary of Defense for Health Affairs, Falls
Defense Center of Excellence for Psychological Health and  Traumatic Brain Injury, Rosslyn, Virginia  Office of the Chairman, Joint Chiefs of Staff  J-1, Manpower and Personnel, Washington, D.C.
Sexual Harassment/Assault Response and Prevention Program Office,  Washington, D.C.
Department of the Air Force    Office of the Assistant Secretary (Manpower and Reserve Affairs),  Washington, D.C.
Office of the Deputy Assistant Secretary (Force  Management Integration), Washington, D.C.
Deputy Chief of Staff for Manpower, Personnel and Services,  Washington, D.C.
Sexual Assault Prevention and Response Program Office,  Washington, D.C.
Sexual Assault Prevention and Response Office, Washington, D.C.
Sexual Assault Prevention and Response Office, Quantico,  Virginia    Health, Safety and Work-Life Directorate, Office of Work-Life,  Washington, D.C.
We conducted this performance audit from February 2009 through  February 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: Comments from the Department of Defense
section_title: Appendix III: Comments from the U.S. Coast Guard
section_title: Appendix IV: GAO Contacts and Staff Acknowledgments
subsections: section_title: Acknowledgments
paragraphs: In addition to the contacts named above, key contributors to this report  include Marilyn K. Wasleski, Assistant Director; Neelaxi Lakhmani,  Assistant Director; Divya Bali; Stacy Bennett; Steve Caldwell; Elizabeth  Curda; Matt Dove; K. Nicole Harms; Jim Houtz; Ron La Due Lake; Kim  Mayo; Geoffrey Peck; Adam Vodraska; and Cheryl A. Weissman.