Sexual Violence: Actions Needed to Improve DOD's Efforts to Address the Continuum of Unwanted Sexual Behaviors
Released: 2017-12-18T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: Unwanted sexual behaviors in the military—including sexual harassment, sexual assault, and domestic violence involving sexual assault—undermine core values, unit cohesion, combat readiness, and public goodwill. Recent studies suggest that these behaviors are part of a “continuum of harm,” which DOD defines as a range of interconnected, inappropriate behaviors that are connected to the occurrence of sexual assault and that support an environment that tolerates these behaviors.

Senate Report 114-255 included a provision for GAO to review efforts by DOD to prevent unwanted sexual behaviors in the military. GAO assessed the extent to which DOD has (1) policies on sexual harassment that include CDC principles and relevant legislative elements; (2) processes for maintaining and reporting consistent data on incidents of unwanted sexual behaviors; and (3) overarching efforts, including a prevention strategy, to address unwanted sexual behaviors across the continuum of harm. GAO reviewed DOD policies and pertinent databases, and interviewed agency officials.

section_title: What GAO Found
paragraphs: The Department of Defense's (DOD) policies on sexual harassment include some but not all of the Centers for Disease Control's (CDC) principles for preventing sexual violence and include most relevant legislative elements. GAO identified six principles from CDC's framework for preventing sexual violence, which CDC defines as including sexual harassment. GAO found that Office of the Secretary of Defense (OSD) and military service policies generally include CDC's principles regarding prevention strategies, but none address risk and protective factors, which identify conditions or behaviors that might heighten or lower the risk of sexual harassment victimization or perpetration, respectively. Additionally, a statutory provision in fiscal year 2013 mandated that DOD, among other things, develop a comprehensive sexual harassment policy that includes prevention training, mechanisms for anonymous reporting, and mechanisms for resolving incidents of sexual harassment. OSD and service policies are generally consistent with those required elements except for the inclusion of anonymous reporting. DOD is developing a new department-wide policy that will address sexual harassment, but it is too early to determine how the policy will address these issues. Without policies that include CDC's principles and mechanisms for anonymous reporting, DOD may miss opportunities to address and potentially reduce incidents of unwanted sexual behaviors. Finally, a statutory change in fiscal year 2017 redefined sexual harassment for certain purposes so it is no longer defined solely as a form of sex discrimination but is recognized also as an adverse behavior on the spectrum of behavior that can contribute to an increase in the incidence of sexual assault. While officials indicated a need to update policies, they were unclear on the full implications, if any, of this change.

DOD has processes for maintaining and reporting consistent data on incidents of unwanted sexual behaviors including sexual assault and incidents of domestic violence that involve sexual assault, but does not have similar processes for maintaining and reporting data on incidents of sexual harassment. Specifically, DOD uses centralized databases to maintain and report data on incidents of sexual assault and domestic violence that involve sexual assault, but relies on military service-specific databases for information on incidents of sexual harassment. DOD has not established standard data elements and definitions to guide the services in maintaining and reporting data on sexual harassment. Inconsistencies in data elements and definitions generally mean that one service may be maintaining data that is more or less detailed than, or that differs from, the data maintained by other services. Such inconsistencies may create difficulties in reporting department-wide sexual harassment data, since the individual service data must be adapted to fit reporting requirements.

DOD has several overarching efforts to address unwanted sexual behaviors across the continuum of harm, including developing an overarching prevention strategy. However, it is unclear whether the strategy under development will contain key elements for long-term and results-oriented strategic planning such as long-term goals, strategies to achieve goals, and metrics to gauge progress. Without incorporating these elements into its overarching prevention strategy, DOD may not be in a position to effectively coordinate and integrate prevention activities and reduce instances of unwanted sexual behaviors.

section_title: What GAO Recommends
paragraphs: GAO recommends that DOD fully include in its new policy on sexual harassment CDC's principles for sexual violence prevention and mechanisms for anonymous reporting, develop standard data elements and definitions for reporting sexual harassment incidents, and incorporate in its overarching prevention strategy elements key for a long-term, results-oriented strategy. DOD generally concurred with the recommendations.

section_title: Letter
paragraphs: Unwanted sexual behaviors in the military—including sexual harassment,  sexual assault, and domestic violence involving sexual assault— undermine core values, unit cohesion, combat readiness, and public  goodwill. Recent studies by the Department of Defense (DOD) and the  RAND Corporation suggest that unwanted sexual behaviors do not exist  in isolation but are part of a “continuum of harm.” DOD defines this  continuum of harm as a range of interconnected, inappropriate behaviors  that are connected to the occurrence of sexual assault and support an  environment that tolerates these behaviors. According to RAND,  servicemembers who experienced sexual harassment or gender  discrimination also experienced higher rates of sexual assault, and  approximately one-third of servicemembers who are sexually assaulted  stated that the offender sexually harassed them before the assault.

Concerned about the prevalence of unwanted sexual behaviors,  Congress has taken a number of legislative actions. Among other  provisions, Congress in 2008 mandated that DOD implement a  centralized, case-level database for the collection and maintenance of  information regarding sexual assaults. In 2011, Congress mandated that  DOD publish annual reports on all sexual assaults involving  servicemembers. In 2013, Congress mandated that DOD develop a  comprehensive sexual harassment policy and a plan for data collection.  Most recently, in 2016, Congress changed the definition of sexual  harassment for purposes of investigations by commanding officers into  complaints of harassment, and also mandated that DOD report on the  annual number of incidents of domestic violence, including those  involving sexual assault, whether substantiated or unsubstantiated. In  2016, Congress also took actions regarding hazing in the military— another problem behavior that may or may not have a sexual  component—by mandating that DOD establish a data collection system  for hazing, improve hazing training, and issue annual reports on hazing.

We have reported previously on DOD’s efforts to prevent and respond to  unwanted sexual behaviors in the military, as well as on other problem  behaviors such as hazing. In 2016, we reported on DOD and Coast  Guard efforts to prevent and track incidents of hazing in the military and  recommended, among other things, that DOD and the Coast Guard issue  guidance on the collection and tracking of hazing incident data and  evaluate the prevalence of hazing. DOD and the Department of  Homeland Security, which oversees the Coast Guard, concurred with all  of our recommendations and have begun taking actions to address  them. In 2015, we reported on our evaluation of DOD’s sexual assault  prevention strategy—based Centers for Disease Control’s (CDC) sexual  violence framework—and made five recommendations to improve upon  and implement that strategy. DOD concurred with those five  recommendations and is currently in the process of implementing them.  This is one of several reviews we have conducted on sexual assaults in  the military. We last reviewed DOD’s sexual harassment program in 2011  and made five recommendations, including that DOD establish an  oversight framework to help guide the department’s efforts to prevent and  address sexual harassment incidents and that DOD specify uniform data  elements that the military services should use when collecting and  reporting information on formal sexual harassment complaints. DOD  concurred with our recommendations but did not implement them. In  2010, we reported on domestic abuse at DOD and recommended that  DOD establish an oversight framework to guide its efforts in preventing  and treating domestic abuse. DOD concurred and implemented this  recommendation. Additional information on our prior related work is  provided at the end of this report.

Senate Report 114-255, accompanying a bill for the National Defense  Authorization Act (NDAA) for Fiscal Year (FY) 2017, included a provision  that we review efforts by DOD to prevent unwanted sexual behaviors in  the military. We assessed the extent to which DOD has (1) policies on  sexual harassment that include CDC principles and relevant legislative  elements; (2) processes for maintaining and reporting consistent data on  incidents of unwanted sexual behaviors; and (3) overarching efforts,  including a prevention strategy, to address unwanted sexual behaviors  across the continuum of harm.

For our first objective, we obtained and reviewed Office of the Secretary  of Defense (OSD) and service-level sexual harassment policies. We  compared the policies with a framework developed by CDC for preventing  sexual violence, which CDC defines as including non-contact unwanted  sexual behaviors, sexual harassment, and physical sexual assault. We  reviewed CDC’s framework for preventing sexual violence as well as our  report on DOD’s sexual assault prevention strategy to identify six  principles that an organization can include in a sexual violence prevention  strategy or policy. DOD previously used this framework to guide its  strategy for preventing sexual assault. The socioecological model that  underpins and informs CDC’s prevention framework is based on the  concept of addressing the health of a given population by identifying  common risk and protective factors and applying effective, tested  strategies. In addition, we reviewed DOD’s sexual harassment policies  to determine the extent to which they included three elements identified in  section 579 of the NDAA for FY 2013, which directed, among other  things, that DOD develop a comprehensive policy on sexual  harassment. The three elements are (1) prevention training for  members of the armed forces; (2) mechanisms for reporting sexual  harassment, including mechanisms for anonymous reporting; and (3)  mechanisms for resolving sexual harassment that include the prosecution  of perpetrators. Two of our analysts independently reviewed the policies  and determined the degree to which each element was included.

For our second objective, we reviewed DOD reports to Congress that  provide incident data regarding unwanted sexual behaviors, including  DOD’s most recent annual report on sexual assault in the military. We  identified the databases that generate the reported data and reviewed the  processes for assuring the consistency of data in those databases. In  evaluating the reported data, we reviewed pertinent statutory provisions  and DOD guidance. We also reviewed Standards for Internal Control in  the Federal Government that address agencies’ use of quality data and  our prior reports evaluating sexual assault data.

For our third objective, we obtained information on current efforts within  OSD to develop an overarching strategy across the continuum of harm.  We reviewed our prior work to identify key elements of strategic plans,  which include (1) a mission statement, (2) long-term goals, (3) strategies  to achieve goals, (4) external factors that could affect goals, (5) use of  metrics to gauge progress, and (6) evaluations of the plan to monitor  goals and objectives. We also identified collaborative efforts by OSD  offices that guide and oversee programs for addressing unwanted sexual  behaviors. We obtained information on the purpose and scope of each  effort, as well as on the participating offices. We interviewed DOD officials  in positions designed to integrate activities across the continuum of harm  to determine current activities and initiatives that the department is  undertaking to address coordination. In identifying DOD’s collaborative  efforts, we reviewed our prior work on collaboration among federal  agencies but we did not assess the effectiveness of the department’s  collaborative efforts.

We conducted this performance audit from August 2016 to December  2017, 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. Further details on our  scope and methodology are presented in appendix I.
subsections: section_title: Background
subsections: section_title: DOD Definitions of Unwanted Sexual Behaviors
paragraphs: DOD has defined various types of unwanted sexual behaviors, including  sexual assault, sexual harassment, and domestic violence.

Sexual assault: DOD defines sexual assault as intentional sexual  contact, characterized by use of force, threats, intimidation, abuse of  authority, or when the victim does not or cannot consent. The term  includes a broad category of sexual offenses consisting of the  following specific Uniform Code of Military Justice offenses: rape,  sexual assault, aggravated sexual contact, abusive sexual contact,  forcible sodomy (forced oral or anal sex), or attempts to commit these  acts.

Sexual harassment: DOD defines sexual harassment as a form of sex  discrimination that involves unwelcome sexual advances, requests for  sexual favors, and other verbal or physical conduct of a sexual nature  when (1) submission to such conduct is made either explicitly or  implicitly a term or condition of a person’s job, pay, or career; (2)  submission to or rejection of such conduct by a person is used as a  basis for career or employment decisions affecting that person; or (3)  such conduct has the purpose or effect of unreasonably interfering  with an individual’s work performance or creates an intimidating,  hostile, or offensive working environment. However, as noted  earlier, a provision of the NDAA for FY 2017 changed the definition of  sexual harassment for the military for purposes of investigations by  commanding officers so that it is no longer defined solely as a form of  sex discrimination, but is recognized as an adverse behavior on the  spectrum of behavior that can contribute to an increase in the  incidence of sexual assault. We discuss this changed definition of  sexual harassment later in this report.

Domestic violence: DOD defines domestic violence as an offense  under the United States Code, the Uniform Code of Military Justice, or  state law involving the use, attempted use, or threatened use of force  or violence against a person, or a violation of a lawful order issued for  the protection of a person who is a current or former spouse, a person  with whom the abuser shares a child in common or a current or former  intimate partner with whom the abuser shares or has shared a  common domicile. Sexual assault of spouses and intimate partners  is a subset of domestic violence.

section_title: DOD Entities with Key Roles and Responsibilities in Addressing Unwanted Sexual Behaviors
paragraphs: Various offices and organizations within DOD play a role in addressing  unwanted sexual behaviors in the military. The Under Secretary of  Defense for Personnel and Readiness is responsible for developing the  overall policy and guidance for the department’s efforts to prevent and  respond to instances of sexual assault, except for criminal investigative  policy matters assigned to the DOD Inspector General and legal  processes in the Uniform Code of Military Justice.
subsections: section_title: DOD’s Sexual Assault Prevention and Response Program
paragraphs: The Under Secretary of Defense for Personnel and Readiness oversees  the Sexual Assault Prevention and Response Office (SAPRO), which  serves as the department’s single point of authority, accountability, and  oversight for its sexual assault prevention and response program. The  responsibilities of the Under Secretary of Defense for Personnel and  Readiness and SAPRO with regard to sexual assault prevention and  response 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 mandated annual  reports to Congress on sexual assaults involving servicemembers.

The Secretaries of the military departments are responsible for  establishing policies for preventing and responding to sexual assault  within their respective military service, and for ensuring compliance with  DOD’s policy. Further, they are responsible for establishing policies that  ensure commander accountability for program implementation and  execution. Each military service has established an office that is  responsible for overseeing and managing the military service’s sexual  assault prevention and response program. Each military service also  maintains a primary policy document on its sexual assault prevention and  response program. Much like DOD’s directive and instruction on sexual  assault prevention and response, the military service policies outline  responsibilities of relevant stakeholders, including commanders, sexual  assault response coordinators, and victim advocates and training  requirements for all personnel.

section_title: DOD’s Military Equal Opportunity Program
paragraphs: The Under Secretary of Defense for Personnel and Readiness has  responsibility for developing the overall policy for DOD’s military equal  opportunity program and monitoring compliance with the department’s  policy.  According to the policy, all servicemembers are afforded equal  opportunity in an environment free from harassment, including sexual  harassment, and unlawful discrimination on the basis of race, color,  national origin, religion, sex (including gender), and sexual orientation.  The chain of command is used as the primary and preferred channel to  (1) identify and correct unlawful discrimination practices, (2) process and  resolve complaints of unlawful discrimination or harassment, to include  sexual, and (3) ensure that military equal opportunity matters are taken  seriously and acted on as necessary. The Office of Diversity  Management and Equal Opportunity (ODMEO) oversees the  department’s efforts to promote equal opportunity, diversity, and inclusion  management, and to help prevent unlawful discrimination and  harassment throughout DOD. The Defense Equal Opportunity  Management Institute develops training and studies on equal opportunity.  Behaviors under the purview of the military equal opportunity program  include unlawful discrimination on the basis of color, national origin, race,  religion, or sex.

The Secretaries of the military departments are responsible for  developing policies to prevent unlawful discrimination and harassment,  (including sexual harassment), ensuring compliance with DOD’s policy,  and establishing both formal and informal means of resolving complaints.  The chain of command is the primary and preferred channel for  identifying and correcting discriminatory practices and resolving  servicemembers’ complaints of sexual harassment. The military  services encourage servicemembers to resolve any complaints of sexual  harassment they may have at the lowest possible level first.

For servicemembers who wish to report a complaint of sexual  harassment, DOD provides two complaint options—formal and informal.

A formal complaint is an allegation of sexual harassment that a  complainant submits in writing to the authority designated for the receipt  of such complaints in military service implementing guidance. Formal  complaints require specific actions to be taken, are subject to timelines,  and require documentation of the actions taken, in accordance with  federal law. In contrast, an informal complaint is an allegation of sexual  harassment, made either orally or in writing, which is not submitted as a  formal complaint. Informal complaints may be resolved directly by the  complainant, such as by confronting the individual or by involving another  individual or the chain of command. Servicemembers who elect to resolve  their complaints informally may submit a formal complaint if they are  dissatisfied with the outcome of the informal process. In 2014, DOD  directed the military services to develop implementing instructions and  mechanisms for reporting instances of sexual harassment  anonymously.

section_title: DOD’s Family Advocacy Program
paragraphs: The Deputy Assistant Secretary of Defense for Military Community and  Family Policy under the Under Secretary of Defense for Personnel and  Readiness is responsible for the development and oversight of policy for  the military departments to implement a coordinated community response  approach to addressing domestic abuse. The DOD Family Advocacy  Program (FAP) office provides guidance and technical assistance to the  military departments and DOD components to support their efforts to  address, among other things, domestic abuse.

The Secretaries of the military departments are responsible for  developing military service-wide policies, supplementary standards, and  instructions to provide for the requirements within their respective  installations FAPs. Each military service has established a FAP that is  responsible for overseeing and managing, among other things, the  installation-level FAPs and the military service’s domestic violence and  domestic abuse prevention and response programs. When domestic  abuse does occur, the military service installation FAP conducts a risk  assessment and works to ensure the safety of the victims and help  military families overcome the effects as well as change destructive  patterns.

section_title: CDC and Its Sexual Violence Prevention Efforts
paragraphs: CDC is one of the major operating components of the Department of  Health and Human Services, which serves as the federal government’s  principal agency for protecting the health of U.S. citizens. As part of its  health-related mission, CDC serves as the national focal point for  developing and applying disease prevention and control, environmental  health, and health promotion and education activities. CDC, among other  things, conducts research to enhance prevention, develops and  advocates public health policies, implements prevention strategies,  promotes healthy behaviors, fosters safe and healthful environments, and  provides associated training.

In 1992, CDC established the National Center for Injury Prevention and  Control as the lead federal organization for violence prevention. The  center’s Division of Violence Prevention focuses on stopping violence,  including sexual violence, before it begins and works to achieve this by  conducting research on the factors that put people at risk for violence,  examining the effective adoption and dissemination of prevention  strategies, and evaluating the effectiveness of violence prevention  programs. In 2004, CDC published a framework for effective sexual  violence prevention strategies. This framework includes prevention  concepts and strategies, such as identifying risk and protective factors  (i.e., factors that may put a person at risk for committing sexual assault or  that, alternatively, may prevent harm). CDC’s framework defines sexual  violence as including non-contact unwanted sexual behaviors, sexual  harassment, and physical sexual assault.

section_title: Continuum of Harm
paragraphs: DOD has acknowledged that connections exist across the continuum of  unwanted sexual behaviors including sexual harassment and sexual  assault and that this continuum of harm is reflected in key documents that  guide prevention and response activities. For example, SAPRO has also  reported that certain behavior and activities, such as hazing, can lead to  sexual assault. Additionally, DOD’s Prevention Roundtable and 2014- 2016 Sexual Assault Prevention Strategy have both adopted CDC’s  definition of “prevention” as it applies to sexual violence. CDC defines  sexual violence to include sexual harassment and sexual assault.

In 2014 and 2017, DOD contracted with RAND to conduct independent  assessments of behaviors across the continuum of harm, including sexual  assault and sexual harassment. In its 2014 report, RAND found that (1)  34 percent of male servicemembers who were surveyed reported that the  sexual assault was part of a hazing incident, (2) servicemembers who  experienced sexual harassment or gender discrimination in the past year  also experienced higher rates of sexual assault, and (3) approximately  one-third of servicemembers who are sexually assaulted stated the  offender sexually harassed them before the assault. In its 2017 report,  RAND found that (1) people are more likely to engage in problematic  behaviors, such as sexual harassment, if that person perceives that peers  and leaders condone those actions and (2) some organizations  responsible for addressing unlawful discrimination and sexual harassment  lack adequate policies, plans, information systems, and resources  needed to establish a departmental approach to certain behavioral  issues, inform senior leadership about these problems, and ensure that  leadership’s decisions about problematic behaviors are uniformly  enforced.

CDC research revealed that behaviors such as bullying and homophobic  teasing in early adolescence are significant predictors of sexual  harassment over time. According to the CDC, these youth are at an  increased potential to perpetrate sexual violence and engage in sexually  harassing behavior. In response, CDC recommends that communities  work to prevent all types of violence from occurring and coordinate and  integrate responses to violence in a way that recognizes these  connections. CDC’s research has also established that survivors of one  form of violence are more likely to be victims of other forms of violence,  that survivors of violence are at higher risk for behaving violently, and that  people who behave violently are more likely to commit other forms of  violence. Further, CDC states that violence prevention and intervention  efforts that focus on only one form of violence can be broadened to  address multiple, connected forms of violence to increase the public  health impact.

section_title: DOD’s Policies on Sexual Harassment Include Some but Not All of CDC’s Principles and Most Relevant Legislative Elements
paragraphs: DOD’s policies on sexual harassment include some but not all of CDC’s  principles and most relevant legislative elements. OSD and military  service-specific sexual harassment policies generally include prevention  strategies that CDC has identified in its principles for sexual violence  prevention but leave out risk and protective factors, as well as risk  domains. Additionally, DOD’s sexual harassment policies include most  elements identified in section 579 of the NDAA for FY 2013, but do not  consistently include mechanisms for anonymous reporting. ODMEO  officials stated that they plan to issue a new policy that is intended to  focus on sexual harassment and other forms of harassment, but it is too  early to know whether that policy will include all the CDC principles or  mechanisms for anonymous reporting. We also noted during our review  that most existing policies have not yet been updated to reflect a  provision in the fiscal year 2017 NDAA that redefined sexual harassment  for certain purposes so it is no longer defined solely as a form of sex  discrimination but is recognized also as an adverse behavior on the  spectrum of behaviors that can contribute to an increase in the incidence  of sexual assault.
subsections: section_title: DOD’s Sexual Harassment Policies Include Some of CDC’s Principles for Preventing Sexual Violence but Not Others
paragraphs: DOD’s sexual harassment policies include some of the principles that  have been developed by CDC as part of a framework for preventing  sexual violence, but other principles are not included. OSD includes  sexual harassment as part of its broader military equal opportunity  policy. It addresses, among other things, processes for preventing and  responding to cases of discrimination, including sexual harassment;  education and training in equal opportunity; and complaints processing.  The military services’ policies on sexual harassment cover similar topics,  such as chain of command responsibilities, complaint processing, and  definitions for sexual harassment; however, they have some  differences. For example, while all policies include provisions on sexual  harassment prevention training, the Army’s and the Navy’s policies  include specific characteristics of effective training. Both policies also  specify what should be included in trainings for different levels of the  chain of command. The Marine Corps and Air Force policies simply state  that commanders must conduct sexual harassment prevention training.

CDC’s framework defines sexual violence as including non-contact  unwanted sexual behaviors, sexual harassment, and physical sexual  assault. We applied six principles for sexual violence prevention from  CDC’s framework to DOD’s sexual harassment policies. These principles  are:

Risk factors: Factors that may put people at risk for sexual violence  perpetration or victimization, such as an organizational climate that  either explicitly or implicitly condones sexual harassment.

Protective factors: Factors that may protect high-risk people from  harm, such as an organizational climate that promotes respect  amongst personnel at all levels.

Primary strategies for prevention: Strategies that occur before sexual  violence takes place to prevent initial perpetration, such as sexual  harassment prevention training.

Secondary strategies for prevention: Immediate responses after  sexual violence has occurred to address the early identification of  victims and the short-term consequences of violence, such as  mechanisms for reporting instances of sexual harassment and  immediate interventions.

Tertiary strategies for prevention: Long-term responses after sexual  violence has occurred to address the lasting consequences of  violence and sex-offender treatment interventions, such as long-term  treatment of the victim and perpetrator.

Risk domains: Levels at which risk and protective factors should be  categorized, including: individual, relationship, community, and  societal. In its sexual assault prevention strategy, DOD adapted risk  domains to the military population, using the levels of: individual,  relationship, leaders at all levels, military community, and society.

Our comparison of DOD sexual harassment policies with CDC’s  framework for preventing sexual violence showed that the policies include  some of the principles in the framework but not others (see table 1.)

Our analysis showed that the OSD and the Air Force policies each  include two of the six principles in CDC’s framework, and the Army, the  Navy, and the Marine Corps policies include three principles. Specifically,  the policies generally identify sexual harassment prevention training for  the armed forces, a primary strategy for prevention. In addition, the  policies generally outline mechanisms for reporting and responding to  sexual harassment, considered a secondary strategy for prevention. The  Army, the Navy, and the Marine Corps policies outline counseling support  and referral services, as well as specifying the options available for  administrative or judicial punishment, including discharge from service for  perpetrators, which can be considered to be tertiary strategies for  prevention.

Common elements missing from DOD’s sexual harassment policies are  risk factors and protective factors, which identify conditions or behaviors  that might heighten or lower the risk of sexual harassment victimization or  perpetration, respectively. Examples of risk factors for sexual violence  identified by the CDC include, but are not limited to, alcohol and drug use,  hypermasculinity, emotionally unsupportive family environments, general  tolerance of sexual violence within the community, and societal norms  that support male superiority and sexual entitlement. Examples of  protective factors from the CDC include emotional health and  connectedness, and empathy and concern for how one’s actions affect  others. Additionally, RAND identified an organizational climate that is  oppositional to sexual violence as a protective factor. The policies also  did not include risk domains, which would categorize risk and protective  factors at the individual, relationship, community, and society levels.  ODMEO officials told us that they are familiar with the CDC framework  and are considering using it as a source of best practices for a new  sexual harassment prevention strategy. DOD has previously used  CDC’s sexual violence prevention framework to guide its sexual assault  prevention strategy.

In the absence of more comprehensive policies on sexual harassment  that fully include principles in the CDC framework for sexual violence  prevention, DOD may be missing opportunities to address and potentially  reduce incidents of sexual harassment in the military population based on  risk and protective factors and effective, tested strategies. Specifically,  DOD may be missing the opportunity to identify risk factors, which would  help to recognize situations where individuals and populations may be at  a higher risk of sexual harassment perpetration or victimization; identify  protective factors to lower the risk of sexual harassment; develop  mechanisms to address sexual harassment across risk domains—at the  individual, relationship, community, and society levels; and develop  tertiary strategies, or long-term responses after sexual violence has  occurred to address the lasting consequences of violence and sex- offender treatment interventions.

section_title: DOD’s Sexual Harassment Policies Include Most Elements Mandated in the NDAA for FY 2013, but Some Do Not Include Mechanisms for Anonymous Reporting
paragraphs: DOD’s sexual harassment policies include three elements required by  section 579 of the NDAA for FY 2013 but some do not include one  element involving the anonymous reporting of incidents. Section 579  mandated that DOD, among other things, develop a comprehensive  sexual harassment policy that includes the following elements: (1)  prevention training for members of the armed forces; (2) mechanisms for  reporting sexual harassment, including mechanisms for anonymous  reporting; and (3) mechanisms for resolving sexual harassment that  include the prosecution of perpetrators. In 2014, the Office of the  Undersecretary of Defense for Personnel and Readiness issued a policy  memorandum addressing the provisions of Section 579 and directed the  military services to develop implementing instructions that include  mechanisms for anonymous reporting.

We compared DOD’s policies with the required elements in section 579  and found that OSD and military service policies generally include  required elements except for the element focused on DOD including  anonymous reporting in its policies for sexual harassment. The OSD,  Army, and Marine Corps policies do not include anonymous reporting, while the Air Force policy and a new Navy policy do. Officials from  ODMEO said that providing an option for anonymous reporting is  important because it increases the odds that incidents will be reported.  ODMEO officials also told us that the services have hotlines that  servicemembers can use to anonymously report complaints of sexual  harassment, and the Air Force and Navy policies note that their  respective military servicemembers have options for anonymous  reporting. While the military services may have mechanisms in place for  anonymous reporting of sexual harassment, these mechanisms are not  included in OSD’s policy—as required by section 579—or the policies of  two of the Services, those of the Army and the Marine Corps.  Without  including anonymous reporting of sexual harassment complaints in  DOD’s sexual harassment policies, the statutory requirement for  anonymous reporting may be interpreted and applied inconsistently  throughout the military services, or left unmet.

section_title: Development of New OSD Harassment Policy May Provide Opportunities for Enhanced Oversight and More Consistent Approaches
paragraphs: OSD is developing a new policy—planned to be issued in fiscal year  2018—that will specifically focus on various forms of harassment,  including sexual harassment, hazing, and bullying. ODMEO officials who  are developing the new policy stated that it is intended, among other  things, to enhance oversight of sexual harassment prevention and  response within the department. However, because the policy is under  development, it is too early to determine how the policy will address the  CDC principles and anonymous reporting, as discussed earlier. Further, it  is unclear how OSD plans to improve oversight and whether it intends to  include performance goals, objectives, milestones, and metrics as we  previously recommended in 2011.

Although OSD in 2014 directed the military services to improve their  oversight of sexual harassment, none of the military services were able to  demonstrate that they had implemented all the required elements.

Specifically, DOD’s 2014 policy memorandum addressing the provisions  of section 579 also directs the military services to develop a sexual  harassment oversight framework to be reviewed quarterly by a senior  leadership forum that includes long-term goals, objectives, and  milestones; criteria for measuring progress; results-oriented performance  measures to assess effectiveness of service sexual harassment policies  and programs; standards for holding leaders accountable for promoting,  supporting, and enforcing policies, plans and programs; and strategies to  implement the oversight framework.

While some of the military services have included elements of the  oversight framework directive from the 2014 policy memorandum, none of  them were able to provide information that demonstrated that they had  fulfilled all requirements set forth by that policy memorandum. For  instance, when asked, none of the military services were able to provide  details that they have senior leader forums that review their oversight  efforts on a quarterly basis. Officials from the Air Force told us that they  were waiting for ODMEO to release a new sexual harassment policy  before establishing the oversight framework. Officials from the Navy  referred us to their July 2017 sexual harassment policy, which instructs  the Navy Sexual Harassment Prevention and Equal Opportunity Office to  develop and implement standards for holding leaders accountable for  promoting, supporting, and enforcing sexual harassment prevention and  response policies, plans, and programs, and to develop results-oriented  performance measures to assess the effectiveness of sexual harassment  prevention and response policies and programs. Officials from the Army  referred us to their SHARP Campaign Plan, which outlines methods to  hold leaders accountable for taking appropriate action to address sexual  harassment; goals and objectives for the program; and ways to measure  program effectiveness. The Marine Corps did not respond to our request  for information regarding an oversight framework for sexual harassment.

A new department-wide policy on sexual harassment could be helpful to  the military services as they review and update their respective policies.  As noted earlier, military service policies have some differences in how  they address aspects of sexual harassment. The Marine Corps told us  that they have been waiting for additional guidance from OSD before  updating their sexual harassment policies. However, following publicized  incidents of Marines posting inappropriate photos on line of female  servicemembers without their consent, the Marine Corps updated its  guidance in May 2017 adding “the distribution or broadcasting of an  intimate image, without consent” to its list of sexual harassment incidents  that mandate separation processing. Additionally, in May 2017, a  Marine Corps official said the service was revising its sexual harassment  policy. The Navy updated its sexual harassment policy in July 2017  without additional guidance from OSD.

We also noted during our review that most existing policies have not yet  been updated to reflect a provision in the fiscal year 2017 NDAA that  redefined sexual harassment for certain purposes so it is no longer  defined solely as a form of sex discrimination but is recognized also as an  adverse behavior on the spectrum of behavior that can contribute to an  increase in the incidence of sexual assault. We asked DOD officials from  several offices about the implications of this change. They identified some  actions they will take, but the full implications, if any, of the change are  unclear. Officials from the Assistant Secretary of Defense for Readiness  said that there are no significant implications of the sexual harassment  definition change beyond making conforming revisions to policy  documents and guidance. ODMEO officials said that adjusting to the new  definition of sexual harassment would not significantly affect their work at  the OSD level, since they are already updating their sexual harassment  policy to reflect this change and since sexual harassment is expected to  remain within the responsibilities of ODMEO. They added that the military  services will likely have to adjust to the new definition of sexual  harassment, but did not offer details in how they would have to adjust.

The Navy’s new policy dated July 2017 reflects the new definition, but the  other military services have yet to incorporate the change. Officials from  SAPRO said that they are working with ODMEO to revise surveys on  unwanted sexual behaviors to reflect the new definition. SAPRO officials  further stated that sexual harassment should remain under ODMEO’s  purview since ODMEO personnel are trained specifically in sexual  harassment response. Officials from the Army’s SHARP program said  that the new definition means that sexual harassment will more often be  considered misconduct, and taken more seriously.

Since OSD is in the process of updating its policy, we are not making any  recommendations. However, it will be important for OSD and the military  services to address our prior recommendation regarding improving the  oversight framework as well as incorporating the new definition of sexual  harassment required by the fiscal year 2017 NDAA while updating their  policies.

section_title: DOD Has Processes for Maintaining and Reporting Consistent Data on Incidents of Sexual Assault and Domestic Abuse That Involves Sexual Assault, but Does Not Have Reasonable Assurance of Consistent Data on Sexual Harassment
paragraphs: DOD has processes for maintaining and reporting consistent data on  sexual assault incidents and domestic violence incidents that involve  sexual assault, but the department does not have similar assurance of  consistent data on incidents of sexual harassment. SAPRO and FAP  each use centralized databases that enable them to maintain and report  consistent data on those incidents that fall under their purview. In  contrast, DOD relies on military service-specific databases on sexual  harassment incidents and does not have assurance of consistent data  from these databases because it has not established standard data  elements and definitions to guide the military services in maintaining and  reporting these data.
subsections: section_title: DOD Has Developed and Plans to Further Improve Centralized Databases That Enable It to Maintain and Report Consistent Data on Sexual Assault Incidents and Domestic Violence Incidents That Involve Sexual Assault
paragraphs: DOD uses centralized databases to maintain and report data on sexual  assault incidents in the military and domestic violence incidents involving  sexual assault. Specifically, SAPRO and the military services use the  Defense Sexual Assault Incident Database (DSAID), and FAP uses the  DOD Central Registry. These databases maintain data on incidents that  are included in statutorily required annual reports to Congress on sexual  assaults in the military. In 2011, Congress mandated that DOD provide  annual reports that include:  the number of sexual assaults committed against and by members of  the armed forces that were reported to military officials, including  unsubstantiated and substantiated reports with a synopsis of each  substantiated case organized by offense and the action taken,  including disciplinary actions;  the policies, processes, and procedures implemented by the  Secretary concerned during the year covered by the report in  response to incidents of sexual assaults;  the number of substantiated sexual assault cases in which the victim  is deployed where the assailant is a foreign national; and a description of the implementation of the accessibility plan, including  a description of the steps taken to ensure that trained personnel,  appropriate supplies, and transportation resources are available to  deployed units.

The most recent DOD annual report on sexual assault was issued in May  2017 and covered fiscal year 2016. The report includes data on the  number of both restricted and unrestricted reports of sexual assault  involving servicemembers. The report also contains separate  enclosures for the Army, the Navy (including the Marine Corps), the Air  Force, and the National Guard, as well as annexes on the Workplace and  Gender Relations Survey of Active Duty Members (WGRA) and the  Military Investigation and Justice Experience Survey (MIJES). The  WGRA annex discusses topics including the continuum of harm and the  MIJES annex contains information on closed cases of sexual assault.

SAPRO and FAP both contributed sexual assault incident data to the  fiscal year 2016 report, and our review of the underlying databases found  that data elements and definitions were defined and management was  able to process the data into consistent information. Specifically, the two  databases used are the:

DSAID Data on Sexual Assault Incidents: DSAID captures DOD-wide  data on certain incidents of sexual assault that involve a  servicemember or in some cases, when a sexual assault involves a  servicemember’s spouse or adult family member or a DOD civilian or  contractor. However, FAP-related sexual assault incidents are not  captured in DSAID.  Using information generated by DSAID, SAPRO  includes both substantiated and unsubstantiated reports of sexual  assault in its annual report.

In 2017, we reviewed DSAID and found that DOD had taken steps to  ensure the quality and consistency of data in DSAID as well as to  monitor the data entered into the system. In addition, OSD had  provided the military services with definitions for required data  elements in the database, which include details on the incident, victim,  and alleged offender. In addition, we identified several technical  challenges with the system, including issues with the system’s speed  and ease of use; interfaces with other external DOD databases; and  users’ ability to query data and generate reports. At the time of the  report’s release, DOD had plans to modify DSAID. As of July 2017,  DOD officials told us that they are still in the process of making  modifications to DSAID to resolve or alleviate the technical challenges  for users.

DOD Central Registry Data on Domestic Abuse Incidents Involving  Sexual Assault: The DOD Central Registry captures DOD-wide data  on reports of domestic abuse on populations within FAP’s purview,  including on family members of servicemembers as well as on their  intimate partners. The DOD Central Registry includes details of  each case such as the status of cases, the demographics of the  perpetrator and victim, the specific type of abuse, and other details  surrounding the incident. FAP officials explained that they do not use  the “substantiated” and “unsubstantiated” terminology like SAPRO  does. Rather, FAP, which is not responsible for determining criminal  or legal disposition, uses the terms “met criteria” and “not met criteria”  for maltreatment. This difference in terminology has to do with FAP’s  process for determining if an incident meets the clinical criteria to be  classified as abuse for the purpose of developing an  intervention/treatment plan for both the victim and the offenders  involved in the allegations of domestic violence.

Incidents that are determined as having met criteria are entered into  the DOD Central Registry. We reviewed the DOD Central Registry  and found that it includes well defined data elements and descriptions  for collecting data on cases of domestic violence including those that  involve sexual assault. The data in the DOD Central Registry includes  46 discrete data elements, including the relationship between the  victim and perpetrator, the timeline of the case, and actions taken and  treatments administered in response to the incident. The elements are  defined and described in an OSD policy.

In its annual reporting to Congress, FAP provides the number of domestic  violence incidents involving sexual assault that met criteria and the total  number of instances of domestic violence that did not meet criteria.  However, FAP does not maintain or report data on the total number of  reported domestic violence incidents that specifically involve sexual  assault. That is because only the details of cases that meet criteria are  recorded in the DOD Central Registry. A FAP official said that the military  services likely have more detailed information about cases that did not  meet the criteria, but it does not collect these data in the DOD Central  Registry. A provision in the NDAA for FY 2017 requires DOD to submit an  annual report on child abuse and domestic abuse incident data, including  the number of incidents reported during the year involving the physical or  sexual abuse of a spouse, intimate partner, or child. This report is to be  submitted simultaneously with submission of DOD’s annual sexual  assault report to Congress. FAP officials told us that they are currently  working with SAPRO to ensure that all reported incidents of domestic  violence involving sexual assault, including those that did not meet the  criteria, are included in the annual sexual assault report.

section_title: DOD Reports Annually on Sexual Harassment, but Does Not Have Reasonable Assurance That the Military Services Maintain Consistent Data on Sexual Harassment Incidents
paragraphs: Though not required to do so, DOD has included sexual harassment  incident data in an appendix of its annual report on sexual assault in the  military. The appendix provides information on the total number of  sexual harassment reports over the fiscal year and the total number of  substantiated sexual harassment reports. It also breaks down complaints  by sex, service, and pay grade. ODMEO generates the reported data  through annual data calls to each military service; however, it does not  have assurance that the services maintain consistent data on sexual  harassment incidents consistent with federal standards of internal control.

The military services maintain sexual harassment incident data in military  service-specific databases, and there is no centralized database similar to  DSAID or the Central Registry. The military service databases are  intended to collect data on formal complaints. According to the military  services, the Army, the Air Force, and the Marine Corps use web-based  systems, and the Navy tracks data using an Excel spreadsheet. Each  service has a discrete process for entering and performing quality checks  on sexual harassment incident data in its respective database, as shown  in table 2.

Although the military services perform some data quality checks as  shown in table 2, ODMEO does not have assurance the military services  are maintaining consistent data because it has not defined standard data  elements and definitions for the information in their databases. Rather,  the individual military services have established their own data elements  and definitions. We compared data elements and definitions from each of  the military services and found that there are several data elements that  remain consistent throughout the services. For example, each military  service records whether the complainant and offender are in the same  unit, what their relationship is to each other, and the disposition of cases.

However, we also found inconsistencies in data fields and their definitions  across the military services, and some of the military services have data  fields and definitions that do not exist in other databases. For example,  the Marine Corps records whether or not the incident involves alcohol or  drug use, which the rest of the military services do not record, and the  military services record dates differently between their respective  databases. For example, the Air Force records an initial date, the date the  complaint form was signed, the date the general court martial was sent,  the date the legal review was completed, and the final review date. The  Marine Corps records the date the incident was reported, the date the  incident occurred and whether the incident occurred over multiple dates;  the dates associated with notifications and status updates to general  courts martial proceedings; the dates associated with steps in the  investigation, including any extensions; the dates associated with  dispositions; and the dates associated with appeals. Additionally, the  military services have different ways of categorizing sexual harassment  incidents, as shown in table 3.

As shown in table 3, while some data descriptions are similar—for  instance, each of the military services include crude/offensive behavior,  unwanted sexual attention, and sexual coercion—there are differences as  well. The Air Force also categorizes sexual harassment into verbal,  nonverbal, physical, and other, for example, whereas the other military  services’ top-level categories are different. The Navy has a “not  applicable” category that it describes as sexual harassment complaints  that do not fall under sexual harassment, and only the Air Force has an  “other” category. Because the military services have different descriptors  for similar data fields, DOD cannot ensure that the services are  categorizing similar types of sexual harassment in the same way.

In addition, we found that the Army is more detailed in characterizing  different types of sexual harassment. Specifically, as shown in table 4, the  Army has an additional data field that provides more detailed descriptions  of three types of sexual harassment; the other military services’  respective databases do not have this level of detail.

Because the Army has this additional data field, it can capture information  on multiple types of harassment that may occur in a single incident. The  other military services, in contrast, do not have this capability in their  respective databases. To illustrate, if one case of sexual harassment  involved both verbal and nonverbal forms of sexual harassment, the Army  could choose a more specific characterization to describe the incident,  while the other military services would characterize the incident in more  general terms.

ODMEO officials are considering adapting an existing system to track  instances of sexual harassment department-wide. That system, called  Force Risk Reduction (FR2), is currently used to track safety issues like  military injuries, civilian workers’ compensation claims, and casualty  notifications at DOD. ODMEO recently completed a pilot of the system  with the Marine Corps, the Navy, and the Army to test whether it would be  useable for adaptation for sexual harassment data, and is planning a  second pilot to include the Air Force and the National Guard Bureau.

According to ODMEO officials, their adaptation of FR2 is intended to  collect aggregate-level sexual harassment data from the military services,  and the military services will continue to operate and rely on their  individual databases to maintain more detailed case-level information on  incidents. For example, ODMEO’s adaptation of FR2 would not have  details such as descriptions of specific incidents, or information on dates  associated with investigations or appeals. These types of data will  continue to be maintained in the service systems. ODMEO officials told  us that their new data system, if implemented, is not designed to collect  case-level details in order to avoid personally identifiable information.

Federal internal control standards state that management should define  the identified information requirements at the relevant level and requisite  specificity for appropriate personnel. Management should also process  the obtained data into quality information. Consistency of information  meets the identified information requirements when relevant data from  reliable sources are used. While DOD is exploring implementing a  system to track instances of sexual harassment department-wide, as  currently planned this system will not collect case-level details and  individual military service systems will continue to be relied upon for this  type of information.

Inconsistencies in data elements and definitions among the military  services generally mean that one military service may be maintaining  sexual harassment data that are more or less detailed than sexual  harassment data maintained by other military services, or that is simply  different from the data maintained by other military services. Additionally,  inconsistent data elements and definitions may create difficulties in  reporting sexual harassment data from the military services to OSD for a  department-wide report, since ODMEO has to adapt data from the  services to fit reporting requirements. Without standard data elements  and definitions for sexual harassment data, DOD will continue to lack  assurance about the consistency of these data across the military  services.

section_title: DOD Has Several Overarching Efforts to Address Unwanted Sexual Behaviors across the Continuum of Harm
paragraphs: DOD has several overarching efforts to address unwanted sexual  behaviors across the continuum of harm. Specifically, the department  established an office to oversee the integration and coordination of  unwanted sexual behaviors in 2015 and is in the process of developing  an overarching prevention strategy. However, because the strategy is  under development, it is unclear whether it will contain key elements for  long-term and results-oriented strategic planning. DOD also has ongoing  collaborative efforts to address unwanted sexual behaviors along the  continuum of harm. Specifically, we identified 15 collaborative efforts,  including regular meetings, Integrated Product Teams, and working  groups that involve multiple entities that address unwanted sexual  behaviors.
subsections: section_title: DOD Is Developing an Overarching Prevention Strategy to Address the Continuum of Harm, but It Is Unclear Whether DOD Will Include Key Elements of a Long-Term, Results- Oriented Strategy
paragraphs: DOD has taken steps to integrate activities related to the continuum of  harm and is in the process of developing an overarching prevention  strategy. Based on its research, DOD has sought to understand and  define the continuum of harm, including the shared characteristics that  contribute to increased unwanted sexual behaviors along the continuum  and implications for prevention and response efforts. Also, in November  2015, DOD established a new entity—the Office of the Executive Director  for Force Resiliency, within the Office of the Assistant Secretary of  Defense for Readiness—to oversee policies and initiatives related to the  continuum of harm. Specifically, the Executive Director for Force  Resiliency was expected to provide senior leader policy guidance and  oversight on high visibility departments that include SAPRO and ODMEO.  In November 2016, the Office of the Executive Director for Force  Resiliency was absorbed under the Assistant Secretary of Defense for  Readiness. According to the Assistant Secretary of Defense for  Readiness, the functions of the Office of the Executive Director for Force  Resiliency remain and coordination of the efforts of several offices that  address the continuum of harm continues.

Officials from the Assistant Secretary of Defense for Readiness and  SAPRO told us that they are drafting an overarching prevention strategy  to encompass behaviors along the continuum of harm. However, because  the strategy is still under development, its contents and timelines are  unclear. We have previously identified six elements of strategic  management planning that are key for establishing a long-term, results- oriented strategic planning framework: (1) a mission statement, (2) long- term goals, (3) strategies to achieve goals, (4) external factors that could  affect goals, (5) the use of metrics to gauge progress, and (6) evaluations  of the plan to monitor goals and objectives.

By incorporating the elements of a comprehensive and results-oriented  strategy into its overarching prevention strategy, the department will be  better positioned to effectively coordinate and integrate prevention  activities and reduce unwanted sexual behaviors. A mission statement,  along with long-term goals and strategies to achieve those goals, should  help to focus efforts in integrating prevention activities, and metrics and  evaluations will allow the department to gauge progress and make  changes as necessary, while also accounting for external factors that may  impact progress towards goals.

section_title: DOD Has Ongoing Collaborative Efforts to Address Behaviors along the Continuum of Harm
paragraphs: Our review identified 15 collaborative efforts that DOD has used to  address behaviors along the continuum of harm, including sexual  harassment, sexual assault, and domestic violence involving sexual  assault. Three of these efforts are cross-cutting between all three of the  key OSD stakeholders—ODMEO, FAP, and SAPRO—and five involve  cross-cutting efforts by at least two of the key stakeholders. Figure 1  lists DOD’s 15 collaborative efforts.

Regarding the three cross-cutting efforts involving all three of the key  stakeholders,

The Sexual Assault Prevention and Response Integrated Product  Team provides a forum for OSD, the military departments, and the  National Guard Bureau to address sexual assault prevention efforts.  The team meets bimonthly and serves as the implementation and  oversight arm for DOD’s Sexual Assault Prevention and Response  (SAPR) program. The team also coordinates new policies; reviews  existing SAPR policies and programs to ensure they are consistent  with applicable instructions; and monitors the progress of program  elements including DOD’s SAPR strategic plan tasks, DOD’s sexual  assault prevention strategy tasks, and implementation of NDAA- related sexual assault issues. SAPRO leads this effort.

The Prevention Collaboration Forum and working group develops  coordinated prevention approaches that address factors impacting  personnel readiness such as sexual harassment, sexual assault, and  domestic violence involving sexual assault. According to its proposed  charter, the focus of the forum is on enhancing the health of military  unit and family climates as well as strengthening and promoting the  resiliency and readiness of the total force through a coordinated effort  around integrated policies, collaborative direction of research,  alignment of resources, analysis of gaps, and synchronization of  activities. The Assistant Secretary of Defense for Readiness leads this  effort with SAPRO providing administrative and facilitation support.

The Victim Assistance Leadership Council advises the Under  Secretary of Defense for Personnel and Readiness on policies and  practices related to victim assistance across DOD. According to its  charter, the council provides a forum for senior leaders to exchange  information and collaborate on issues affecting victims of all forms of  crime and harassment within DOD, including but not limited to victims  of sexual harassment, sexual assault, and domestic violence involving  sexual abuse. Leadership rotates between SAPRO, FAP, and  ODMEO and other offices.

Regarding the cross-cutting efforts involving two of the three key  stakeholders, the Sexual Harassment Prevention and Response Working  Group is led by ODMEO and includes SAPRO. The group was  established to evaluate how to best position sexual harassment  prevention and response policy and oversight and to leverage technology  to automate annual reporting requirements. The four other cross-cutting  efforts are (1) the hazing and bullying working group, (2) retaliation  working groups created under the SAPR Integrated Process Team, (3)  domestic abuse rapid improvement events, and (4) ODMEO and SHARP  meetings.

The remaining collaborative efforts we identified are specific to FAP,  SAPRO, and ODMEO. For example, the Sexual Assault Prevention  Roundtable is a forum for representatives from OSD, the military  departments, and the National Guard Bureau to share information on  sexual assault prevention efforts and requirements. According to its  charter, the roundtable’s activities include, among other things, sharing  promising practices and prevention updates; discussing challenges in  prevention program implementation, including servicemember training,  and identifying approaches to address them; identifying metrics to assess  the impact and effectiveness of prevention efforts, and opportunities to  collaborate on research projects; and tracking the implementation of  prevention tasks identified in the DOD SAPR strategy. SAPRO leads this  effort. The Defense Diversity Working Group is an ODMEO-specific group  that collaborates with various OSD and military service offices on military  and civilian diversity and inclusion issues and implements mandated  diversity plans and programs.

section_title: Conclusions
paragraphs: Studies by DOD and others have shown that unwanted sexual behaviors  do not exist in isolation but are part of a range of interconnected,  inappropriate behaviors that are connected to the occurrence of a sexual  assault. While DOD has policies and procedures to prevent and respond  to these types of unwanted behaviors, some of the policies do not include  key elements like anonymous reporting of sexual harassment and  principles in the CDC framework for sexual violence prevention. Fully  including these elements in the department’s policies can help ensure  that the military services are interpreting and applying prevention and  response efforts consistently and may also decrease the risk of  perpetration or victimization related to instances on unwanted sexual  behaviors. Further, DOD has developed reliable data systems for  collecting and reporting data on some of the unwanted sexual behaviors  including sexual assault and instances of domestic violence with sexual  assault. However, inconsistencies in sexual harassment data elements  and definitions may be creating difficulties in developing department-wide  reports on unwanted sexual behaviors. Improving and standardizing data  collection efforts will not only improve the quality of data that DOD and  the military services collect but may also increase the ability for DOD to  further develop its understanding of the connection between unwanted  sexual behaviors. Finally, DOD officials have stated that they are in the  early stages of developing an overarching strategy to address the  interconnected nature of the range of unwanted sexual behaviors. To  ensure that the department is appropriately concentrating its efforts to  prevent and respond to the full range of unwanted behaviors, it is  important that DOD include elements of a long-term, results-oriented  strategy into its overarching prevention strategy. In doing so, DOD will be  in a better position to effectively coordinate and integrate prevention  activities and ultimately reduce instances of unwanted sexual behaviors.

section_title: Recommendations for Executive Action
paragraphs: We are making the following four recommendations to DOD:  The Under Secretary of Defense for Personnel and Readiness should  fully include in the new policy for sexual harassment the principles in the  Centers for Disease Control’s framework for sexual violence prevention,  including risk and protective factors, risk domains, and tertiary strategies.  (Recommendation 1)

The Under Secretary of Defense for Personnel and Readiness should  include in the new policy for sexual harassment mechanisms for  anonymous reporting of incidents consistent with section 579 of the  National Defense Authorization Act for FY 2013. (Recommendation 2)

The Under Secretary of Defense for Personnel and Readiness should (1)  direct the Office of Diversity Management and Equal Opportunity to  develop standard data elements and definitions for maintaining and  reporting information on sexual harassment incidents at the military  service level, and (2) direct the military services to incorporate these data  elements and definitions into their military service-specific databases.  (Recommendation 3)

The Under Secretary of Defense for Personnel and Readiness should  direct the Assistant Secretary of Defense for Readiness to incorporate in  its continuum of harm prevention strategy all the elements that are key for  establishing a long-term, results-oriented strategic planning framework.  The elements are (1) a mission statement, (2) long-term goals, (3)  strategies to achieve goals, (4) external factors that could affect goals, (5)  use of metrics to gauge progress, and (6) evaluations of the plan to  monitor goals and objectives. (Recommendation 4)

section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to DOD and CDC for review and  comment. In its written comments, DOD concurred with three  recommendations and partially concurred with one, noting planned  actions to address this recommendation. DOD’s comments are reprinted  in their entirety in appendix II. DOD and CDC also provided technical  comments, which we incorporated into the report as appropriate.

DOD concurred with our three recommendations that DOD fully include in  the new policy for sexual harassment the principles in the CDC's  framework for sexual violence prevention, that DOD also include in the  new sexual harassment policy mechanisms for anonymous reporting, and  that DOD incorporate in its continuum of harm strategy all the elements  that are key for establishing a long-term, results-oriented strategic  planning framework.

With regard to our recommendation that DOD develop standard data  elements and definitions for maintaining and reporting information on  sexual harassment incidents and direct the military services to  incorporate these into their databases, DOD partially concurred and  stated that while a 2013 policy memorandum provides standard data  elements and definitions, the services collect other data elements based  on their unique needs.  DOD stated that ODMEO will conduct a review to  determine compliance with DOD reporting requirements and identify  emerging policy modifications or changes/additions to standard  definitions.

We are sending copies of this report to the appropriate congressional  committees, the Secretary of Defense, the Under Secretary of Defense  for Personnel and Readiness, and the Director, Centers for Disease  Control and Prevention. In addition, the report is available at no charge on  the GAO website http://www.gao.gov.

If you or your staff have any questions about this report, please contact  me at (202) 512-3604 or farrellb@gao.gov. Contact points for our Offices  of Congressional Relations and Public Affairs may be found on the last  page of this report. GAO staff who made key contributions to this report  are listed in appendix III.

section_title: Appendix I: Scope and Methodology
paragraphs: To determine the extent to which the Department of Defense (DOD) has  policies on sexual harassment that include Centers for Disease Control  and Prevention (CDC) principles and relevant legislative elements, we  obtained and reviewed Office of the Secretary of Defense (OSD) and  service-level sexual harassment policies. We compared the policies with  a framework developed by the CDC for preventing sexual violence, which  CDC defines as including non-contact unwanted sexual behaviors, sexual  harassment, and physical sexual assault. CDC’s model is based on the  concept of addressing the health of a given population based on common  risk and protective factors and effective, tested strategies. We reviewed  CDC’s framework for preventing sexual violence as well as our report on  DOD’s sexual assault prevention strategy to identify six principles that an  organization can include in a sexual violence prevention strategy or  policy:

Risk factors: Factors that may put people at risk for sexual violence  perpetration or victimization, such as an organizational climate that  either explicitly or implicitly condones sexual harassment;

Protective factors: Factors that may protect high-risk people from  harm, such as an organizational climate that promotes respect among  personnel at all levels;

Primary strategies for prevention: Strategies that occur before sexual  violence takes place to prevent initial perpetration, such as sexual  harassment prevention training;

Secondary strategies for prevention: Immediate responses after  sexual violence has occurred to address the early identification of  victims and the short-term consequences of violence, such as  reporting mechanisms and immediate interventions;

Tertiary strategies for prevention: Long-term responses after sexual  violence has occurred to address the lasting consequences of  violence and sex-offender treatment interventions, such as the long- term treatment of the victim and perpetrator; and

Risk domains: Levels at which risk and protective factors should be  categorized, including: individual, relationship, community, and  society. DOD has previously adapted risk domains to the military  population, using the levels of: individual, relationship, leaders at all  levels, military community, and society.

DOD previously used CDC’s framework for preventing sexual violence in  the department’s 2014-2016 Sexual Assault Prevention Strategy. In  addition, we reviewed the OSD and service-level sexual harassment  policies to determine the extent to which they included three elements  identified in the National Defense Authorization Act (NDAA) for FY 2013,  which directed DOD to develop a comprehensive policy that includes  sexual harassment prevention training for the armed forces; mechanisms  for reporting incidents, including mechanisms for anonymous reporting;  and mechanisms for responding to and resolving instances of sexual  harassment, including for the prosecution of perpetrators. Two GAO  analysts independently reviewed the policies and determined whether or  not each element was included. Any discrepancies were resolved through  discussion and consultation with a third analyst. We interviewed officials  in the Under Secretary of Defense for Personnel and Readiness’ Office of  Diversity Management and Equal Opportunity, who oversee department- wide policy on sexual harassment, to obtain an understanding of their  roles and processes regarding sexual harassment as well as the status of  policy development in that area. We also interviewed officials from military  equal opportunity offices in the Air Force, the Navy, and the Marine  Corps, as well as officials from the Army’s Sexual Harassment/Assault  Response and Prevention Office to obtain an understanding of the  service sexual harassment offices and roles, as well as the status of  updates to their respective policies.

To determine the extent to which DOD has processes for maintaining and  reporting consistent data on incidents of unwanted sexual behaviors, we  reviewed DOD reports to Congress that provide incident data regarding  unwanted sexual behaviors, including DOD’s most recent annual report  on sexual assault in the military. We identified the databases that  generate the reported data and evaluated the processes for assuring the  quality and consistency of data in those databases—including the  Defense Sexual Assault Incident Database, which maintains sexual  assault data; the Central Registry database, which maintains data on  domestic violence involving sexual assault; and various military service- level databases that maintain sexual harassment data. To evaluate  DOD’s reported data we reviewed pertinent statutory provisions, DOD  guidance, and the Standards for Internal Control in the Federal  Government that address agencies’ use of quality data and our prior  reports evaluating sexual assault data. In evaluating the reported data,  we obtained and reviewed statutory provisions with reporting  requirements, as well as DOD guidance on data collection for sexual  harassment, sexual assault, and domestic violence involving sexual  abuse. With regard to DOD efforts to collect and maintain sexual assault  data, we met with OSD, Navy, Air Force, and Marine Corps officials in  their respective Sexual Assault Prevention and Response offices as well  as officials in the Army’s Sexual Harassment/Assault Response and  Prevention office. We also reviewed our prior report on DOD’s Defense  Sexual Assault Incident Database and our prior report that evaluated  sexual assault data across agencies. To determine whether DOD has  processes for collecting and maintaining consistent data for domestic  violence with sexual assault, we obtained and compared data elements  and processes from DOD’s Central Registry database, which contains  data for domestic violence throughout the department. We also obtained  and reviewed policies that outline processes for collecting and reporting  domestic violence involving sexual abuse data, and interviewed officials  from Family Advocacy Program offices in OSD and the Army, Navy,  Marine Corps, and Air Force to determine data reliability and  comprehensiveness. To determine the extent to which reports of sexual  assault, including reports of sexual assault among servicemembers and  reports of domestic abuse involving sexual assault, meet statutory  requirements for reporting, we reviewed DOD reports to Congress that  provide sexual assault incident data, including DOD’s most recent annual  report on sexual assault in the military and compared those reports with  requirements in the NDAA for FY 2011, which directs DOD to report the  total number of substantiated and unsubstantiated sexual assault  incidents, among other things. With regard to sexual harassment data,  we interviewed officials in the Under Secretary of Defense for Personnel  and Readiness’ Office of Diversity Management and Equal Opportunity,  as well as officials from the Military Equal Opportunity offices in the Air  Force, Marine Corps, and Navy, and officials from the Army Sexual  Harassment/Assault Response and Prevention office. We collected and  compared data fields and data definitions from the Army, Navy, Marine  Corps, and Air Force offices that address sexual harassment. We  compared the data elements to determine whether the data elements and  definitions across the services are consistent.

To identify the extent to which DOD has overarching efforts, including a  prevention strategy, to address unwanted sexual behaviors across the  continuum of harm, we met with officials in the Office of the Assistant  Secretary of Defense for Readiness and DOD’s Sexual Assault  Prevention and Response office. We reviewed our prior work and  provisions from the Government Performance and Results Act to identify  key elements that should be included in strategic plans as well as  standards for coordinating within agencies. Key elements include (1)  mission statement, (2) long-term goals, (3) strategies to achieve goals, (4)  external factors that could affect goals, (5) use of metrics to gauge  progress, and (6) evaluations of the plan to monitor goals and objectives.  We identified and reviewed coordinating mechanisms used by OSD and  the service offices that guide and oversee efforts to address unwanted  sexual behaviors. We reviewed DOD, RAND Corporation, and CDC  reports that addressed the continuum of harm and the relationship  between the various forms of unwanted sexual behaviors. We  interviewed officials from OSD and service-level Sexual Assault  Prevention and Response, Family Advocacy, and Military Equal  Opportunity offices and the Army’s Sexual Harassment/Assault Response  and Prevention to identify the various efforts in which they participate. We  also collected and reviewed charters and meeting notes for integrated  product teams and working groups to identify their intended purposes,  their activities, their membership, and whether they involved multiple  offices addressing unwanted sexual behaviors. In identifying DOD’s  collaborative efforts, we also reviewed our prior work on collaboration  among federal agencies but we did not assess the effectiveness of  department’s collaborative efforts.

We conducted this performance audit from August 2016 to December  2017 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

section_title: Appendix II: Comments from the Department of Defense

section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the staff named above, key contributors to this report  include Thomas Gosling (Assistant Director); Isabel Band; Matthew Bond;  Vincent Buquicchio; Caroline DeCelles; Mae Jones; Kirsten Lauber; and  Brian Pegram.

section_title: Related GAO Products
paragraphs: Sexual Assault: Better Resource Management Needed to Improve  Prevention and Response in the Army National Guard and Army Reserve.  GAO-17-217. Washington, D.C.: February 27, 2017.

Military Personnel: DOD Has Processes for Operating and Managing Its  Sexual Assault Incident Database. GAO-17-99. Washington, D.C.:  January 10, 2017.

Sexual Violence Data: Actions Needed to Improve Clarity and Address  Differences Across Federal Data Collection Efforts. GAO-16-546.  Washington, D.C.: July 19, 2016.

DOD and Coast Guard: Actions Needed to Increase Oversight and  Management Information on Hazing Incidents Involving Servicemembers.  GAO-16-226. Washington, D.C.: February 9, 2016.

Sexual Assault: Actions Needed to Improve DOD’s Prevention Strategy  and to Help Ensure It Is Effectively Implemented. GAO-16-61.  Washington, D.C.: November 4, 2015.

Military Personnel: Actions Needed to Address Sexual Assaults of Male  Servicemembers. GAO-15-284. Washington, D.C.: March 19, 2015.

Military Personnel: DOD Needs to Take Further Actions to Prevent  Sexual Assault during Initial Military Training. GAO-14-806. Washington,  D.C.: September 9, 2014.

Military Personnel: DOD Has Taken Steps to Meet the Health Needs of  Deployed Servicewomen, but Actions Are Needed to Enhance Care for  Sexual Assault Victims. GAO-13-182. Washington, D.C.: January 29,  2013.

Preventing Sexual Harassment: DOD Needs Greater Leadership  Commitment and an Oversight Framework. GAO-11-809. Washington,  D.C.: September 21, 2011.

Military Justice: Oversight and Better Collaboration Needed for Sexual  Assault Investigations and Adjudications. GAO-11-579. Washington,  D.C.: June 22, 2011.

Military Personnel: DOD’s and the Coast Guard’s Sexual Assault  Prevention and Response Programs Need to Be Further Strengthened.  GAO-10-405T. Washington, D.C.: February 24, 2010.

Military Personnel: Additional Actions Are Needed to Strengthen DOD’s  and the Coast Guard’s Sexual Assault Prevention and Response  Programs. GAO-10-215. Washington, D.C.: February 3, 2010.

Military Personnel: DOD’s and the Coast Guard’s Sexual Assault  Prevention and Response Programs Face Implementation and Oversight  Challenges. GAO-08-924. Washington, D.C.: August 29, 2008.

Military Personnel: The DOD and Coast Guard Academies Have Taken  Steps to Address Incidents of Sexual Harassment and Assault, but  Greater Federal Oversight Is Needed. GAO-08-296. Washington, D.C.:  January 17, 2008.


Question-summary annotations: questions: question: Why is it alarming that OSD and military service policies do not address risk and protective factors?
answer: GAO found that Office of the Secretary of Defense (OSD) and military service policies generally include CDC's principles regarding prevention strategies, but none address risk and protective factors, which identify conditions or behaviors that might heighten or lower the risk of sexual harassment victimization or perpetration, respectively.

question: What did a provision in 2013 require the DOD to do?
answer: Additionally, a statutory provision in fiscal year 2013 mandated that DOD, among other things, develop a comprehensive sexual harassment policy that includes prevention training, mechanisms for anonymous reporting, and mechanisms for resolving incidents of sexual harassment.

question: What do OSD and service policies lack of the required policy elements?
answer: OSD and service policies are generally consistent with those required elements except for the inclusion of anonymous reporting.

question: Why might DOD gain from including CDC's principles for anonymous reporting?
answer: Without policies that include CDC's principles and mechanisms for anonymous reporting, DOD may miss opportunities to address and potentially reduce incidents of unwanted sexual behaviors.

question: How was sexual harassment redefined in 2017?
answer: Finally, a statutory change in fiscal year 2017 redefined sexual harassment for certain purposes so it is no longer defined solely as a form of sex discrimination but is recognized also as an adverse behavior on the spectrum of behavior that can contribute to an increase in the incidence of sexual assault.
child_questions: question: What were officials unclear on in relation to this redefinition?
answer: While officials indicated a need to update policies, they were unclear on the full implications, if any, of this change.

question: How dod DOD’s policies on sexual harassment differ from the CDC’s?
answer: The Department of Defense's (DOD) policies on sexual harassment include some but not all of the Centers for Disease Control's (CDC) principles for preventing sexual violence and include most relevant legislative elements.
child_questions: question: What did GAO identify in CDC’s framework for preventing sexual violence?
answer: GAO identified six principles from CDC's framework for preventing sexual violence, which CDC defines as including sexual harassment.

questions: question: What processes does DOD lack in regards to sexual harassment?
answer: DOD has processes for maintaining and reporting consistent data on incidents of unwanted sexual behaviors including sexual assault and incidents of domestic violence that involve sexual assault, but does not have similar processes for maintaining and reporting data on incidents of sexual harassment.
child_questions: question: Why does DOD have an inconsistency in data on sexual harassment?
answer: Specifically, DOD uses centralized databases to maintain and report data on incidents of sexual assault and domestic violence that involve sexual assault, but relies on military service-specific databases for information on incidents of sexual harassment.
child_questions: question: What does it mean for services to have inconsistencies in data?
answer: DOD has not established standard data elements and definitions to guide the services in maintaining and reporting data on sexual harassment. Inconsistencies in data elements and definitions generally mean that one service may be maintaining data that is more or less detailed than, or that differs from, the data maintained by other services.

question: Why does it matter that DOD does not maintain consistent data across services?
answer: Such inconsistencies may create difficulties in reporting department-wide sexual harassment data, since the individual service data must be adapted to fit reporting requirements.

questions: question: What has DOD done to address unwanted sexual behaviors?
answer: DOD has several overarching efforts to address unwanted sexual behaviors across the continuum of harm, including developing an overarching prevention strategy.
child_questions: question: What concerns are there about the DOD's efforts for the long-term?
answer: However, it is unclear whether the strategy under development will contain key elements for long-term and results-oriented strategic planning such as long-term goals, strategies to achieve goals, and metrics to gauge progress.

question: How might the DOD's prevention strategy prove ineffective?
answer: Without incorporating these elements into its overarching prevention strategy, DOD may not be in a position to effectively coordinate and integrate prevention activities and reduce instances of unwanted sexual behaviors.

questions: question: Why does GAO need to review DOD's efforts?
answer: Senate Report 114-255 included a provision for GAO to review efforts by DOD to prevent unwanted sexual behaviors in the military.
child_questions: question: What did GAO assess about DOD's policies?
answer: GAO assessed the extent to which DOD has (1) policies on sexual harassment that include CDC principles and relevant legislative elements; (2) processes for maintaining and reporting consistent data on incidents of unwanted sexual behaviors; and (3) overarching efforts, including a prevention strategy, to address unwanted sexual behaviors across the continuum of harm. GAO reviewed DOD policies and pertinent databases, and interviewed agency officials.