Military Personnel: DOD Has Made Limited Progress toward Improving Oversight of the Exceptional Family Member Program
Released: 2020-02-05T00:00:00

Letter

Background

DOD requires each Military Service to establish its own EFMP for active duty servicemembers. According to DOD guidance, EFMPs are to have three components—identification and enrollment, assignment coordination, and family support.

Identification and enrollment: DOD requires servicemembers to enroll in their Military Service’s EFMP once eligible family members are identified by medical and educational personnel at each installation.

Assignment coordination: Before finalizing a servicemember’s assignment to a new location, DOD requires each Military Service to consider any family member’s special needs, including the availability of required medical and special educational services at a new location.

Family support: DOD requires each Military Service’s EFMP to help families with special needs identify and gain access to programs and services at their current, as well as proposed locations.

As required by the NDAA for Fiscal Year 2010, DOD established the Office of Community Support for Military Families with Special Needs (Office of Special Needs or OSN) to develop, implement, and oversee a policy to support these families. Among other things, this policy must (1) address assignment coordination and family support services for families with special needs; (2) incorporate requirements for resources and staffing to ensure appropriate numbers of case managers are available to develop and maintain services plans that support these families; and (3) include requirements regarding the development and continuous updating of a services plan for each military family with special needs.

OSN is also responsible for monitoring the Military Services’ EFMPs and collaborating with the Military Services to standardize EFMP components as appropriate. For example, as part of its guidance for monitoring the Military Services’ EFMPs, DOD requires each Military Service to certify or accredit its family support services provided through the EFMP. In addition, DOD states that each Military Service must balance the need for overarching consistency across EFMPs with the need for each Military Service to provide family support that is consistent with their specific mission. Table 1 provides an overview of the procedures each Military Service must establish for the assignment coordination and family support components of the EFMP that we identified in our May 2018 report.

Key Aspects of Assistance for Families with Special Needs Vary Widely Across DOD Which Leads to Potential Gaps in Support

In May 2018, DOD reported that each Military Service provides family support services in accordance with DOD guidance, as well as Military Service-specific guidance. However, we found that, the type, amount, and frequency of assistance families with special needs receive varied by Military Service, which could lead to gaps in assistance (see table 2).

For example, in our May 2018 report, we found that the Marine Corps is the only Military Service that specifies a minimum frequency (quarterly) with which families with special needs should be contacted by their family support providers. The other Military Services either do not have requirements for regular contact with these families (Air Force and Army) or require contact only for selected families (Navy). In addition, we reported that unlike the Marine Corps, the Air Force, Army, and Navy choose not to employ special education attorneys. For example, Marine Corps attorneys may represent families with special needs who fail to receive special education services from local school districts, as specified in their children’s individualized education programs (IEP). Officials from the Air Force, Army, and Navy told us that they find other ways to help families with special needs resolve special education issues. For example, Army officials said EFMP managers could refer families with special needs to other organizations that provide legal support.

Services Plans

As we reported in May 2018, services plans are an important part of providing family support during the relocation process because they describe the necessary services and support for a family with special needs and provide a record for the gaining installation. However, we found that every Military Service had created relatively few services plans compared to the number of servicemembers or the number of family members enrolled in the EFMP (see table 3).

The Military Services and OSN provided a number of reasons as to why they do not develop and maintain a services plan for each family with special needs. For example, Air Force officials said they first consider whether a services plan will help each family receive the required services. In addition, Army and Marine Corps officials said they may not develop a services plan if a family does not request it. According to a Navy official, some families also lack the required services plans because installations may not have the staff needed to develop them. Finally, OSN officials said the Military Services may not have developed many services plans during fiscal year 2016 because DOD had not yet approved a standardized form that all of the Military Services could use, and because some families’ circumstances did not require a services plan.

In our May 2018 report, we recommended that DOD assess the extent to which each Military Service is developing a services plan for each family with special needs. DOD concurred with our recommendation, but as of January 2020, we determined that DOD has not fully implemented the recommendation because it has not yet assessed the extent to which each Military Service is developing services plans for each family with special needs. In its annual report to the congressional defense committees in April 2019, DOD stated that it was exploring legislative changes to the law that would require a services plan to be developed and updated only for those families who request services. A senior official from DOD stated that although this proposal received Office of Management and Budget approval, it was not included in the NDAA for fiscal year 2020. Also, in April 2019, in response to our recommendation, DOD reported to us that the Military Services had begun using a standardized form to develop services plans. In January 2020, a senior DOD official said its standardized form provides an option for a family to decline a services plan, and that the Department began collecting data related to services plans in the last quarter of 2019.

Resources

To meet requirements of the NDAA for Fiscal Year 2010, in April 2017, DOD stated that it issued to the Military Services guidance that directed them to “rogram, budget, and allocate sufficient funds and other resources, including staffing,” to meet DOD’s policy objectives for the EFMP. We reported in May 2018 that DOD relies on each Military Service to determine what level of funds and resources are sufficient and what constitutes an appropriate number of family support personnel. To determine the appropriate number of family support providers and staffing levels, the Military Service officials with whom we spoke said they consider a number of factors, including the number of families with special needs enrolled in the EFMP at any given installation. See Table 4 for a summary of EFMP family support providers and other key personnel at CONUS installations.

In May 2018, based on our analysis of EFMP family support providers and other key personnel at CONUS installations, we found that DOD had not developed a standard for determining the sufficiency of funding and resources each Military Service allocates for family support. As a result, the Military Services may not know the extent to which their funding and resources for family support comply with DOD’s policy. Federal internal control standards require that agencies establish control activities, such as developing clear policies, in order to accomplish agency objectives, such as those of the Military Services’ EFMPs.

Because DOD had not identified and addressed potential gaps in family support across the Military Services’ EFMPs, such as those we identified in types of assistance, services plans, and resources, we concluded that some families with special needs may not get the assistance they require, particularly when they relocate. We recommended in our May 2018 report that DOD assess the extent to which each Military Service is providing sufficient resources to staff an appropriate number of family support providers. DOD concurred with our recommendation. In April 2019, the most recent update DOD provided on this recommendation, DOD officials said they were planning to pilot a staffing tool to help the Military Services determine the number of family support providers needed at each installation; the pilot is expected to last 2 years before it can be implemented across the Military Services.

DOD Described Plans to Improve EFMP Oversight, but Lacks a Way to Fully Assess Performance across the Military Services and a Process for Evaluating Their Monitoring Activities

We reported in May 2018 that OSN had several efforts underway to improve its oversight of the EFMP. For example, to help provide a more consistent EFMP screening process across the Military Services and improve the collection of comparable assignment coordination data, OSN had planned for each Military Service to use standard screening forms for family members with special medical or educational needs prior to making new assignments. In January 2020, DOD told us that the forms were approved, but related guidance had not yet been developed for implementation across all of the Military Services. In addition, OSN planned to centralize the management of EFMP data across the Military Services. In April 2019, DOD reported that 82 percent of the EFMP related data terms were collectable across the Military Services which can improve OSN’s monitoring and reporting capabilities of the EFMP.

Despite OSN’s initial efforts, we found that DOD lacked common performance measures for assignment coordination and family support, and therefore is unable to fully assess EFMP performance across the Military Services. In our May 2018 report, we recommended that DOD direct OSN to develop common performance metrics for assignment coordination and family support, in accordance with leading practices for performance measurement. DOD concurred with our recommendation. In April 2019, the most recent update DOD provided on this recommendation, DOD officials told us that each Military Service submits data on assignment coordination and family support to the EFMP data repository on a quarterly basis, and that OSN was currently developing additional performance metrics for assignment coordination and family support. Until these metrics are fully developed and implemented, DOD will remain unable to fully assess the effectiveness of its efforts related to assignment coordination and family support at each of its installations.

We also found in May 2018 that OSN did not have a process to systematically evaluate the results of the Military Services’ monitoring activities. Instead, DOD requires each Military Service to monitor its own assignment coordination and family support provided through the EFMP and requires each Military Service to assess performance at least once every 4 years using standards developed by a national accrediting body. In addition, DOD requires personnel from each of the Military Service’s headquarters to periodically visit installations as part of their monitoring activities. We also reported that the Military Services’ family support programs were not accredited by a national accrediting body because, according to Military Service officials, they were unable to obtain funding for engaging in that process. Instead, each Military Service has a self-certification process based on standards that meet those of a national accrediting body, Military Service-specific standards, and best practices. We also reported in May 2018 that OSN officials did not systematically review the results of monitoring activities, such as the certification process, because they rely on each Military Service to self- monitor. In addition, officials said efforts to standardize certification of EFMPs have been unsuccessful because the Military Services cannot agree on a set of standards that can be used across installations.

We recommended in our May 2018 report that DOD implement a systematic process for evaluating the results of the Military Services’ monitoring activities. DOD concurred with our recommendation but has not yet fully implemented it. DOD last commented on this recommendation in April 2019 and said the family support component is monitored and evaluated through each Military Service’s certification process, which includes specific standards for the EFMP. In addition, OSN participated in a monitoring site visit to Marine Corps Base Quantico in December 2018 and plans to participate in additional site visits that are coordinated by each Military Service’s certification team. We will consider this recommendation implemented only when DOD provides evidence that it has implemented a systematic process to evaluate the results of each Military Service’s monitoring activities.

In conclusion, DOD relies on each Military Service to implement its policy on support for families with special needs. In doing so, they also rely on each Military Service to determine the extent to which its assistance to families with special needs complies with this policy. As it plans for the future, DOD will need to balance the flexibility it provides each Military Service to implement its policy with the need to assess the adequacy of the Military Services’ EFMPs in serving families with special needs, including any gaps in services these families receive.

Chairwoman Speier, Ranking Member Kelly, and Members of the Subcommittee, this completes my prepared statement. I would be pleased to respond to any questions that you may have at this time.

Contact and Staff Acknowledgements

For further information regarding this testimony, please contact Jacqueline M. Nowicki, Director of Education, Workforce, and Income Security Issues at (617) 788-0580 or nowickij@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this statement.

GAO staff who made key contributions to this statement include Bill MacBlane (Assistant Director), Brian Egger (Analyst-in-Charge), Holly Dye, Robin Marion, James Rebbe, Shelia Thorpe, Walter Vance, Kelsey Kreider, and Mimi Nguyen.

This is a work of the U.S. government and is not subject to copyright protection in the United States. The published product may be reproduced and distributed in its entirety without further permission from GAO. However, because this work may contain copyrighted images or other material, permission from the copyright holder may be necessary if you wish to reproduce this material separately.