Enlisted servicemembers can be separated from the military when they are found to be unsuitable for continued military service. If a servicemember is diagnosed with a non-disability mental condition that interferes with the servicemember’s ability to function in the military, a commanding officer may initiate the separation process. Separated servicemembers may appeal their separation to a discharge review board within 15 years after separation from the military. Further, separated servicemembers may appeal the discharge review board’s decision by applying to a board for the correction of military records. Once enlisted servicemembers have been separated from military service, they receive a certificate of release from the military— Department of Defense Form 214 (DD Form 214)—that includes dates of service, last duty assignment, pay grade and rank, awards received, and a characterization of their service—such as honorable or general under honorable conditions.entities, such as the applicable military service, VA, and the servicemember. Servicemembers receive two copies of the DD Form 214—a copy that includes the characterization of their service and the reason for the separation and one that does not. The reason for the separation is noted by a separation code, as well as a narrative that explains the reason for the separation. According to DOD policy, separation codes are to be used by the military services so that data on the cause of separations can be collected and trends in separations analyzed, which may, in turn, influence changes in DOD separation policy. DOD established six separation codes that the military services may use for non-disability mental conditions on the DD Form 214, but the military services have discretion as to which codes they choose to use. Five of these separation codes pertain only to non- disability mental conditions. They are (1) acute adjustment disorder, (2) disruptive behavior disorder, (3) impulse control disorder, (4) personality disorder, and (5) other non-disability mental disorder. The sixth code available for use by the military services, “condition, not a disability,” is a broader separation code that includes both non-disability physical and mental conditions. DOD’s separation policy, dated January 27, 2014, contains eight separation requirements that the military services must follow when separating enlisted servicemembers for non-disability mental conditions. Of the eight separation requirements, five apply to all enlisted servicemembers and three more apply only to enlisted servicemembers who served in an imminent danger pay (IDP) area, such as Iraq or Afghanistan. 1. The servicemember must be notified in writing that a non-disability mental condition is the basis of the proposed separation, 2. the servicemember must be formally counseled concerning deficiencies and afforded an opportunity to overcome those deficiencies, 3. evidence must demonstrate that the servicemember is unable to function effectively because of a non-disability mental condition, 4. the servicemember must receive a non-disability mental condition diagnosis by a authorized mental health provider,5. the servicemember must be counseled in writing that the diagnosis of a non-disability mental condition does not qualify as a disability. For servicemembers who served in an IDP area, the non-disability mental condition diagnosis must 6. be corroborated by a peer- or higher-level mental health professional, 7. be endorsed by the military service’s surgeon general, and 8. include an assessment to determine whether the servicemember has symptoms of PTSD or other mental illness co-morbidity. Over time, DOD has expanded its separation requirements. In 2011 and 2014 DOD revised its policy by extending its separation requirements to apply to servicemembers being separated for any non-disability mental condition. See table 1 for an explanation of the policy changes since 2008. DOD and three of the four military services—Army, Navy, and Marine Corps—cannot identify the number of enlisted servicemembers separated for non-disability mental conditions because, for most separations, they do not use available codes to specifically designate the reason why servicemembers were separated. Instead, they use the broad separation code, “condition, not a disability,” that mixes non-disability mental conditions with non-disability physical conditions, making it difficult to distinguish one from the other without a time-consuming and resource- intensive record review. In contrast, the Air Force is able to track the specific reasons for its servicemember separations because it uses the full array of separation codes available. DOD policy requires a separation code to be used by the military services so that DOD can track and analyze the reason for separations and evaluate DOD’s separation policy to determine if changes are needed. However, according to DOD officials, the military services can choose to use any of the six available codes that DOD provides the military services to record non-disability mental conditions, including the “condition, not a disability” code. Moreover, under the internal control standard for control activities, all transactions—such as separations of enlisted servicemembers—need to be clearly and accurately documented so they can be examined when needed; for example, to monitor trends in the reasons for servicemembers’ separations. The three military services had varying reasons for using the broad separation code, “condition, not a disability.” Navy and Marine Corps officials stated that they have historically used this code for most separations but Navy officials could not explain why they use this broad code instead of using one of the separation codes specific to non- disability mental conditions. Marine Corps officials cited concerns with potential stigma the servicemember may face if a more specific code is used. Army officials had a similar concern, stating that they use the broad separation code for most non-disability mental condition separations to protect enlisted servicemembers after they leave the service. Army and Marine Corps officials told us they were concerned that employers may request the servicemember’s copy of the DD Form 214 that has the separation code on it, and having a code specific to a mental condition might stigmatize the servicemember. Army officials stated that this issue has been discussed in media articles for several years. In contrast, both Air Force and DOD officials told us that they do not have evidence that including the separation code on the DD Form 214 has caused problems for servicemembers, as suggested by the Army. An Air Force official said that, unlike the Army, the Air Force does not have information that using these codes has caused problems for separated Air Force servicemembers. Likewise, DOD officials told us that they have not heard that this is a problem. According to DOD officials, characterization of service, such as honorable or dishonorable, is usually the piece of information that employers want from the form. By including the characterization of service on both of the servicemember’s copies of the DD Form 214, DOD believes that the servicemember could provide an employer with the copy that does not contain the reason for the separation and the employer will be satisfied because the characterization of service is indicated. Because the three military services are using the broad separation code “condition, not a disability” for most separations, the resulting data cannot be used to identify the number of servicemembers separated for non- disability mental conditions. There is no other systematic way to track these separations; that is, without a tedious and time-consuming manual review. In one instance for example, in response to a request from DOD for information on the number of separations for non-disability mental conditions, the Army undertook a 6-month manual review of over 2,000 servicemember files—all because it does not delineate separations for non-disability mental versus non-disability physical conditions in any data system. If DOD and the military services cannot systematically identify or periodically evaluate the number of enlisted servicemembers separated for non-disability mental conditions, they cannot assess how well the separation policy and process is working or respond specifically to key stakeholders, including the Congress, about trends in or concerns about separations for non-disability mental conditions. From fiscal years 2008 through 2012, when the services were filing compliance reports, most services did not report full compliance with DOD separation requirements for separations for personality disorder. We also found that the reports contained incomplete and inconsistent data, and DOD conducted limited review of these reports. Further, based on a review of separation policies, we found that none of the services’ policies address all DOD requirements for non-disability mental condition separations. Additionally, DOD and the military services do not have oversight processes in place to ensure compliance with DOD requirements in this regard. From fiscal years 2008 through 2012, DOD required the military services to monitor and report to DOD on their compliance with DOD requirements for separating servicemembers for personality disorders; however, while the services generally reported improved compliance over the 5 years of reporting, we found in the 2012 compliance reports that three of the services had not yet achieved full compliance with all of DOD’s 2008 separation requirements. For each of the 20 compliance reports the services submitted for fiscal years 2008 through 2012, the military services were required to review a sample of at least 10 percent of their personality disorder separations for the fiscal year and assess the service’s compliance with DOD’s 2008 separation requirements. Compliance, according to DOD, was achieved if the sample reviewed met a 90 percent compliance threshold for each requirement. According to DOD officials, the annual compliance reports were discontinued in 2013 because the military services’ 2012 compliance reports indicated that the services were compliant with all of DOD’s 2008 requirements. However, it is unclear how DOD came to this conclusion when our review of the 2012 compliance reports found that the Air Force, Marine Corps, and Navy did not report compliance with all DOD requirements.