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entitled 'Military Recruiting: Clarified Reporting Requirements and 
Increased Transparency Could Strengthen Oversight over Recruiter 
Irregularities' which was released on January 28, 2010. 

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Report to the Subcommittee on Military Personnel, Committee on Armed 
Services, House of Representatives: 

United States Government Accountability Office: 
GAO: 

January 2010: 

Military Recruiting: 

Clarified Reporting Requirements and Increased Transparency Could 
Strengthen Oversight over Recruiter Irregularities: 

GAO-10-254: 

GAO Highlights: 

Highlights of GAO-10-254, a report to the Subcommittee on Military 
Personnel, Committee on Armed Services, House of Representatives. 

Why GAO Did This Study: 

To sustain a viable military force, the Department of Defense (DOD) 
depends on recruiting several hundred thousand qualified individuals 
into the military each year. The service components rely on their 
recruiters to act with the utmost integrity because even a single 
incident of wrongdoing on the part of a recruiter—a recruiter 
irregularity—can adversely affect the service components’ ability to 
recruit qualified individuals. GAO was asked to (1) analyze data on 
reported cases of recruiter irregularities across the service 
components, (2) review the extent to which the service components have 
guidance and procedures to address recruiter irregularities, and (3) 
review the extent to which the Office of the Secretary of Defense 
(OSD) has oversight over recruiter irregularities. GAO analyzed the 
data on recruiter irregularities reported to OSD by the service 
components; reviewed the service components’ recruiter irregularity 
case files; examined relevant guidance and procedures from the service 
components; and interviewed service components’ recruiting command 
personnel, recruiters, and OSD officials. 

What GAO Found: 

From fiscal year 2006 through 2008, the total number of substantiated 
cases of recruiter irregularities across the service components 
represented a small percentage of overall accessions (i.e., number of 
individuals entering military service), and the service components 
have taken various actions against the recruiters responsible for 
these irregularities. Specifically, the number of substantiated cases 
of recruiter irregularities as a percentage of overall accessions was 
0.26 percent in fiscal year 2006, 0.22 percent in fiscal year 2007, 
and 0.18 percent in fiscal year 2008. The most common types of 
recruiter irregularity reported involved concealment or falsification 
of documents or information, sexual misconduct, and quality control 
measures (e.g., valid parental signatures). The action most commonly 
applied against recruiters who committed irregularities varied by 
service component. Removal from recruiting was the most commonly 
applied action in the Marine Corps while adverse administrative action 
(e.g., a letter of reprimand in the recruiter’s personnel file) was 
most commonly applied in the Army. 

All service components have guidance and procedures on addressing 
recruiter irregularities and have improved oversight over them, but 
the manner in which data on recruiter irregularities are shared within 
the service components varied. Although some differences exist, the 
service components are similar in how they identify, investigate, and 
adjudicate recruiter irregularities. In addition, the service 
components have taken steps to identify and prevent recruiter 
irregularities, including establishing quality control checks to help 
identify recruiter irregularities and providing training for 
recruiters to help prevent recruiter irregularities. However, in most 
service components, not all levels of command have regular access to 
information on recruiter irregularities that occur. Without regular 
access to information, commanders may not be able to take full 
advantage of servicewide recruiter irregularity data and opportunities 
to learn from their peers. 

Although OSD has implemented requirements for the service components 
to regularly report on recruiter irregularities, it does not have 
complete oversight over the recruiter irregularities that occur. In 
December 2006, OSD issued a memorandum for the service components on 
tracking and reporting recruiter irregularities, and the service 
components have been providing recruiter irregularity data to OSD. 
However, because some of the reporting requirements lack clarity, the 
service components do not interpret the reporting requirements in the 
same way. Further, the data provided to OSD by the National Guard are 
incomplete and the relevant offices within the National Guard Bureau 
do not provide appropriate caveats regarding these data, such as 
including information on the States and Territories that did not 
submit recruiter irregularity data. Unless OSD clarifies the reporting 
requirements in its memorandum and directs the service components to 
provide transparency in the data they report, it will be unable to 
maintain complete oversight over the extent to which recruiter 
irregularities are occurring and make determinations on whether 
corrective action is needed. 

What GAO Recommends: 

GAO is making several recommendations to improve the service components’
sharing of recruiter irregularity data, the clarity of OSD’s reporting 
guidance, and the transparency of the data reported to OSD. In 
commenting on a draft of this report, DOD concurred with GAO’s 
recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-10-254] or key 
components. For more information, contact Brenda S. Farrell at (202) 
512-3604 or farrellb@gao.gov. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Substantiated Cases of Irregularities Represent a Small Percentage of 
Accessions, and Actions Have Been Taken against the Recruiters 
Responsible: 

The Service Components Have Developed Guidance and Procedures to 
Address Recruiter Irregularities, but Not All Service Components Share 
Recruiter Irregularity Data throughout All Levels of Command: 

OSD Implemented Recruiter Irregularity Reporting Requirements, but 
Lacks Complete Oversight over Irregularities: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: Examples of Recruiter Irregularities in Fiscal Year 2008: 

Appendix III: Examples of Dispositions in Fiscal Year 2008: 

Appendix IV: Comments from the Department of Defense: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Number of Recruiters in Fiscal Years 2006 through 2009, by 
Service Component: 

Table 2: Enlisted Accessions for Each Service Component in Fiscal 
Years 2006 through 2009: 

Table 3: Total Number of Substantiated Recruiter Irregularities, 
Accessions, and Irregularities as a Percentage of Accessions, Fiscal 
Years 2006 through 2008: 

Table 4: Cases of Substantiated Recruiter Irregularities as a 
Percentage of All Cases of Reported Recruiter Irregularities, Fiscal 
Years 2006 through 2008: 

Table 5: Most Commonly Reported Types of Recruiter Irregularities as a 
Percentage of All Reported Recruiter Irregularities in Fiscal Year 
2008, by Service Component: 

Table 6: Examples of Substantiated Recruiter Irregularities by Type, 
Fiscal Year 2008: 

Table 7: Most Commonly Reported Actions Taken against Recruiters as a 
Percentage of All Actions Taken, Fiscal Year 2008: 

Table 8: Examples of Actions Taken against Recruiters Who Committed 
Recruiter Irregularities, Fiscal Year 2008: 

Table 9: Organizations and Offices Contacted: 

Table 10: Examples of Substantiated Recruiter Irregularities by Type, 
Fiscal Year 2008: 

Table 11: Examples of Dispositions, Fiscal Year 2008: 

Figures: 

Figure 1: Organization of the Service Recruiting Commands: 

Figure 2: Overview of the Enlistment Process: 

Figure 3: The Service Components' Process for Addressing Recruiter 
Irregularities: 

Figure 4: The Service Components' Processes for Reporting of the 
Recruiter Irregularity Data: 

Figure 5: Army National Guard States and Territories Reporting 
Recruiter Irregularity Data for Fiscal Year 2008 during the January 
2009 Reporting Cycle: 

Abbreviations: 

ASVAB: Armed Forces Vocational Aptitude Battery: 

DOD: Department of Defense: 

MEPCOM: Military Entrance Processing Command: 

MEPS: Military Entrance Processing Station: 

OSD: Office of the Secretary of Defense: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

January 28, 2010: 

The Honorable Susan A. Davis: 
Chairwoman: 
The Honorable Joe Wilson: 
Ranking Member: 
Subcommittee on Military Personnel: 
Committee on Armed Services: 
House of Representatives: 

To sustain a viable all-volunteer military force, the Department of 
Defense (DOD) depends on recruiting several hundred thousand qualified 
individuals into the military each year. Although DOD's service 
components have generally met their recruiting goals in recent years, 
[Footnote 1] the recruiting environment continues to present 
challenges, partly due to the length, frequency, and difficult nature 
of deployments expected of servicemembers. While the present economic 
downturn has increased the number of individuals expressing an 
interest in military service, DOD estimates that only 3 out of 10 
American youth ages 17 to 24 are qualified to join the military. If 
economic conditions improve, it may become more difficult for the 
military to find qualified recruits to carry out its challenging 
mission. 

The service components have assigned 30,000 recruiting personnel to 
carry out DOD's goal of recruiting high-quality individuals into the 
military. Recruiters serve as the military's representatives in 
communities throughout the United States, and the service components 
rely on them to act with the utmost integrity in order to win and 
maintain the public's trust. DOD recognizes that even a single 
incident of wrongdoing on the part of a recruiter can erode public 
confidence in the recruiting process and damage a service component's 
reputation. To prevent such incidents from occurring, the service 
components' recruiting commands have developed guidance that governs 
recruiter irregularities, and instituted procedures for (1) reporting 
allegations of recruiter irregularities and (2) conducting an 
investigation to determine whether a case is substantiated or 
unsubstantiated. Substantiated cases of recruiter wrongdoing are those 
cases in which the service components determine that a recruiter 
violated recruiting guidance based on a review of the facts in the 
case. 

Oversight of the service components' recruiting programs is the 
responsibility of the Office of the Secretary of Defense (OSD), Under 
Secretary of Defense for Personnel and Readiness. That office is 
responsible for policy development, planning, resource management, and 
program evaluation specific to the readiness of the force, including 
those affecting the recruiting force. In establishing oversight over 
recruiter irregularities, OSD issued a directive-type memorandum 
defining recruiter irregularities as those willful and unwillful acts 
of omission and improprieties that are perpetrated or alleged to be 
perpetrated by a recruiter to facilitate the recruiting process for an 
applicant.[Footnote 2] Recruiter irregularities encompass a range of 
actions including, for example, administrative paperwork errors, 
instructing applicants not to reveal certain disqualifying conditions, 
and criminal misconduct.[Footnote 3] 

In 2006, we reported that substantiated cases of recruiter 
irregularities were low relative to overall accessions (i.e., the 
number of individuals entering military service)--less than 1 percent. 
[Footnote 4] However, we found at that time that the service 
components and OSD were not able to determine the full extent to which 
recruiter irregularities were occurring within their command 
structures, thus preventing them from fully addressing the problem. 
For example, we determined that none of the service components could 
provide a comprehensive and accurate report on recruiter 
irregularities within its own organization because the service 
components used multiple data systems that were not integrated and 
maintained the data in different formats; lacked standardized 
procedures for recording the data; and did not account for all 
allegations of recruiter irregularities. As a result, we recommended 
that OSD establish an oversight framework to assess recruiter 
irregularities to include developing criteria and common definitions 
across the services for maintaining recruiter irregularity data, 
implementing a reporting requirement across the services, directing 
the services to develop internal systems and processes that better 
capture and integrate data on recruiter irregularities, and directing 
the commander of DOD's Military Entrance Processing Command (MEPCOM) 
to track and report allegations and service-identified incidents of 
recruiter irregularities to OSD. In providing comments on our report, 
OSD agreed to establish a standardized framework allowing for a fair 
and accurate assessment of recruiter irregularities across the 
services, including establishing the criteria and common definitions 
for maintaining data on recruiter irregularities, and for the services 
to develop internal processes that better capture and integrate these 
data. OSD partially concurred with the recommendation to establish a 
reporting requirement across the services, but disagreed with the 
recommendation for MEPCOM to track and report allegations and 
incidents of recruiter irregularities to OSD because it said such a 
requirement would duplicate the reporting performed by the service 
components.[Footnote 5] Following our report, OSD issued the 
memorandum in December 2006 setting the definitions of recruiter 
irregularities and the requirements for the service components to 
track and report on all cases of recruiter irregularities. 

In this context, you asked us to examine the service components' 
policies and procedures for addressing recruiter irregularities and 
OSD's oversight framework for assessing recruiter irregularities. This 
report addresses the following questions: 

1. What have the data shown on the incidence and types of reported 
cases of recruiter irregularities across the service components and 
what actions have the service components taken in substantiated cases 
of recruiter irregularities? 

2. To what extent have the service components developed guidance and 
procedures to address recruiter irregularities, what progress have 
they made in increasing their oversight over recruiter irregularities, 
and to what extent is information on recruiter irregularities shared 
within the service components? 

3. To what extent does OSD have oversight over recruiter 
irregularities that occur across the service components? 

In conducting this review, we focused our scope on recruiter 
irregularities that affect the active, reserve, and National Guard 
components of DOD's military services that occurred from fiscal year 
2006 through fiscal year 2008. To provide information on the number 
and type of recruiter irregularities, we analyzed recruiter 
irregularity data that OSD received from the service components for 
that period. However, due to possible reporting errors in the 2006 
data resulting from the new reporting requirement on recruiter 
irregularities issued by OSD in December 2006, we were unable to 
present trends in recruiter irregularities. Additionally, we did not 
include fiscal year 2009 data in our analysis of recruiter 
irregularities across the service components because the data covering 
the full fiscal year 2009 will not be reported to OSD by the service 
components in time to be included in our analysis. Although we found 
recruiter irregularity data for the active and reserve components to 
be sufficiently reliable for the purposes of this report, we could not 
present the data on recruiter irregularities reported by the National 
Guard because States and Territories do not report their data 
consistently and the different systems used by States and Territories 
for maintaining and reporting these data lead to data reliability 
issues. As part of our first objective, we also requested and reviewed 
case files from each of the active and reserve components for all 
substantiated cases of recruiter irregularities that occurred in 
fiscal year 2008 to provide illustrative examples of the types of 
recruiter irregularities that occur and the actions taken by the 
service components against recruiters responsible for committing 
recruiter irregularities. However, because the National Guard Bureau 
does not maintain centralized data on cases of recruiter 
irregularities, we selected and obtained case files from all seven 
States (Alabama, California, Indiana, Minnesota, Oklahoma, 
Pennsylvania, and Wisconsin) that reported more than four 
substantiated recruiter irregularities in fiscal year 2008. To assess 
the extent to which the service components' have guidance and 
procedures in place to address recruiter irregularities, we obtained 
and reviewed the service components' written guidance related to the 
enlistment process and recruiter conduct. To determine the extent to 
which OSD has oversight over recruiter irregularities, we interviewed 
officials from OSD and MEPCOM. We supplemented our work for all three 
objectives with site visits to the service components' recruiting 
commands to interview recruiting command officials, staff from 
military entrance processing stations (MEPS), and recruiters. 

We conducted this performance audit from February 2009 through January 
2010 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. More 
information on our scope and methodology is available in appendix I. 

Results in Brief: 

OSD data have shown that from fiscal year 2006 through fiscal year 
2008, substantiated cases of recruiter irregularities across the 
service components represented a small percentage of overall 
accessions, and the service components have taken various actions 
against the recruiters responsible for these irregularities. The total 
number of substantiated cases of recruiter irregularities as a 
percentage of overall military accessions was 0.26 percent (616 cases 
out of 239,629 accessions) in fiscal year 2006, 0.22 percent (526 
cases out of 242,602 accessions) in fiscal year 2007, and 0.18 percent 
(450 cases out of 248,797 accessions) in fiscal year 2008. The 
substantiated cases, however, represented less than one-quarter of all 
reported cases of recruiter irregularities. Of the 7,081 cases of 
recruiter irregularities reported by the service components during 
this time period, substantiated cases comprised 22.5 percent (or 1,592 
cases). The types of recruiter irregularities most frequently reported 
from fiscal year 2006 through fiscal year 2008 varied by service 
component. For example, in fiscal year 2008, the most common type of 
recruiter irregularity reported by all service components except the 
Air Force Reserve involved the concealment or falsification of 
documents or information, such as when a recruiter omitted information 
concerning prior criminal violations in an applicant's application 
packet. The incidence of other types of recruiter irregularities 
reported for fiscal year 2008 varied by service component. For 
example, sexual misconduct constituted the second most commonly 
reported type of recruiter irregularity in the Marine Corps, while 
quality control measures, such as a recruiter failing to obtain 
parental signatures on an applicant's application form, constituted 
the second most commonly reported type of recruiter irregularity in 
the Army. The types of actions taken against recruiters who committed 
irregularities in fiscal year 2008 also varied by service component. 
For example, the type of action most commonly applied in the Marine 
Corps was removal from recruiting. In contrast, the type of action 
most commonly applied in the Army was adverse administrative action, 
such as placing a letter of reprimand in the recruiter's permanent 
personnel file. Within the National Guard, the types of actions taken 
against a recruiter who committed irregularities varied among the 
seven States included in our review, likely due to the differences in 
state laws and guidance that govern how investigations are conducted 
and actions applied. 

The service components have developed guidance and procedures to 
address recruiter irregularities and have improved their oversight 
over them, but the manner in which information is shared within the 
service components varies.[Footnote 6] All service components have 
guidance on recruiter irregularities and have instituted procedures 
for reporting allegations of recruiter irregularities, conducting 
investigations, and adjudicating cases of recruiter irregularities. In 
addition, the service components have taken steps to identify and 
prevent recruiter irregularities, including establishing quality 
control checks throughout the enlistment process and providing 
training for recruiters on issues related to recruiter irregularities. 
However, as we reported in prior work, in order to make improvements 
and promote knowledge sharing, leaders at all levels of an 
organization need to receive information on a continuous basis about 
problems that may be occurring across the organization.[Footnote 7] 
The Air Force has taken initiative to regularly share servicewide 
recruiter irregularity data, including information on the types of 
recruiter irregularities committed and the disposition of cases, with 
all levels of command within the Air Force Recruiting Service and all 
recruiting staff. Air Force officials explained that making this 
information available to all levels within the Air Force Recruiting 
Service provides commanders with examples of how others are addressing 
recruiter irregularities, promotes consistent application of such 
actions in substantiated cases of recruiter irregularities across the 
Air Force, and serves as a deterrent to future recruiter 
irregularities. However, while all service components regularly 
provide recruiter irregularity data to their recruiting command 
headquarters, in most service components outside of the Air Force, not 
all levels of command have regular access to information on the 
recruiter irregularities occurring. This is because the other service 
components do not have procedures for the data to regularly flow back 
to the commanders at levels below the recruiting headquarters to 
inform their efforts. Without continuous access to information on 
recruiter irregularities across their service component, commanders 
may not be able to take full advantage of servicewide recruiter 
irregularity data and opportunities to learn from their peers. We are 
recommending that the Secretary of Defense direct the Secretaries of 
the Army and Navy to identify mechanisms for the regular sharing of 
recruiter irregularity data within their service components. 

Although OSD requires the service components to report on cases of 
recruiter irregularities, OSD does not have complete oversight over 
the recruiter irregularities that have occurred across the service 
components because the reporting requirements lack clarity and the 
data are incomplete. In December 2006, OSD issued a memorandum that 
defines recruiter irregularities, establishes specific reporting 
categories to capture the types of recruiter irregularities that occur 
and the actions the service components take in response, and requires 
semiannual reporting of recruiter irregularities by the service 
components to OSD.[Footnote 8] Although issuing the memorandum was an 
important first step in providing effective oversight over recruiter 
irregularities consistent with good management practices outlined in 
federal control standards, OSD still lacks comprehensive information 
on recruiter irregularities across the service components because some 
of the reporting requirements in the memorandum lack clarity and the 
data provided by the National Guard are incomplete. For example, 
although most service components report only on cases involving 
applicants, at least one service component reported on all cases of 
infractions by recruiters, such as the use of a government vehicle for 
personal use or inappropriate relationship with other military 
personnel. In addition, recruiting officials with whom we spoke cited 
several problems with categorization, including reporting categories 
being too broad and lack of clarity on how to report cases in which 
more than one type of irregularity was committed or more than one 
action was taken against the recruiter. OSD officials said that the 
reporting requirements will be clarified when the 2006 memorandum is 
turned into an instruction for the service components to follow, but 
they have not developed the instruction yet. With respect to the 
National Guard data, the data provided to OSD by the National Guard 
are incomplete.[Footnote 9] For example, our review of the recruiter 
irregularity data that the Army National Guard States and Territories 
provided to the Army National Guard Strength Maintenance Division in 
January 2009 showed that 18 of the 54 States and Territories did not 
provide the data for fiscal year 2008. The National Guard Bureau, in 
turn, has not provided the appropriate caveats in its reports to OSD 
about the States and Territories that did not provide their recruiter 
irregularity data, and OSD officials have not asked for such caveats. 
Unless OSD clarifies the reporting requirements in the memorandum and 
directs the service components to provide transparency in the data 
they report, it will be unable to maintain complete oversight over the 
extent to which recruiter irregularities are occurring across the 
service components and determine whether corrective action is needed. 
We are recommending that the Secretary of Defense direct the Under 
Secretary of Defense for Personnel and Readiness to (1) complete the 
instruction on tracking and reporting data on recruiter irregularities 
to clarify the requirements and categories for the types of recruiter 
irregularities to be reported and actions taken; (2) direct the 
National Guard Bureau to provide transparency in the data that it 
reports to OSD and disclose any limitations in these data; and (3) 
include the appropriate disclosures concerning data limitations in the 
recruiter irregularity reports that it produces on the basis of these 
data for the Congress and others. 

In commenting on a draft of this report, DOD stated that it concurred 
with our recommendations. DOD described the actions that it plans to 
take to work with the service components on addressing our 
recommendations and plans to complete these actions during fiscal year 
2010. 

Background: 

Subject to the authority, direction, and control of the Secretary of 
Defense, it is the responsibility of the services to recruit and train 
their forces. The service components depend on military recruiters to 
meet their annual recruiting missions. In fiscal year 2009, the 
service components utilized 30,936 military recruiters. Of those, 
26,381 were frontline recruiters assigned a monthly recruiting goal. 
[Footnote 10] The remaining recruiters held supervisory and staff 
positions throughout the services' recruiting commands. (See table 1 
for the number of recruiters for fiscal year 2006 through fiscal year 
2009.) 

Table 1: Number of Recruiters in Fiscal Years 2006 through 2009, by 
Service Component: 

Total recruiters: 

Fiscal year: 2006; 
Army: Active and Reserve: 11,410; 
Army: National Guard: 6,313; 
Navy: Active and Reserve: 5,133; 
Marine Corps: Active and Reserve: 3,388; 
Air Force: Active: 2,284; 
Air Force: Reserve: 412; 
Air Force: National Guard: 464; 
DOD: 29,404. 

Fiscal year: 2007; 
Army: Active and Reserve: 11,347; 
Army: National Guard: 7,558; 
Navy: Active and Reserve: 5,261; 
Marine Corps: Active and Reserve: 3,633; 
Air Force: Active: 2,259; 
Air Force: Reserve: 411; 
Air Force: National Guard: 464; 
DOD: 30,933. 

Fiscal year: 2008; 
Army: Active and Reserve: 12,232; 
Army: National Guard: 7,893; 
Navy: Active and Reserve: 5,499; 
Marine Corps: Active and Reserve: 4,033; 
Air Force: Active: 1,992; 
Air Force: Reserve: 424; 
Air Force: National Guard: 464; 
DOD: 32,537. 

Fiscal year: 2009; 
Army: Active and Reserve: 11,171; 
Army: National Guard: 7,042; 
Navy: Active and Reserve: 5,670; 
Marine Corps: Active and Reserve: 4,033; 
Air Force: Active: 2,033; 
Air Force: Reserve: 429; 
Air Force: National Guard: 558; 
DOD: 30,936. 

Frontline recruiters: 

Fiscal year: 2006; 
Army: Active and Reserve: 10,381; 
Army: National Guard: 4,919; 
Navy: Active and Reserve: 4,796; 
Marine Corps: Active and Reserve: 3,388; 
Air Force: Active: 1,624; 
Air Force: Reserve: 339; 
Air Force: National Guard: 464; 
DOD: 25,911. 

Fiscal year: 2007; 
Army: Active and Reserve: 10,281; 
Army: National Guard: 5,027; 
Navy: Active and Reserve: 5,027; 
Marine Corps: Active and Reserve: 3,633; 
Air Force: Active: 1,580; 
Air Force: Reserve: 342; 
Air Force: National Guard: 464; 
DOD: 26,354. 

Fiscal year: 2008; 
Army: Active and Reserve: 11,190; 
Army: National Guard: 4,970; 
Navy: Active and Reserve: 5,321; 
Marine Corps: Active and Reserve: 4,033; 
Air Force: Active: 1,320; 
Air Force: Reserve: 347; 
Air Force: National Guard: 464; 
DOD: 27,645. 

Fiscal year: 2009; 
Army: Active and Reserve: 10,283; 
Army: National Guard: 4,456; 
Navy: Active and Reserve: 5,348; 
Marine Corps: Active and Reserve: 4,033; 
Air Force: Active: 1,346; 
Air Force: Reserve: 357; 
Air Force: National Guard: 558; 
DOD: 26,381. 

Source: Office of the Under Secretary of Defense for Personnel and 
Readiness. 

Note: Unlike the Air Force, the Army, Navy, and Marine Corps 
recruiters recruit for both active and reserve components of their 
services. 

[End of table] 

Each of the military services has its own recruiting command, which is 
responsible for the service's recruiting mission and functions. 
[Footnote 11] The role of the recruiting command is to provide support 
to the recruiting force and guidance for the recruitment and 
enlistment process. In addition, the recruiting command plays a role 
in developing the recruiting goals. The commands are structured 
similarly across the services with some variation in organizational 
structure, as noted in figure 1. The recruiting command is the 
recruiting headquarters for each service, with subordinate commands 
between the headquarters level and recruiting stations or substations 
where frontline recruiters work to reach out to prospective applicants 
and communicate to them the benefits of joining the military. 

Figure 1: Organization of the Service Recruiting Commands: 

[Refer to PDF for image: illustration] 

Service Recruiting Commands Headquarters: 

Army Brigades (6): 
* Battalions (43); 
* Companies (260); 
* Recruiting stations (1724). 

Navy: Region (East); Region (West): 
* Districts (26); 
* Zones (259); 
* Recruiting stations (1468). 

Marine Corps: Region (Eastern); Region (Western): 
* Districts (6); 
* Recruiting stations (48); 
* Recruiting substations (636). 

Air Force[A]: Groups (3); 
* Squadrons (24); 
* Flights (182); 
* Recruiting stations (988). 

Air Force Reserve[A]: Squadrons(3); 
* Recruiting stations (271). 

Source: GAO analysis of information from the service components. 

[A] The Department of the Air Force is the only military department in 
which the recruiting commands for the active and reserve components 
are separate. 

Note: The Army National Guard and the Air National Guard have 
recruiting entities that are separate from the recruiting commands for 
the Army and the Air Force. Recruiting in the Army National Guard is 
overseen by the Army National Guard Strength Maintenance Division 
within the National Guard Bureau. Recruiting in the Air National Guard 
is overseen by the Air National Guard Recruiting and Retention Service 
within the National Guard Bureau. 

[End of figure] 

Since 2006, most of the service components have been able to achieve 
their recruiting goals, and all service components met their 
recruiting goals in fiscal years 2008 and 2009. (See table 2 for 
accession goals and achievements from fiscal year 2006 through fiscal 
year 2009.) Service component officials and recruiters alike have 
attributed the high rate of recruiting success to the conditions of 
the economy and the services' competitive advantage over the civilian 
job market, particularly given the rising unemployment rate. DOD found 
that more youth are willing to consider military service during 
periods of high unemployment. Recruiters reported, however, that while 
they have seen an increase in the number of individuals interested in 
military service, many of them do not meet the military's 
qualification requirements. DOD estimated that approximately 7 out of 
10 youth ages 17 to 24 do not meet the military's entrance standards 
for reasons including medical conditions, prior criminal records, and 
existence of young dependents. 

Table 2: Enlisted Accessions for Each Service Component in Fiscal 
Years 2006 through 2009: 

Service component: Army; 
Fiscal year 2006: Accessions achieved: 80,635; 
Fiscal year 2006: Percentage of goal achieved: 101; 
Fiscal year 2007: Accessions achieved: 80,407; 
Fiscal year 2007: Percentage of goal achieved: 101; 
Fiscal year 2008: Accessions achieved: 80,517; 
Fiscal year 2008: Percentage of goal achieved: 101; 
Fiscal year 2009: Accessions achieved: 70,045; 
Fiscal year 2009: Percentage of goal achieved: 108. 

Service component: Army National Guard; 
Fiscal year 2006: Accessions achieved: 69,042; 
Fiscal year 2006: Percentage of goal achieved: 99; 
Fiscal year 2007: Accessions achieved: 66,652; 
Fiscal year 2007: Percentage of goal achieved: 95; 
Fiscal year 2008: Accessions achieved: 65,192; 
Fiscal year 2008: Percentage of goal achieved: 103; 
Fiscal year 2009: Accessions achieved: 56,071; 
Fiscal year 2009: Percentage of goal achieved: 100. 

Service component: Army Reserve; 
Fiscal year 2006: Accessions achieved: 34,379; 
Fiscal year 2006: Percentage of goal achieved: 95; 
Fiscal year 2007: Accessions achieved: 35,734; 
Fiscal year 2007: Percentage of goal achieved: 101; 
Fiscal year 2008: Accessions achieved: 39,870; 
Fiscal year 2008: Percentage of goal achieved: 106; 
Fiscal year 2009: Accessions achieved: 36,189; 
Fiscal year 2009: Percentage of goal achieved: 105. 

Service component: Navy; 
Fiscal year 2006: Accessions achieved: 36,679; 
Fiscal year 2006: Percentage of goal achieved: 100; 
Fiscal year 2007: Accessions achieved: 37,361; 
Fiscal year 2007: Percentage of goal achieved: 101; 
Fiscal year 2008: Accessions achieved: 38,485; 
Fiscal year 2008: Percentage of goal achieved: 100; 
Fiscal year 2009: Accessions achieved: 35,527; 
Fiscal year 2009: Percentage of goal achieved: 100. 

Service component: Navy Reserve; 
Fiscal year 2006: Accessions achieved: 9,722; 
Fiscal year 2006: Percentage of goal achieved: 87; 
Fiscal year 2007: Accessions achieved: 10,627; 
Fiscal year 2007: Percentage of goal achieved: 100; 
Fiscal year 2008: Accessions achieved: 9,134; 
Fiscal year 2008: Percentage of goal achieved: 100; 
Fiscal year 2009: Accessions achieved: 7,793; 
Fiscal year 2009: Percentage of goal achieved: 101. 

Service component: Marine Corps; 
Fiscal year 2006: Accessions achieved: 32,337; 
Fiscal year 2006: Percentage of goal achieved: 100; 
Fiscal year 2007: Accessions achieved: 35,603; 
Fiscal year 2007: Percentage of goal achieved: 100; 
Fiscal year 2008: Accessions achieved: 37,991; 
Fiscal year 2008: Percentage of goal achieved: 100; 
Fiscal year 2009: Accessions achieved: 31,413; 
Fiscal year 2009: Percentage of goal achieved: 100. 

Service component: Marine Corps Reserve; 
Fiscal year 2006: Accessions achieved: 8,056; 
Fiscal year 2006: Percentage of goal achieved: 100; 
Fiscal year 2007: Accessions achieved: 7,959; 
Fiscal year 2007: Percentage of goal achieved: 110; 
Fiscal year 2008: Accessions achieved: 7,629; 
Fiscal year 2008: Percentage of goal achieved: 100; 
Fiscal year 2009: Accessions achieved: 8,805; 
Fiscal year 2009: Percentage of goal achieved: 122. 

Service component: Air Force; 
Fiscal year 2006: Accessions achieved: 30,889; 
Fiscal year 2006: Percentage of goal achieved: 100; 
Fiscal year 2007: Accessions achieved: 27,801; 
Fiscal year 2007: Percentage of goal achieved: 100; 
Fiscal year 2008: Accessions achieved: 27,848; 
Fiscal year 2008: Percentage of goal achieved: 100; 
Fiscal year 2009: Accessions achieved: 31,983; 
Fiscal year 2009: Percentage of goal achieved: 100. 

Service component: Air Force Reserve; 
Fiscal year 2006: Accessions achieved: 6,932; 
Fiscal year 2006: Percentage of goal achieved: 105; 
Fiscal year 2007: Accessions achieved: 7,110; 
Fiscal year 2007: Percentage of goal achieved: 104; 
Fiscal year 2008: Accessions achieved: 7,323; 
Fiscal year 2008: Percentage of goal achieved: 105; 
Fiscal year 2009: Accessions achieved: 8,604; 
Fiscal year 2009: Percentage of goal achieved: 109. 

Service component: Air National Guard; 
Fiscal year 2006: Accessions achieved: 9,138; 
Fiscal year 2006: Percentage of goal achieved: 97; 
Fiscal year 2007: Accessions achieved: 9,975; 
Fiscal year 2007: Percentage of goal achieved: 93; 
Fiscal year 2008: Accessions achieved: 10,749; 
Fiscal year 2008: Percentage of goal achieved: 126; 
Fiscal year 2009: Accessions achieved: 10,075; 
Fiscal year 2009: Percentage of goal achieved: 106. 

Service component: DOD; 
Fiscal year 2006: Accessions achieved: 317,809; 
Fiscal year 2006: Percentage of goal achieved: 99; 
Fiscal year 2007: Accessions achieved: 319,229; 
Fiscal year 2007: Percentage of goal achieved: 99; 
Fiscal year 2008: Accessions achieved: 324,738; 
Fiscal year 2008: Percentage of goal achieved: 102; 
Fiscal year 2009: Accessions achieved: 296,505; 
Fiscal year 2009: Percentage of goal achieved: 103. 

Source: Office of the Under Secretary of Defense for Personnel and 
Readiness. 

[End of table] 

Even in this favorable recruiting environment, irregularities can 
occur and checks have been built into the enlistment process that may 
help minimize recruiter irregularities. These checks begin with the 
initial prescreening of the applicant conducted by the recruiter and 
involve a background review, an initial determination of physical 
eligibility, and a review of education credentials. After the initial 
prescreening, the military pays the applicant to travel to 1 of the 65 
military entrance processing stations (MEPS) located throughout the 
country.[Footnote 12] Each MEPS station is staffed with military and 
civilian personnel, including liaisons representing each service 
component and MEPS staff who are responsible for quality control 
checks that are designed to prevent anyone not qualified for their 
service component from entering. Upon arrival at the MEPS, applicants 
meet with their service component's liaison who reviews their 
qualifications. Applicants are also administered the Armed Services 
Vocational Aptitude Battery (ASVAB) that determines the applicant's 
qualifications for enlistment and for a specific military job. 
[Footnote 13] In addition, a MEPS doctor conducts a medical 
examination to determine whether the applicant meets the physical 
entrance standards. When the applicant has met the qualifications for 
military enlistment, the applicant signs an enlistment contract and is 
sworn into the service before entering into the delayed entry program. 
[Footnote 14] In this program, applicants become members of the 
Individual Ready Reserve in an unpaid status until they receive orders 
to report for basic training. Prior to shipping to basic training, the 
applicant must return to the MEPS to undergo a brief physical 
examination that ascertains that the applicant continues to meet the 
physical fitness standards for entering the military. Upon successful 
completion of this final exam, the applicant is sworn into the 
military and shipped to basic training. Figure 2 illustrates the steps 
in the enlistment process. 

Figure 2: Overview of the Enlistment Process: 

[Refer to PDF for image: illustration] 

Applicants: 

Recruiting stations/substations: 
Army; 
Navy; 
Marine Corps; 
Air Force. 

MEPS: 
* MEPS liaison interview; 
* ASVAB test; 
* Physical exam; 
* First enlistment oath. 

Delayed Entry Program. 

MEPS: 
* Physical exam; 
* Second enlistment oath. 

Service basic training. 

Source: GAO analysis of information from the service components; Art 
Explosion (clip art). 

[End of figure] 

Substantiated Cases of Irregularities Represent a Small Percentage of 
Accessions, and Actions Have Been Taken against the Recruiters 
Responsible: 

Substantiated Cases of Recruiter Irregularities across the Service 
Components Comprise a Small Percentage of Overall Accessions: 

From fiscal year 2006 through fiscal year 2008, the total number of 
substantiated cases of recruiter irregularities across the service 
components comprised a small percentage of overall accessions. 
[Footnote 15] As table 3 shows, the total number of substantiated 
cases of recruiter irregularities comprised less than 0.4 percent of 
accessions in every service component during this period. For example, 
there were 321 substantiated recruiter irregularity cases in the Army 
in fiscal year 2006, comprising 0.28 percent of the Army's accessions. 

Table 3: Total Number of Substantiated Recruiter Irregularities, 
Accessions, and Irregularities as a Percentage of Accessions, Fiscal 
Years 2006 through 2008: 

Fiscal year 2006: Substantiated irregularities; 
Service component: Army: 321; 
Service component: Navy: 159; 
Service component: Marine Corps: 102; 
Service component: Air Force: 14; 
Service component: Air Force Reserve: 20; 
Total: 616. 

Fiscal year 2006: Accessions; 
Service component: Army: 115,014; 
Service component: Navy: 46,401; 
Service component: Marine Corps: 40,393; 
Service component: Air Force: 30,889; 
Service component: Air Force Reserve: 6,932; 
Total: 239,629. 

Fiscal year 2006: Substantiated irregularities as percentage of 
accessions; 
Service component: Army: 0.28; 
Service component: Navy: 0.34; 
Service component: Marine Corps: 0.25; 
Service component: Air Force: 0.05; 
Service component: Air Force Reserve: 0.29; 
Total: 0.26. 

Fiscal year 2007: Substantiated irregularities; 
Service component: Army: 278; 
Service component: Navy: 93; 
Service component: Marine Corps: 119; 
Service component: Air Force: 25; 
Service component: Air Force Reserve: 11; 
Total: 526. 

Fiscal year 2007: Accessions; 
Service component: Army: 116,141; 
Service component: Navy: 47,988; 
Service component: Marine Corps: 43,562; 
Service component: Air Force: 27,801; 
Service component: Air Force Reserve: 7,110; 
Total: 242,602. 

Fiscal year 2007: Substantiated irregularities as percentage of 
accessions; 
Service component: Army: 0.24; 
Service component: Navy: 0.19; 
Service component: Marine Corps: 0.27; 
Service component: Air Force: 0.09; 
Service component: Air Force Reserve: 0.15; 
Total: 0.22. 

Fiscal year 2008: Substantiated irregularities; 
Service component: Army: 253; 
Service component: Navy: 101; 
Service component: Marine Corps: 71; 
Service component: Air Force: 17; 
Service component: Air Force Reserve: 8; 
Total: 450. 

Fiscal year 2008: Accessions; 
Service component: Army: 120,387; 
Service component: Navy: 47,619; 
Service component: Marine Corps: 45,620; 
Service component: Air Force: 27,848; 
Service component: Air Force Reserve: 7,323; 
Total: 248,797. 

Fiscal year 2008: Substantiated irregularities as percentage of 
accessions; 
Service component: Army: 0.21; 
Service component: Navy: 0.21; 
Service component: Marine Corps: 0.16; 
Service component: Air Force: 0.06; 
Service component: Air Force Reserve: 0.11; 
Total: 0.18. 

Source: GAO analysis of data provided by the Office of the Under 
Secretary of Defense for Personnel and Readiness. 

Notes: Accessions numbers for the Army, Navy, and the Marine Corps 
include both active and reserve component accessions. 

We did not present the number of cases of recruiter irregularities for 
the National Guard because not all States and Territories consistently 
report data and because of concerns about the reliability of the data 
reported. 

We did not present fiscal year 2009 recruiter irregularity data 
because full fiscal year 2009 data will not be available in time to 
include in our analysis. 

[End of table] 

From fiscal year 2006 through fiscal year 2008, less than 25 percent 
of the total reported cases of recruiter irregularities were found to 
be substantiated, as shown in table 4. However, the proportion of 
recruiter irregularities reported during that period that were found 
to be substantiated varied--both among the service components and 
within individual service components. For example, of the cases of 
recruiter irregularities reported in the Army during fiscal year 2008, 
15 percent were found to be substantiated by commanders based on a 
review of the facts of an investigation; during the same period, 71 
percent of the Air Force's reported cases were substantiated. 

Table 4: Cases of Substantiated Recruiter Irregularities as a 
Percentage of All Cases of Reported Recruiter Irregularities, Fiscal 
Years 2006 through 2008: 

Service component: Army; 
Fiscal year 2006 (total): 18.8% (1,710); 
Fiscal year 2007 (total): 15.9% (1,747); 
Fiscal year 2008 (total): 15.1% (1,681); 
Average, fiscal years 2006-2008 (total): 16.6% (5,138). 

Service component: Navy; 
Fiscal year 2006 (total): 33.8% (471); 
Fiscal year 2007 (total): 36.3% (256); 
Fiscal year 2008 (total): 27.4v (369); 
Average, fiscal years 2006-2008 (total): 32.2% (1,096). 

Service component: Marine Corps; 
Fiscal year 2006 (total): 53.1% (192); 
Fiscal year 2007 (total): 56.4% (211); 
Fiscal year 2008 (total): 60.2% (118); 
Average, fiscal years 2006-2008 (total): 56.0% (521). 

Service component: Air Force; 
Fiscal year 2006 (total): 9.0% (155); 
Fiscal year 2007 (total): 62.5% (40); 
Fiscal year 2008 (total): 70.8% (24); 
Average, fiscal years 2006-2008 (total): 25.6% (219). 

Service component: Air Force Reserve; 
Fiscal year 2006 (total): 51.3% (39); 
Fiscal year 2007 (total): 28.9% (38); 
Fiscal year 2008 (total): 26.7% (30); 
Average, fiscal years 2006-2008 (total): 36.4% (107). 

Service component: Total; 
Fiscal year 2006 (total): 24.0% (2,567); 
Fiscal year 2007 (total): 22.9% (2,292); 
Fiscal year 2008 (total): 20.3% (2,222); 
Average, fiscal years 2006-2008 (total): 22.5% (7,081). 

Source: GAO analysis of data provided by the Office of the Under 
Secretary of Defense for Personnel and Readiness. 

Note: We did not present the number of cases of recruiter 
irregularities for the National Guard because not all States and 
Territories consistently report data and because of concerns about the 
reliability of the data reported. 

We did not present fiscal year 2009 recruiter irregularity data 
because full fiscal year 2009 data will not be available in time to 
include in our analysis. 

[End of table] 

Concealment or Falsification of Documents or Information Was the Most 
Commonly Reported Irregularity: 

From fiscal year 2006 through fiscal year 2008, recruiter 
irregularities involving concealment or falsification, such as when a 
recruiter omitted information concerning prior criminal violations in 
an applicant's application packet, constituted the most commonly 
reported type of recruiter irregularity by all service components 
except the Air Force Reserve. For the Air Force Reserve, quality 
control measures, such as a recruiter failing to obtain parental 
signatures on an applicant's application form, were the most common 
type of recruiter irregularity reported. The second most commonly 
reported type of recruiter irregularity varied among the service 
components. For example, in fiscal year 2008, it involved quality 
control measures in the Army, while during the same fiscal year, it 
involved sexual misconduct in the Marine Corps. (See table 5 for the 
types of recruiter irregularities most commonly reported by the 
service components in fiscal year 2008.) 

Table 5: Most Commonly Reported Types of Recruiter Irregularities as a 
Percentage of All Reported Recruiter Irregularities in Fiscal Year 
2008, by Service Component: 

Service component: Army; 
n=: 1681; 
Most common (percentage): Concealment/falsification (50.7%); 
Second most common (percentage): Quality control measures (41.8%). 

Service component: Navy; 
n=: 369; 
Most common (percentage): Concealment/falsification (64.8%); 
Second most common (percentage): Fraternization or unauthorized 
relationship with an applicant (10.6%). 

Service component: Marine Corps; 
n=: 118; 
Most common (percentage): Concealment/falsification (44.9%); 
Second most common (percentage): Sexual misconduct (22.9%). 

Service component: Air Force; 
n=: 24; 
Most common (percentage): Concealment/falsification (50.0%); 
Second most common (percentage): Fraternization or unauthorized 
relationship with an applicant (41.7%). 

Service component: Air Force Reserve; 
n=: 30; 
Most common (percentage): Quality control measures (53.3%); 
Second most common (percentage): Concealment/falsification (33.3%). 

Source: GAO analysis of data provided by the Office of the Under 
Secretary of Defense for Personnel and Readiness. 

Note: We did not present the most commonly reported types of recruiter 
irregularities for the National Guard because not all States and 
Territories consistently report data and because of concerns about the 
reliability of the data reported. 

[End of table] 

Our review of the service components' case files of recruiter 
irregularities reported in fiscal year 2008 identified examples of 
recruiter irregularities illustrating each of the eight recruiter 
irregularity categories established in OSD's memorandum.[Footnote 16] 
As the examples in table 6 show, recruiters across the service 
components committed a range of recruiter irregularities, from 
administrative or paperwork errors to inappropriate relationships with 
applicants or recruits. (Additional examples can be found in appendix 
II.) 

Table 6: Examples of Substantiated Recruiter Irregularities by Type, 
Fiscal Year 2008: 

Criminal misconduct: 
A recruiter in charge of a recruiting station was involved in the 
purchasing of illegal drugs with a recruit (Navy). 

Sexual misconduct: 
A recruiter impregnated a 17 year-old student in a high school in 
which he was responsible for recruiting (Marine Corps). 

Sexual harassment: 
A recruiter sent sexually suggestive jokes to an applicant via e-mail, 
made inappropriate comments to the applicant, and refused to leave the 
applicant's place of employment (Air Force Reserve). 

Fraternization or unauthorized relationship with an applicant: 
A recruiter requested inappropriate pictures from a recruit, exchanged 
inappropriate personal text messages with the recruit, and engaged in 
a sexual relationship with the recruit (Army). 

Concealment or falsification: 
A recruiter omitted a driving under the influence violation from an 
applicant's application packet (Air Force). 

False promise/coercion: 
A recruiter misled an applicant about the length of reserve service 
the applicant's contract would require (Army National Guard). 

Testing irregularity: 
A recruiter attempted to have a recent recruit take the ASVAB for an 
applicant (Marine Corps). 

Quality control measures: 
A recruiter did not obtain the signature of both parents on the 
parental consent form required for enlistment (Army). 

Source: GAO analysis of recruiter irregularity case files provided by 
the service components. 

[End of table] 

Actions Taken against Recruiters in Substantiated Cases of Recruiter 
Irregularities Varied by Service Component: 

From fiscal year 2006 through fiscal year 2008, all service components 
took actions against recruiters who committed irregularities, but the 
service components varied in the types of actions that they most 
commonly took against these recruiters during these fiscal years. For 
example, as can be seen in table 7, in fiscal year 2008, the most 
common type of action taken by the Army involved adverse 
administrative action, such as placing a letter of reprimand in the 
recruiter's permanent personnel file, while the most common type of 
action taken in the Marine Corps involved removal from recruiting. 

Table 7: Most Commonly Reported Actions Taken against Recruiters as a 
Percentage of All Actions Taken, Fiscal Year 2008: 

Service component: Army; 
n=: 253; 
Most common (percentage): Adverse administrative action (65.6%); 
Second most common (percentage): Article 15 Non-Judicial Punishment 
(16.2%). 

Service component: Navy; 
n=: 101; 
Most common (percentage): Non-adverse administrative action (42.6%); 
Second most common (percentage): Article 15 Non-Judicial Punishment 
(35.6%). 

Service component: Marine Corps; 
n=: 71; 
Most common (percentage): Removed from recruiting (49.3%); 
Second most common (percentage): Removed from service and adverse 
administrative action (16.9% each). 

Service component: Air Force; 
n=: 17; 
Most common (percentage): Non-adverse administrative action (29.4%); 
Second most common (percentage): Article 15 Non-Judicial Punishment 
(23.5%). 

Service component: Air Force Reserve; 
n=: 8; 
Most common (percentage): Removed from recruiting, non-adverse 
administrative action, and administrative or processing error (25.0% 
each); 
Second most common (percentage): Adverse administrative action and 
Article 15 Non-Judicial Punishment (12.5%). 

Source: GAO analysis of data provided by the Office of the Under 
Secretary of Defense for Personnel and Readiness. 

Note: We did not present the most commonly reported actions for the 
National Guard because not all States and Territories consistently 
report data and because of concerns about the reliability of the data 
reported. 

[End of table] 

The OSD memorandum provides the service components with specific 
categories to use when reporting on the status of cases, including 
categories for cases in which action has been taken, cases that are 
still ongoing, and cases that were determined to be unsubstantiated. 
[Footnote 17] Our review of the service components' case files of 
recruiter irregularities reported in fiscal year 2008 identified 
examples illustrating each of OSD's reporting categories. As can be 
seen in table 8, the service components sometimes take different 
actions against recruiters who committed similar types of recruiter 
irregularities. For instance, an Air Force recruiter was court- 
martialed for fraternizing with an applicant, while a Navy recruiter 
received an Article 15 Non-Judicial Punishment for a similar type of 
offense. (Additional examples can be found in appendix III.) 

Table 8: Examples of Actions Taken against Recruiters Who Committed 
Recruiter Irregularities, Fiscal Year 2008: 

Court martial/civil conviction: 
For fraternizing with an applicant, a recruiter was court-martialed 
and was reduced in rank, confined for 30 days, and made to forfeit two-
thirds of a month's pay for 2 months (Air Force). 

Removed from service: 
For sexual misconduct, a recruiter was removed from service (Marine 
Corps). 

Removed from recruiting: 
For fraternizing with an applicant, a recruiter was reduced in rank 
and transferred to a non-recruiting unit (Army National Guard). 

Article 15 Non-Judicial Punishment: 
For fraternizing with an applicant, a recruiter was reduced in rank, 
received restriction and extra duties, and was made to forfeit pay 
(Navy). 

Adverse administrative action: 
For failing to ensure that an applicant's enlistment documents were 
completed correctly, a recruiter was given a letter of reprimand by 
his battalion commander (Army). 

Non-adverse administrative action: 
For failing to perform adequate quality control checks on an 
applicant's application packet; thereby allowing the wrong ASVAB score 
to be filed in an applicant's application packet, a recruiter received 
counseling, which directed him to perform quality control checks on 
other application packets (Air Force Reserve). 

Administrative or processing error: 
For failing to conduct a thorough prequalification interview of an 
applicant, a recruiter was judged to have committed a recruiter error. 
The recruiter was not punished, but his battalion commander used the 
error as an example in teaching his recruiters how to properly 
document information (Army). 

Source: GAO analysis of recruiter irregularity case files provided by 
the service components. 

[End of table] 

For all service components, the determination of the action to apply 
in cases of recruiter irregularities is vested with the recruiting 
unit, and the commanders of the responsible recruiting units take a 
variety of factors into consideration when deciding on the actions to 
take against recruiters who commit irregularities. Several service 
component officials we interviewed reported that these commanders 
generally decide on the appropriate action to take against a recruiter 
on a case-by-case basis. For example, a Marine Corps Recruiting 
Command official told us that the commanders who are ultimately 
responsible for taking action against a recruiter can take into 
account how a particular action will affect a recruiter's family 
before deciding upon the appropriate level of action. This can lead to 
different actions taken in cases that fall into similar recruiter 
irregularity categories. While the Army National Guard States and 
Territories follow states' and territories' laws and guidance that 
govern how actions are applied, our review of selected recruiter 
irregularity case files from the Army National Guard also showed that 
the actions taken against recruiters who committed irregularities 
varied among States. For example, we found that different actions were 
taken against the recruiters from different States who engaged in 
irregularities falling into the sexual misconduct category, ranging 
from non-adverse administrative action to removal from service. A 
recruiter in one State who admitted to a sexual relationship with an 
applicant received non-adverse administrative action, which included 
counseling, a 12-month suspended reduction in rank, and a 12-month 
suspension from favorable personnel actions, such as the ability to be 
promoted, be reassigned, or receive awards or bonuses. However, a 
recruiter in another State who provided alcohol to and engaged in a 
sexual relationship with an applicant was removed from service. 

In the view of the recruiting command officials and recruiters with 
whom we spoke, the actions taken against recruiters who committed 
irregularities have generally been fair and sufficiently strict to act 
as deterrents against future recruiter irregularities. Further, they 
said that the ongoing training that recruiters receive includes 
examples of the actions taken against other recruiters who committed 
irregularities, thereby reinforcing the seriousness of committing a 
recruiter irregularity. For example, an Air Force recruiter told us 
that he realizes that he stands to receive strict punishment, such as 
a reduction in rank or removal from the Air Force, if he commits a 
recruiter irregularity. 

The Service Components Have Developed Guidance and Procedures to 
Address Recruiter Irregularities, but Not All Service Components Share 
Recruiter Irregularity Data throughout All Levels of Command: 

The Service Components Have Developed Guidance to Address Recruiter 
Irregularities: 

All of the service components have developed guidance on recruiter 
irregularities and have instituted procedures for reporting 
allegations of recruiter irregularities, conducting an investigation, 
and adjudicating cases.[Footnote 18] Some service components have 
guidance specifically focused on recruiter irregularities. For 
example, the U.S. Army Recruiting Command developed a regulation that 
specifically focuses on recruiter irregularities--Regulation 601-45, 
Recruiting Improprieties Policies and Procedures--which covers the 
definitions of recruiter irregularities, the process of reporting 
irregularities up the chain of command, and the investigation and 
adjudication of recruiter irregularity cases.[Footnote 19] Other 
service components, such as the Marine Corps, address recruiter 
irregularities within their existing framework of recruiting guidance. 
For example, the Marine Corps uses Marine Corps Order 1130.65A, Total 
Force Recruiting Quality Control, which covers recruiting in general, 
but includes provisions that apply to the reporting of recruiter 
irregularities and the actions that should be taken against recruiters 
who commit irregularities.[Footnote 20] 

The Army National Guard Strength Maintenance Division and the Air 
National Guard Recruiting and Retention Service within the National 
Guard Bureau[Footnote 21] have also issued guidance providing the Army 
and Air National Guards of the 54 States and Territories with a broad 
framework for addressing recruiter irregularities.[Footnote 22] This 
guidance supplements laws and guidance that the Army National Guard 
and Air National Guard from each State and Territory follow. However, 
the implementation of National Guard Bureau guidance is at the 
discretion of the individual States and Territories. State National 
Guard recruiters typically operate under Title 32 of the U.S. Code 
through which they are federally funded but under state control. 
Therefore, State National Guard recruiters are subject to state laws 
and guidance unlike active duty recruiters operating under Title 10 of 
the U.S. Code who are subject to the Uniform Code of Military Justice 
and service component guidance in the event they commit a recruiter 
irregularity.[Footnote 23] The Secretary of Defense issued a model 
code of military justice to recommend to the states for use with 
respect to the National Guard when not in federal service.[Footnote 
24] According to an official within the Office of the Chief Counsel 
within the National Guard Bureau, many states have partially adopted 
this model military code while others have not adopted it at all. 

The service components have similar procedures for identifying, 
investigating, and adjudicating recruiter irregularities. As figure 3 
shows, recruiter irregularity allegations can be brought to light 
through a variety of sources, such as complaints submitted through 
congressional representatives, service component hotlines, and 
recruiting staff reporting on the suspicious behavior of a fellow 
recruiter. Once an allegation is brought to the attention of the 
service component, all service components follow several steps, 
including the appointment of the investigating officer, the 
investigation process, and the review of the report produced by the 
investigating officer. The investigation report and the 
recommendations therein are used by the appropriate unit commander to 
determine whether the allegation can be substantiated.[Footnote 25] 
When it is determined that an allegation is substantiated, the 
commander also determines the appropriate action and provides the 
recruiter with the opportunity to present additional information and 
appeal the decision. The service components' recruiting command 
headquarters are notified of all final decisions in recruiter 
irregularity cases. 

Figure 3: The Service Components' Process for Addressing Recruiter 
Irregularities: 

[Refer to PDF for image: illustration] 

Allegation of recruiter irregularity reported to service component: 

Sources Of Allegations: 
Recruiting staff; 
Military entrance processing station; 
Hotline; 
Congressional inquiry; 
Basic training. 

Investigating officer appointed. 

Investigation conducted. 

Investigation report produced; 

Unsubstantiated: 
Unsubstantiated allegations fowarded to recruiting command headquarters
(Case is closed). 

Substantiated: 
Commanding officer determines appropriate actions. 

Recruiting headquarters are notified of final outcome (Case is closed). 

Source: GAO analysis of information from the service components; Art 
Explosion (clip art). 

[End of figure] 

Although the procedures for investigating and adjudicating cases of 
recruiter irregularities are generally similar across the service 
components, some differences exist. For example, the Army and the Air 
Force require that all recruiter irregularity investigations undergo a 
legal review--a review of the investigation report findings by the 
service component's Judge Advocate's office--while the Navy, Marine 
Corps, and Air Force Reserve do not have such a requirement. 

Service component officials we interviewed generally agreed that the 
existing service component guidance on recruiter irregularities is 
sufficient and informs those involved on how to handle recruiter 
irregularities that come to light. Further, recruiters we interviewed 
generally agreed that service component guidance they receive on 
recruiter irregularities is sufficient and that they know how to 
report any cases of recruiter irregularities that they may come across. 

The Service Components Have Taken Steps to Identify and Prevent 
Recruiter Irregularities: 

The service components have instituted a number of quality control 
checks to help identify recruiter irregularities, including the use of 
a hotline for individuals to report recruiter irregularities, periodic 
inspections of recruiting stations, and opportunities for recruits to 
reveal any potential recruiter irregularities committed by their 
recruiter during the enlistment process.[Footnote 26] The service 
components use the following mechanisms to ensure that recruiters are 
abiding by recruiting standards and verify the accuracy of information 
in applicant packets: 

* Hotline. Most service components make telephone numbers available to 
applicants and parents for reporting any suspected cases of recruiter 
irregularities by posting a notice in recruiting stations with a 
hotline listed or providing a card to applicants with the service 
component's hotline number listed. For example, Navy recruiters 
provide applicants with hotline cards that list recruiter and 
applicant rights, activities that recruiters are prohibited from 
doing, and a hotline number that applicants can call to report any 
alleged recruiter irregularities to the Navy Recruiting Command 
Inspector General's office. 

* Periodic inspections. All of the service components conduct periodic 
inspections and command visits to recruiting stations. For example, 
the Marine Corps Recruiting Command's inspection program includes 
monthly visits and annual inspections by recruiting station commanders 
of the recruiting substations for which they are responsible. While 
these inspections do not focus specifically on identifying recruiter 
irregularities, recruiting command officials told us that some 
recruiter irregularities are identified in the course of the 
inspections process. 

* Opportunities to reveal irregularities. All of the service 
components provide recruits with an opportunity to disclose any 
information about themselves that could disqualify them from 
enlistment, such as medical issues or criminal history, and also allow 
applicants to bring up any inappropriate behavior displayed by their 
recruiter, such as a recruiter telling an applicant to conceal a 
medical problem in order to facilitate the enlistment process. 
Officials we interviewed generally agreed that such opportunities for 
disclosure, commonly known as a "moment of truth," provide a powerful 
tool for identifying recruiter irregularities. 

All of the service components have programs in place to help prevent 
recruiter irregularities, including recruiter screening programs and 
recruiter training. In addition, the Army and Army National Guard have 
established policies requiring more than one person to be present when 
a recruiter interacts with an applicant of the opposite gender. 
[Footnote 27] 

* Screening programs. All service components have recruiter screening 
programs to screen their recruiter candidates. For example, the Air 
Force Recruiting Service's screening program includes face-to-face 
interviews with recruiter candidates, reviews of the candidates' 
history of meeting physical standards, reviews of performance reports 
from the previous 3 years, and a credit check. Recruiting command 
officials acknowledged that recruiting is a stressful job and said 
that the rigorous screening of individuals interested in becoming 
recruiters helps ensure that only those individuals who are most 
qualified; are sufficiently motivated; have a high level of integrity; 
and are not burdened by additional external stressors, such as 
financial debt or ongoing divorce proceedings, are selected to receive 
training at the recruiter schools. Recruiting command officials also 
stated that these programs help screen out individuals who may be more 
susceptible to committing recruiter irregularities. 

* Recruiter training. Once individuals are selected to become 
recruiters, they are required to attend the service component's or the 
National Guard's recruiter school, as appropriate, for initial 
recruiter training.[Footnote 28] The service components' recruiting 
school officials and recruiters interviewed said that topics on 
ethical behavior, prohibited practices, fraternization, and sexual 
harassment are covered during the initial training. Additionally, they 
said that instructors share examples of actual recruiter 
irregularities with the new recruiters in order to inform them of 
situations to avoid. After graduating from the service component's 
recruiter school, recruiters receive ongoing training, covering topics 
such as sexual harassment and the reporting of suspected recruiter 
irregularities. For example, the Marine Corps Recruiting Command 
developed a new course that all recruiters are required to take 
annually, covering ethical and unethical behavior and case studies of 
actual recruiter irregularity cases. Officials stated that the course, 
once implemented, will help recruiters identify situations that can 
lead to recruiter irregularities and ways they can avoid those 
situations. Service component officials and recruiters we interviewed 
generally agreed that existing training on recruiter irregularities is 
sufficient to help prevent future recruiter irregularities. 

* "Buddy" or "no one alone" policies. The Army has implemented a 
policy requiring that whenever a recruiter comes in contact with a 
prospect, applicant, or future soldier of the opposite gender, at 
least one other qualifying person of any gender be present.[Footnote 
29] Also, according to the Chief of the Army National Guard Strength 
Maintenance Division, the Army National Guard in 26 states have 
implemented the same policy. 

The Service Components' Oversight and Data Sharing Have Improved, but 
Not All Service Components Share Data throughout All Levels of Command: 

Since we reported in our prior work that the service components' 
recruiting commands did not have oversight over recruiter 
irregularities, the service components have improved oversight. 
[Footnote 30] In our prior work, we reported that the service 
components had limited oversight over recruiter irregularities because 
multiple data systems for collecting and tracking recruiter 
irregularity data were being used. Because these systems were not 
integrated, the service components did not have oversight over all 
recruiter irregularities. Since then, the service components have made 
progress in establishing systems that have allowed for more consistent 
tracking and reporting of the recruiter irregularity data. We found 
that local recruiting units responsible for gathering and tracking 
recruiter irregularity data have systems and processes in place for 
passing the data up the chain of command to the service components' 
recruiting command headquarters on a regular basis. Each service 
component's recruiting command has an office at the headquarters level 
that is responsible for entering the data received from the local 
recruiting units into the service components' database or spreadsheet 
and consolidating and reporting these data to OSD on a semiannual 
basis. 

Although the reporting process is generally similar across the service 
components, some differences exist, as shown in figure 4. For example, 
most of the service components have only one recruiting command office 
in place that is responsible for gathering and tracking recruiter 
irregularity data; however, the U.S. Army Recruiting Command has two 
offices that are responsible for gathering and tracking recruiter 
irregularities--the Recruiting Standards Division and the Staff Judge 
Advocate's office. The Recruiting Standards Division provides its 
consolidated recruiter irregularity data to the Staff Judge Advocate's 
office, which then consolidates the data from both offices for the 
purpose of reporting to OSD. In addition, while the local recruiting 
units provide recruiter irregularity updates to the recruiting command 
on a daily basis in the Army and on a weekly basis in the Air Force, 
they do so on a monthly basis in the other service components. 

Some of the service components are continuing to refine their systems 
for tracking and reporting recruiter irregularity data. For example, 
the Navy is in the process of procuring a new data system that will 
allow for functions such as trend analysis and advanced querying of 
recruiter irregularity data. In addition, the Air Force Reserve has 
recently updated its instruction to require recruiting personnel to 
report all actual or suspected recruiter irregularities to their 
senior recruiter and to inform the Air Force Reserve Command 
Recruiting Service Inspector General of all allegations.[Footnote 31] 

Figure 4: The Service Components' Processes for Reporting of the 
Recruiter Irregularity Data: 

[Refer to PDF for image: illustration] 

U.S. Army Recruiting Command: 
Recruiting Brigades (Report daily) to Recruiting Standards Division; 
Recruiting Brigades’ Judge Advocates (Report weekly) to Staff Judge 
Advocate’s Office. 

U.S. Air Force Recruiting Service: 
Recruiting Squadrons (Report weekly) to Staff Judge Advocate’s Office. 

U.S. Air Force Reserve Command Recruiting Service: 
Recruiting Squadrons (Report monthly) to Inspector General’s Office; 
Recruiting Service Operations Office (Report monthly) to Inspector 
General’s Office. 

U.S. Navy Recruiting Command: 
Recruiting Districts (Report monthly) to Recruiting Regions; 
Recruiting Regions(Report monthly) to Inspector General’s Office; 
Naval Criminal Investigative Service (Report as cases arise) to Staff 
Judge Advocate’s Office, who reports to Inspector General’s Office; 
Recruiting Regions’ Judge Advocates (Report as cases arise) to Staff 
Judge Advocate’s Office, who reports to Inspector General’s Office. 

U.S. Marine Corps Recruiting Command: 
Recruiting Districts (Report monthly) to Recruiting Regions; 
Recruiting Regions (Report monthly) to Manpower Division. 

Source: GAO analysis of information from the service components. 

[End of figure] 

While all service components regularly provide recruiter irregularity 
data to the recruiting command headquarters, with the exception of the 
Air Force, they do not regularly make recruiter irregularity data 
available to all levels of command. This is because most of the 
service components do not have procedures in place to disseminate 
recruiter irregularity data to the commanders at levels below the 
recruiting headquarters. In contrast, the Air Force Recruiting Service 
shares recruiter irregularity data with leadership at all levels of 
command within the Air Force Recruiting Service and all recruiting 
staff through monthly and quarterly reports and newsletters. These 
reports contain information on the circumstances of the recruiter 
irregularity committed and the actions taken against the recruiter. 
[Footnote 32] Air Force officials we interviewed explained that making 
this information available to personnel at all levels within the Air 
Force Recruiting Service provides commanders with examples of how 
others are addressing recruiter irregularities, promotes consistent 
application of actions in substantiated cases of recruiter 
irregularities across the Air Force, and serves as a deterrent to 
committing recruiter irregularities. Air Force recruiters we 
interviewed also generally agreed that the recruiter irregularity 
reports shared by the recruiting command have a strong deterring 
effect because everyone knows what will happen if they commit an 
irregularity. 

In order to make improvements and promote knowledge sharing, leaders 
at all levels of an organization need to receive information on a 
regular basis about the problems that may be occurring across the 
organization.[Footnote 33] Although the other service components have 
some efforts in place to communicate and share limited information on 
recruiter irregularities that occur within their service component, 
information on the range of recruiter irregularities occurring is not 
included or consistently shared with all levels within the recruiting 
command. For example, according to recruiting command officials, the 
U.S. Army Recruiting Command holds a quarterly meeting for 
headquarters officials, including the Commanding General and 
representatives from the Staff Judge Advocate's office, the Recruiting 
Standards Division, and the Inspector General's office to review and 
discuss trends in recruiter irregularities across the recruiting 
command and determine if there is a need for additional training or 
changes in policies to address any issues found. We also found that 
all service components, at a minimum, occasionally share examples of 
serious recruiter irregularities that have occurred or have been 
showcased by the media as part of the continuous training provided to 
recruiters on recruiter irregularity issues. However, without 
processes that allow for the regular flow of recruiter irregularity 
data from the headquarters to all command levels, commanders may not 
be able to take full advantage of servicewide recruiter irregularity 
data that would enable them to improve their operations. Further, 
commanders may not be able to seize opportunities to learn from their 
peers about shared experiences on handling recruiter irregularities. 

OSD Implemented Recruiter Irregularity Reporting Requirements, but 
Lacks Complete Oversight over Irregularities: 

OSD Has Implemented Recruiter Irregularity Reporting Requirements, 
Sponsored Research, and Provided Information-Sharing Opportunities on 
Recruiter Irregularity Issues: 

In December 2006, OSD issued the memorandum regarding the tracking and 
reporting of recruiter irregularities by the service components. 
[Footnote 34] The issuance of the memorandum constituted OSD's 
response to our 2006 recommendation for OSD to establish an oversight 
framework to assess recruiter irregularities, including criteria and 
common definitions across the service components. Such oversight is 
needed for OSD to have the tools for assessing and evaluating 
recruiting programs to assure itself that program objectives are being 
met--consistent with good management practices outlined in federal 
internal control standards.[Footnote 35] The memorandum defined 
recruiter irregularities, established specific categories for 
classifying irregularities and dispositions, and included a reporting 
template for the service components to use when providing recruiter 
irregularity data to OSD on a semiannual basis--in January and July of 
each year. OSD involved the service components in the development of 
the memorandum by convening a meeting of representatives from each of 
the service components to obtain their input on this guidance, 
including input on the proposed terminology and the reporting 
categories. OSD officials said that the issuance of the memorandum was 
important to their oversight over recruiter irregularities because it 
enabled them to monitor recruiter irregularities across the service 
components over time. 

Recruiting command officials we contacted reported familiarity with 
the memorandum, and the service components have been providing 
recruiter irregularity data to OSD semiannually, as required. 
Recruiting command officials we interviewed reported using the 
definitions in the memorandum when submitting their recruiter 
irregularity data to OSD. In our review of the service components' 
data compiled by OSD, we found that since the memorandum was issued, 
all of the service components have been submitting semiannual reports 
following the memorandum's reporting format. Recruiting command 
officials we interviewed also reported updating data submitted to OSD 
to reflect recently closed cases in accordance with the requirements 
set forth in the memorandum. 

In addition to obtaining and reviewing the recruiter irregularity data 
submitted by the service components, OSD contracted with RAND to 
conduct an analysis of recruiter irregularities across the service 
components. Among the issues that RAND is examining are the effects of 
recruiter irregularities on military readiness, public perceptions of 
the military, and the effect that factors, such as deployment history 
and recruiter incentives, have on the occurrence of recruiter 
irregularities. RAND is expected to produce its report in February 
2010. OSD officials said that once they obtain the results of both 
RAND's and GAO's reviews, they will convene another meeting of 
stakeholders from each of the service components to discuss recruiter 
irregularity issues, including the service components' experiences 
with reporting data on recruiter irregularities. Following this 
meeting, OSD officials stated that a DOD instruction for the reporting 
of recruiter irregularity data will be issued.[Footnote 36] 

OSD also provides several opportunities for the sharing of information 
on recruiter irregularities. For example, MEPCOM holds an annual 
Commanders' Conference for representatives from the service components 
to discuss a variety of issues, including recruiter irregularity 
issues.[Footnote 37] Another example is the annual Leadership 
Conference, which brings together recruiting command officials to 
discuss various recruiting-related issues. Although OSD officials 
explained that recruiter irregularities is not the only topic 
addressed at these events and not every conference or meeting will 
have recruiter irregularities on the agenda, these events provide 
opportunities for officials from the service components to share their 
experiences in addressing recruiter irregularities. Some recruiting 
command officials said that they would like additional information on 
what others are doing with respect to recruiter irregularities. For 
example, Navy officials said that they would like OSD to share lessons 
learned in addressing recruiter irregularities among the service 
components, and Air Force officials also said that it would help if 
OSD regularly provided the service components with DOD-wide recruiter 
irregularity data to enable them to see if the other service 
components are experiencing similar problems.[Footnote 38] 

OSD Lacks Complete Oversight over Recruiter Irregularities Due to a 
Lack of Clarity in the Memorandum: 

Although issuing the memorandum was an important first step in 
providing effective oversight over recruiter irregularities and 
establishing the means for assessing OSD's programs related to 
recruiter irregularities, OSD still lacks complete oversight over the 
recruiter irregularities that are occurring because of inconsistencies 
in what is reported to OSD and how reports are prepared. We found that 
the inconsistencies in reporting were the result of differences in how 
the service components interpreted the requirements in the memorandum, 
interpreted the reporting categories in the memorandum, and reported 
cases involving more than one type of irregularity or disposition. 
Without more clarity, the service components may not be reporting the 
recruiter irregularity data in the same manner, precluding meaningful 
comparisons among them. 

We found that the service components and the National Guard states do 
not all interpret the requirements of the memorandum in the same 
manner; specifically, some recruiting officials were uncertain about 
the types of issues involving recruiters to include in the reporting. 
For example, while the majority of the service components reported 
only on irregularities committed by a recruiter when dealing with an 
applicant or a recruit, the Air Force Reserve, the Air National Guard 
States, and five out of seven Army National Guard States[Footnote 39] 
whose files we reviewed reported on all cases of recruiter 
irregularities,[Footnote 40] including cases in which no applicant or 
recruit was involved. Examples of these cases included recruiters 
committing offenses such as adultery with a non-applicant, 
inappropriate relationship with other military personnel, use of a 
government vehicle for personal benefit, or submission of fraudulent 
receipts for travel. OSD officials said that the memorandum is clear 
on the need to report only those recruiter irregularities in which an 
applicant is involved and the memorandum defines recruiter 
irregularities as those willful and unwillful acts of omission and 
improprieties that are perpetrated or alleged to be perpetrated by a 
recruiter to facilitate the recruiting process for an applicant. 
However, in some of our interviews with recruiting command officials, 
we found that they were not clear about the need to report only 
irregularities in which an applicant or a new recruit was involved. 
Some officials explained that they included all cases of recruiter 
irregularities because they wanted to be as transparent as possible in 
reporting every case of a recruiter irregularity to OSD. In addition, 
we identified at least one instance in which a state Air National 
Guard unit was not reporting any recruiter irregularity cases that 
were unsubstantiated, even though the memorandum specifically includes 
a category for unsubstantiated cases. In our discussions with 
officials in that location, they explained that they did not believe 
that those cases should be reported to anyone at the National Guard 
Bureau, and that it would help if OSD, through the National Guard 
Bureau, provided clear guidance to the States and Territories on the 
reporting of unsubstantiated cases. 

We also found that the reporting categories in the memorandum were 
seen as too broad and that the service components did not interpret 
these categories in the same manner. First, some recruiting officials 
said that the reporting categories in the memorandum are too broad to 
provide them with a clear picture of the types of recruiter 
irregularities that are occurring. For example, officials at the 
Recruiting Standards Division of the U.S. Army Recruiting Command and 
officials at the Navy Recruiting Command said that while they use the 
memorandum's categories for reporting to OSD, they continue to rely on 
their own internal reporting categories. The Recruiting Standards 
Division has 12 categories and the Navy has more than 20 categories 
that are used internally to provide a picture of the recruiter 
irregularities that are occurring within their service components. For 
example, while the memorandum has a single category for all types of 
concealment or falsification, the Recruiting Standards Division 
distinguishes among the specific types of information concealed, such 
as medical information, prior police records, information on 
dependents, or history of prior service. Likewise, while the 
memorandum's categories do not specifically address cases where the 
recruiter did not obtain appropriate parental consent for applicants 
under the age of 18, the Navy has a specific category for parental 
consent issues. Second, officials associated with the service 
components that continue to use their internal reporting categories 
acknowledged that decisions on how to place cases into one of the 
eight reporting categories as required by the memorandum can be 
subjective. For example, Navy officials told us that it is generally 
up to the individual who compiles the service component's data for OSD 
to decide how cases should be transferred from the Navy categories 
into the broader categories outlined in the memorandum. Furthermore, 
an official with the Inspector General's office of the Navy Recruiting 
Command told us that the office's staff found the definitions and the 
reporting categories in the memorandum confusing and that the Navy's 
interpretation of these categories would likely differ from that of 
the other service components. 

Some recruiting officials said that the memorandum also lacks clarity 
on how to report cases involving more than one type of irregularity or 
more than one type of disposition. OSD officials said that they expect 
the service components to report the more serious recruiter 
irregularity category when more than one category applies, and 
although we found that the service components generally did that, this 
was not clearly communicated in the memorandum. For example, Army and 
Air Force officials said that while they would handle such situations 
by reporting the most egregious type in cases involving more than one 
type of recruiter irregularity committed by the same recruiter, they 
have not received guidance from OSD on this. Additionally, such 
determinations will likely be made subjectively. For example, 
reasonable officials may differ in their opinion on whether 
falsification of documents is a more or less egregious case of a 
recruiter irregularity than a false promise made to an applicant. 
Similarly, some recruiting officials reported lack of clarity on how 
to report cases involving more than one type of disposition. OSD 
officials told us they expect the service components to report the 
final disposition of a case. However, several recruiting officials 
said that this has not been clearly communicated to them. For example, 
officials from one of the Marine Corps recruiting districts that we 
visited said that the memorandum is not clear on the reporting of 
cases where more then one type of disposition applies, such as a 
recruiter first receiving punishment under Article 15 of the Uniform 
Code of Military Justice and then being removed from recruiting. 
Several recruiting officials responsible for reporting said that they 
are reporting preliminary actions against the recruiter even if the 
data would later need to be changed once the final action in the case 
is determined. For example, a Marine Corps recruiting official and an 
official with the U.S. Army Recruiting Command's Staff Judge Advocate 
Office explained that they would report the preliminary actions at the 
time of required reporting. In fact, two Army case files that we 
reviewed showed that while the cases were ultimately found to be 
unsubstantiated, they were initially reported to OSD as having 
resulted in non-adverse administrative action because recruiters were 
temporarily suspended from recruiting while charges of inappropriate 
sexual relationship and sexual assault against them were investigated. 
[Footnote 41] However, other service components may not be approaching 
this situation in the same manner. For example, Air Force recruiting 
officials told us that they only report the final disposition to OSD 
and not the preliminary actions. The memorandum does not explicitly 
address how such situations should be handled in reporting. 

OSD officials acknowledged that the service components may have 
questions related to reporting, particularly given the relative 
newness of the memorandum. OSD officials told us that after the 
memorandum was issued in December 2006, their plan was to monitor the 
service components' experiences with reporting and issue a DOD 
instruction that would incorporate the guidance in the memorandum and 
clarify any reporting issues that the service components might be 
experiencing. However, 3 years after its issuance, the memorandum has 
not been turned into a DOD instruction for the service components to 
follow when reporting to OSD. At the time of this reporting, OSD 
officials told us that they plan to wait for the issuance of this 
report and the RAND study before issuing the instruction. However, the 
continuing absence of definitive guidance may result in poor data 
quality that would prevent OSD from having complete and consistent 
information on recruiter irregularities across the service components 
and the National Guard and compromise its ability to maintain 
appropriate oversight over this important issue. 

OSD Also Lacks Complete National Guard Data: 

OSD does not receive complete information from the National Guard. The 
memorandum applies to all service components, including the Army and 
Air National Guards. Officials with the Army National Guard Strength 
Maintenance Division and Air National Guard Recruiting and Retention 
Service told us that following the issuance of the memorandum, they 
began to request recruiter irregularity data from all States and 
Territories, and provided them with the definitions and the reporting 
template from the memorandum. The data from individual States and 
Territories are then aggregated by the Army and Air National Guard 
officials and forwarded to OSD.[Footnote 42] However, not all States 
and Territories in the Army National Guard report their recruiter 
irregularity data. As seen in figure 5, our review of the recruiter 
irregularity data that the Army National Guard States and Territories 
provided to the Army National Guard Strength Maintenance Division in 
January 2009 showed that 18 of the 54 States and Territories did not 
provide the data for fiscal year 2008.[Footnote 43] During the July 
2009 reporting cycle, 16 of the 54 States and Territories did not 
report their recruiter irregularity data. Of the 38 that reported 
data, the reporting period identified by the States and Territories on 
their reports varied from State to State. For example, some reports 
submitted in August 2009 covered the first 3 quarters of fiscal year 
2009, others covered only the 2nd and 3rd quarter of fiscal year 2009, 
and others only covered the 3rd quarter of fiscal year 2009. Moreover, 
two reports were not labeled, making it unclear what reporting period 
they covered. Army National Guard officials acknowledged problems with 
State reporting, but said that although they provide guidance based on 
the memorandum to the States and Territories, they rely on them to 
submit their data in accordance with that guidance. 

Figure 5: Army National Guard States and Territories Reporting 
Recruiter Irregularity Data for Fiscal Year 2008 during the January 
2009 Reporting Cycle: 

[Refer to PDF for image: map of the United States] 

Provided data for fiscal year 2008: 
Alabama: 
Arizona: 
California: 
Colorado: 
Delaware: 
Florida: 
Georgia: 
Guam: 
Hawaii: 
Idaho: 
Indiana: 
Kansas: 
Kentucky: 
Louisiana: 
Maine: 
Minnesota: 
Missouri: 
Nebraska: 
Nevada: 
New Hampshire: 
New Mexico: 
New York: 
North Carolina: 
Ohio: 
Oklahoma: 
Pennsylvania: 
Rhode Island: 
South Carolina: 
South Dakota: 
Tennessee: 
Utah: 
Vermont: 
Virgin Islands: 
Washington: 
West Virginia: 
Wisconsin: 

Did not provide data for fiscal year 2008: 
Alaska: 
Arkansas: 
Connecticut: 
District of Columbia: 
Illinois: 
Iowa: 
Maryland: 
Massachusetts: 
Michigan: 
Mississippi: 
Montana: 
New Jersey: 
North Dakota: 
Oregon: 
Puerto Rico: 
Texas: 
Virginia: 
Wyoming: 

Source: GAO analysis of recruiter irregularity data submitted to the 
Army National Guard Strength Maintenance Division by the States and 
Territories. 

Note: Of the 36 States and Territories that reported their recruiter 
irregularity data during the January 2009 reporting cycle, 3 only 
provided the data for part of fiscal year 2008, and 4 did not provide 
documentation of whether their data cover the full fiscal year 2008. 

[End of figure] 

OSD also lacks a complete picture of the total number of recruiter 
irregularities occurring in the Air National Guard because of concerns 
regarding the quality of the data. Although, according to the Air 
National Guard, all States and Territories report their recruiter 
irregularity data, OSD has raised questions about the quality of the 
Air National Guard data. For example, when the Air National Guard 
initially reported zero irregularities for both fiscal years 2007 and 
2008, OSD officials expressed doubts about the absence of even a 
single allegation of a recruiter irregularity in the Air National 
Guard, particularly given that the report should include not only 
substantiated cases but also those that are ultimately found to be 
unsubstantiated. Following electronic communication from OSD regarding 
this issue, the Air National Guard reported two cases of recruiter 
irregularities for fiscal year 2008. Moreover, Air National Guard 
officials have not maintained supporting documentation for the 
information reported by each State and Territory. For example, one 
Territory did not submit a report (either by mail or electronically) 
during the January 2009 reporting cycle. An Air National Guard 
official at the Air National Guard Recruiting and Retention Service 
told us that this Territory reported having no recruiter 
irregularities in a telephone conversation with his office, but 
documentation of this conversation does not exist. The absence of such 
documentation raises questions about the accuracy and completeness of 
the data that the Air National Guard Recruiting and Retention Service 
receives. 

Both Army and Air National Guard officials told us that although they 
follow up with the States and Territories, they cannot force them to 
comply. Officials said that they follow up with States and Territories 
via e-mail or telephone if the reports appear to contain obvious 
mistakes, such as the totals not adding up to the numbers reported in 
each individual reporting category. They also follow up if no reports 
have been submitted. However, they said that it is ultimately up to 
individual States and Territories to submit their reports because the 
National Guard Bureau has no command and control authority over them. 
Specifically, while the National Guard Bureau personnel operate under 
Title 10 of the U.S. Code, the National Guard personnel at the state 
level typically operate under Title 32. Consequently, even though the 
National Guard Bureau can direct States and Territories to submit 
their recruiter irregularity data in accordance with the memorandum, 
officials told us that they have no mechanism to force States and 
Territories to comply. 

While the National Guard Bureau cannot force States and Territories to 
comply with the reporting requirements in the memorandum, it has not 
been transparent with respect to the total numbers reported to OSD, 
thus preventing OSD from having a complete picture of recruiter 
irregularities that occur in the National Guard. The Army and Air 
National Guard officials aggregate the data that they receive from the 
States and Territories and report the total numbers to OSD. However, 
no information is provided on how many States or Territories did not 
submit their recruiter irregularity reports or whether any of these 
reports failed to cover the full reporting period. OSD officials 
acknowledged that the Army National Guard Strength Maintenance 
Division and the Air National Guard Recruiting and Retention Service 
within the National Guard Bureau obtain recruiter irregularity data 
from the States and Territories and that each State and Territory 
maintains its own processes for collecting these data. However, while 
aware of this, OSD does not request that the National Guard officials 
provide caveats or any other explanatory notes on the limitations of 
the recruiter irregularity data when submitting these data to OSD. 
Consequently, OSD's own reports summarizing the recruiter irregularity 
data received from the service components and the National Guard do 
not disclose any limitations of the data on which they are based. 

Conclusions: 

Recruiters work in a challenging environment and play a critical role 
in providing the military services with qualified men and women 
prepared to serve their country. Although instances of recruiter 
wrongdoing are infrequent, even a single case can undermine the trust 
that the American public has in its military. The service components 
recognize this reality, and all have made substantial progress since 
2006 in increasing their oversight over recruiter irregularities. In 
particular, all service components have established procedures for 
reporting cases of recruiter irregularities up the chain of command. 
While these systems assure that their recruiting command headquarters 
receive regular reports on recruiter irregularities, the Air Force is 
unique in sharing recruiter irregularity data regularly with all of 
the different levels of command to provide opportunities for 
commanders at all levels to compare their progress in addressing 
recruiter irregularities with the other recruiting units and to learn 
from their experiences. The Army, Navy, and Marine Corps could benefit 
from doing likewise. OSD has also taken steps to increase its 
oversight over recruiter irregularities occurring across the service 
components by implementing semiannual reporting requirements and 
establishing common definitions for the service components to use. 
While these are important first steps, in order for the reporting 
requirements to have a meaningful effect, it is critical that the 
services fully understand them and uniformly report accurate data. 
Without OSD monitoring and promptly addressing problems that the 
service components may experience with respect to reporting their 
recruiter irregularity data, the quality of the data received by OSD 
from the service components could be compromised. Furthermore, OSD's 
ability to rely on the data provided will be significantly diminished 
if OSD does not receive complete information on which National Guard 
States and Territories submit the data and how complete their data 
are. While the National Guard Bureau cannot force States and 
Territories to comply with the reporting requirements, at the very 
least it must be transparent about the completeness of the data that 
it provides to OSD. Without such transparency from the National Guard 
Bureau, OSD will not be able to meaningfully analyze recruiter 
irregularity trends across the service components and identify areas 
where corrective action may be needed. 

Recommendations for Executive Action: 

We recommend that the Secretary of Defense take the following four 
actions: 

1. direct the Secretaries of the Army and Navy to identify mechanisms 
for the regular sharing of the recruiter irregularity data throughout 
all levels of command, and: 

2. direct the Under Secretary of Defense for Personnel and Readiness 
to: 

* complete and issue the instruction on tracking and reporting data on 
recruiter irregularities to clarify the requirements for the types of 
recruiter irregularities to be reported and the placement of recruiter 
irregularity cases and actions taken into reporting categories; 

* direct the relevant offices within the National Guard Bureau to 
adjust their reporting procedures in ways that will provide 
transparency in the data reported to OSD and any limitations on the 
data; and: 

* include the appropriate disclosures concerning data limitations in 
the recruiter irregularity reports that OSD produces on the basis of 
the National Guard data for the Congress and others. 

Agency Comments and Our Evaluation: 

In written comments on a draft of the report, DOD concurred with each 
of our four recommendations. Specifically, DOD stated that it will 
address these recommendations through a DOD instruction that it plans 
to publish. Regarding our recommendation that the Secretary of Defense 
direct the Secretaries of the Army and the Navy to identify mechanisms 
for the regular sharing of recruiter irregularity data throughout all 
levels of command, DOD stated that the sharing of these data already 
occurs, and that the Army and the Navy have clarified their reporting 
processes. We agree that the service components have made progress in 
establishing systems that have allowed for more consistent tracking 
and reporting of the recruiter irregularity data, and our report 
highlighted instances of such data being shared within the service 
components. However, we continue to believe that in order for 
commanders to continually evaluate and improve their recruiting 
operations, processes must be in place for the regular flow of such 
information. DOD said that its soon-to-be-published instruction will 
require the service components to formalize their processes for 
disseminating the recruiter irregularity data to the appropriate 
levels of command. We believe that these formal processes will 
constitute an important step in ensuring that recruiter irregularity 
information is shared in a consistent and timely manner. DOD also 
agreed with our recommendations that the Secretary of Defense direct 
the Under Secretary of Defense for Personnel and Readiness to (1) 
complete and issue the instruction on tracking and reporting recruiter 
irregularity data that clarifies the reporting requirements, (2) 
direct the relevant offices within the National Guard Bureau to adjust 
their reporting procedures in order to provide greater transparency in 
the data reported, and (3) include the appropriate disclosures 
concerning any limitations in the data it receives. DOD said that it 
decided to wait to issue the instruction until this GAO study is 
complete, in order to incorporate our recommendations, and that it 
plans to publish the instruction during fiscal year 2010 after 
reconvening representatives from the service components to discuss 
their reporting processes and procedures for the tracking and 
reporting of recruiter irregularity data. DOD's comments in their 
entirety appear in appendix IV. 

We are sending copies of this report to interested congressional 
committees; the Secretaries of Defense, the Army, the Navy, and the 
Air Force; and the Commandant of the Marine Corps. This report will be 
available at no charge on GAO's Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3604 or by e-mail at 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 major 
contributions to the report are listed in appendix V. 

Signed by: 

Brenda S. Farrell, Director:
Defense Capabilities and Management: 

[End of section] 

Appendix I: Scope and Methodology: 

For this review, we analyzed recruiter irregularities across all of 
the service components: the Army and Army Reserve, the Navy and Navy 
Reserve, the Marine Corps and Marine Corps Reserve, and the Air Force 
and Air Force Reserve. In addition, we analyzed recruiter 
irregularities in the Army National Guard and the Air National Guard. 
For the purposes of this review, the term recruiter irregularity is 
defined according to the memorandum issued by the Office of the 
Secretary of Defense (OSD) as those willful and unwillful acts of 
omission and improprieties that are perpetrated by a recruiter or 
alleged to be perpetrated by a recruiter to facilitate the recruiting 
process for an applicant. 

To conduct our work, we examined relevant guidance issued by OSD, the 
service components, the Army National Guard, and the Air National 
Guard; reviewed and analyzed data on recruiter irregularities reported 
by the service components to OSD from fiscal year 2006 through fiscal 
year 2009; and reviewed reports issued by GAO and the Department of 
Defense (DOD) related to recruiting and recruiter irregularities, 
including surveys conducted by DOD on recruiters' quality of life 
across the service components.[Footnote 44] In addition, we conducted 
a case file review of all substantiated cases of recruiter 
irregularities reported by the service components for fiscal year 
2008, and a case file review of all substantiated cases of recruiter 
irregularities reported by seven States on recruiter irregularities 
committed by recruiters in the Army National Guard for fiscal year 
2008.[Footnote 45] We interviewed OSD officials in the Washington, 
D.C. metropolitan area and conducted site visits to service 
components' recruiting commands and the Military Entrance Processing 
Command (MEPCOM) to interview recruiting command officials and 
recruiters from all the service components. We selected our interviews 
with 24 recruiters using a nonprobability convenience sample to 
accommodate our 10 site visits.[Footnote 46] In the course of our 
work, we contacted or visited the organizations and offices listed in 
table 9. 

Table 9: Organizations and Offices Contacted: 

Air Force: 

Name of organization or office: Air Force Recruiting Service; 
Location: Randolph Air Force Base, TX. 

Name of organization or office: Air Force Recruiting School; 
Location: Lackland Air Force Base, TX. 

Name of organization or office: Air Force 369th Recruiting Group; 
Location: Lackland Air Force Base, TX. 

Name of organization or office: Air Force 341st Recruiting Squadron; 
Location: Lackland Air Force Base, TX. 

Name of organization or office: Air Force Recruiting B-Flight; 
Location: San Antonio, TX[A]. 

Name of organization or office: Air Force Recruiting Stations; 
Location: Schaumberg, IL.
Location: Louisville, KY.
Location: Mira Mesa, CA.
Location: Washington, D.C. 

Air Force Reserve: 

Name of organization or office: Air Force Reserve Command Recruiting 
Service; 
Location: Warner Robins, GA. 

Name of organization or office: Air Force Reserve Recruiting Station; 
Location: San Antonio, TX. 

Air National Guard: 

Name of organization or office: National Guard Bureau-Air National 
Guard Recruiting and Retention Service; 
Location: Arlington, VA. 

Name of organization or office: Air National Guard Recruiting Station 
149th Fighter Wing; 
Location: Lackland Air Force Base, TX. 

Army: 

Name of organization or office: Army Recruiting Command; 
Location: Fort Knox, KY. 

Name of organization or office: Army Recruiting and Retention School; 
Location: Fort Jackson, SC. 

Name of organization or office: Army 1st Recruiting Brigade; 
Location: Fort Meade, MD. 

Name of organization or office: Army 3rd Medical Recruiting Brigade; 
Location: Fort Knox, KY. 

Name of organization or office: Army Baltimore Recruiting Battalion; 
Location: Fort Meade, MD. 

Name of organization or office: Army Recruiting Stations; 
Location: 
Elizabethtown, KY.
Location: Lemon Grove, CA.
Location: Radcliff, KY.
Location: Washington, D.C. 
Location: Chicago, IL[A]. 

Army National Guard: 

Name of organization or office: National Guard Bureau-Army National 
Guard Strength Maintenance Division; 
Location: Arlington, VA. 

Name of organization or office: Army National Guard Strength 
Maintenance Training Center; 
Location: Little Rock, AR. 

Name of organization or office: Illinois Army National Guard, 
Recruiting; 
Location: Chicago, IL[A]. 

Name of organization or office: Army National Guard Recruiting Station; 
Location: Chicago, IL[A]. 

Marine Corps: 

Name of organization or office: Marine Corps Recruiting Command; 
Location: Quantico, VA. 

Name of organization or office: Marine Corps Recruiters School; 
Location: San Diego, CA. 

Name of organization or office: Marine Corps Western Recruiting Region; 
Location: San Diego, CA. 

Name of organization or office: 12th Marine Corps Recruiting District; 
Location: San Diego, CA. 

Name of organization or office: 4th Marine Corps Recruiting District; 
Location: New Cumberland, PA. 

Name of organization or office: Marine Corps Recruiting Stations; 
Location: Frederick, MD.
Location: San Diego, CA. 

Name of organization or office: Marine Corps Recruiting Substations; 
Location: Louisville, KY.
Location: Chicago, IL[A].
Location: Poway, CA.
Location: Washington, D.C. 

Navy: 

Name of organization or office: Navy Recruiting Command; 
Location: Millington, TN. 

Name of organization or office: Navy Recruiting Command, Recruit 
Quality Assurance Team; 
Location: Great Lakes, IL. 

Name of organization or office: Navy Recruiting District Chicago; 
Location: North Chicago, IL. 

Name of organization or office: Navy Recruiting Stations; 
Location: Escondido, CA.
Location: Louisville, KY.
Location: Washington, D.C. 

National Guard Bureau: 

Name of organization or office: Office of the Chief Counsel; 
Location: Arlington, VA. 

Office of the Secretary of Defense: 

Name of organization or office: Office of the Under Secretary of 
Defense for Personnel and Readiness; 
Location: Washington, D.C. 

Name of organization or office: Military Entrance Processing Command; 
Location: North Chicago, IL. 

Name of organization or office: Military Entrance Processing Stations; 
Location: Fort Meade, MD.
Location: Des Plaines, IL.
Location: Louisville, KY.
Location: San Diego, CA. 

Source: GAO. 

[A] For cases where we interviewed recruiters away from their 
recruiting station location, the metropolitan location is indicated. 

[End of table] 

To assess the number and types of recruiter irregularities occurring in 
the service components, we obtained and reviewed recruiter irregularity 
data reported by the service components to OSD from fiscal year 2006 
through fiscal year 2009, and the service components' accessions data 
for the same time period. We were unable to present trends in recruiter 
irregularities from fiscal year 2006 through fiscal year 2009 and 
decided not to present data for fiscal year 2009 because (1) the 
memorandum issued by OSD in December 2006 required the service 
components to retroactively collect recruiter irregularity data for 
fiscal year 2006 to report to OSD, which may have resulted in the 
fiscal year 2006 data being less complete than the data in subsequent 
fiscal years and (2) recruiter irregularity data reported by the 
service components for fiscal year 2009 do not include data from the 
fourth quarter of the fiscal year, which will not be reported until 
January 2010. We interviewed officials within the Army National Guard 
Strength Maintenance Division and the Air National Guard Recruiting and 
Retention Service about their data system for tracking and maintaining 
recruiter irregularity data and determined that these data were not 
reliable. Specifically, we were unable to present data on recruiter 
irregularities reported by the National Guard because recruiter 
irregularity data are maintained at the state level of command and we 
did not review each state's processes and procedures for collecting and 
maintaining these data. Furthermore, while some States and Territories 
reported their recruiter irregularity data to the Army National Guard 
Strength Maintenance Division and the Air National Guard Recruiting and 
Retention Service within the National Guard Bureau in accordance with 
the memorandum, others did not consistently report their data or did 
not report them at all. In addition, we assessed the reliability of 
each service component's recruiter irregularity data system, including 
the systems' ability to track and maintain recruiter irregularities. 
For each service component, we also interviewed personnel responsible 
for maintaining and overseeing these data systems. Additionally, we 
assessed the quality control measures in place to ensure that the data 
are reliable for reporting purposes. We found the recruiter 
irregularity data reported by the service components to be sufficiently 
reliable for the purposes of this review. 

To provide illustrative examples of the types of recruiter 
irregularities that occur across the service components and the actions 
taken against recruiters involved in recruiter irregularities, we 
conducted a case file review of all substantiated cases of recruiter 
irregularities reported by each of the service components and closed in 
fiscal year 2008. We reviewed a total of 346 case files for all the 
service components: Air Force (16), Air Force Reserve (7), Army (138), 
Army National Guard (53), Marine Corps (69), and Navy (63). The number 
of case files that we reviewed for fiscal year 2008 did not always 
reflect the total number of cases reported to OSD for the same year 
because some cases may have been closed and reported to OSD following 
our review of the case files. Although we included the Army National 
Guard in our case file review, we selected a nongeneralizeable sample 
of States for our case file review because the National Guard Bureau 
does not maintain centralized data on cases of recruiter 
irregularities. We selected States that reported more than four 
substantiated recruiter irregularities for fiscal year 2008. These 
States and their corresponding number of substantiated cases of 
recruiter irregularities as reported for fiscal year 2008 are: Alabama 
(10), California (20), Indiana (7), Minnesota (6), Oklahoma (8), 
Pennsylvania (5), and Wisconsin (7).[Footnote 47] 

To assess the extent to which the service components have guidance in 
place to identify and address recruiter irregularities, we reviewed the 
guidance issued by the service components on recruiter irregularities 
and their procedures for reporting allegations, conducting 
investigations, and adjudicating cases of recruiter irregularities 
within the recruiting commands. We interviewed recruiting command 
officials and recruiters from the service components to gain their 
perspective on the causes of recruiter irregularities, the guidance in 
place to address them, and training and prevention programs aimed at 
reducing them. We also obtained their views on the fairness of the 
actions taken against recruiters as a result of their involvement in 
recruiter irregularity incidents, the deterring effect of those actions 
taken, and the consistency with which actions are applied. To determine 
the extent to which the relevant offices within the National Guard 
Bureau maintain oversight over recruiter irregularities occurring in 
the Army and Air National Guards, we examined the guidance issued by 
the Army National Guard Strength Maintenance Division and the Air 
National Guard Recruiting and Retention Service. However, we did not 
review National Guard guidance issued by the 54 individual National 
Guard States and Territories due to time and staffing limitations. 

To assess the extent to which OSD maintains oversight of recruiter 
irregularities occurring across the service components, we reviewed the 
December 2006 memorandum issued by OSD that requires each service 
component to submit a semiannual report to OSD on recruiter 
irregularities. We conducted interviews with officials from OSD's 
Office of the Under Secretary of Defense for Personnel and Readiness, 
as well as officials from MEPCOM and 4 military entrance processing 
stations. We also interviewed service component officials to obtain 
their perspective on the memorandum and their experiences in addressing 
the reporting requirements it sets forth. We also interviewed OSD and 
National Guard officials on reporting issues within the National Guard. 

We conducted this performance audit from February 2009 through January 
2010 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: Examples of Recruiter Irregularities in Fiscal Year 2008: 

Table 10 provides examples that we identified in the course of our 
review of the service components' files of recruiter irregularities for 
fiscal year 2008--in addition to those provided in table 6 of this 
report--illustrating each recruiter irregularity category in the Office 
of the Secretary of Defense's memorandum. 

Table 10: Examples of Substantiated Recruiter Irregularities by Type, 
Fiscal Year 2008: 

Recruiter irregularity category: Criminal misconduct; 
Example: A recruiter became aggressive with a recruit and engaged in a 
verbal altercation with the recruit's boyfriend (Navy). 
Example: A recruiter committed multiple irregularities, which included 
sexually harassing a recruit and high school students, meeting with 
female recruits without adequate supervision, influencing a recruit to 
lie to recruiter irregularity investigators, and failing to safely 
transport applicants in a government vehicle (Army). 

Recruiter irregularity category: Sexual misconduct; 
Example: A recruiter consumed alcohol with applicants and engaged in 
inappropriate sexual conduct (Air Force). 
Example: A recruiter engaged in a sexual relationship with a 16 year-
old applicant (Marine Corps). 

Recruiter irregularity category: Sexual harassment; 
Example: A recruiter inappropriately touched a recruit while taking an 
unsupervised body fat measurement of the recruit (Navy). 
Example: A recruiter made sexually suggestive comments to an applicant 
(Marine Corps). 

Recruiter irregularity category: Fraternization or unauthorized 
relationship with an applicant; 
Example: A recruiter visited an applicant's home twice without 
supervision and kissed the applicant (Army National Guard). 
Example: A recruiter purchased alcohol for an underage recruit and 
consumed it with him (Marine Corps). 

Recruiter irregularity category: Concealment or falsification; 
Example: A recruiter falsified the results of a required physical 
fitness test for two recruits (Army). 
Example: A recruiter withheld medical documents from an applicant's 
application packet; the applicant had been previously temporarily 
disqualified from service for a hairline fracture (Air Force). 

Recruiter irregularity category: False promise/coercion; 
Example: A recruiter employed a false document and an individual who 
impersonated a Navy officer to falsely assure a recruit that the 
recruit would be able to change her military occupation upon her 
arrival at basic training (Navy). 
Example: A recruiter conducted himself inappropriately with a recruit 
who expressed a reluctance to ship to basic training before he had 
cleared up a family issue (Army). 

Recruiter irregularity category: Testing irregularity; 
Example: A recruiter arranged for another individual to take the ASVAB 
for a recruit (Army National Guard). 
Example: A recruiter provided a recruit with an unauthorized ASVAB 
study guide (Marine Corps). 

Recruiter irregularity category: Quality control measures; 
Example: A recruiter was found to have in his possession a template of 
a child custody form, despite this being a violation of Army 
regulations (Army). 
Example: A recruiter authorized the enlistment of a recruit who was 
subsequently disqualified at the MEPS for testing positive on a drug 
test (Air Force Reserve). 

Source: GAO analysis of recruiter irregularity case files provided by 
the service components. 

[End of table] 

[End of section] 

Appendix III: Examples of Dispositions in Fiscal Year 2008: 

Table 11 provides examples that we identified in the course of our 
review of the service components' files of recruiter irregularities for 
fiscal year 2008--in addition to those provided in table 8 of this 
report--illustrating the violation disposition categories set out in 
the Office of the Secretary of Defense's memorandum. 

Table 11: Examples of Dispositions, Fiscal Year 2008: 

Disposition category: Court martial/civil conviction; 
Example: For engaging in an intimate relationship with an applicant, a 
recruiter was court-martialed, reduced in rank, confined for 30 days, 
given 30 days of hard labor, and made to forfeit $1,000 per month for 
3 months (Air Force). 
Example: For providing a recruit with the answers to the ASVAB, a 
recruiter was court-martialed, reduced in rank, and discharged with an 
"other than honorable discharge" (Army). 

Disposition category: Removed from service; 
Example: For submitting false high school diplomas in order to 
fraudulently enlist five recruits who did not meet minimum educational 
enlistment qualifications, a recruiter was removed from service 
(Marine Corps).
Example: For instructing two recruits to conceal their criminal 
records at their MEPS processing, a recruiter was removed from service 
(Navy). 

Disposition category: Removed from recruiting; 
Example: For allowing a recruit to use his government vehicle and 
government credit card, a recruiter was removed from recruiting duty 
(Marine Corps). 
Example: For falsifying high school verification letters for five 
applicants, a recruiter was removed from recruiting (Army). 

Disposition category: Article 15 Non-Judicial Punishment; 
Example: For falsifying information about references on a recruit's 
background investigation forms, a recruiter received article 15 Non-
Judicial Punishment, whereby he was reduced in rank, made to forfeit 
$500 per month for 2 months, and reprimanded (Air Force). 
Example: For forging multiple signatures in a recruit's application 
packet, a recruiter received article 15 Non-Judicial Punishment, 
whereby he was reduced in rank and made to forfeit half of one month's 
pay for 2 months (Navy). 

Disposition category: Adverse administrative action; 
Example: For allowing a recruit to ship to basic training despite the 
recruit having an unresolved criminal violation on her record, a 
recruiter received a letter of reprimand from his recruiting battalion 
commander (Army). 
Example: For failing to perform an adequate medical pre-screening of 
recruits, a recruiter received a letter of reprimand from his 
recruiting squadron commander (Air Force). 

Disposition category: Non-adverse administrative action; 
Example: For enlisting an applicant who was 
not eligible for enlistment, a recruiter received counseling. (Army 
National Guard). 

Disposition category: Administrative or processing error; 
Example: For failing to properly question an applicant, and thus 
failing to uncover that the applicant had not completed a legal 
probation sentence, a recruiter was judged to have committed a 
recruiter error (Army). 
Example: For failing to conduct an initial fitness test for a recruit, 
a recruiter was judged to have committed a recruiter error. (Navy). 

Source: GAO analysis of recruiter irregularity case files provided by 
the service components. 

[End of table] 

[End of section] 

Appendix IV: Comments from the Department of Defense: 

Office Of The Under Secretary Of Defense: 
Personnel And Readiness: 
4000 Defense Pentagon: 
Washington, DC 20301-4000: 

January 14, 2010: 

Ms. Brenda S. Farrell: 	
Director, Defense Capabilities and Management: 
U.S. Government Accountability Office: 
441 G. Street, N.W. 
Washington, DC 20548: 

Dear Ms. Farrell: 
	
This is the Department of Defense's (DoD) response to the Government 
Accountability Office's (GAO) draft report, "Military Recruiting: 
Clarified Reporting Requirements and Increased Transparency Could 
Strengthen Oversight over Recruiter Irregularities," dated December 8, 
2009 (GAO Code 351327/GA0-10-254). 

The Department concurs with the report's recommendations. We will work 
with each of the Services to improve the sharing of recruiter 
irregularity data, to clarify our reporting guidance, and to provide 
greater data transparency regarding data limitations. This guidance 
will be promulgated in a new DoD Instruction. 

We certainly agree with the GAO statement that instances of recruiter 
wrongdoing are infrequent, but that even a single case can undermine 
the trust that the American public has in its military. We take this 
issue very seriously and, as noted in the report, we have made 
substantial progress since the GAO's 2006 report addressing this same 
issue. The Office of the Under Secretary for Personnel and Readiness 
will work in concert with the Services to implement the appropriate 
recommendations in a timely manner. We believe these actions can be 
completed during FY 2010. 

The enclosure contains detailed departmental comments on each of the 
four recommendations identified by GAO. The Department appreciates the 
opportunity to comment on the draft report. 

Sincerely, 

Signed by: 

Gail H. McGinn: 
Deputy Under Secretary of Defense (Plans): 
Performing the Duties of the Under Secretary of Defense (Personnel and 
Readiness): 

Enclosure: As stated: 

[End of letter] 

GAO Draft Report Dated December 8, 2009: 
GA0-10-254 (GAO Code 351327): 

"Military Recruiting: Clarified Reporting Requirements And Increased 
Transparency Could Strengthen Oversight Over Recruiter Irregularities" 

Department Of Defense Comments To The GAO Recommendations: 

Recommendation 1: GAO recommends that the Secretary of Defense direct 
the Secretaries of the Army and Navy to identify mechanisms for the 
regular sharing of the recruiter irregularity data throughout all 
levels of command (p. 46/GAO Draft Report). 

DOD Response: Concur. 

Currently, each of the Services shares the recruiter irregularity data 
throughout all levels of command. Both Army and Navy have clarified 
their processes, and we are confident these processes accomplish the 
intent identified by GAO. However, in its soon to be published 
instruction, DoD plans to require each Service to formally establish a 
process which will ensure the widest possible dissemination of these 
data to the appropriate levels of command and other outside agencies. 

Recommendation 2: GAO recommends that the Secretary of Defense direct 
the Under Secretary of Defense for Personnel and Readiness to complete 
and issue the instruction on tracking and reporting data on recruiter 
irregularities to clarify the requirements for the types of recruiter 
irregularities to be reported and the placement of recruiter 
irregularity cases and actions taken into reporting categories (p. 
46/GAO Draft Report). 

DOD Response: Concur. 

In February 2009, when GAO announced this audit, DoD had already 
planned to reconvene its workgroup comprised of each of the Services 
and Components to review current processes and policies prior to 
publishing an instruction. DoD decided to delay convening the 
workgroup until the GAO audit was complete so that it could include 
the recommendations of the audit where appropriate. The new 
instruction should be published during FY 2010. 

Recommendation 3: GAO recommends that the Secretary of Defense direct 
the Under Secretary of Defense for Personnel and Readiness to direct 
the relevant offices within the National Guard Bureau to adjust their 
reporting procedures in ways that will provide transparency in the 
data reported to OSD and any limitations on the data (p. 46/GAO Draft 
Report). 

DOD Response: Concur. 

DoD will work closely with representatives from the Army National 
Guard and the Air National Guard to ensure the guidance provided in 
the new instruction is sufficient to ensure complete and accurate 
reporting of the data. The new guidance will provide justification for 
each agency to publish internal policies and procedures that will 
establish more stringent reporting requirements. 

Recommendation 4: GAO recommends that the Secretary of Defense direct 
the Under Secretary of Defense for Personnel and Readiness to include 
the appropriate disclosures concerning data limitations in the 
recruiter irregularity reports that OSD produces on the basis of the 
National Guard data for the Congress and others (p. 47/GAO Draft 
Report). 

DOD Response: Concur. 

DoD will work closely with representatives from the Army National 
Guard and the Air National Guard to ensure the guidance provided in 
the new instruction is sufficient to ensure complete and accurate 
reporting of the data. The new guidance will provide justification for 
each agency to publish internal policies and procedures that will 
establish more stringent reporting requirements. In future reports, if 
data are incomplete, it will be so noted as data limitations. 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Brenda S. Farrell, (202) 512-3604 or farrellb@gao.gov. 

Staff Acknowledgments: 

In addition to the contact above, Elizabeth McNally, Assistant 
Director; Natalya Barden; Seth Carlson; K. Nicole Harms; Joanne 
Landesman; Katherine Lenane; Amber Lopez; Steven Putansu; Terry 
Richardson; and Daniel Webb made key contributions to this report. 

[End of section] 

Footnotes: 

[1] “Service components” refers to the Army, the Army Reserve, the 
Marine Corps, the Marine Corps Reserve, the Navy, the Navy Reserve, 
the Air Force, and the Air Force Reserve. 

[2] Office of the Under Secretary of Defense for Personnel and 
Readiness Memorandum, Tracking and Reporting of Recruiter 
Irregularities (Dec. 21, 2006). 

[3] OSD groups recruiter irregularities into the following eight 
categories: criminal misconduct; sexual misconduct; sexual harassment; 
fraternization or unauthorized relationship with an applicant; 
concealment or falsification; testing irregularity; false promise or 
coercion; and quality control measures, which are irregularities 
resulting from administrative oversight. 

[4] GAO, Military Recruiting: DOD and Services Need Better Data to 
Enhance Visibility over Recruiter Irregularities, [hyperlink, 
http://www.gao.gov/products/GAO-06-846] (Washington, D.C.: August 8, 
2006). 

[5] An OSD official also told us that MEPCOM only receives information 
on a subset of recruiter irregularities that are identified while the 
applicants are being processed at one of its military entrance 
processing stations, and would not know about irregularities that may 
come to light through other sources. MEPCOM has no direct command and 
control authority over the service components’ recruiters, but is 
required to refer any allegations of recruiter irregularities that it 
identifies to the recruiter’s commanders within the appropriate 
service component. 

[6] United States Army Recruiting Command Regulation 601-45, 
Recruiting Improprieties Policies and Procedures (July 13, 2009); 
Marine Corps Order 1130.65A, Total Force Recruiting Quality Control 
(Feb. 20, 1987); Navy Recruiting Command Instruction 1137.3, 
Investigating and Reporting of Allegations and Complaints (Apr. 3, 
2009); Air Force Recruiting Service Instruction 36-2001, Recruiting 
Procedures for the Air Force (Apr.1, 2005); Air Force Reserve Command 
Instruction 36-2001, Air Force Reserve Recruiting Procedures (June 1, 
2009). 

[7] GAO, Executive Guide: Effectively Implementing the Government 
Performance and Results Act, [hyperlink, 
http://www.gao.gov/products/GAO/GGD-96-118] (Washington, D.C.: June 
1996); and GAO, Managing for Results: Enhancing Agency Use of 
Performance Information for Management Decision Making, [hyperlink, 
http://www.gao.gov/products/GAO-05-927] (Washington, D.C.: September 
9, 2005). 

[8] Office of the Under Secretary of Defense for Personnel and 
Readiness Memorandum, Tracking and Reporting of Recruiter 
Irregularities (Dec. 21, 2006). 

[9] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[10] Frontline recruiters are those recruiting personnel who directly 
interact with applicants in the recruiting process. 

[11] The Army Recruiting Command is located at Fort Knox, Kentucky; 
the Navy Recruiting Command is located in Millington, Tennessee; the 
Marine Corps Recruiting Command is located at Quantico, Virginia; the 
Air Force Recruiting Service is located at Randolph Air Force Base, 
Texas; and the Air Force Reserve Command Recruiting Service is located 
at Warner Robins, Georgia. 

[12] The MEPS are under the direction and control of MEPCOM, which is 
under the direct operational authority of the Deputy Under Secretary 
of Defense for Military Personnel Policy within the Office of the 
Under Secretary of Defense for Personnel and Readiness. MEPCOM’s role 
is to ensure that all service applicants meet DOD standards for 
enlistment. 

[13] The ASVAB test can also be administered to applicants at their 
high school or a Military Entrance Test site. 

[14] The Army National Guard refers to its delayed entry program as 
the Recruit Sustainment Program. 

[15] The determination of whether a reported recruiter irregularity 
within the service components is substantiated or unsubstantiated is 
made by commanders within a recruiter’s chain of command based on a 
review of the facts of an investigation. 

[16] OSD’s memorandum groups recruiter irregularities into the 
following eight categories: criminal misconduct; sexual misconduct; 
sexual harassment; fraternization or unauthorized relationship with an 
applicant; concealment or falsification; testing irregularity; false 
promise or coercion; and quality control measures, which are 
irregularities resulting from administrative oversight. 

[17] The categories established by OSD for the service components to 
use in reporting are: court-martial/civil conviction, removed from 
service, removed from recruiting, Article 15 Non-Judicial Punishment, 
adverse administrative action, non-adverse administrative action, 
administrative or processing error, unsubstantiated, action pending, 
and an on-going investigation. 

[18] United States Army Recruiting Command Regulation 601-45, 
Recruiting Improprieties Policies and Procedures (July 13, 2009); 
Marine Corps Order 1130.65A, Total Force Recruiting Quality Control 
(Feb. 20, 1987); Navy Recruiting Command Instruction 1137.3, 
Investigating and Reporting of Allegations and Complaints (Apr. 3, 
2009); Air Force Recruiting Service Instruction 36-2001, Recruiting 
Procedures for the Air Force (Apr. 1, 2005); Air Force Reserve Command 
Instruction 36-2001, Air Force Reserve Recruiting Procedures (June 1, 
2009). 

[19] United States Army Recruiting Command Regulation 601-45, 
Recruiting Improprieties Policies and Procedures (July 13, 2009). 

[20] Marine Corps Order 1130.65A, Total Force Recruiting Quality 
Control (Feb. 20, 1987). 

[21] According to 10 U.S.C. §10501, the National Guard Bureau is a 
joint activity of the Department of Defense, and is a channel of 
communication on all matters pertaining to the National Guard between 
the Departments of the Army and the Air Force and the states. 

[22] National Guard Regulation 601-1, Personnel-Procurement: Army 
National Guard Strength Maintenance Program (Apr. 28, 2006); Air 
National Guard Instruction 36-2602, Air National Guard Recruiting 
Expenditures and Management of Recruiting and Retention Programs (Mar. 
28, 1997). 

[23] National Guard recruiters that recruit under Title 10—such as 
Reserve Component Career Counselors who recruit servicemen and 
servicewomen that are separating from active duty—are subject to the 
Uniform Code of Military Justice and service component guidance in the 
event they commit a recruiter irregularity. 

[24] The Bob Stump National Defense Authorization Act for Fiscal Year 
2003, Pub. L. No. 107-314, §512 (2002), directed the Secretary of 
Defense to prepare a model state code of military justice and a model 
state manual for courts-martial to recommend to the states for use 
with respect to the National Guard when not in federal service. 

[25] The determination of the appropriate unit commander can be based 
on a number of factors, to include where the recruiter irregularity 
investigation was initiated, the seriousness of the allegation, and 
the type of action that is recommended. The following service 
component recruiting command levels can be involved in the 
investigation review and adjudication process: Army—recruiting 
command, recruiting brigade, or recruiting battalion; Navy—recruiting 
region or recruiting district; Marine Corps—recruiting command, 
recruiting region, recruiting district, or recruiting station; Air 
Force—recruiting command, recruiting group, or recruiting squadron; 
and Air Force Reserve—recruiting command, recruiting squadron, or 
recruiting station. 

[26] The service components’ quality control checks are further 
complemented by the checks done at the MEPS to identify any 
discrepancies in the enlistment paperwork, such as signature 
verification and the use of biometrics (i.e., technologies that 
automate the identification of people by distinct physical or 
behavioral characteristics, such as fingerprint recognition). 

[27] This policy is referred to as the “buddy” policy by the Army’s 
active and reserve components and as the “no one alone” policy by the 
Army National Guard. 

[28] The Army Recruiting and Retention School is located at Fort 
Jackson, South Carolina; the Navy Recruiting Orientation Unit is 
located at Naval Air Station Pensacola, Pensacola, Florida; the Marine 
Corps Recruiters School is located at Marine Corps Recruit Depot, San 
Diego, California; the Air Force Recruiting School is located at 
Lackland Air Force Base, Texas; and the Army National Guard Strength 
Maintenance Training Center is located at Camp Robinson, Arkansas. Air 
Force Reserve and Air National Guard recruiters attend the Air Force 
Recruiting School in Texas. 

[29] The Army includes, among others, the following individuals in its 
definition of a qualifying person: a family member (18 or older), 
recruiter, applicant (male or female, 18 or older), and future soldier 
(male or female). 

[30] GAO, Military Recruiting: DOD and Services Need Better Data to 
Enhance Visibility Over Recruiter Irregularities, [hyperlink, 
http://www.gao.gov/products/GAO-06-846] (Washington, D.C.: August 8, 
2006). 

[31] Air Force Reserve Command Instruction 36-2001, Air Force Reserve 
Recruiting Procedures (June 1, 2009). 

[32] The Air Force Recruiting Service develops and distributes the 
following reports on recruiter irregularities with personally 
identifying information left out: a monthly report to the Commander of 
the Air Force Recruiting Service, recruiting squadron commanders, and 
recruiting group commanders, which covers recruiter irregularities 
that resulted or may potentially result in a courts-martial; a monthly 
newsletter to all recruiting personnel, which covers recruiter 
irregularities that resulted in courts-martial, removal from 
recruiting, or removal from service; a quarterly report to all 
recruiting personnel, which covers recruiter irregularities that 
resulted in a letter of reprimand or a more serious action. 

[33] GAO, Executive Guide: Effectively Implementing the Government 
Performance and Results Act, [hyperlink, 
http://www.gao.gov/products/GAO/GGD-96-118] (Washington, D.C.: June 
1996); and GAO, Managing for Results: Enhancing Agency Use of 
Performance Information for Management Decision Making, [hyperlink, 
http://www.gao.gov/products/GAO-05-927] (Washington, D.C.: September 
9, 2005). 

[34] Office of the Under Secretary of Defense for Personnel and 
Readiness Memorandum, Tracking and Reporting of Recruiter 
Irregularities (Dec. 21, 2006). 

[35] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[36] The memorandum states that the guidance that it contains shall be 
incorporated into a DOD instruction, but does not specify when such an 
instruction should be issued. 

[37] MEPCOM is overseen by the Office of the Under Secretary of 
Defense for Military Personnel Policy, which is one of the offices 
within OSD. 

[38] OSD officials said that they shared the data on recruiter 
irregularities with the service components. However, they said that 
the recruiting command personnel change frequently as existing 
personnel are reassigned to other posts, which may necessitate more 
frequent sharing of information. 

[39] An official from the Air National Guard Recruiting and Retention 
Service did not know whether all Air National Guard States and 
Territories were reporting on cases of recruiter irregularities that 
did not involve applicants or recruits. 

[40] One of the Army National Guard States whose case files we 
reviewed only included cases involving applicants; however, an 
official with that State indicated that he would generally include all 
cases of recruiter irregularities in his report to the Army National 
Guard Strength Maintenance Division, even those not involving 
applicants or recruits. 

[41] Both soldiers were then reinstated to their recruiting duties 
after allegations against them were found to be unsubstantiated, and 
the disposition was updated in the subsequent report to OSD. 

[42] Unless otherwise noted, Army and Air National Guard officials 
refer to officials from the Army National Guard Strength Maintenance 
Division and the Air National Guard Recruiting and Retention Service 
within the National Guard Bureau. 

[43] Another State submitted a report for fiscal year 2008 in August 
2009, 6 months after it was due in January 2009. 

[44] Joint Advertising, Market Research and Studies, 2008 Recruiter 
Quality of Life Survey Topline Report (August 2008); and Joint 
Advertising, Market Research and Studies, 2005 Recruiter Quality of 
Life Survey Topline Report (February 2006). 

[45] The Air National Guard was excluded from the case file review as 
they had reported zero recruiter irregularities for fiscal year 2008 at 
the time of our case file review. The Air National Guard later reported 
two recruiter irregularities for fiscal year 2008 after the case file 
review had been completed. 

[46] Out of the 24 recruiters that we interviewed, 8 held supervisory 
positions, such as recruiting station commander and flight chief. 

[47] Although the total number of substantiated recruiter 
irregularities 
reported by these States was 63 in fiscal year 2008, we received and 
reviewed 53 case files. This is because in some case files, there was 
more than one recruiter involved in the recruiter irregularity 
incident. While the service components may maintain a single case file 
for a case involving multiple recruiters, they report to OSD on each 
individual recruiter who committed or was alleged to have committed a 
recruiter irregularity. 

[End of section] 

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