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entitled 'Military Personnel: DOD Needs Data to Determine if Active 
Duty Service Has an Impact on the Ability of Guard and Reservists to 
Maintain Their Civilian Professional Licenses or Certificates' which 
was released on May 28, 2008.

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GAO-08-790R: 

United States Government Accountability Office: 
Washington, DC 20548: 

May 27, 2008: 

Congressional Committees: 

Subject: Military Personnel: DOD Needs Data to Determine if Active Duty 
Service Has an Impact on the Ability of Guard and Reservists to 
Maintain Their Civilian Professional Licenses or Certificates: 

Since 2001, the Department of Defense (DOD) has relied on more than 
600,000 members of the National Guard and Reserve components [Footnote 
1] to support various operations abroad and at home. In particular, 
from September 2001 to July 2007, the department deployed more than 
434,000 reservists to support operations in DOD's Central Command area 
of responsibility that includes Afghanistan and Iraq. Furthermore, DOD 
has modified its mobilization policy, which had previously limited the 
cumulative amount of time that reservists could be involuntarily called 
to active duty for the Global War on Terrorism. Under DOD's new policy, 
which went into effect in January 2007, involuntary mobilizations for 
reserve component service members are generally limited to no more than 
12 months, and there are no cumulative limits on these involuntary 
mobilizations. 

While on active duty, reservists may be unable to take the required 
professional development courses or periodic tests needed to retain 
their professional currency in fields such as accounting or software 
engineering. The Uniformed Services Employment and Reemployment Rights 
Act (USERRA) [Footnote 2] protects rights of qualifying National Guard 
members, reservists, and certain other members of the uniformed 
services returning to their civilian employment after being absent due 
to military service. The act, however, does not explicitly address 
issues related to licenses and certifications. 

In the National Defense Authorization Act for Fiscal Year 2008, 
[Footnote 3] Congress mandated that we examine the number and type of 
professional or other licensure or certification requirements that may 
be adversely affected by extended periods of active duty, and identify 
options that would help provide relief. Specifically for this report, 
our objectives were to examine (1) DOD's efforts to identify the extent 
to which active duty service has had an impact on the ability of 
reservists to maintain professional licenses or certifications in their 
civilian careers, and (2) current relief options for addressing these 
issues if needed. [Footnote 4] 

For our first objective, we examined relevant policies and procedures 
governing the collection of reserve component demographic information 
and determined what, if any, data DOD collects on a routine basis. We 
also interviewed officials in the Office of the Secretary of Defense, 
the U.S. Air Force Reserve and Air National Guard, U.S. Army Reserve 
and Army National Guard, U.S. Marine Corps Reserve, U.S. Navy Reserve, 
National Guard Bureau, and Defense Manpower Data Center (DMDC) 
responsible for collecting reserve component demographic data, 
conducting surveys of personnel attitudes and concerns, and 
administering pre-and postmobilization processing. For our second 
objective, we met with and obtained documentation from the National 
Governors Association regarding state initiatives to provide relief to 
reservists experiencing challenges with maintaining state professional 
licenses and certifications subsequent to active duty. We also obtained 
information from the association about its 2007 survey instrument of 
state programs and services available to members of the National Guard, 
reserve, active forces, and their families, as well as its 
collaboration with DOD on the issue. In addition, we interviewed 
officials in the Office of the Secretary of Defense about any existing 
programs that are designed to provide similar relief to servicemembers. 
We conducted this performance audit from March 2008 through May 2008 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. We believe that the 
evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objectives. 

Summary: 

The degree to which reservists serving on active duty have had 
difficulty maintaining professional licenses or certifications in their 
civilian careers is unclear, because neither DOD's Office of the 
Assistant Secretary of Defense for Reserve Affairs nor the reserve 
components collect the necessary data to track and monitor the issue. 
While all members of the Ready Reserve are required to provide their 
civilian employment information upon joining the reserves and to review 
and update that information each year, the required information 
includes employment status, the employer's name, the employer's mailing 
address, the civilian's job title, and the total number of years in the 
current occupation, but does not include information on the impact 
active duty service potentially has on maintaining licenses and 
certifications. Officials at DMDC, which administers DOD's 
departmentwide Status of Forces Survey, confirmed that surveys of 
reservists conducted to date have not inquired about the impact of 
active duty service on a reservist's ability to maintain civilian 
professional licenses and certifications. Without any initial 
information on the scope of the issue, DOD is unable to identify the 
extent, if any, of the impact of active duty on the ability of 
reservists to maintain professional licenses or certifications in their 
civilian careers. 

DOD's Office of the Assistant Secretary of Defense for Reserve Affairs 
has not established relief policies and practices specifically designed 
to assist reservists in maintaining their civilian credentials. 
However, relief mechanisms do exist that may be applicable or serve as 
a model if DOD determines that a need exists to address the issue of 
expired professional licenses and certification. Some states, for 
example, have enacted provisions to provide relief to reservists in 
certain circumstances. In addition, different entities within DOD have 
developed programs and initiatives to assist servicemembers in 
obtaining licenses and certification. Further, the Office of the Under 
Secretary of Defense for Personnel and Readiness administers a program 
for military spouses who have experienced similar challenges 
maintaining civilian professional licenses and certifications because 
of their partner's active duty obligations. Although the focus of that 
program is on providing assistance to military spouses to acquire new 
licenses and certifications, military spouses who need to renew their 
credentials upon relocating, such as nurses, are also eligible. 

DOD reviewed a draft of this report but did not provide formal agency 
comments. DOD did provide technical comments and we made changes to the 
report where appropriate. 

Background: 

Occupational credentialing is an official recognition of a process by 
which an individual meets a set of defined standards, generally through 
education, training, experience, and testing. Two primary types of 
occupational credentialing are licensure and certification. 

1) Licensure: Licenses are granted primarily by state - but also 
federal and local - government agencies to individuals to regulate the 
practice of a specific occupation or profession, such as a physician, a 
cosmetologist, or an air traffic control tower operator. Federal, 
state, or local laws and/or regulations define the standards that 
individuals must meet to become licensed. Licenses are typically 
required and issued by a government entity, i.e., individuals are not 
authorized to practice an occupation in a location without first 
obtaining the required license. 

2) Certification: Occupational certification can be broadly grouped 
into two areas: (1) certifications granted by organizations or 
professional associations, and (2) vendor or product-related 
certifications. Each certifying organization sets its own standards for 
certification. Certification requirements generally include one or more 
of the following: education, training, work experience, and 
examination. Certification is not usually required by law to practice 
an occupation except in cases where a licensing body or board for a 
particular occupation in a state includes certification as part of the 
licensing requirements. 

Having complete civilian employer information has been important to 
DOD's reserve components because the data support outreach to employers 
and enhance the department's ability to make informed decisions 
concerning which reservists should be called for active duty to 
minimize the impact that mobilizations might have on areas with small 
populations or occupations such as law enforcement, and to determine 
how businesses may be affected by reserve activation. In 2001, DOD 
established a database to collect reported employer information from 
reservists on a voluntary basis. More recently, the Under Secretary of 
Defense for Personnel and Readiness made the submission of employer 
information mandatory. We have issued several reports on DOD's programs 
to capture reservists' civilian employment information. [Footnote 5] 

DOD Has Not Been Collecting Data on the Impact Active Duty Service May 
Have on the Ability of Guard and Reservists to Maintain Their Civilian 
Professional Licenses or Certificates: 

Neither DOD nor the services have been collecting the necessary data to 
track and monitor what impact active duty service may have on 
reservists' ability to maintain civilian professional licenses and 
certifications. In March 2003, the Under Secretary of Defense for 
Personnel and Readiness issued a directive-type memorandum directing 
each military department to implement a civilian employment information 
program for the collection of employer information from members of the 
Ready Reserve and cited the need to use the information in 
accomplishing employer outreach. [Footnote 6] In August 2004, the 
Office of the Under Secretary issued an instruction establishing 
employment-related information reporting requirements for each person 
assigned to the reserves. [Footnote 7] In October 2005, we reported 
that the services had not enforced the requirement for reservists to 
enter required employer information. In that report, we recommended 
that the Secretary of Defense direct the service secretaries to take 
steps to enforce the requirement for reservists to report their 
civilian employment information and develop a plan to maintain current 
civilian employment information. In February 2007, we reported DOD had 
made progress capturing employment information on its reservists, but 
several challenges to collect complete information remained. Subsequent 
to a recommendation in that report, the office of the Under Secretary 
reissued the instruction in March 2008, [Footnote 8] requiring each 
member to review and update his or her civilian employment information 
annually. This information is general, however, and does not include 
information on the impact of active duty service on maintaining 
licenses and certification. 

Presently, the DOD instruction requires reservists to provide only the 
following employment-related information: 

* status as full-time, part-time, voluntary, student, or not currently 
employed;
* current position title;
* current position begin date;
* current position end date;
* the corresponding Department of Labor classification;
* status if self-employed;
* employer's name and address;
* status if considered a "first responder;" and; 
* date the information was reviewed or updated. 

Civilian employment information is generally entered by reservists 
through an online Web application established and administered by DMDC. 
However, because the DOD instruction requires reservists to provide 
only the information listed above, the application does not include a 
field allowing reservists to provide information on their civilian 
professional licenses and certifications. 

DOD and service officials told us that neither reservists nor existing 
studies examining the reserve components or military compensation have 
identified a lapse of civilian professional licenses and certifications 
as an area of concern. A director with the Employer Support for the 
Guard and Reserve said that this organization also has not received any 
requests or questions from reservists seeking assistance in addressing 
the challenges associated with the lapse of civilian professional 
licenses. Separately, an official at the Reserve Forces Policy Board, 
the principal policy adviser to the Secretary of Defense on matters 
relating to the reserve components, stated the matter of reserve 
component licensure and certification has never been an issue for the 
board to monitor and shared feedback from the Army Reserve and National 
Guard explaining that those components had not identified the matter as 
a significant issue either. DMDC officials responsible for developing 
and administering the Status of Forces Survey for the reserve 
components confirmed that the matter of reservists experiencing 
challenges maintaining civilian professional licenses and 
certifications due to active duty service obligations has never been 
included as part of the survey's inquiries. 

To address the matters raised by our audit work, however, DMDC 
officials stated their plans to address the matter and provided us with 
their revisions to DMDC's upcoming June 2008 Status of Forces Survey. 
The survey will provide respondents an opportunity to identify whether 
their occupation required a license or certification, the occupational 
field that required the license or certification, and whether the 
status of their license or certification was affected by active duty 
service. By collecting such responses, DOD will be able to determine 
the extent to which active duty service has an impact on the ability of 
reservists to maintain professional licenses and certifications in 
their civilian careers. This will provide DOD and Congress the basis 
for determining whether active duty service has had an impact on the 
ability of reservists to maintain professional licenses or 
certifications in their civilian careers or the degree to which it has 
affected retention decisions. DOD needs this information before it can 
explore if potential modifications to existing relief mechanisms, or 
new ones, are needed. 

Relief Opportunities Exist Both Outside and Within DOD: 

Relief mechanisms currently exist both outside and within DOD that may 
have applicability, or provide a model, if DOD determines that a need 
exists to provide assistance to reservists in maintaining their 
civilian credentials. Some of these programs are found within 
legislation issued by the states, which play the primary role in 
issuing occupational licenses. Other initiatives, which are primarily 
designed to help servicemembers obtain civilian professional 
credentials, are being administered by various entities within DOD. 

According to a survey by the National Governors Association, a number 
of states have enacted provisions to provide relief for reservists 
experiencing challenges maintaining civilian professional licenses and 
certifications in certain circumstances. With the support of the Office 
of Deputy Under Secretary for Military Community and Family Policy, the 
National Governors Association publishes a report which compiles state 
and territorial responses to a survey addressing ways in which they 
provide support for members of the National Guard, the Reserves and 
their families, including descriptions of relief provisions. [Footnote 
9] These provisions provide relief ranging from waiving deadlines and 
fees for professional license renewals, to ensuring licenses or 
certifications remain valid while deployed, to providing grace periods 
of varying lengths for returning servicemembers whose professional 
licenses expire while serving on active duty, and deferring continuing 
education requirements until members return from active duty. The state 
of Virginia, for example, allows for a waiver of educational 
requirements for reactivation of a real estate license for any 
salesperson or broker, which has been inactive for more than 3 years 
when the holder of the inactive license is a member or the spouse of a 
member of the armed forces of the United States who was permanently 
assigned outside Virginia for a portion of the time the license was 
inactive. However, the holder must show, to the satisfaction of the 
board, currency in the field of real estate. [Footnote 10] Under Ohio 
law, any holder of an expired license or certificate granted by the 
state or its subdivisions that was not renewed because of service in 
the armed forces, is granted a renewal at the usual cost without 
penalty or reexamination within 6 months of an honorable discharge or 
separation under honorable conditions. [Footnote 11] Attorneys who are 
members of the North Carolina bar are exempt from their continuing 
education requirements for any calendar year in which they served full-
time active duty in the armed forces. [Footnote 12] Lastly, for those 
operating under a license or certification in the state of New York 
prior to being called to active duty, New York automatically extends 
their credentials during their period of active duty and for 12 months 
after release from active duty with certain exceptions related to 
limited permits and previous revocations or suspensions. [Footnote 13] 

Presently, the Army and Navy operate Web sites that provide information 
on credentialing opportunities and explain how servicemembers can 
obtain civilian certification and license requirements related to their 
military occupational specialties. The Army and Navy established these 
Web sites in April 2002 and June 2006, respectively. The Web sites 
identify the civilian credentials that relate to military occupational 
specialties, explain the steps to obtain the credentials, and identify 
available programs that will help pay credentialing fees. [Footnote 14] 
In a related action, the National Defense Authorization Act for Fiscal 
Year 2006 gave the Secretary of Defense authority to pay for expenses 
for members of the armed forces to obtain professional credentials and 
necessary examinations as long as the credentials were not a 
prerequisite for appointment in the armed forces, [Footnote 15] and the 
Office of the Undersecretary of Defense for Personnel and Readiness 
issued a memorandum [Footnote 16] on February 12, 2007, establishing 
DOD policy and guidance for setting up discretionary programs for the 
payment of professional credentialing expenses to military members. 
According to the memorandum, military departments may pay credentialing 
expenses if the preponderance of a servicemember's assigned military 
duties are covered by the credential and the credential has been 
approved for those assigned duties. Furthermore, once the servicemember 
has obtained the required certification or license, the military 
department may pay the fees required for renewal of the certification 
or license. Paying for credentialing solely as a component of 
retention, recruiting, or transition programs, or to acquire an 
educational degree, however, is not allowed under this act. The policy 
also requires the military departments that desire to use this 
authority to provide their credentialing programs to the Under 
Secretary of Defense for Personnel and Readiness for review, but allows 
them to begin implementation upon receipt of the policy. In addition, 
departments using the authority are required to provide an assessment 
report to the Under Secretary of Defense for Personnel and Readiness no 
later than November 30, 2008. This assessment is to address areas set 
out in an attachment to the policy including things such as the 
methodologies used to determine eligibility and program effectiveness, 
a review of funds expended, and a corresponding assessment for the 
reserve component if assessment results differ significantly between 
the active and reserve components. 

More recently, on April 14, 2008, the U.S. Army Reserve officially 
announced its Employer Partnership initiative with private industry 
organizations to align military and civilian credentialing and 
licensing. A principal objective of the initiative is to provide 
licensing reciprocity between private industry and DOD. For example, a 
reservist who has completed certain civilian occupation-specific 
training and experience could forgo initial military training in the 
same skill area. Similarly, a reservist who has completed certain skill-
specific training in the military would be eligible, under this 
program, to receive the equivalent civilian licenses. The initiative's 
intent is to minimize training expenditures and duplication for 
individuals who hold both civilian careers and military service 
obligations. In addition, the intent of the program is to facilitate 
the recruitment and retention of individuals in both their civilian and 
military careers. Currently, the Army Reserve has entered cooperative 
agreements with a Virginia-based healthcare provider and a trucking 
association. 

DOD has also introduced a program for military spouses to obtain or 
renew professional licenses. DOD implemented this program in light of 
the increased obligations assumed by the trailing spouse subsequent to 
increases in operational tempo and the extended tours of duty during 
the Global War on Terrorism. In June 2007, the Military Community and 
Family Policy office within the Office of the Under Secretary of 
Defense for Personnel and Readiness, in conjunction with the Department 
of Labor, established a program to support active duty military spouses 
in acquiring or renewing civilian professional licenses and 
certification. The goal is to help military spouses obtain and retain 
portable careers in "high-growth, high-demand" occupations in the 
fields of information technology, education, health services, financial 
services, and the construction trades. Under the program, military 
spouses receive grants to pay for expenses directly related to 
postsecondary education and training, including credentialing and 
licensing fees. The initiative targets military spouses with a general 
education diploma, high-school diploma, or some postsecondary education 
and who are married to active-duty servicemembers in junior enlisted or 
officer pay grades. [Footnote 17] Military spouses who need to renew 
credentials upon relocating, such as nurses, also are eligible. DOD and 
the Department of Labor are jointly investing $35 million in eight 
states demonstrating this initiative (California, Colorado, Florida, 
Georgia, Hawaii, Maine, North Carolina, and Washington) targeting 18 
military installations. In January 2008, the first account was granted; 
as of April 2008, 8,000 individuals had received the briefing regarding 
the availability of the account and 1,000 had been approved to receive 
the assistance. 

Agency Comments and Our Evaluation: 

DOD reviewed a draft of this report. However, DOD did not provide 
formal agency comments because the report discussed action the 
department was already taking in response to our finding that DOD has 
not been collecting information on what impact active duty service may 
have on reservists' ability to maintain professional licenses or 
certifications in their civilian careers. DOD did provide technical 
comments, and we incorporated those changes where appropriate. 

We are sending copies of this report to the Secretary of Defense and 
the Secretaries of the Army, Navy, and Air Force. We will also make 
copies available to others on request. In addition, the report will be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

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

Signed by: 

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

[End of section] 

List of Congressional Committees: 

The Honorable Carl Levin:
Chairman:
The Honorable John McCain:
Ranking Member:
Committee on Armed Services:
United States Senate: 

The Honorable Ike Skelton:
Chairman:
The Honorable Duncan L. Hunter:
Ranking Member:
Committee on Armed Services:
United States House of Representatives: 

[End of section] 

Enclosure I: 

GAO Contacts and Staff Acknowledgments: 

GAO Contact: 

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

Acknowledgments: 

In addition to the individual named above, David Moser (Assistant 
Director), Grace Coleman, Nicole Harms, Charles Perdue, John W. 
Wheeler, Jr., and Ricardo Marquez made key contributions to this 
report. 

[End of section] 

Footnotes: 

[1] For purposes of this report, the term reserve component, or 
reservists, refers to the collective forces of the Army Reserve, the 
Army National Guard, the Navy Reserve, the Air Force Reserve, the Air 
National Guard, and the Marine Corps Reserve. 

[2] Pub. L. No. 103-353 (1994), as amended, codified at 38 U.S.C.  
4301-4334. 

[3] Pub. L. No. 110-181,  516 (2008). 

[4] We are reporting on these objectives because neither DOD nor the 
services were collecting, tracking, reporting, or tracking civilian 
professional license and certification data during the time of this 
review. 

[5] GAO, Reserve Forces: DOD Actions Needed to Better Manage Relations 
between Reservists and Their Employers, GAO-02-608 (Washington, D.C.: 
June 13, 2002). GAO, Military Personnel: Federal Management of 
Servicemember Employment Rights Can Be Further Improved, GAO-06-60 
(Washington, D.C.: Oct. 19, 2005). GAO, Military Personnel: Federal 
Agencies Have Taken Actions to Address Servicemembers' Employment 
Rights, but a Single Entity Needs to Maintain Visibility to Improve 
Focus on Overall Program Results, GAO-08-254T (Washington, D.C.: Nov. 
8, 2007). GAO, Military Personnel: Additional Actions Needed to Improve 
Oversight of Reserve Employment Issues, GAO-07-259 (Washington, D.C.: 
Feb. 8, 2007). 

[6] Under Secretary of Defense for Personnel and Readiness Memorandum 
on Civilian Employment Information Program (Mar. 21, 2003). 

[7] Department of Defense Instruction 7730.54, Reserve Components 
Common Personnel Data System (RCCPDS), enclosure 10 (Aug. 6, 2004). 

[8] Department of Defense Instruction 7730.54, Reserve Components 
Common Personnel Data System (RCCPDS), enclosure 10 (Mar. 31, 2008). 

[9] National Governors Association, State and Territorial Support for 
Members of the National Guard, the Reserves, and their Families (July 
30, 2007). 

[10] Va. Code Ann.  54.1-2105.04. 

[11] Ohio Rev. Code Ann.  5903.10 (2008). 

[12] N.C. Gen. Stat. Ann. State Bar Rules, Ch. 1, Subch. D, .1517 
(2008). 

[13] N.Y. Mil. Law  308-b (2008). 

[14] The July 2007 Task Force on Returning Global War on Terror Heroes 
report cited the Army and Navy Web sites as progress in improving 
civilian workforce and credentialing, but stated additional analysis 
needs to be conducted for the Air Force and the Marines to assist all 
members transitioning from the military. 

[15] Pub. L. No. 109-163,  538 (2006) (codified at 10 U.S.C.  2015). 

[16] Under Secretary of Defense for Personnel and Readiness Memorandum 
on Payment of Credentialing Expenses for Military Members (Feb. 12, 
2007). 

[17] Specifically, the initiative is directed to spouses who are 
married to servicemembers in pay grades E1 through E5 and O1-O3. 

[End of section] 

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