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B-173688, JAN 23,1975

B-173688 Jan 23, 1975
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COMMITTEE ON ARMED SERVICES UNITED STATES SENATE THIS IS OUR REPORT ON THE NEED FOR AND USES OF DATA RECORDED ON DD FORM 214. IT IS GIVEN TO ALL PERSONNEL RELEASED FROM ACTIVE DUTY. PRIMARY CONCERNS OF THE SUBCOMMITTEE WERE: 1. IDENTIFYING ITEMS ON THE REPORT THAT ARE INJURIOUS TO VETERANS. 3. DETERMINING WHETHER CONTINUED USE OF THE REPORT IS JUSTIFIED. WE BELIEVE THE SEPARATION REPORT WOULD NOT BE NEEDED BY VETERANS IF THE (1) VETERANS ADMINISTRATION'S SYSTEM WAS EXPANDED TO PROVIDE ALL VETERANS WITH INFORMATION CONCERNING THEIR ELIGIBILITY FOR VETERANS BENEFITS AND (2) MILITARY CENTRAL DEPOSITORIES FOR PERSONNEL RECORDS WERE REQUIRED TO PROVIDE TIMELY RESPONSES TO INQUIRIES. RECOMMENDATIONS TO THE SECRETARY OF DEFENSE ARE SET FORTH ON PAGE 23.

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B-173688, JAN 23,1975

PRECIS-UNAVAILABLE

THE HONORABLE JOHN C. STENNIS:

CHAIRMAN, COMMITTEE ON ARMED SERVICES

UNITED STATES SENATE

THIS IS OUR REPORT ON THE NEED FOR AND USES OF DATA RECORDED ON DD FORM 214, REPORT OF SEPARATION FROM ACTIVE DUTY, A SUMMARY RECORD OF AN INDIVIDUAL'S MILITARY SERVICE. IT IS GIVEN TO ALL PERSONNEL RELEASED FROM ACTIVE DUTY.

WE MADE OUR REVIEW PURSUANT TO THE REQUEST OF SENATOR HAROLD E. HUGHES, CHAIRMAN, SUBCOMMITTEE ON DRUG ABUSE IN THE MILITARY SERVICES, SENATE COMMITTEE ON ARMED SERVICES. PRIMARY CONCERNS OF THE SUBCOMMITTEE WERE:

1. DETERMINING THE CIRCUMSTANCES THAT LED THE DEPARTMENT OF DEFENSE TO DEVELOP THE SEPARATION REPORT.

2. IDENTIFYING ITEMS ON THE REPORT THAT ARE INJURIOUS TO VETERANS.

3. DETERMINING THE USES MADE OF THE RECORDED DATA BY OFFICIALLY DESIGNATED RECIPIENTS.

4. IDENTIFYING OCCASIONS THAT MIGHT REQUIRE VETERANS TO USE THEIR SEPARATION REPORT.

5. DETERMINING WHETHER CONTINUED USE OF THE REPORT IS JUSTIFIED.

WE FOUND THAT THE DEPARTMENT OF DEFENSE DEVELOPED A STANDARD SEPARATION REPORT TO SERVE ADMINISTRATIVE NEEDS. ITS ORIGIN EVOLVED FROM THE PRACTICE OF CHARACTERIZING AN INDIVIDUAL'S MILITARY SERVICE AND DESCRIBING IT ON HIS DISCHARGE CERTIFICATE.

THE REPORT CAN CONTAIN DEROGATORY INFORMATION. THEREFORE, THE PRACTICE OF ROUTINELY PROVIDING IT TO ALL INDIVIDUALS RELEASED FROM MILITARY SERVICE DOES NOT ADEQUATELY SAFEGUARD THEIR PRIVACY. THE MAJORITY OF INDIVIDUALS WHO SERVE IN THE MILITARY DO WELL, AND THE SEPARATION REPORT THEY RECEIVE DOES NOT ADVERSELY AFFECT THEM IN CIVILIAN LIFE. HOWEVER, FOR THOSE WHO DO NOT PERFORM WELL AND WHOSE SEPARATION REPORT REFLECTS THIS, THE REPORT CAN ADVERSELY AFFECT THEM, PARTICULARLY IN SEEKING CIVILIAN EMPLOYMENT.

WE BELIEVE THE SEPARATION REPORT WOULD NOT BE NEEDED BY VETERANS IF THE (1) VETERANS ADMINISTRATION'S SYSTEM WAS EXPANDED TO PROVIDE ALL VETERANS WITH INFORMATION CONCERNING THEIR ELIGIBILITY FOR VETERANS BENEFITS AND (2) MILITARY CENTRAL DEPOSITORIES FOR PERSONNEL RECORDS WERE REQUIRED TO PROVIDE TIMELY RESPONSES TO INQUIRIES.

OUR QUESTIONNAIRE RESULTS SHOWED THAT A DOCUMENT DESCRIBING AN INDIVIDUAL'S WORK EXPERIENCE, TRAINING, AND EDUCATION WOULD BENEFIT ALL VETERANS SEEKING CIVILIAN EMPLOYMENT AND THAT THIS WOULD CONFORM TO THE TYPE OF DATA NORMALLY EXCHANGED BETWEEN CIVILIAN EMPLOYERS.

RECOMMENDATIONS TO THE SECRETARY OF DEFENSE ARE SET FORTH ON PAGE 23.

BECAUSE OF THE TIME LIMITATION IMPOSED BY THE IMPENDING DEPARTURE OF SENATOR HUGHES FROM THE SENATE AND AT THE REQUEST OF HIS OFFICE, WE DID NOT OBTAIN ADVANCE REVIEW AND COMMENTS FROM OFFICIALS OF ORGANIZATIONS WHOSE ACTIVITIES ARE DISCUSSED IN THIS REPORT. HOWEVER, WE DISCUSSED THE REPORT'S CONTENTS WITH AGENCY OFFICIALS AND HAVE GIVEN CONSIDERATION TO THEIR VIEWS WHERE APPROPRIATE. IN ACCORDANCE WITH HIS WISHES, WE ARE SENDING COPIES OF THE REPORT TO THE DIRECTOR, OFFICE OF MANAGEMENT AND BUDGET; SECRETARIES OF DEFENSE, ARMY, NAVY, AND AIR FORCE; OTHER CONGRESSIONAL COMMITTEES; MEMBERS OF CONGRESS; AND OTHER INTERESTED PARTIES.

APPENDIX I

REPORT ON THE NEED FOR AND USES OF DATA RECORDED ON DD FORM 214, REPORT OF SEPARATION FROM ACTIVE DUTY

HISTORY AND EVOLUTION OF SEPARATION REPORT

THE MILITARY SERVICES HAVE USED A UNIFORM, STANDARD SEPARATION REPORT FOR ABOUT 25 YEARS. THE DEPARTMENT OF DEFENSE (DOD) DEVELOPED THE REPORT AS A CONVENIENCE DOCUMENT TO ELIMINATE THE PRACTICE OF EACH SERVICE PREPARING ITS OWN NONUNIFORM SEPARATION REPORT. ACCORDING TO DOD, THE SEPARATION REPORT HAS BEEN FREQUENTLY REVIEWED AND REVISED OVER THE YEARS TO ADD NEEDED ITEMS OR TO ELIMINATE THOSE NO LONGER CONSIDERED NECESSARY. RECORDS WERE NOT AVAILABLE FOR EXAMINATION, HOWEVER, TO IDENTIFY ALL THE CHANGES MADE OVER TIME AND THE REASONS WHY SPECIFIC ITEMS WERE INCLUDED.

THE USE OF SEPARATION REPORTS HAS EVOLVED FROM THE MILITARY DEPARTMENTS' PRACTICE OF CHARACTERIZING AN INDIVIDUAL'S MILITARY SERVICE AND OF DESCRIBING THE CHARACTER OF SERVICE ON A DISCHARGE CERTIFICATE. AWARDING DISCHARGE CERTIFICATES APPEARS TO HAVE BEEN A EUROPEAN MILITARY TRADITION WHICH WAS ADOPTED IN THIS COUNTRY DURING THE NATION'S EARLY ORIGINS.

THE FIRST CERTIFICATES WERE RELATIVELY SIMPLE DOCUMENTS. FOR EXAMPLE, CERTIFICATES AWARDED TO ARMY VETERANS IN 1841 CONTAINED DATA ON THEIR PHYSICAL CHARACTERISTICS, NORMAL OCCUPATIONS, DATES OF SERVICE, AND WHETHER THEY WERE BEING DISCHARGED UNDER HONORABLE CONDITIONS OR MERELY DISCHARGED.

OVER THE YEARS, MORE AND MORE DATA WAS ADDED AND THE TYPES OF DISCHARGES INCREASED. BY 1902, ARMY DISCHARGES CONTAINED AN ENLISTMENT RECORD WHICH INCLUDED DATES OF SERVICE, BATTLES PARTICIPATED IN, KNOWN VOCATIONS, AND CHARACTER OF SERVICE. ARMY REGULATIONS ISSUED AT THE TIME PROVIDED THAT:

"THE CAUSE OF DISCHARGE AND THE SOLDIER'S AGE AT DATE OF ENLISTMENT WILL BE STATED IN THE BODY OF THE DISCHARGE CERTIFICATE. HIS CHARACTER OF SERVICE WILL BE ACCURATELY DESCRIBED AT THE BOTTOM OF THE CERTIFICATE, BUT IF NOT SUFFICIENTLY GOOD TO ALLOW OF HIS REENLISTMENT THE WORDS 'NO OBJECTION TO HIS REENLISTMENT IS KNOWN TO EXIST' WILL BE ERASED. THE WORDS 'SERVICE HONEST AND FAITHFUL' OR 'SERVICE NOT HONEST AND FAITHFUL', AS THE CASE MAY BE, WILL BE ENTERED ON THE BACK OF THE DISCHARGE CERTIFICATE."

THIS ENLISTMENT RECORD REMAINED BASICALLY UNCHANGED FOR ARMY VETERANS UNTIL 1944, WHEN A RECORD SIMILAR TO THE CURRENT SEPARATION REPORT WAS DEVELOPED. THE WAR DEPARTMENT STATED THAT THE:

"ENLISTED RECORD AND REPORT OF SEPARATION CONTAINS MUCH OF THE INFORMATION NEEDED BY PROSPECTIVE EMPLOYERS AND THAT REQUIRED BY VARIOUS GOVERNMENT AGENCIES IN ADMINISTERING ACTS FOR THE BENEFIT OF VETERANS.

IN JULY 1947 THE ENLISTED RECORD AND REPORT OF SEPARATION WAS REMOVED FROM THE BACK OF THE DISCHARGE CERTIFICATE AND ISSUED AS A SEPARATE DOCUMENT. ABOUT THIS TIME, THE TITLE OF THIS REPORT WAS CHANGED TO THE "REPORT OF SEPARATION FROM ARMED FORCES OF THE UNITED STATES" AND DESIGNATED AS DD FORM 214. IN JUNE 1956, DOD INSTRUCTED THE SERVICES THAT CERTAIN REASONS FOR DISCHARGE SHOULD NOT BE NARRATIVELY DESCRIBED ON THE SEPARATION REPORT. INSTEAD, A SYSTEM OF NUMERICAL CODE DESIGNATORS WAS ESTABLISHED TO DENOTE REASONS FOR DISCHARGE INVOLVING UNSUITABILITY, INAPTITUDE, UNFITNESS, AND OTHER CAUSES.

THESE NUMERICAL CODES, SEPARATION PROGRAM NUMBERS (SPNS) AND REENLISTMENT CODES, HAVE BEEN THE SUBJECT OF CONSIDERABLE CONTROVERSY.

DOD ACTION TO ELIMINATE SPNS AND REENLISTMENT CODES FROM REPORTS

A NUMBER OF THE SPNS IDENTIFIED PARTICULARLY OFFENSIVE OR UNFAVORABLE CHARACTERISTICS. SOME DESCRIBED SUCH THINGS AS UNSUITABILITY, UNSANITARY HABITS, DRUG ABUSE, SEXUAL DEVIANCY, BED WETTING, PERSONALITY DISORDERS, ALCOHOLISM, AND INAPTITUDE. CRITICS OF THE SEPARATION REPORT EXPRESSED THE FEAR THAT THE MEANING OF THESE CODES WERE COMMONLY KNOWN BY CIVILIAN EMPLOYERS AND WERE USED TO THE DETRIMENT OF THE VETERANS.

THE SAME CONCERN APPLIES TO REENLISTMENT CODES BECAUSE INDIVIDUALS CONSIDERED UNSUITABLE FOR REENLISTMENT BY THE MILITARY COULD ALSO BE CONSIDERED EQUALLY UNDESIRABLE FOR EMPLOYMENT BY CIVILIAN EMPLOYERS.

IN MARCH 1972 THE SECRETARY OF DEFENSE EXPRESSED HIS CONCERN OVER THE POSSIBLE PUBLIC DISCLOSURE OF THE REASONS FOR SEPARATION AND REQUESTED A REVIEW OF THE PROCEDURES AND PRACTICES FOLLOWED. IN A MEMORANDUM TO THE ASSISTANT SECRETARY OF DEFENSE (MANPOWER AND RESERVE AFFAIRS), THE SECRETARY STATED THAT:

"I CONTINUE TO BE CONCERNED THAT PRACTICES WHICH MAKE POSSIBLE PUBLIC DISCLOSURE OF SOME OF THE UNDERLYING REASONS FOR ADMINISTRATIVE DISCHARGES MAY BE INCONSISTENT WITH OUR POLICY DIRECTIVE ON INVASION OF PRIVACY, AND COULD HAVE AN UNJUST AND UNFAIR IMPACT ON SOME DISCHARGED PERSONNEL.

"I RECOGNIZE, OF COURSE, THAT THIS IS A COMPLEX MATTER, AND THAT NOTATIONS HAVE BEEN PLACED ON DISCHARGE FORMS FOR MANY YEARS.

"I ALSO AM AWARE THAT SOME OF THE NOTATIONS ARE FREQUENTLY HELPFUL TO MEN AND WOMEN WHO HAVE SERVED IN THE ARMED FORCES-- FOR EXAMPLE, IN CONNECTION WITH VETERANS ADMINISTRATION PROCEDURES.

"I BELIEVE, HOWEVER, THAT WE SHOULD AGAIN REVIEW THE PROCEDURES RELATING TO ADMINISTRATIVE DISCHARGES, AND THE PRACTICES WE FOLLOW, FOR CONSISTENCY WITH OUR POLICY WHICH PROTECTS AGAINST INVASION OF PRIVACY OF THE INDIVIDUAL."

THE REVIEW WAS COMPLETED ON AUGUST 1, 1972. THE ASSISTANT SECRETARY OF DEFENSE CONCLUDED THAT THE DISCLOSURE OF THE REASON FOR DISCHARGE ON THE SEPARATION REPORT DID NOT CONSTITUTE AN INVASION OF PRIVACY NOR VIOLATE THE INDIVIDUAL'S RIGHTS. ESSENTIALLY, HIS POSITION WAS THAT THE VETERAN, NOT THE GOVERNMENT, RELEASED THE INFORMATION TO OTHERS.

THE ASSISTANT SECRETARY ACKNOWLEDGED THAT, THROUGH THE YEARS, CIVILIAN EMPLOYERS HAVE LEARNED OF THE SEPARATION REPORT. HE NOTED, HOWEVER, THAT MORE THAN 90 PERCENT OF THE SERVICEMEN BEING DISCHARGED ANNUALLY RECEIVED HONORABLE DISCHARGES WITH FAVORABLE REASONS FOR SEPARATION AND THAT THESE MEMBERS ALSO USED THE SEPARATION REPORT IN SEEKING EMPLOYMENT AND VARIOUS VETERANS ADMINISTRATION (VA) AND STATE VETERANS' BENEFITS.

HE STATED THAT:

"ALTHOUGH SPNS COULD BE DELETED FROM THE INDIVIDUAL'S COPY OF THE DD FORM 214, I CONCUR WITH THE OTHER SERVICES AND HEALTH AND ENVIRONMENT THAT THE INEQUITY OF SUCH ACTION TO THE GREAT BULK OF HONORABLE DISCHARGED MEMBERS, THE PROBABLE INCREASED WORKLOAD RESULTING FROM ADDITIONAL INQUIRIES FROM THE VETERANS ADMINISTRATION AND OTHERS, THE RESULTING SLOWDOWN OF SEPARATION PROCESSING AND THE RESULTING UNTENABLE LEGAL PRACTICE REGARDING CERTIFICATION FOR THE DD 214, OUTWEIGH THE VALUE OF ANY GRATUITOUS BENEFITS THAT WOULD BEFALL THE SMALL PERCENTAGE OF INDIVIDUALS WITH SO CALLED STIGMATIZING SPNS. I CANNOT AGREE WITH THE SEEMING UNDERTONE OF THE SUGGESTION WHICH IMPLIES THAT 'WE' ARE STIGMATIZING PEOPLE. THOSE WHO ARE STIGMATIZED BY THE CIRCUMSTANCES OF THEIR DISCHARGES STIGMATIZE THEMSELVES. WE SIMPLY MAKE THE FACT A MATTER OF RECORD; A RECORD WHICH WE DO NOT MAKE AVAILABLE TO THE GENERAL PUBLIC."

THE ASSISTANT SECRETARY OF DEFENSE RECOMMENDED THAT NO CHANGES BE MADE TO THE EXISTING SYSTEM OF RECORDING PERSONAL INFORMATION ON SEPARATION FORMS EXCEPT FOR:

-- RESTRICTING MASTER LISTS OF SPNS FROM NON-GOVERNMENTAL ORGANIZATIONS, BECAUSE IT WAS FOUND THAT SEVERAL MILITARY DEPARTMENTS WERE NOT ADEQUATELY LIMITING ACCESS OF THEIR PUBLICATIONS CONTAINING SPN IDENTIFICATIONS.

-- TERMINATING THE USE OF NARRATIVE DESCRIPTIONS IDENTIFYING REASONS FOR DISCHARGE, TO THE EXTENT SUCH DESCRIPTIONS WERE STILL BEING USED.

-- DEVELOPING A NEW SET OF SPNS FOR OFFICERS AND ENLISTED PERSONNEL.

THE SECRETARY OF DEFENSE CONCURRED WITH THESE RECOMMENDATIONS; HOWEVER, IN 1973 HE AGAIN RAISED THE ISSUE OF THE POSSIBLE ADVERSE IMPACT OF DISCLOSING SPNS AND REENLISTMENT CODES ON SEPARATION REPORTS. THE MILITARY DEPARTMENTS WERE ASKED TO REASSESS THE NEED TO DISCLOSE THIS INFORMATION ON SEPARATION REPORTS AND TO RECOMMEND PROPOSED CHANGES. ONLY THE AIR FORCE SUPPORTED ELIMINATING SPNS AND REENLISTMENT CODES. THE OTHER SERVICES MAINTAINED THAT SUCH INFORMATION:

-- DID NOT COMPROMISE AN INDIVIDUAL'S PRIVACY, SINCE ONLY HE CHOOSES TO PRESENT OR RELEASE THIS INFORMATION.

-- SHOULD ENHANCE EMPLOYMENT OPPORTUNITIES OF THE VAST MAJORITY OF VETERANS RECEIVING FAVORABLE DISCHARGES AND SEPARATION REPORTS.

-- WAS NEEDED BY THE VA AND SELECTIVE SERVICE SYSTEM IN THEIR ADMINISTRATIVE OPERATIONS.

-- WOULD PREVENT AN INCREASED WORKLOAD AT THE NATIONAL PERSONNEL RECORD CENTER BECAUSE OF INCREASED REQUESTS FROM VETERANS FOR DOCUMENTATION ON REASONS FOR THEIR DISCHARGES.

-- WOULD NOT PREVENT EMPLOYERS FROM REQUIRING THE VETERAN TO OBTAIN THE INFORMATION AS A PRECONDITION TO EMPLOYMENT.

HOWEVER, IN MARCH 1974, THE SECRETARY OF DEFENSE DECIDED TO ELIMINATE THE (1) USE OF SPNS (2) REENLISTMENT CODES, AND (3) AUTHORITY FOR DISCHARGE FROM THE SERVICEMAN'S COPY OF THE SEPARATION REPORT; THIS INFORMATION WAS RETAINED ON THE OTHER COPIES OF THE REPORT. DOD'S MEMORANDUM TO THE MILITARY DEPARTMENTS STATED THAT:

"THE PRESENCE OF THIS INFORMATION CAN BE A CAUSE OF UNDESIRABLE DISCRIMINATION AGAINST THE INDIVIDUAL BY PRIVATE EMPLOYERS OR OTHER PERSONS IN CIVILIAN LIFE. THE DEPARTMENT DOES NOT INTEND OR DESIRE SUCH RESULT, WHATEVER THE CIRCUMSTANCES OF AN INDIVIDUAL'S SEPARATION FROM ACTIVE DUTY."

DOD ANNOUNCED THAT ANY FORMER SERVICE MEMBER WHO WISHED A SEPARATION REPORT WITH THE REASON FOR DISCHARGE, AUTHORITY FOR DISCHARGE, AND REENLISTMENT CODE DELETED COULD OBTAIN A REVISED SEPARATION DOCUMENT. ALSO, ANY SEPARATING SERVICEMAN WHO WANTED TO KNOW THE REASON FOR SEPARATION COULD, ON REQUEST, OBTAIN A SEPARATE NARRATIVE DOCUMENT WHICH WOULD IDENTIFY THE SPECIFIC REASON. OBTAINING THIS NARRATIVE DOCUMENT IS INTENDED BY DOD TO BE OPTIONAL WITH THE INDIVIDUAL SERVICEMAN AND NECESSARY UNDER THE FREEDOM OF INFORMATION ACT.

DATA USED TO PREPARE REPORT AND SEPARATION PROCEDURES FOLLOWED

DOD AND IMPLEMENTING SERVICE REGULATIONS ON PREPARING THE SEPARATION REPORT PROVIDE THAT IT IS AN IMPORTANT SUMMARY RECORD OF SERVICE WHICH MUST BE PREPARED ACCURATELY AND COMPLETELY FOR EACH SERVICEMAN BEING RELEASED OR DISCHARGED FROM ACTIVE DUTY. IT IS PREPARED FROM INFORMATION IN THE INDIVIDUAL'S OFFICIAL PERSONNEL RECORDS AND MUST BE EXPLAINED TO AND EXAMINED BY THE SERVICEMAN BEFORE SEPARATION FROM THE SERVICE. SINCE THE REPORT IS A SUMMARY RECORD OF AN INDIVIDUAL'S MILITARY SERVICE, NUMEROUS OTHER SERVICE RECORDS ARE USED IN ITS PREPARATION, INCLUDING

-- ENLISTMENT CONTRACT OR INDUCTION ORDER;

-- RANK AND PERFORMANCE RECORD; -- CERTIFICATE OF CLEARANCE;

-- MILITARY LEAVE RECORD;

-- OCCUPATION, TRAINING, AND AWARDS DOCUMENT;

-- RECORD OF COURT-MARTIAL CONVICTIONS AND TIME LOST;

-- MEDICAL RECORDS; AND

-- MILITARY PAY RECORDS.

SEPARATION REPORTS ARE PREPARED BY ADMINISTRATIVE CLERKS AT THE PLACE OF SEPARATION. WE VISITED 11 SEPARATION CENTERS-- A MIX OF ARMY, AIR FORCE, NAVY, AND MARINE CORPS ACTIVITIES-- TO OBSERVE SEPARATION PROCEDURES AND FOUND THAT:

-- OFFICIAL SERVICE RECORDS ONLY WERE BEING USED TO PREPARE THE SEPARATION REPORT.

-- INFORMATION ON THE REPORT WAS EXPLAINED, QUESTIONS ANSWERED, AND EACH SERVICEMAN REQUIRED TO REVIEW THE REPORT FOR ACCURACY AND COMPLETENESS.

-- EXPLANATIONS OF VARIOUS RIGHTS AND BENEFITS AVAILABLE TO VETERANS WERE PROVIDED.

-- REPORTS GIVEN TO SERVICEMEN EXCLUDED SPNS AND REENLISTMENT CODES.

MOST SEPARATION CENTERS WERE OFFERING TO PROVIDE AT THE SERVICEMAN'S REQUEST THE REASON FOR SEPARATION IN THE FORM OF A SEPARATE NARRATIVE DOCUMENT. AT THREE SEPARATION CENTERS, WE FOUND THAT THE NARRATIVE DOCUMENT WAS BEING ROUTINELY PREPARED AND DISTRIBUTED TO ALL DEPARTING SERVICE MEMBERS. AS STATED EARLIER, THIS WAS IN VIOLATION OF DOD'S CURRENT POLICY TO MAKE THE INFORMATION AVAILABLE ONLY AT THE OPTION OF THE INDIVIDUAL.

THE REPORT AND IDENTIFICATION OF POTENTIALLY ADVERSE ITEMS

MUCH INFORMATION IN THE SEPARATION REPORT IS IDENTIFICATION TYPE DATA, SUCH AS NAME, SEX, SOCIAL SECURITY NUMBER, DATE OF BIRTH, ADDRESS OF RECORD, AND CITIZENSHIP STATUS. A COPY OF THE REPORT IS INCLUDED AS APPENDIX III.

ELIMINATING SPNS AND REENLISTMENT CODES FROM THE COPY OF THE SEPARATION REPORT GIVEN THE INDIVIDUAL HAS REMOVED THOSE ITEMS OF GREATEST CONCERN AND POTENTIAL DAMAGE IN INDIVIDUALS. THE DOD CHANGE HAS NOT, HOWEVER, ELIMINATED ALL THE POTENTIALLY ADVERSE INFORMATION RECORDED ON THE REPORT. USERS OF THE REPORT CAN MAKE A GENERAL JUDGMENT ABOUT AN INDIVIDUAL FROM THE FOLLOWING INFORMATION. SOME OF THESE JUDGMENTS CAN BE UNFAVORABLE.

CHARACTER OF SERVICE (ITEM 9E)

FOR SOME INDIVIDUALS THIS ENTRY IS POTENTIALLY THE MOST DAMAGING ITEM ON THE REPORT. THE MAJORITY OF VETERANS WILL HAVE THEIR SERVICE CHARACTERIZED AS HONORABLE, WHICH IS THE DESIGNATION MOST READILY UNDERSTOOD AND ACCEPTED BY THE GENERAL PUBLIC. SIGNIFICANT NUMBERS OF VETERANS WILL HAVE THEIR SERVICE CHARACTERIZED AS UNDER HONORABLE CONDITIONS (A CATEGORY NOT WIDELY UNDERSTOOD AND SUBJECT TO MISINTERPRETATION), UNDER OTHER THAN HONORABLE CONDITIONS, OR DISHONORABLE.

TYPE OF CERTIFICATE ISSUED (ITEM 9F)

THE MILITARY DEPARTMENTS HAVE DEVELOPED STANDARD DISCHARGE FORMS WHICH ARE RELATED TO THE CHARACTER OF SERVICE DESIGNATION GIVEN THE INDIVIDUAL. ANYONE FAMILIAR WITH THESE FORMS COULD IDENTIFY THE CHARACTER OF SERVICE EVEN IF THIS INFORMATION WAS NOT SHOWN ON THE SEPARATION FORM. FOR EXAMPLE, THE CITATION DD FORM 260 IDENTIFIES A DISHONORABLE DISCHARGE.

RECORD OF SERVICE (ITEM 13)

TOURS OF SERVICE ARE NORMALLY OF A FIXED TERM AND COMMONLY KNOWN BY THE PUBLIC-AT-LARGE. A RELEASE FROM SERVICE EARLIER THAN THE NORMAL TERM CAN RAISE QUESTIONS ABOUT THE REASONS AND CIRCUMSTANCES OF THE INDIVIDUAL'S EARLY RELEASE.

TIME LOST (ITEM 21)

LOST TIME CONNOTES "BAD TIME" THAT AN INDIVIDUAL HAS SPENT IN THE SERVICE. IT REFLECTS THE INDIVIDUAL'S UNAUTHORIZED ABSENCES, TIME IN CONFINEMENT, AND NONPERFORMANCE OF DUTY BECAUSE OF CIVIL ARREST. REPRESENTS A CLEAR INDICATION TO THE USER OF THE REPORT THAT THE INDIVIDUAL HAS HAD PROBLEMS WHILE IN THE MILITARY SERVICE.

DECORATIONS, MEDALS, BADGES, COMMENDATIONS, CITATIONS, AND CAMPAIGN RIBBONS AWARDED OR AUTHORIZED (ITEM 26)

AN OMISSION OF AN ENTRY CAN ADVERSELY AFFECT AN INDIVIDUAL, BECAUSE MOST SERVICEMEN ARE EXPECTED TO RECEIVE SOME TYPE OF MEDAL OR COMMENDATION. FOR EXAMPLE, A GOOD CONDUCT MEDAL IS GIVEN TO MOST SERVICEMEN WHO HAVE A CLEAN RECORD. THE ABSENCE OF THIS RECOGNITION WOULD INDICATE THAT THE INDIVIDUAL'S PERFORMANCE WAS NOT SATISFACTORY.

DESIGNATED USERS OF REPORT

DOD'S INSTRUCTION ON THE SEPARATION REPORT STATES THAT THE PURPOSE OF THE FORM IS TO PROVIDE THE:

-- MILITARY SERVICES WITH A SOURCE OF INFORMATION ON MILITARY PERSONNEL FOR ADMINISTRATIVE PURPOSES AND FOR MAKING DETERMINATIONS OF ELIGIBILITY FOR ENLISTMENT OR REENLISTMENT.

-- INDIVIDUAL WITH A BRIEF, CLEAR-CUT RECORD OF HIS TERM OF ACTIVE SERVICE WITH THE ARMED FORCES.

-- APPROPRIATE GOVERNMENTAL AGENCIES WITH AN AUTHORITATIVE SOURCE OF INFORMATION REQUIRED IN ADMINISTERING FEDERAL AND STATE LAWS APPLYING TO INDIVIDUALS WHO HAVE BEEN DISCHARGED OR OTHERWISE RELEASED.

DOD'S INSTRUCTION ALSO PROVIDES THAT EACH MILITARY DEPARTMENT IS RESPONSIBLE FOR PRESCRIBING PROCEDURES GOVERNING THE DISTRIBUTION OF THE SEPARATION REPORT: (1) THE ORIGINAL IS TO BE GIVEN TO THE SERVICEMAN, (2) ONE COPY IS TO BE USED AS THE SERVICE RECORD COPY, (3) ONE COPY IS SENT TO THE VA DATA PROCESSING CENTER, AND (4) ONE COPY IS SENT TO THE APPROPRIATE STATE DIRECTOR OF THE SELECTIVE SERVICE SYSTEM. IF THE INDIVIDUAL IS TRANSFERRED TO A VA HOSPITAL, A COPY IS FORWARDED TO THE HOSPITAL WITH HIS MILITARY RECORDS. OTHERWISE, IMPLEMENTING SERVICE REGULATIONS PROVIDE THAT THIS COPY WILL EITHER BE GIVEN TO THE INDIVIDUAL OR PLACED IN HIS SERVICE RECORD BOOK.

THE MILITARY DEPARTMENTS DISTRIBUTE ADDITIONAL COPIES OF THE SEPARATION REPORT AS PERMITTED IN THE DOD INSTRUCTION. THE NAVY PREPARES ONE ADDITIONAL COPY, WHICH IT PLACES IN THE SERVICE RECORD BOOK. THE OTHER SERVICES DISTRIBUTE ADDITIONAL COPIES AS FOLLOWS.

(TABLE OMITTED)

USE OF REPORT BY OFFICIALLY DESIGNATED RECIPIENTS

WE EXAMINED THE USEFULNESS AND NEED FOR THE SEPARATION REPORT FOR EACH DESIGNATED RECIPIENT.

DOD AND MILITARY DEPARTMENTS

THE REPORT SERVES TWO BASIC FUNCTIONS WITHIN DOD AND THE MILITARY DEPARTMENTS: (1) A CONVENIENT SUMMARY RECORD OF AN INDIVIDUAL'S TERM OF MILITARY SERVICE, FROM WHICH ADMINISTRATIVE AND STATISTICAL REPORTS ARE PREPARED AND (2) MILITARY DEPARTMENTS USE IT IN RECRUITING ACTIVITIES TO ASSIST THEM IN IDENTIFYING AND EVALUATING POSSIBLE CANDIDATES FOR REENLISTMENT.

OFFICIALS OF THE AIR FORCE, ARMY, NAVY, AND MARINE CORPS STATED THAT THE REPORT MAKES THE PREPARATION OF ADMINISTRATIVE AND STATISTICAL REPORTS EASIER. THE REPORT IS USED, FOR EXAMPLE, TO COLLECT DATA ON AND IDENTIFY TRENDS IN THE TYPES OF DISCHARGES ISSUED AND SPECIFIC REASONS WHY INDIVIDUALS ARE SEPARATED FROM THE SERVICE. OFFICIALS TOLD US THAT THE ABSENCE OF THE SEPARATION REPORT WOULD NOT PRELUDE ANY NECESSARY REPORTS FROM BEING PREPARED. HOWEVER, THE USE OF THE PRIMARY RECORDS FOR PREPARING OTHER REPORTS WOULD NOT BE AS CONVENIENT AS THE PRESENT SEPARATION DOCUMENT.

THE ARMY, AIR FORCE, AND MARINE CORPS USE THE SEPARATION REPORT IN THEIR RECRUITING ACTIVITIES TO IDENTIFY, ASSESS, AND CONTACT POTENTIAL CANDIDATES FOR REENLISTMENT. THE NAVY USES ANOTHER DOCUMENT, CALLED SEPARATION ORDERS, FOR THIS PURPOSE. IF INITIAL CONTACT EFFORTS ARE UNSUCCESSFUL, THE RECRUITING ACTIVITIES ULTIMATELY DESTROY THEIR COPIES OF THE REPORTS.

THE RECRUITING ACTIVITIES' PRIMARY INTEREST IN SEPARATION REPORTS IS TO IDENTIFY THE REENLISTMENT CODES GIVEN INDIVIDUALS UPON SEPARATION. AS A RESULT OF DOD'S RECENT POLICY CHANGE IN MARCH 1974, REENLISTMENT CODES NO LONGER APPEAR ON THE VETERAN'S COPY OF THE SEPARATION DOCUMENT. ACCORDINGLY, RECRUITING ACTIVITIES NO LONGER RELY ON THE VETERAN TO MAKE THIS INFORMATION AVAILABLE BUT ON THEIR OWN SERVICES' CAPABILITIES TO PROVIDE THIS INFORMATION WHEN NEEDED.

NATIONAL PERSONNEL RECORD CENTER AND ARMY RESERVE COMPONENTS PERSONNEL AND ADMINISTRATION CENTER

THE NATIONAL PERSONNEL RECORD CENTER IS THE FOCAL POINT FOR QUERIES ABOUT AN INDIVIDUAL'S MILITARY SERVICE. THE CENTER, IN ST. LOUIS, MISSOURI, IS THE MILITARY CENTRAL DEPOSITORY FOR PERSONNEL RECORDS AND MAINTAINS MORE THAN 32 MILLION RECORD FILES. IT IS A GENERAL SERVICES ADMINISTRATION ACTIVITY AND IS RESPONSIBLE FOR MOST MILITARY RECORDS MANAGEMENT.

THE ARMY RESERVE COMPONENTS CENTER IS COLOCATED AT THE FACILITY AND IS RESPONSIBLE FOR MAINTAINING THE RECORDS OF ARMY RESERVISTS AND NATIONAL GUARDSMEN. THESE TWO ACTIVITIES ESTIMATED THAT MORE THAN 2 MILLION REQUESTS FOR INFORMATION WILL BE RECEIVED IN FISCAL YEAR 1975 ABOUT FORMER SERVICEMEN.

THE RECORDS MANAGEMENT SYSTEM AT THE NATIONAL PERSONNEL RECORD CENTER IS NOT AUTOMATED, SO RESPONDING TO INQUIRIES FOR INFORMATION REQUIRES A MANUAL SEARCH, RETRIEVAL, AND REVIEW OF THE INDIVIDUAL'S SERVICE RECORD BOOK. THE CENTER'S INSTRUCTION PROVIDES THAT MAXIMUM USE BE MADE OF THE SEPARATION REPORT IN ANSWERING INQUIRIES, UNLESS THE INQUIRER QUESTIONS THE ACCURACY OF THE INFORMATION PROVIDED. CENTER OFFICIALS INFORMED US THAT, IN RESPONDING TO SUCH INQUIRIES, MAXIMUM USE IS MADE OF THE SUMMARY INFORMATION CONTAINED ON THE SEPARATION REPORT AND THAT IT PROVIDES A QUICK REFERENCE DOCUMENT. THEY SAID THEIR OPERATIONS WOULD BE HAMPERED AND MORE COSTLY IF SUCH A REPORT WAS NOT AVAILABLE. ALTHOUGH STATISTICAL RECORDS ARE NOT MAINTAINED, OFFICIALS SAID THAT MANY INQUIRIES INVOLVE REQUESTS FOR VERIFICATION OF MILITARY SERVICE, THE LAST KNOWN LOCATION OF VETERANS, INFORMATION ON DECORATIONS AND AWARDS, AND REQUESTS FOR COPIES OF THE SEPARATION REPORTS.

THE ARMY RESERVE COMPONENTS CENTER IS AN AUTOMATED SYSTEM AND IT MAINTAINS APPROXIMATELY 3 MILLION RECORD FILES. COMPONENTS CENTER OFFICIALS TOLD US THEY DO NOT USE THE SEPARATION REPORT EXTENSIVELY IN THEIR OPERATIONS. THEY ADVISED US THAT 374,000 REQUESTS FOR INFORMATION WERE RECEIVED IN CALENDAR YEAR 1973, OF WHICH AN ESTIMATED 31,000 WERE FOR COPIES OF SEPARATION REPORTS.

VA

SEPARATION REPORTS ARE USED FOR ESTABLISHING ELIGIBILITY IN A WIDE RANGE OF VETERANS' BENEFIT PROGRAMS, INCLUDING EDUCATIONAL ASSISTANCE, HOME LOAN GUARANTEES, DISABILITY PENSIONS, AND MORTGAGE PROTECTION LIFE INSURANCE. BEFORE OCTOBER 1973, THE SEPARATION REPORT FURNISHED TO THE VA DATA PROCESSING CENTER WAS USED AS THE BASIS FOR MAILING LETTERS TO ELIGIBLE VETERANS INFORMING THEM OF THEIR ENTITLEMENT TO BENEFITS AND ENCOURAGING THEM TO SEEK ASSISTANCE AT THE NEAREST VA FACILITY. THE VETERAN WAS REQUIRED TO FURNISH A COPY OF HIS SEPARATION REPORT TO INITIATE A CLAIM.

STARTING IN OCTOBER 1973, VA IMPLEMENTED A NEW SYSTEM, ALSO USING THE SEPARATION REPORT. ELIGIBLE VETERANS ARE SENT AN ELIGIBILITY PACKAGE FROM THE DATA PROCESSING CENTER SPECIFICALLY IDENTIFYING THEIR ENTITLEMENT TO EDUCATIONAL ASSISTANCE AND LOAN GUARANTEES. UNDER THIS SYSTEM, MOST VETERANS ARE NO LONGER REQUIRED TO FURNISH A SEPARATION REPORT FOR PROVING ELIGIBILITY, AND THEY CAN INITIATE CLAIMS AT THE CLOSEST VA FACILITY ON THE BASIS OF THEIR ELIGIBILITY PACKAGES. INDIVIDUALS WHO HAVE NOT RECEIVED ELIGIBILITY PACKAGES OR HAVE LOST THEM, HOWEVER ARE REQUIRED TO PRODUCE A SEPARATION REPORT AS THE FIRST STEP IN DETERMINING ENTITLEMENT TO BENEFITS.

TO BE AUTOMATICALLY ELIGIBLE FOR VETERANS' BENEFITS INDIVIDUALS MUST HAVE SERVED EITHER HONORABLE OR UNDER HONORABLE CONDITIONS AND HAVE SPENT AT LEAST 180 DAYS ON CONTINUOUS ACTIVE DUTY. VETERANS WHOSE SERVICE HAS BEEN CHARACTERIZED AS LESS THAN HONORABLE-- I.E., HOLDERS OF UNDESIRABLE OR BAD CONDUCT DISCHARGES IN THE CASE OF ENLISTED PERSONNEL-- MAY OR MAY NOT BE ENTITLED TO BENEFITS, DEPENDING ON VA'S MORE DETAILED REVIEW OF THE CIRCUMSTANCES SURROUNDING THE CHARACTERIZATIONS.

SELECTIVE SERVICE SYSTEM

SEPARATION REPORTS ARE USED TO DETERMINE THE RECLASSIFICATION STATUS OF FORMER SERVICEMEN AND TO ESTABLISH THEIR ELIGIBILITY FOR FURTHER OBLIGATION IN THE MILITARY. SELECTIVE SERVICE SYSTEM OFFICIALS TOLD US THAT SEPARATION REPORTS ARE THE SOLE BASIS FOR THESE DETERMINATIONS AND THAT CHARACTER OF SERVICE, TIME SPENT IN SERVICE, AND REENLISTMENT CODES ARE OF PARTICULAR INTEREST.

THE SYSTEM USES THE REPORT FOR INTERNAL PURPOSES AND DOES NOT INTERFACE WITH INDIVIDUAL VETERANS. ITS POLICY, AS DISCUSSED LATER, PROHIBITS THE RELEASE OF INFORMATION IN AN INDIVIDUAL'S FILE TO OTHERS WITHOUT THE INDIVIDUAL'S WRITTEN CONSENT.

GAO'S SURVEY OF THE USE OF REPORT BY NONDESIGNATED USERS

TO IDENTIFY OCCASIONS WHEN VETERANS MIGHT BE REQUIRED TO USE SEPARATION REPORTS, WE INTERVIEWED, USING A QUESTIONNAIRE, 278 NON FEDERAL ORGANIZATIONS, A NUMBER OF STATE EMPLOYMENT OFFICES, SELECTED FEDERAL AGENCIES, AND 23 VETERAN SERVICE ORGANIZATIONS TO DETERMINE THE (1) EXTENT THESE ORGANIZATIONS USED THE REPORT, (2) REASONS FOR USE, AND (3) PARTICULAR TYPE OF MILITARY INFORMATION OF SPECIFIC INTEREST. IF A SEPARATION REPORT REFLECTED ADVERSE INFORMATION ABOUT AN INDIVIDUAL, THE RESPONDENTS WERE ASKED TO RESPOND TO THE IMPLICATIONS FOR THE VETERAN.

THE 278 NON-FEDERAL ORGANIZATIONS WERE CONSIDERED TO BE THE TYPE OF ORGANIZATION HAVING SIGNIFICANCE TO VETERANS IN THEIR TRANSITIONS BACK TO CIVILIAN LIFE. OUR SELECTION INCLUDED PROSPECTIVE EMPLOYERS, FINANCIAL AND EDUCATIONAL INSTITUTIONS, UNIONS, INSURANCE AND BONDING COMPANIES, AND PROFESSIONAL AND VOCATIONAL LICENSING BOARDS. THE EXTENT THAT THE 278 ORGANIZATIONS USED THE SEPARATION REPORT IS SHOWN BELOW.

(TABLE OMITTED)

PROSPECTIVE EMPLOYERS

THE MOST PREVALENT AND POTENTIALLY ADVERSE USE OF THE SEPARATION REPORT OCCURS IN DEALINGS WITH PROSPECTIVE EMPLOYERS. OF THE 111 PROSPECTIVE EMPLOYERS-- INCLUDING LOCAL, COUNTY, AND STATE AGENCIES-- 63 REQUIRED VETERANS TO PRODUCE SEPARATION REPORTS AS PART OF THE JOB APPLICATION PROCESS. ACCORDING TO A NUMBER OF PROSPECTIVE EMPLOYERS, A VETERAN'S FAILURE TO DO SO WOULD CAUSE HIS BEING ELIMINATED FROM FURTHER EMPLOYMENT CONSIDERATION. TO THESE PROSPECTIVE EMPLOYERS THE SEPARATION REPORT PROVIDED INFORMATION ON WHICH TO JUDGE THE VETERANS' CHARACTERS AND WORK SKILLS.

SPECIFICALLY, THE RESPONSES DISCLOSED THAT:

-- ALL 111 PROSPECTIVE EMPLOYERS ROUTINELY ASK FOR MILITARY DATA ON THEIR EMPLOYMENT APPLICATIONS. INFORMATION TYPICALLY REQUESTED INVOLVES THE PERIOD OF MILITARY SERVICE, RANK ATTAINED, BRANCH OF SERVICE, TYPE OF DISCHARGE, AND CHARACTER OF SERVICE.

-- 63 EMPLOYERS (57 PERCENT OF THOSE SURVEYED) REQUIRED THE VETERAN TO PRODUCE HIS SEPARATION REPORT FOR EXAMINATION. THESE EMPLOYERS STATED THAT THE REPORT WAS NECESSARY TO VERIFY THE INFORMATION ON THE EMPLOYMENT APPLICATION, OBTAIN INSIGHT INTO THE INDIVIDUAL'S CHARACTER, AND IDENTIFY THE INDIVIDUAL'S TRAINING AND WORK EXPERIENCE RECEIVED IN THE SERVICE.

-- 31 EMPLOYERS WHO REQUIRED THE REPORT STATED THAT A VETERAN'S FAILURE TO MAKE IT AVAILABLE WOULD RESULT IN HIS BEING ELIMINATED FROM FURTHER EMPLOYMENT CONSIDERATION. SEVENTEEN OTHERS STATED THAT REFUSAL WOULD NOT AUTOMATICALLY BAR EMPLOYMENT; HOWEVER, THEY WOULD SEEK ALTERNATIVE WAYS OF OBTAINING THIS INFORMATION.

-- USERS OF THE REPORT WOULD NOT ARBITRARILY ELIMINATE INDIVIDUALS FROM FURTHER EMPLOYMENT CONSIDERATION WHO HAD NOT PERFORMED WELL IN THE MILITARY. THEY WOULD ATTEMPT TO DETERMINE THE CIRCUMSTANCES SURROUNDING THE INDIVIDUAL'S CHARACTER OF SERVICE AND JUDGE EACH CASE ON ITS OWN MERITS. MOST ACKNOWLEDGED, HOWEVER, THAT VETERANS WHO HAD NOT DONE WELL IN THE MILITARY WOULD FACE DIFFICULTY IN OBTAINING EMPLOYMENT.

-- GENERALLY, USERS OF THE REPORT STATED THEY WOULD NOT LIKE TO SEE ANY INFORMATION DELETED OR REMOVED FROM THE FORM. SOME FELT THAT IT DID NOT ADEQUATELY TREAT OR DESCRIBE THE INDIVIDUAL'S WORK EXPERIENCE IN THE MILITARY, JOB TRAINING, OR EDUCATION RECEIVED IN THE SERVICE.

EMPLOYMENT PROBLEMS CONFRONTING VETERANS WHO HAD NOT DONE WELL IN THE MILITARY WERE REINFORCED BY THE COMMENTS OF GOVERNMENT AND PRIVATE AGENCIES PROVIDING ASSISTANCE TO VETERANS. WE WERE TOLD THAT MANY EMPLOYERS WOULD NOT HIRE AN INDIVIDUAL WHOSE MILITARY SERVICE WAS NOT CHARACTERIZED AS HONORABLE. EVEN THOSE WHO HAVE SERVED "UNDER HONORABLE CONDITIONS" FACE EMPLOYMENT DISCRIMINATION. THE AGENCIES ADVISED US THAT THEY (1) SIMPLY DO NOT REFER HOLDERS OF ADVERSE DISCHARGES TO CERTAIN EMPLOYERS, BECAUSE IT IS CONSIDERED A WASTE OF TIME FOR THE VETERANS, PROSPECTIVE EMPLOYERS, AND PLACEMENT OFFICES, (2) ENCOURAGE VETERANS TO SEEK UPGRADING OF THEIR DISCHARGES, AND (3) HAVE OCCASIONALLY ADVISED VETERANS HAVING SHORT PERIODS OF TIME IN THE SERVICE NOT TO REFLECT THEIR SERVICE ON EMPLOYMENT APPLICATION FORMS. THE AGENCIES ATTEMPT TO EMPHASIZE ONLY THE POSITIVE QUALITIES THAT INDIVIDUALS COULD BRING TO PROSPECTIVE EMPLOYERS.

THE SURVEY RESULTS INDICATED THAT THE SEPARATION REPORT GIVES EMPLOYERS CONSIDERABLY MORE INFORMATION THAN CIVILIAN EMPLOYERS WOULD PROVIDE ON THEIR FORMER EMPLOYEES. NORMALLY, THE EMPLOYERS LIMIT INFORMATION PROVIDED TO OTHERS TO TITLE OR POSITION HELD, PERIOD OF EMPLOYMENT, AND SALARY RECEIVED.

A NUMBER OF FIRMS SPECIFICALLY STATED THAT DATA ON THEIR EMPLOYEES IS CONSIDERED CONFIDENTIAL AND NOT SUBJECT TO DISCLOSURE OUTSIDE THE COMPANY. IN ONE OF THE METROPOLITAN AREAS VISITED, WE INTERVIEWED 21 CIVILIAN EMPLOYERS ABOUT THEIR POLICY OF INFORMING OTHER EMPLOYERS OF REASONS WHY INDIVIDUALS LEFT THEIR EMPLOY. ONLY 10 PERCENT SAID THEY WOULD MAKE THIS INFORMATION AVAILABLE.

(TABLE OMITTED)

IN SUMMARY, THE MAJORITY OF THE EMPLOYERS SAID THAT PERSONNEL INFORMATION WOULD BE RELEASED ONLY WITH THE CONSENT OF THE FORMER EMPLOYEE. IN THIS RESPECT, BOTH DOD AND CIVILIAN EMPLOYER PRACTICES WERE SIMILAR. THE PRACTICE OF ROUTINE DISTRIBUTION OF A SEPARATION REPORT IS UNIQUE TO DOD. CIVILIAN EMPLOYERS DO NOT PROVIDE THIS TYPE OF INFORMATION UNLESS SPECIFICALLY REQUESTED TO DO SO BY THEIR FORMER EMPLOYEES.

FINANCIAL INSTITUTIONS

BANKS, SAVINGS AND LOAN ASSOCIATIONS, CREDIT UNIONS, ETC., DO NOT USE THE SEPARATION REPORT EXTENSIVELY IN DETERMINING WHETHER CREDIT SHOULD BE EXTENDED TO VETERANS. OF THE 30 INSTITUTIONS INTERVIEWED, 25 STATED THAT THEY DID NOT REQUIRE THE REPORT FROM A VETERAN.

THE FIVE INSTITUTIONS REQUIRING THE SEPARATION REPORT GENERALLY USED IT TO AUTHENTICATE THE WORK EXPERIENCES OF RECENTLY SEPARATED VETERANS OR TO ASSIST THE VETERANS IN INITIATING CLAIMS FOR VA HOME LOAN GUARANTEES. THEY DID NOT EXPRESS A STRONG INTEREST IN MILITARY PERFORMANCE OR TYPE OF DISCHARGE RECEIVED. THEY WERE PRIMARILY INTERESTED IN THE VETERANS' ABILITY TO REPAY ANY LOANS MADE AND PROSPECTS FOR CONTINUITY AND STABILITY OF EMPLOYMENT.

INDUSTRIAL AND CRAFT UNIONS

OF THE 20 INDUSTRIAL AND CRAFT UNIONS INTERVIEWED, ONLY 4 UNIONS USED THE SEPARATION REPORT AND THEN ONLY FOR SPECIAL CIRCUMSTANCES AND NOT AS A ROUTINE REQUIREMENT.

-- THREE UNIONS LIMITED MEMBERSHIP ENTRY TO PERSONS UNDER A SPECIFIED AGE. THE AGE REQUIREMENT CAN BE EXCEEDED, HOWEVER, FOR EACH YEAR AN INDIVIDUAL SPENDS IN THE MILITARY, AND THE SEPARATION REPORT IS THEN USED TO VERIFY TOTAL MILITARY TIME. OFFICIALS OF THESE UNIONS INFORMED US THAT THE INDIVIDUAL'S TYPE OF DISCHARGE WAS NOT CONSIDERED IN THE MEMBERSHIP PROCESS.

-- ONE UNION WAIVED THE MEMBERSHIP INITIATION FEE FOR INDIVIDUALS WHO RECEIVED HONORABLE DISCHARGES. NONVETERANS AND VETERANS WITH OTHER THAN HONORABLE DISCHARGES ARE REQUIRED TO PAY THE INITIATION FEE. THE SEPARATION REPORT IS USED TO ESTABLISH THE TYPE OF DISCHARGE RECEIVED AND WHETHER A WAIVER OF THE FEE IS APPROPRIATE.

EDUCATIONAL INSTITUTIONS

OF THE 33 COLLEGES AND UNIVERSITIES AND 27 MEDICAL OR LAW SCHOOLS SURVEYED, ONLY 7 INSTITUTIONS ROUTINELY REQUIRED VETERANS TO PROVIDE SEPARATION DOCUMENTS, AND ONLY 5 OCCASIONALLY REQUIRED IT.

EACH INSTITUTION SURVEYED RESPONDED THAT ALL CANDIDATES APPLYING FOR ADMISSION WERE ASKED WHETHER MILITARY SERVICE HAD BEEN PERFORMED. THE SEVEN INSTITUTIONS ROUTINELY REQUIRING THE SEPARATION REPORT DID SO TO VALIDATE THE ACCURACY OF THE INFORMATION RECORDED ON THE ADMISSIONS FORM. THE FIVE OCCASIONAL USERS REQUIRED THE REPORT ONLY WHEN AN INDIVIDUAL'S APPLICATION IDENTIFIED A POTENTIAL PROBLEM, SUCH AS A DISHONORABLE DISCHARGE.

THE TYPE OF DISCHARGE RECEIVED BY AN INDIVIDUAL COULD HAVE AN ADVERSE IMPACT ON THE ADMISSION OF SOME VETERANS. FOR EXAMPLE, TWO COLLEGES AND UNIVERSITIES AND SEVEN MEDICAL AND LAW SCHOOLS STATED THAT ADVERSE MILITARY INFORMATION COULD AFFECT THEIR ACCEPTANCE OF AN INDIVIDUAL IF THE TYPE OF DISCHARGE COULD AFFECT HIS ABILITY TO OBTAIN A LICENSE TO PRACTICE LAW OR MEDICINE.

INSURANCE AND BONDING COMPANIES.

FIFTEEN INSURANCE COMPANIES AND 13 BONDING COMPANIES WERE SURVEYED. SEVEN INSURANCE COMPANIES REQUESTED THE SEPARATION REPORT ONLY IF THE VETERAN WAS CONVERTING HIS SERVICEMAN GROUP LIFE INSURANCE POLICY TO A COMMERCIAL POLICY. SINCE THE VETERAN MUST CONVERT HIS POLICY WITHIN 120 DAYS OF RELEASE OR DISCHARGE, THE COMPANIES USE THE SEPARATION FORM TO VERIFY THIS TIME RESTRICTION. ALL COMPANIES CONTACTED RESPONDED THAT AN ADVERSE DISCHARGE WOULD NOT AFFECT AN INDIVIDUAL'S INSURABILITY.

OF THE 13 BONDING COMPANIES CONTACTED, 1 INDICATED THAT A SEPARATION REPORT MIGHT BE REQUESTED IF THE INDIVIDUAL BEING BONDED WAS RECENTLY DISCHARGED. WITH REGARD TO AN ADVERSE DISCHARGE ON BONDABILITY, ONLY ONE COMPANY INDICATED THAT IT WOULD AFFECT BONDABILITY AND THIS COMPANY RESPONDED THAT THE CIRCUMSTANCE SURROUNDING THE DISCHARGE WOULD BE EXAMINED BEFORE A DECISION WAS MADE.

PROFESSIONAL AND OCCUPATIONAL LICENSING BOARDS AND OTHER LICENSING AGENCIES

OUR SURVEY OF 29 PROFESSIONAL AND OCCUPATIONAL LICENSING BOARDS AND AGENCIES DISCLOSED THAT 11 BOARDS USED THE SEPARATION REPORT IN THEIR EXAMINATION AND LICENSING PROCESS. THESE BOARDS WERE INVOLVED IN LICENSING THE PROFESSIONS OF DOCTORS, LAWYERS, CERTIFIED PUBLIC ACCOUNTANTS, AND TEACHERS. GENERALLY, BOARD OFFICIALS STATED THAT CANDIDATES ADMITTED TO THESE PROFESSIONS WOULD OCCUPY POSITIONS OF PUBLIC TRUST AND THE SEPARATION REPORT WAS USED AS A CHARACTER REFERENCE.

THE 18 BOARDS NOT USING THE SEPARATION REPORT WERE INVOLVED IN LICENSING SUCH ACTIVITIES AS REAL ESTATE SALESMEN AND BROKERS, ARCHITECTS, POLYGRAPH OPERATORS, BARBERS, AND NURSING HOME ADMINISTRATORS.

VETERAN SERVICE ORGANIZATIONS

SUCH ORGANIZATIONS AS THE AMERICAN LEGION, VETERANS OF FOREIGN WARS, AND AMERICAN VETERANS COMMITTEE TRADITIONALLY AID FORMER SERVICE MEMBERS IN OBTAINING VETERANS BENEFITS, ATTEMPTING TO UPGRADE DISCHARGE CERTIFICATES, COUNSELING, AND OTHER AREAS OF INTEREST TO VETERANS. MOST OF THE 23 ORGANIZATIONS INCLUDED IN OUR SURVEY EXPRESSED THE VIEW THAT THE SEPARATION REPORT WAS ESSENTIAL TO THEIR PROGRAMS OF VETERANS ASSISTANCE. THE INFORMATION ENABLES THEM TO DETERMINE WHAT ACTION IS NEEDED TO START THEIR ASSISTANCE EFFORTS.

MIXED VIEWS WERE EXPRESSED ON THE QUESTION OF REQUIRING VETERANS TO PROVIDE SEPARATION REPORTS TO PROSPECTIVE EMPLOYERS; 15 OFFICIALS SAID THAT VETERANS SHOULD NOT BE REQUIRED TO PROVIDE IT, AND 8 SAW NOTHING IMPROPER ABOUT EMPLOYERS ASKING FOR IT.

STATE EMPLOYMENT SERVICE OFFICE

VETERANS ARE REQUIRED TO PROVIDE SEPARATION REPORTS IN SEEKING UNEMPLOYMENT COMPENSATION, JOB COUNSELING, AND EMPLOYMENT ASSISTANCE OF STATE EMPLOYMENT SERVICE OFFICES FUNDED BY THE DEPARTMENT OF LABOR. THE REPORT IS USED TO DETERMINE IF THE VETERAN IS ELIGIBLE FOR ASSISTANCE AND TO EXPEDITE THE ELIGIBILITY DETERMINATIONS PROCESS BECAUSE THE DEPARTMENT OF LABOR AND STATE EMPLOYMENT SERVICE OFFICES DO NOT RECEIVE THE SEPARATION REPORT.

STATES PROVIDE UNEMPLOYMENT COMPENSATION TO RECENTLY SEPARATED VETERANS FOR A LIMITED PERIOD OF TIME WHILE THE VETERANS ARE SEARCHING FOR EMPLOYMENT. TO BE AUTOMATICALLY ELIGIBLE, A VETERAN MUST HAVE SERVED AT LEAST 90 DAYS OF CONTINUOUS ACTIVE DUTY AND HAVE HIS SERVICE CHARACTERIZED AS HONORABLE OR UNDER HONORABLE CONDITIONS. VETERANS WHOSE SERVICE HAS BEEN CHARACTERIZED AS DISHONORABLE ARE AUTOMATICALLY INELIGIBLE, AND THOSE WHO HAVE SERVED UNDER LESS THAN HONORABLE CONDITIONS ARE REFERRED TO THE VA FOR ELIGIBILITY DETERMINATIONS.

JOB COUNSELING AND EMPLOYMENT PLACEMENT PROGRAMS GIVE VETERANS A PREFERENCE OVER OTHERS WHEN USING EMPLOYMENT SERVICES. VETERANS WITH DISHONORABLE DISCHARGES ARE NOT ELIGIBLE FOR PREFERENTIAL TREATMENT. STATE EMPLOYMENT SERVICE OFFICES USE THE SEPARATION REPORT TO ASSIST THEM IN MAKING THIS DETERMINATION.

FEDERAL AGENCIES

VETERANS WHO HAVE SERVED OTHER THAN DISHONORABLY ARE ENTITLED TO 5 OR 10 VETERANS' PREFERENCE POINTS WHEN APPLYING FOR FEDERAL EMPLOYMENT. FORMER FEDERAL EMPLOYEES, AFTER DISCHARGE FROM MILITARY SERVICE, CAN ASSERT REEMPLOYMENT RIGHTS IF THEY HAVE SERVED UNDER HONORABLE CONDITIONS.

TRADITIONALLY, AGENCIES HAVE REQUIRED THE SEPARATION REPORT AS EVIDENCE OF CHARACTER OF SERVICE. IN THE ABSENCE OF THE REPORT, FEDERAL AGENCIES WILL ACCEPT THE DISCHARGE CERTIFICATE TO AUTHENTICATE THE VETERAN'S RIGHT TO PREFERENTIAL TREATMENT OR REEMPLOYMENT.

CONTROLS OVER ACCESS AND RELEASE OF REPORTS

OFFICIALLY DESIGNATED USERS OF THE SEPARATION REPORT HAVE ESTABLISHED POLICIES GOVERNING ITS UNAUTHORIZED RELEASE. GENERALLY, THESE POLICIES FOLLOW TITLE 5 OF THE U.S.C. SECTION 552, WHICH EXEMPTS PERSONNEL RECORDS FROM PUBLIC DISCLOSURE. FEDERAL GOVERNMENT DEPARTMENTS AND AGENCIES HAVE ACCESS TO PERSONNEL RECORDS FOR OFFICIAL BUSINESS. THE ESTABLISHED POLICIES FOLLOW.

DOD

THE MILITARY DEPARTMENTS ARE PRECLUDED FROM ANSWERING INQUIRIES ABOUT AN INDIVIDUAL'S MILITARY SERVICE AND FROM PROVIDING COPIES OF THE SEPARATION REPORT TO ANYONE OTHER THAN THE INDIVIDUAL INVOLVED WITHOUT HIS PRIOR WRITTEN CONSENT.

MAJOR DEPOSITORIES FOR MILITARY PERSONNEL RECORDS

BOTH THE NATIONAL PERSONNEL RECORD CENTER AND ARMY RESERVE COMPONENTS CENTER HAVE ESTABLISHED FORMAL PROCEDURES PRECLUDING UNAUTHORIZED RELEASE OF SEPARATION REPORT DATA. THESE PROCEDURES ARE GENERALLY DESIGNED TO INSURE THAT ALL REQUESTS FOR PERSONNEL DATA INVOLVING A VETERAN'S SUITABILITY FOR EMPLOYMENT CANNOT BE RELEASED WITHOUT THE INDIVIDUAL'S WRITTEN CONSENT. ONLY FEDERAL AGENCIES CONDUCTING OFFICIALLY AUTHORIZED BUSINESS, SUCH AS SECURITY CLEARANCES AND INVESTIGATIONS, CAN OBTAIN ACCESS TO PERSONNEL FILES WITHOUT THE VETERAN'S FORMAL CONSENT. ALL OTHER REQUESTORS OF INFORMATION, STATE AND LOCAL GOVERNMENTS, PRIVATE COMPANIES AND CITIZENS, REQUIRE SPECIFIC WRITTEN PERMISSION FROM THE INDIVIDUAL.

VA

VA OFFICIALS TOLD US THAT THE CONFIDENTIALITY OF THE SEPARATION REPORT IS CLOSELY PROTECTED. THE REPORT MAINTAINED IN THE CLAIM FILE AT THE REGIONAL OFFICES (THOSE OBTAINED FROM THE VETERAN) IS RELEASABLE ONLY TO THE VETERAN OR TO AUTHORIZED GOVERNMENT AGENCIES. THE SEPARATION REPORTS SENT DIRECTLY TO VA'S DATA PROCESSING CENTER ARE SIMILARLY SAFEGUARDED AND DESTROYED WITHIN A 2-YEAR PERIOD.

SELECTIVE SERVICE SYSTEM.

OFFICIALS TOLD US THAT INFORMATION FROM THE SEPARATION REPORT IS RELEASED ONLY WITH THE WRITTEN CONSENT OF THE INDIVIDUAL INVOLVED. THE SYSTEM CONSIDERS ONLY AN INDIVIDUAL'S DRAFT CLASSIFICATION PUBLIC INFORMATION AND RELEASABLE. CONCLUSIONS

DOD DEVELOPED A STANDARD SEPARATION REPORT TO SERVE ADMINISTRATIVE NEEDS. ITS ORIGIN EVOLVED FROM THE PRACTICE OF CHARACTERIZING AN INDIVIDUAL'S MILITARY SERVICE AND DESCRIBING IT ON A DISCHARGE CERTIFICATE.

THE SEPARATION REPORT IS USED BY

-- DOD AND THE MILITARY DEPARTMENTS TO PREPARE ADMINISTRATIVE AND STATISTICAL REPORTS,

-- ARMY AND AIR FORCE IN RECRUITING ACTIVITIES, -- NATIONAL PERSONNEL RECORD CENTER AND ARMY RESERVE COMPONENTS CENTER TO RESPOND TO INQUIRIES AND REQUESTS FOR MILITARY SERVICE INFORMATION.

-- VA IN IDENTIFYING AND ADVISING VETERANS OF ELIGIBILITY FOR BENEFITS, AND

-- SELECTIVE SERVICE SYSTEM IN RECLASSIFYING THE MILITARY STATUS OF FORMER SERVICEMEN.

THE SEPARATION REPORT CURRENTLY MEETS THESE INFORMATIONAL NEEDS IN AN ADMINISTRATIVELY CONVENIENT WAY. HOWEVER, EVEN THOUGH THESE AGENCIES NEED PERSONNEL INFORMATION TO PERFORM THEIR OFFICIAL BUSINESS, THE SEPARATION REPORT DOES NOT HAVE TO BE THE VEHICLE FOR PROVIDING IT. ON THE OTHER HAND, SINCE ACCESS TO THE REPORT IS SAFEGUARDED AND CONTROLLED BY OFFICIALLY DESIGNATED USERS, THE PROBLEM WITH THE SEPARATION REPORT IS NOT IN THEIR USE OF IT.

THE PROBLEM INVOLVES THE REPORT'S ROUTINE DISTRIBUTION TO VETERANS. THE MAJORITY OF INDIVIDUALS WHO SERVE IN THE MILITARY DO WELL, AND THE SEPARATION REPORT THEY RECEIVE DOES NOT ADVERSELY AFFECT THEM IN CIVILIAN LIFE. HOWEVER, THOSE WHO HAVE NOT PERFORMED WELL AND WHOSE SEPARATION REPORT REFLECTS THIS CIRCUMSTANCE CAN BE ADVERSELY AFFECTED, PARTICULARLY IN SEEKING CIVILIAN EMPLOYMENT.

DOD HAS STATED THAT IT IS NOT ITS INTENTION TO HAVE FORMER SERVICE MEMBERS DISCRIMINATED AGAINST IN CIVILIAN LIFE BECAUSE OF INFORMATION RECORDED ON THE SEPARATION REPORT. DOD ACTION IN MARCH 1974 TO ELIMINATE SPNS AND REENLISTMENT CODES FROM THE SEPARATION DOCUMENT REINFORCED THIS INTENTION AND REMOVED TWO HIGHLY VISIBLE, WIDELY CRITICIZED DATA ITEMS. DOD'S ACTION DID NOT, HOWEVER, COMPLETELY ELIMINATE ALL POTENTIALLY ADVERSE INFORMATION ON THE FORM OR MAKE THE SEPARATION REPORT BENEFICIAL TO FORMER SERVICEMEN. IF DOD INTENDS TO ELIMINATE DISCRIMINATION AGAINST FORMER SERVICE MEMBERS, THEN IT SHOULD NO LONGER MAKE ROUTINE DISTRIBUTION TO EACH INDIVIDUAL AT TIME OF SEPARATION FROM SERVICE.

DOD SHOULD CONSIDER ALTERNATIVE WAYS OF GETTING INFORMATION TO THE AGENCIES AND INDIVIDUALS WHO NEED IT. WE BELIEVE THE SEPARATION REPORT WOULD NOT BE NEEDED BY VETERANS IF:

-- THE VA ELIGIBILITY SYSTEM WAS EXPANDED TO PROVIDE ALL VETERANS WITH INFORMATION CONCERNING THEIR ELIGIBILITY FOR VETERANS BENEFITS.

-- THE NATIONAL PERSONNEL RECORD CENTER AND ARMY RESERVE COMPONENTS CENTER WERE REQUIRED TO PROVIDE TIMELY RESPONSES TO INQUIRIES.

OUR SURVEY RESULTS SHOWED THAT AN ALTERNATIVE TO THE SEPARATION REPORT, WHICH WOULD BENEFIT ALL VETERANS SEEKING CIVILIAN EMPLOYMENT, WOULD BE A DOCUMENT DESCRIBING THE INDIVIDUAL'S WORK EXPERIENCE, TRAINING, AND EDUCATION. THIS WOULD CONFORM TO THE TYPE OF DATA NORMALLY EXCHANGED BY CIVILIAN EMPLOYERS.

RECOMMENDATIONS

WE RECOMMEND THAT THE SECRETARY OF DEFENSE:

-- ELIMINATE THE ROUTINE DISTRIBUTION OF THE SEPARATION REPORT TO ALL INDIVIDUALS RELEASED FROM SERVICE AND MAKE IT AVAILABLE ONLY ON THE WRITTEN REQUEST OF THE INDIVIDUAL INVOLVED.

-- DEVISE ALTERNATIVE METHODS OF PROVIDING NEEDED INFORMATION TO VETERANS AND GOVERNMENT AGENCIES IN ADMINISTERING BENEFITS TO VETERANS.

-- PROVIDE VETERANS WITH A DOCUMENT DESCRIBING THEIR WORK EXPERIENCE, TRAINING, AND EDUCATION WHICH WOULD ASSIST THEM IN SEEKING CIVILIAN EMPLOYMENT.

APPENDIX II

MR. ELMER B. STAATS:

COMPTROLLER GENERAL OF THE UNITED STATES

GENERAL ACCOUNTING OFFICE BUILDING

441 G STREET, N.W.

WASHINGTON, D.C. 20548

OVER THE PAST TWO YEARS I HAVE BECOME INCREASINGLY CONCERNED ABOUT PRACTICES WHICH HAVE DEVELOPED WITHIN THE FEDERAL GOVERNMENT AND OUTSIDE OF IT WITH RESPECT TO THE USE OF INFORMATION RECORDED ON THE "DD FORM 214- - REPORT OF TRANSFER OR DISCHARGE" GIVEN MILITARY PERSONNEL UPON THEIR TRANSFER, RELEASE, OR DISCHARGE. ON THIS FORM IS RECORDED INFORMATION WHICH CAN BE DEROGATORY AND THUS INJURIOUS TO A VETERAN SEEKING CIVILIAN EMPLOYMENT OR OTHER BENEFITS.

THERE ARE INDICATIONS THAT OVER THE YEARS PROSPECTIVE EMPLOYERS, LAW ENFORCEMENT AGENCIES, LENDERS, INSURANCE COMPANIES, VOCATIONAL AND PROFESSIONAL ORGANIZATIONS, AND OTHERS HAVE BECOME ACCUSTOMED TO ASKING VETERANS TO PRESENT THEIR DD FORM 214 FOR EXAMINATION OR TO PROVIDE FACSIMILE COPIES OF THE FORM AS A CONDITION TO OBTAINING EMPLOYMENT OR OTHER BENEFITS. SOME OF THE DATA ON THE FORM ARE ENTERED BY LETTER OR NUMBER CODE, SUCH AS SEPARATION PROGRAM NUMBERS (SPN'S) DENOTING REASON FOR DISCHARGE AND RE-ENLISTMENT (RE) CODES INDICATING WHETHER AN INDIVIDUAL SHOULD BE RE-ENLISTED ON THE BASIS OF HIS PAST MILITARY SERVICE. ALTHOUGH CODED, THESE DATA ARE EASILY TRANSLATED BY INDIVIDUALS AND ORGANIZATIONS WHO OVER THE YEARS HAVE BECOME SOPHISTICATED ABOUT THEIR MEANINGS.

THE DEPARTMENT OF DEFENSE, WHILE ACKNOWLEDGING THAT THE USE OF THESE CODES AND OTHER INFORMATION ON THE DD FORM 214 CAN BE INJURIOUS TO SOME VETERANS, CONTENDS THAT ON THE WHOLE THE DOCUMENT IS MORE BENEFICIAL THAN HARMFUL TO THE VAST MAJORITY OF INDIVIDUALS WHO HAVE LEFT MILITARY SERVICE WITH UNBLEMISHED RECORDS. WHAT IS NOT CLEAR, HOWEVER, IS THE UTILITY OF CERTAIN DATA, PARTICULARLY THE SPN CODE, TO THE DEPARTMENT OF DEFENSE AND TO VARIOUS OTHER OFFICIALLY DESIGNATED RECIPIENTS OF AN INDIVIDUAL'S DD FORM 214 SUCH AS THE VETERANS ADMINISTRATION.

SEVERAL OTHER MATTERS RELATED TO THE DD FORM 214 ARE EQUALLY UNCLEAR. ONE QUESTION ARISES, FOR EXAMPLE, AS TO WHETHER THE USE OF CERTAIN SPN CODES SUCH AS THAT DENOTING DRUG ABUSE CONFLICTS WITH FEDERAL OR STATE STATUTES, REGULATIONS, OR POLICIES, AND WHETHER THE USE OF THESE AND OTHER CODES VIOLATES STATUTES OR REGULATIONS GOVERNING THE CONFIDENTIALITY OF MEDICAL RECORDS, OR CONFLICTS WITH FEDERAL AND STATE LAWS GOVERNING THE ACQUISITION BY CREDIT AGENCIES, LENDING AGENCIES, AND INSURANCE COMPANIES OF DEROGATORY INFORMATION AND THE USES TO WHICH SUCH MATERIAL MAY BE PUT. A FURTHER QUESTION ARISES AS TO WHAT REMEDIES MAY BE AVAILABLE TO THE VETERAN WHO WISHES TO HAVE ANY DEROGATORY INFORMATION ON HIS DD FORM 214 ELIMINATED OR CHANGED.

IF, AS THE DEPARTMENT OF DEFENSE CONTENDS, THE DD FORM 214 IS MORE USEFUL THAN HARMFUL FOR THE BULK OF INDIVIDUALS RECEIVING IT, THEN IT BECOMES NECESSARY TO IDENTIFY THOSE ITEMS ON THE FORM, SUCH AS SPN AND RE CODES, WHICH MIGHT BE INJURIOUS TO THE VETERANS BEST INTERESTS IF DIVULGED AND TO DETERMINE WHETHER IT IS ESSENTIAL TO RETAIN THOSE ITEMS ON THE FORM. WOULD ALSO BE USEFUL TO KNOW WHAT KINDS OF INDIVIDUALS AND ORGANIZATIONS ASK THE VETERAN TO PRODUCE HIS DD FORM 214, ON THAT OCCASIONS, UNDER WHAT CIRCUMSTANCES, AND WITH WHAT KNOWN OR PERCEIVED EFFECTS.

I AM THEREFORE REQUESTING THAT YOU UNDERTAKE A STUDY OF WHAT CIRCUMSTANCES LED TO THE DEVELOPMENT AND ADOPTION BY THE DEPARTMENT OF DEFENSE OF THE DD FORM 214, WHAT PURPOSES THE FORM WAS ORIGINALLY DESIGNED TO SERVE, AND WHETHER CONTINUED USE OF THIS DOCUMENT IN ITS PRESENT OR A MODIFIED FORMAT CAN BE JUSTIFIED ON THE BASIS OF EXISTING REQUIREMENTS AND IN THE LIGHT OF PRACTICES WHICH HAVE GROWN UP RELATED TO ITS USE. IN THIS STUDY, THE FOLLOWING MATTERS SHOULD BE CONSIDERED, IN ADDITION TO THOSE I HAVE SET FORTH ABOVE:

A. THE GOVERNING DEPARTMENT OF DEFENSE INSTRUCTION ENUMERATES THE DESIGNATED RECIPIENTS OF FIVE COPIES OF THE DD FORM 214 AND THEN STATES "F. OTHER COPIES WILL BE DISTRIBUTED IN ACCORDANCE WITH REGULATIONS ISSUED BY THE MILITARY DEPARTMENTS."

1. WHAT LIMITATIONS ON THE AVAILABILITY OF THIS FORM HAVE BEEN INCORPORATED INTO MILITARY DEPARTMENT REGULATIONS OR INSTRUCTIONS, AND ARE THESE LIMITATIONS CONSISTENT AMONG THE SERVICES?

2. TO THE EXTENT THAT THESE FORMS OR ANY INFORMATION THEREON ARE BEING MADE AVAILABLE, WHAT KINDS OF INDIVIDUALS, GROUPS AND ORGANIZATIONS REQUEST COPIES, FOR WHAT PURPOSES, AND WHAT LIMITATIONS EXIST ON THE FURTHER DISTRIBUTION BY THEM OF COPIES OF THE FORM OR OF INFORMATION CONTAINED THEREON?

3. WHAT IS THE SOURCE AND EXTENT OF NON-DESIGNATED RECIPIENTS' KNOWLEDGE ABOUT THE MEANING OF THE NUMBER OR LETTER CODED ENTRIES?

B. THE PREVALENCE OF THE PRACTICE OF REQUESTING VETERANS TO PRODUCE THEIR DD FORM 214 FOR EXAMINATION OR TO FURNISH COPIES SHOULD BE ASSESSED, TO THE EXTENT POSSIBLE, BY CONTACTING INDIVIDUAL VETERANS ASSISTANCE ORGANIZATIONS SUCH AS THE AMERICAN LEGION, THE VETERANS OF FOREIGN WARS, THE DISABLED AMERICAN VETERANS, AND OTHER ORGANIZATIONS FAMILIAR WITH THE FORM, ITS USAGE, AND ITS ADVANTAGES AND DISADVANTAGES.

C. DESIGNATED AS WELL AS NON-DESIGNATED RECIPIENTS OF THE FORM OR OF INFORMATION CONTAINED THEREON SHOULD BE QUESTIONED ABOUT:

1. THE DEGREE OF ESSENTIALITY OF THE FORM AND/OR THE DATA ELEMENTS TO THEIR OPERATIONS.

2. WHETHER THE DATA THEY WOULD REQUIRE ARE AVAILABLE TO THEM FROM OTHER SOURCES AND, IF SO, WHICH ONES?

I WOULD LIKE TO EXPRESS MY APPRECIATION AGAIN FOR YOUR EXCELLENT STUDIES, PERFORMED AT MY REQUEST IN RECENT YEARS, ON THE SUBJECT OF ALCOHOLISM IN BOTH THE CIVILIAN AND MILITARY SEGMENTS OF THE FEDERAL WORK FORCE. I HOPE THAT THIS FURTHER STUDY AND YOUR REPORT THEREON WILL BE EQUALLY USEFUL AND ENLIGHTENING TO THE CONGRESS AND THE AMERICAN PEOPLE.

APPENDIX III OMITTED ..END :

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