Defense Health Care:
DOD Needs to Clarify Policies Related to Occupational and Environmental Health Surveillance and Monitor Risk Mitigation Activities
GAO-15-487: Published: May 22, 2015. Publicly Released: Jun 22, 2015.
What GAO Found
Inconsistencies between Department of Defense (DOD) and military service-specific policies regarding occupational and environmental health surveillance (OEHS) data storage have contributed to fragmentation and duplication of OEHS data between two information technology systems—the Military Exposure Surveillance Library (MESL) and the Defense Occupational and Environmental Health Readiness System (DOEHRS). Not having consistent policies for which system should be used to store OEHS data is contrary to federal standards for internal control. As a result, officials' efforts to store these data have resulted in both fragmentation and duplication, which GAO's prior work has shown may result in inefficiencies. Correspondingly, in some cases, similar types of unclassified OEHS data are being submitted to both MESL and DOEHRS, and in other cases, identical OEHS data are being submitted to both systems. However, neither system serves as a central repository for these data, and as a result, it is difficult to identify complete and comprehensive OEHS data sets, which may lead to problems when officials attempt to use these data in the future. Additionally, DOD's policy for OEHS data does not specifically address quality assurance. Consequently, some of the military services have developed their own guidance, resulting in inconsistent approaches and levels of effort, which has reduced DOD's ability to be confident that the data are sufficiently reliable. Federal standards for internal control state that management should continually monitor information captured and maintained for several factors, including reliability.
The military services use site assessments to identify and address potential occupational and environmental health risks at a deployment site. These assessments may include recommended countermeasures, such as the use of personal protective equipment. However, the extent to which these recommendations are being implemented is unclear because U.S. Central Command (CENTCOM)—the combatant command responsible for military operations in the geographic area that includes Iraq and Afghanistan—does not require base commanders to document their decisions on implementing them. Officials also said they are not monitoring these recommendations, and instead rely on others to elevate concerns, as necessary. In contrast, DOD's policy for its safety and occupational health program requires the department's components, including the combatant commands, to ensure that risk management decisions are documented and reevaluated. Federal standards for internal control also note that appropriate documentation is a key internal control activity and that agencies should monitor their activities for managing identified risks.
Both DOD and the Department of Veterans Affairs (VA) have used OEHS data to a limited extent to address post-deployment health conditions. For example, DOD officials said that the primary limitation with OEHS data collected during deployments continues to be the inability to capture exposure data at the individual servicemember level, although a method to do so is currently being explored. Additionally, DOD and VA use OEHS data to conduct research that may help determine service connections for post-deployment health conditions, but it has been difficult for researchers to establish a causal link between exposures and specific health conditions.
Why GAO Did This Study
OEHS is the regular collection and reporting of occupational and environmental health hazard data that can be used to help prevent, treat, or control disease or injury. In 2005, GAO reported that DOD needed to make improvements with OEHS during deployments to address immediate and long-term health issues.
GAO was asked to assess DOD's current OEHS efforts. This report examines (1) the extent to which the military services centrally store OEHS data and verify its reliability; (2) how, if at all, DOD identifies potential occupational and environmental health risks for sites in Iraq and Afghanistan, and to what extent these risks are mitigated; and (3) the extent to which DOD and VA use OEHS data to address post-deployment health conditions. GAO reviewed and analyzed DOD and military service policies on OEHS data storage and quality assurance, as well as policies related to conducting and monitoring assessments for deployment sites. GAO also interviewed DOD, military service, and VA officials, as well as groups representing servicemembers and veterans.
What GAO Recommends
GAO recommends that DOD clarify its policies for the storage and quality assurance of OEHS data, and require other related policies to be amended accordingly. GAO also recommends that CENTCOM revise its policy to require adequate documentation and consistent monitoring of deployment risk mitigation activities. In commenting on the report, DOD concurred with GAO's recommendations, and VA generally agreed with the conclusions.
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Recommendations for Executive Action
Comments: The Department of Defense (DOD) concurred with our recommendation. In November 2016, officials told us that draft versions of the revised DoDI 6490.03, Deployment Health, and the new Defense Health Agency Procedural Instruction (DHA PI) 6490.03, Deployment Health, are still under review with DOD components. These revised and updated documents will address the recommendation on OEHS data storage. Additionally, DoDI 6055.05, Occupational and Environmental Health (OEH), and Military Service and Combatant Command policy and guidance documents are still being revised to be consistent with DoDI 6490.03 and DHA PI 6490.03 after they are published. These revisions will ensure the consistency among policies. In February 2018, DOD informed GAO that it determined that all OEHS data will now be stored in DOEHRS because the MESL system was terminated following the transfer of all OEHS data from MESL to DOEHRS in September 2017, and that this requirement will be included in its policy update on OEHS data storage. In the interim, DOD has informed the military services and combatant commands of the forthcoming policy changes. As of February 2018, DOD expected that these policies would be amended by December 2018.
Recommendation: To eliminate the fragmentation and duplication in the storage of unclassified OEHS data, the Secretary of Defense should determine which IT system--DOEHRS or MESL--should be used to store specific types of unclassified OEHS data, clarify the department's policy accordingly, and require all other departmental and military-service-specific policies to be likewise amended and implemented to ensure consistency.
Agency Affected: Department of Defense
Comments: DOD concurred with our recommendation. In August 2016, officials told us that draft versions of the revised DoDI 6490.03, Deployment Health, and the new Defense Health Agency Procedural Instruction (DHA PI) 6490.03, Deployment Health, are in review among the DOD Components. Further, DoDI 6055.05, Occupational and Environmental Health (OEH) and Military Service and Combatant Command policy and guidance documents will be revised to be consistent with DoDI 6490.03 and DHA PI 6490.03 after they are published. In addition, DOD is exploring improvement to the data quality assurance functionality within the Defense Occupational and Environmental Health Readiness System Industrial Hygiene (DOEHRS-IH). A new DOEHRS-IH version (22.214.171.124) was released on August 19, 2016 that contained several system enhancements and defect corrections to improve overall data quality in the system. The revised policies and the new DOEHRS-IH functionality will appropriately address the recommendation on quality assurance of OEHS data. In February 2018, DOD told us that DODI 6490.03 and DHA-PI 6490.03 are still in the process of being revised, and they expected this process to be complete by December 2018. In addition, it expects that Service and Component policies will be subsequently revised to address performing quality assurance reviews of OEHS data, and expects this to be complete by the second quarter of fiscal year 2019.
Recommendation: To ensure the reliability of OEHS data, the Secretary of Defense should establish clear policies and procedures for performing quality assurance reviews of the OEHS data collected during deployment, to include verifying the completeness and the reasonableness of these data, and require that all other related military-service-specific policies be amended and implemented to ensure consistency.
Agency Affected: Department of Defense
Comments: DOD concurred with our recommendation. In August 2016, officials told us that the current DoDI 6055.01, DoD Safety and Occupational Health Program, requires DoD components to establish procedures that document, archive, and reevaluate risk management decisions on a recurring basis. Draft versions of the revised DoDI 6490.03, Deployment Health, and the new Defense Health Agency Procedural Instruction (DHA PI) 6490.03, Deployment Health, include language that is consistent with DoDI 6055.01. Additionally, U.S. Central Command Regulation 40-2 (CCR 40-2), which was updated as of March 8, 2016, references the requirement to establish procedures to assure risk management decisions are documented, archived, and reevaluated on a recurring basis. DOD is also exploring a risk management decision and monitoring functionality in DOEHRS-IH. It has identified and approved the necessary system change requests required to improve risk management decisions and monitoring functionality. These functionalities are primarily focused around the Occupational & Environmental Health Site Assessment (OEHSA) and associated exposure pathways, sampling plans, and assessments. Subject to the availability of FY 2017 funding, DOD will implement the system change requests, and achieve the required enhancements to DOEHRS-IH. These policies once published and the new DOEHRS-IH functionality will appropriately address the recommendation on documenting and monitoring risk management decisions. In February 2018, DOD told us that DODI 6490.03 and DHA-PI 6490.03 are still in the process of being revised, and they expected this process to be complete by December 2018.
Recommendation: To ensure that potential occupational and environmental health risks are mitigated for servicemembers deployed to Iraq and Afghanistan, the Secretary of Defense should require CENTCOM to revise its policy to ensure that base commanders' decisions on whether to implement risk mitigation recommendations identified in OEHSAs are adequately documented and consistently monitored by the appropriate command.
Agency Affected: Department of Defense