Recommendation: The Assistant Secretary for the Administration for Children and Families (ACF) should establish an ongoing process to proactively share information and best practices with states about programs it administers that are available to serve kin caregivers, especially in states with a relatively large share of grandparent caregivers. This could be achieved, for example, by leveraging regional office staff to provide additional assistance and information sharing, particularly related to kinship navigator programs. (Recommendation 1)

Agency: Department of Health and Human Services: Administration for Children and Families
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Administrator for the Administration for Community Living (ACL) should establish an ongoing process to proactively share information and best practices with states about using National Family Caregiver Support Program (NFCSP) funds to serve older relative caregivers of children, especially in states with a relatively large share of grandparent caregivers. This could be achieved, for example, by leveraging regional office staff to share information from states and area agencies on aging that have successfully used this program to serve older relative caregivers. (Recommendation 2)

Agency: Department of Health and Human Services: Administration for Community Living
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Defense should ensure that the Secretaries of the Military Departments revise AFI 36-3026, Volume 1, to provide detailed guidance for financial determinations and to establish consistent medical standards for all of the military services to use in determining the dependency status of incapacitated adult children, including what household and personal expenses and income are allowable, how these are to be calculated, and what medical documentation is required. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and indicated that it would develop and apply a single set of financial and medical standards across the Department. DOD indicated that these standards would be published in an upcoming policy memorandum.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Secretaries of the Military Departments and the Director of the Defense Finance and Accounting Service, identifies and implements the most effective means to provide information to families of incapacitated adult children to assist them in completing the dependency determination process. Such methods could include providing additional application instructions to families, making improvements to the DD Form 137-5, Dependency Statement – Incapacitated Child Over Age 21, such as providing detailed explanations of allowable expenses and how they should be calculated, providing detailed information about available support services, and providing additional and more advance notice to families. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation and noted that existing instructional tools exist to help families navigate the dependency determination process. However, DOD indicated that a Under Secretary of Defense for Personnel and Readiness user group will identify additional means to improve the information available to military families.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness clearly defines oversight responsibilities of the Department of Defense Human Resources Activity and the military services for the incapacitated adult child dependency process, including the consistent tracking, monitoring, and reporting of reliable data on incapacitated adult child dependency applications and determinations across the military services for use in data-driven decision-making. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation and stated that while current DOD guidance does not include specific oversight responsibilities for the incapacitated adult child program DOD concurred with the need for a single office to provide oversight of the program. DOD noted that the Under Secretary of Defense for Personnel and Readiness would identify the office and assign responsibility within 60 days of our report.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness directs the Department of Defense Human Resources Activity to exercise its oversight responsibilities for the incapacitated adult child dependency process, as clarified, including the use of consistent and reliable data on applications and determinations for data-driven decision-making to identify and address deficiencies and to inform program efforts. (Recommendation 4)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation, however DOD noted that it would address the recommendation after it takes action on our recommendation related to defining oversight responsibilities for the incapacitated adult child dependency determination process.

Recommendation: The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness clarifies the definition of a nondependent family member in DOD Instruction 1315.19 and the circumstances under which nondependent family members should be considered for services provided by the Exceptional Family Member Program. (Recommendation 5)

Agency: Department of Defense
Status: Open

Comments: DOD concurred with this recommendation and stated that it will review its policy to determine if the definition of a nondependent family member continues to be current and appropriate.

Recommendation: The Secretary of Defense should ensure that the Secretaries of the Military Departments revise military service-level policy to ensure consistency with the DOD Instruction 1315.19 definition of nondependent family members and the circumstance under which a nondependent family member should be considered for services provided by the Exceptional Family Member Program. (Recommendation 6)

Agency: Department of Defense
Status: Open

Comments: DOD partially concurred with this recommendation and stated that if DOD determines the current definition of a nondependent family member is no longer appropriate, it will ensure that Service-level policies will be revised to be consistent with the definition.

Recommendation: The Secretary of Defense should direct the Office of Special Needs (OSN) to assess the extent to which each Service is (1) providing sufficient resources for an appropriate number of family support providers, and (2) developing services plans for each family with special needs, and to include these results as part of OSN's analysis of any gaps in services for military families with special needs in each annual report issued by the Department to the congressional defense committees. (Recommendation 1)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation. In April 2019, DOD officials noted they plan to pilot a staffing tool that will help the Services determine the number of family support providers needed at each installation. The pilot currently includes multiple Services and is expected to last two years. DOD officials also noted that DOD is in the process of standardizing its case management processes for military families with special needs through its family needs assessment form. Among other things, this form is meant to help family support providers address requirements for individualized services plans and gain a better understanding of each family's current needs and goals. In its 2018 annual report to the congressional defense committees, DOD noted the National Defense Authorization Act for Fiscal Year 2010 requirement to develop and continuously update an individualized services plan for each military family with special needs. However, DOD said OSN may propose legislative changes to this requirement that would require an individualized services plan to be developed and updated only for those families that request services from family support providers. As of June 2020, we will consider closing this recommendation when the staffing tool is finalized and OSN has assessed each Service's number of family support providers and efforts to develop services plans.

Recommendation: The Secretary of Defense should direct the Office of Special Needs (OSN) to develop common performance metrics for assignment coordination and family support, in accordance with leading practices for performance measurement. (Recommendation 2)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation. In April 2019, DOD officials noted that each Service submits data for assignment coordination and family support to the EFMP data repository on a quarterly basis. According to DOD officials, in 2018, the data repository was expanded to include a full year of quarterly data for each Service, and OSN is currently developing additional performance metrics for assignment coordination and family support. DOD also noted that it will continue to use the data repository to identify gaps and trends related to assignment coordination and family support, including collecting data from each installation. As of June 2020, we await documentation that OSN has developed performance metrics for assignment coordination and family support and uses them to identify gaps and trends across the Services.

Recommendation: The Secretary of Defense should implement a systematic process for evaluating the results of monitoring activities conducted by each Service's EFMP. (Recommendation 3)

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation. In April 2019, DOD said the family support component is monitored and evaluated through the each Service's certification process which includes specific standards for the EFMP. In addition, OSN participated in a monitoring site visit to Marine Corps Base Quantico in December 2018 and plans to participate in additional site visits that are coordinated by each Service's certification team. As of June 2020, we will consider closing this recommendation when DOD implements a process to evaluate the results of each Service's certification process.

Recommendation: To help college financial aid administrators more effectively implement eligibility rules for unaccompanied homeless youth, the Secretary of Education should make available an optional worksheet or form that college financial aid administrators can voluntarily use to document unaccompanied homeless youth status or encourage the use of existing forms that are available.

Agency: Department of Education
Status: Open

Comments: Education agreed that it would be helpful to make forms developed by outside organizations knowledgeable about homelessness issues available for financial aid administrators to use for documenting the status of unaccompanied homeless youth. Education also said that it plans to highlight the availability of these forms and provide guidance at its annual conference and in updates to the Federal Student Aid Handbook. Education noted that it will not endorse the use of a specific form but that it will highlight forms that already exist that may be useful to financial aid administrators. In July 2020, Education reported that it planned to update the Federal Student Aid Handbook by the spring of 2021 to inform financial aid administrators about the availability of such forms that have been developed by outside entities. We will close this recommendation when Education provides GAO with the updated handbook.