Military Personnel: DOD Needs to Strengthen the Annual Review and
Certification of Military Personnel Obligations (29-NOV-04,
GAO-05-87R).
Each year, Congress appropriates billions of dollars to pay and
support U.S. military personnel at home and overseas. In fiscal
year 2003, military personnel (MILPERS) appropriations amounted
to more than $109 billion. Once the funds are appropriated, the
military services are responsible for ensuring that the funds are
properly obligated and disbursed. Their end-of-the-fiscal-year
review is critical to the next year's budget formulation process
because the services use the obligations for the most recent
fiscal year completed as a point of reference in developing their
new budgets, and Congress uses this information as a point of
comparison in its review of the new budget requests. In our prior
work for the House and Senate appropriation and authorization
committees, reviewing the services' budget justifications, we
found that although the services were conducting annual reviews
and certifications, the services did not review transactions by
matching obligations to individual disbursements in all of the
years that disbursements can occur, as required by the Department
of Defense (DOD) Financial Management Regulation. We also found
that the services disbursed some obligations for purposes other
than those reported in their budget submission, but their
year-end reviews did not show how these funds were actually
disbursed. As a result of our work, the report by the conferees
for the House and Senate defense appropriations committees for
fiscal year 2004 directed "the Secretary of Defense to ensure
that the services strengthen the annual review process by
including a review of the accuracy of prior year appropriations
below the budget activity level. To facilitate this review, the
financial management improvement initiative should include
financial decision-making processes that provide transparency of
disbursements at the same level as the budget submission." In its
report for fiscal year 2005, the House Appropriations Committee
reiterated this direction. For this letter, we examined whether
the military services are reviewing the accuracy of their MILPERS
obligation balances as required by DOD's Financial Management
Regulation and as directed by congressional conferees, and, if
not, what factors are preventing the services from doing this.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-05-87R
ACCNO: A14016
TITLE: Military Personnel: DOD Needs to Strengthen the Annual
Review and Certification of Military Personnel Obligations
DATE: 11/29/2004
SUBJECT: Accounting procedures
Appropriated funds
Budget obligations
Budget outlays
Cost analysis
Defense economic analysis
Military appropriations
Military personnel
Funds management
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GAO-05-87R
United States Government Accountability Office Washington, DC 20548
November 29, 2004
The Honorable Donald H. Rumsfeld Secretary of Defense
Subject: Military Personnel: DOD Needs to Strengthen the Annual Review and
Certification of Military Personnel Obligations
Dear Mr. Secretary:
Each year, Congress appropriates billions of dollars to pay and support
U.S. military personnel at home and overseas. In fiscal year 2003,
military personnel (MILPERS) appropriations amounted to more than $109
billion.1 Once the funds are appropriated, the military services are
responsible for ensuring that the funds are properly obligated and
disbursed. Their efforts include conducting an annual review and
certification to ensure that obligations are still needed in the amounts
and for the purposes obligated and that disbursements are supported by a
proper obligation of funds. The end-of-the-fiscal-year review is critical
to the next year's budget formulation process because the services use the
obligations for the most recent fiscal year completed as a point of
reference in developing their new budgets, and Congress uses this
information as a point of comparison in its review of the new budget
requests.
In our prior work for the House and Senate appropriation and authorization
committees, reviewing the services' budget justifications, we found that
although the services were conducting annual reviews and certifications,
the services did not review transactions by matching obligations to
individual disbursements in all of the years that disbursements can occur,
as required by the Department of Defense (DOD) Financial Management
Regulation.2 We also found that the services disbursed some obligations
for purposes other than those reported in their budget submission, but
their year-end reviews did not show how these funds were actually
disbursed. Specifically, the year-end reviews did not
1 MILPERS appropriations are used for pay, benefits, incentives,
allowances, housing, subsistence, travel for military personnel, and
reserve training.
2 DOD 7000.14-R, vol. 3, chapter 8, paragraph 080402.B(2), November 2000;
chapter 11, paragraph 110301, January 2001.
provide transparency over disbursements that occurred
after the first year
of the appropriation. As a result of our work, the report
by the conferees
for the House and Senate defense appropriations
committees for fiscal
year 2004 directed "the Secretary of Defense to ensure
that the services
strengthen the annual review process by including a
review of the
accuracy of prior year appropriations below the budget
activity level. To
facilitate this review, the financial management
improvement initiative
should include financial decision-making processes that
provide
transparency of disbursements at the same level as the
budget
submission."3 In its report for fiscal year 2005, the
House Appropriations
Committee reiterated this direction.4
For this letter, we examined whether the military
services are reviewing
the accuracy of their MILPERS obligation balances as
required by DOD's
Financial Management Regulation and as directed by
congressional
conferees, and, if not, what factors are preventing the
services from
doing this.
To answer this objective, we reviewed applicable Office
of the Secretary of
Defense (OSD) regulations and the services' procedures
for performing
the reviews; interviewed OSD officials in the Office of
Accounting,
Finance, Policy and Analysis, within the office of the
Under Secretary of
Defense (Comptroller/Chief Financial Officer), as well as
service
Comptroller officials; and reviewed Defense Finance and
Accounting
Service (DFAS) financial reports. We conducted our review
from August
2004 to October 2004 in accordance with generally
accepted government
auditing standards. We determined that the data used in
this letter are
generally reliable for the purposes for which we used
them. (See encl. I for
more information on our scope and methodology.)
The military services are not matching obligations to
Results in Brief disbursements at the individual disbursement transaction
level in all of the years that
disbursements can occur as required by the Financial
Management
Regulation. Additionally, the services are not reporting
the obligation
balances at the budget submission level as directed by
congressional
conferees. This has made it difficult, if not impossible,
for decision makers
to oversee how the services actually use MILPERS funds.
One reason for
3 H.R. Conf. Rep. No. 108-283, 62 (2003). 4 H.R. Rep. No. 108-553, 20
(2004).
this is that OSD has not provided the services with explicit instructions
in the Financial Management Regulation requiring them to review MILPERS
obligations at the budget justification level, especially as related to
disbursements made after the first year of the appropriation. Moreover,
OSD has not effectively monitored the services' compliance with the
Financial Management Regulation's requirement to review obligation
balances. Unless the services strengthen their year-end reviews and
certification processes, the actual use of MILPERS funds will continue to
be masked and the baseline for future budget requests may be inaccurate.
In addition, OSD has not ensured that the detailed financial data from
DFAS that the services need to conduct their reviews have been readily
available. DFAS only produces the detailed data for the first year of the
appropriation. Nevertheless, some of the services have begun to gather
MILPERS budget execution data at the budget justification level for all
years of the appropriation. For example, the Army and Marine Corps have
started to obtain needed data from DFAS to improve their review and follow
the congressional direction. Until all the services can strengthen their
budget execution accounting and related year-end review process to ensure
that their MILPERS obligations are valid, accurate, and matched to
individual disbursements and summarized at the level at which funds were
justified to Congress, decision makers will find it difficult, if not
impossible, to properly oversee how the services actually use the
appropriations. As a result, neither DOD nor the Congress has reliable
information on the status of MILPERS appropriations and future budget
submissions could be over-or understated.
We are recommending that OSD clarify the Financial Management Regulation
provisions applicable to the year-end review and certification process for
MILPERS obligations, monitor the services' annual review results, and take
steps to ensure that the services have the financial information they need
to conduct proper reviews.
MILPERS appropriations are available for obligation for a period of 1 year
(or for the duration of the fiscal year in which the budget authority was
appropriated). However, the appropriated funds remain available for 5
additional fiscal years for the payment of obligations (e.g., for
permanent change-of-station contracts or pay adjustments that were
incurred during the year of appropriation). Thus, the military services
can disburse MILPERS obligations over a period of up to 6 years. For
example, about 94 percent of fiscal year 2003 MILPERS obligations were
disbursed during the first year. The remaining 6 percent, or about $6.5
billion, was not disbursed (i.e., remained as unliquidated obligations)
and is available to
Background
disburse for up to 5 additional fiscal years. MILPERS obligations differ
from other obligations such as for operations and maintenance and
procurement where payments are made for specific transactions, such as
under a contract. MILPERS individual payments are made against a planned
level of obligations for like items,5 such as incentive bonuses and
payroll checks. The MILPERS fund manager allots an amount to DFAS to
expend for like disbursements.
The annual review and certification process for MILPERS appropriations
serves as an important oversight and internal control tool for decision
makers in OSD, the military services, and the House and Senate
appropriation and authorization committees, as well as input to financial
statements, to ensure that appropriated funds are properly obligated and
disbursed at the end of each fiscal year. OSD officials responsible for
Financial Management Regulations (the Office of Accounting, Finance,
Policy and Analysis) within the office of the Under Secretary of Defense
(Comptroller/Chief Financial Officer) stated that the services are
required to review commitments and obligation transactions for timeliness,
accuracy, and completeness and ensure that unliquidated amounts are
valid.6 The review covers the obligation balances for each year, starting
with the appropriation year plus 5 years to expend until the appropriation
cancels.7 Only the first year of the appropriation is reviewed at the line
item level. The subsequent 5 years of obligations can only be reviewed at
the budget activity and subactivity level because of data limitations.
Based on this review, the services must then certify to the President and
the Secretary of the Treasury8 that obligations are accurate and that
disbursements from the account are supported by an obligation and are
otherwise proper.9 When the year-end reviews identify funds that are no
5 OSD and service officials referred to this as an open allotment where
the fund manager provides DFAS with authority to make appropriate
disbursements for transactions that meet the criteria.
6 DOD 7000.14-R, vol. 3, chapter 8, paragraph 080401, and paragraph
080403, November 2000.
7 As of October 2004 (fiscal year 2005), for example, the services would
have obligation balances subject to review for prior-year appropriations
for fiscal years 2000, 2001, 2002, 2003, and 2004.
8 31 U.S.C. S: 1554(b)(1).
9 31 U.S.C. S: 1554(b)(2)(E).
longer needed, the services should deobligate the funds and make them
available for other permissible purposes.10
In our prior work on MILPERS budgets, we found that the obligations
reported at the end of the appropriation year were not always disbursed as
reported. In researching some of the differences, we also found that the
services' obligation reviews for the 5 years after the obligations were
made could not identify the changes at the same level of detail as that
used in the budget request to Congress. Moreover, the reports used for the
review did not provide information on where the funds were moved or an
audit trail to the disbursements.
DOD submits its MILPERS budget request, including a report of actual
obligations for the fiscal year just completed, at three levels of detail.
The broadest level is the budget activity (BA), followed by subactivity
groups (SAG) and line items.11 As an example, table 1 shows these three
levels in the Air Force's fiscal year 2003 budget request to Congress. The
fiscal year 2003 budget data is the most recent year available for which
the services have certified their obligations as valid and accurate.
Table 1: Examples of Levels of Budget Submission in the Air Force's Fiscal Year
2003 MILPERS Budget Justification Book
Dollars in millions
Actual Estimate Requested
Levels of budget Title FY 2001 FY 2002 FY 2003
submission
Budget activity Pay and allowance for $6,129.5 $6,609.0 $7,204.3
officers
Subactivity group Basic allowance for 642.8 717.8 778.9
housing, officers
Line item Domestic with dependents, 421.4 473.4 517.7
officers
Source: Air Force.
10 Funds also can be released to OSD for transfer into the Foreign
Currency Fluctuation account if they are transferred within 2 years after
the appropriation year; this account exists to minimize the effect to the
Operations and Maintenance and the MILPERS accounts of unanticipated
declines in the value of the dollar vis-`a-vis foreign currencies.
11 The services use different terms to denote these levels. For example,
the Air Force refers to subactivity groups as project codes and line items
as subproject codes; the Army refers to them as subactivity groups and
program elements; the Navy refers to them as subactivity groups and
summary account identifiers; and the Marine Corps refers to them as
subactivity groups and line items. We use budget activity, subactivity,
and line item to generically describe these various levels within a budget
request.
o The Air Force requested nearly $7.2 billion in the Pay and Allowance
budget activity for officers. Within this broad budget activity were
several SAGs, one of which was Basic Allowance for Housing. Finally,
within this SAG were several different line items, one of which was
Domestic with Dependents.
o The Air Force also included the amount it certified as obligated for
each of the three levels of detail for (1) the fiscal year that was just
completed (2001) as a point of comparison for the budget request and (2)
the estimate of how much it planned to use for the current fiscal year
(2002).
Table 2 shows how the military services would review their obligations at
the three levels of budget detail for the prior-year 2001 appropriation
and the subsequent 5 years before the appropriation cancelled. For
example, the services would track the fiscal year 2001 obligations at all
three levels of detail, but they would track the fiscal year 2002 to
fiscal year 2006 obligations at only the budget activity and subactivity
levels and not at the line item level. Thus, the way that obligations are
disbursed after the initial year of appropriation is not transparent. For
example, Congress and decision makers in OSD and the services would assume
that the $421.4 million obligation for the line item "Domestic with
Dependents" which was certified as correct at the end of the fiscal year
would disburse for this purpose. However, because disbursements are not
tracked at this level after the first year, the Air Force cannot determine
if the $421.4 million obligated was actually disbursed for Domestic with
Dependents in fiscal years 2002 through 2006. Consequently, if the $421.4
million is not dispersed, or is dispersed differently, the baseline of the
budget will be incorrect and may mask true requirements and actual
spending patterns.
Table 2: Financial Tracking of Services' Disbursements to Obligations for Fiscal
Year 2001 Appropriations Financial tracking of disbursements to obligations
Levels of budget Fiscal year of
5 years to
submission Title appropriation expend (fiscal
years)
2001 2002 2003 2004 2005 2006
Pay and Yes Yes Yes Yes Yes Yes
Budget activity allowance
for officers
Basic allowance Yes Yes Yes Yes Yes Yes
Subactivity group for
housing,
officers
Line item Domestic with Yes No No No No No
dependents,
officers
Services Are Not Reviewing the Accuracy of Obligations Because OSD Has Not
Provided Instructions, Monitored Compliance, or Ensured Access to Detailed Data
Source: GAO analysis of DOD information.
Note: The line item level is usually a summary level of like
disbursements. Fiscal years 2005 and 2006 are displayed as if the services
followed the current reporting format.
The Army had financial information at the line item level, but the
information was cumbersome to crosswalk to the budget submission level of
detail. Starting in fiscal year 2004, a new accounting structure will
allow the Army to compare disbursement data to the budget submission level
of detail.
The military services are not reviewing the accuracy of their MILPERS
obligation balances, as required by the Financial Management Regulation
and as directed by congressional conferees. OSD has not provided the
services with explicit instruction in the Financial Management Regulation
to guide them in their year-end reviews and has not effectively monitored
their compliance with the regulation as it is currently written. Also, OSD
has not ensured that the services have available the detailed financial
data they need for their annual reviews. Despite this, some of the
services have begun to gather the necessary financial reporting data.
Until the services can strengthen their year-end review process, the
actual use of MILPERS funds will continue to be masked and the baseline
for budget requests may be inaccurate. Additionally, it will be difficult,
if not impossible, for decision makers to oversee properly how the
services actually use MILPERS funds.
OSD Has Not Provided Clear Guidance or Monitored Annual Reviews
DOD's Financial Management Regulation sets out general instructions on the
review process that DOD components are to follow. The services are
responsible for conducting reviews of outstanding commitments and
obligation transactions for timeliness, accuracy, and completeness.12 As
part of this process, they are to perform a review of obligations that
have not disbursed (unliquidated obligations).13 Even though DOD's
Financial Management Regulation requires that the services review and
match individual disbursements to obligations, 14 it does not provide
explicit instructions requiring them to review MILPERS appropriations at
the transaction level until the appropriation cancels.
OSD officials who are responsible for the financial management regulation
on obligation reviews told us that they are considering revisions that
would require the services to review MILPERS obligations three times a
year, as they require for other appropriation accounts. The triannual
review would enhance DOD's and the services' ability to ensure that
individual disbursements are being matched to obligations and are
complying with DOD regulations and sound accounting and internal control
requirements. Showing budget execution data at the same level of detail at
which it was requested would be useful for both agency and congressional
oversight and financial decision-making. However, OSD officials said that
specific instructions on how MILPERS obligations should be reviewed are
not needed because they believe the regulation is adequate. We found that
the regulations do not specifically state how MILPERS obligations are to
be reviewed. Specific language on how MILPERS obligations reviews are to
be conducted would make clear to the services how detailed the reviews
should be. But the officials agreed that a revision requiring DOD
components to submit copies of their review results to OSD for monitoring
purposes is needed.15 In addition, OSD officials told us they are
considering whether to follow the congressional conferee's direction,
which calls for providing transparency of
12 DOD 7000.14-R, vol. 3, chapter 8, paragraph 080401, November 2000.
13 DOD 7000.14-R, vol. 3, chapter 8, paragraph 080403, November 2000.
14 DOD 7000.14-R, vol. 3, chapter 11, paragraph 110302(D), January 2001.
15 The regulation requires the services' fund managers to confirm to their
assistant secretaries (Financial Management and Comptroller) that a review
has been performed, but it does not require them to notify OSD. DOD
7000.14-R, vol. 3, chapter 8, paragraph 080405(B), November 2000.
disbursements at the same level (line item level) as the budget submission
until the appropriation cancels.
OSD Has Not Ensured Availability of Detailed Financial Data, but Services Have
Taken Steps to Obtain Data
The financial information provided by DFAS does not provide the detailed
information that the services need to match obligations to disbursements
at the budget submission (or line item) level for the 5 years after the
year of appropriation, nor does it provide an audit trail to the
individual disbursements, required for sound management and internal
control. The services' fund holders use monthly reports (Accounting Report
M-1002)16 provided by DFAS to review their obligation balances and
disbursements. While these reports contain summaries of obligations and
disbursements for all 6 years of the appropriation, they do not include
data down to the line item level (budget submission level) for any of the
years. For the first year of appropriation, the services have relied on
other financial data (i.e., summaries of like items) to perform their
year-end reviews to the line item level. However, they do not have similar
data to make the review at the line item level for the subsequent 5 years
that funds can be disbursed or until the appropriation cancels.17
Moreover, OSD and service officials acknowledge that there is no
requirement that the services use funds remaining after the year of
appropriation for the purposes obligated and reported in the budget
submission. If funds are used differently than reported, the actual use of
funds is masked, and the baseline for the budget requests may be
inaccurate and/or misleading. For example, obligated MILPERS funds that
are not disbursed for officers' basic pay in the year of appropriation
could be used for another authorized purpose for that year of
appropriation, such as enlisted personnel bonuses, within the next 5 years
of availability. However, current financial reports would not show this
variance. As a result, the reported obligations in the budget submission
may not represent how the services actually expend the funds and may not
be an accurate point of comparison for future budget requests.
16 DOD 7000.14-R, vol. 6A, chapter 4, paragraph 0406, January 2002.
17 DOD is also working to implement a new military personnel and payroll
system-the Defense Integrated Military Human Resource System (DIMHRS).
DIMHRS eventually will provide uniform personnel and payroll services to
each of the Services, the Reserves, and the Air and Army National Guard,
but this review did not cover the extent it will interface with the DFAS
financial systems and provide the type of reports discussed in this
letter.
Recently, the military services have taken steps-albeit different ones-to
get access to the detailed financial information they need to strengthen
their review of the accuracy of obligation balances. Officials in each
service provided the following descriptions on what they are currently
doing and their limitations for making a more detailed review.
o The Air Force has started to review the accuracy of prior-year
obligations, but it does not yet have the financial information needed to
make the review at the line item level. Air Force comptroller officials
told us that DFAS will be able to provide financial reports at the line
item level by November 2005 and will be able to match obligations to
disbursements at this level beginning in fiscal year 2006.
o Beginning with the fiscal year 2004 appropriations, the Army has been
able to match disbursements to obligations at the line item level because
the service built a data warehouse that can be used to research and
summarize obligations and disbursements. Army officials told us that,
starting with the fiscal 2004 MILPERS appropriation, they would be able to
produce financial reports at the budget submission level.
o The Marine Corps has a different DFAS system than the other services.
It has an integrated personnel and pay system and data history that allows
it to compare disbursements to obligations at the most detailed level of
each individual disbursement. The Marine Corps also has a data warehouse
that can be used to research obligations and individual disbursement
transactions that make up the financial reports. Officials told us that,
although they do not currently get financial reports from DFAS at the line
item level after the year of appropriation, DFAS could revise its
reporting format to provide such detail for a one-time cost of about
$90,000. With revised reports (M-1002) and the data warehouse, the Marine
Corps could review and certify the accuracy of outstanding obligations at
the line item level and research related transactions by matching
disbursements to obligations.
o Although the Navy has taken a number of steps to improve its review of
the accuracy of obligations in the year of appropriation, Navy officials
told us they have no plans to request a change in the monthly account
reports (M-1002) to show obligations and disbursements at the line item
level for the additional 5 years. Navy comptroller officials do not view
the improved oversight that such information would provide as either
necessary or required.
Conclusions Each year, transparency over the disbursement of several
billion dollars of MILPERS appropriations is placed at risk because the
military services are not reviewing the accuracy of their obligation
balances at the level of detail required by DOD's Financial Management
Regulation and as directed by congressional conferees. Although the
services conduct the annual reviews, it is OSD's responsibility to ensure
that the services have clear guidance and sufficiently detailed data to
undertake these reviews at the level of detail required. Although three of
the four services have initiated steps to obtain financial data at the
necessary level of detail, their efforts have varied. Until OSD can ensure
that the services are doing the reviews as required, the actual use of
some MILPERS funds will continue to be masked and the baseline for budget
requests may be inaccurate.
Recommendations for We are making two recommendations to ensure that the
services are reviewing the accuracy of MILPERS obligations and
disbursements as
Executive Action required. You should direct the Under Secretary of
Defense (Comptroller/Chief Financial Officer) to require
o the Office of Accounting, Finance, Policy and Analysis to monitor the
services' review results and to clarify the regulation that applies to the
review and certification of the accuracy of MILPERS obligations, by
including MILPERS accounts in its triannual review requirements and
providing specific guidance to the services to match obligations to
individual disbursement transactions until the appropriation cancels and
o the Defense Finance and Accounting Service to change the format in the
monthly financial reports for MILPERS appropriations to include
information at the line item level (budget submission level) for all 6
years that funds can be disbursed until the appropriation cancels.
Title 31 U.S.C. S: 720 requires the head of a federal agency to submit a
written statement of the actions taken on our recommendations to the
Senate Committee on Governmental Affairs and the House Committee on
Government Reform no later than 60 days after the date of this letter. A
written statement must also be sent to the House and Senate Committees on
Appropriations with the agency's first request for appropriations made
more than 60 days after the date of this letter.
Agency Comments
and Our Evaluation
The Under Secretary of Defense (Comptroller) provided written comments to
a draft of this letter. The Department of Defense's comments are included
in enclosure II. DOD concurred with both of our recommendations. DOD
concurs with the intent to clarify the requirements of the year-end
certification process by requiring triannual reviews for MILPERS accounts.
DOD stated that it will include MILPERS appropriations in the triannual
review requirements of the Department of Defense Financial Management
Regulation. DOD also concurs with the intent to ensure that the services
have the financial information they need to conduct proper reviews of
MILPERS accounts. DOD stated that it will direct the departments of the
Navy and the Air Force, in conjunction with the Defense Finance and
Accounting Service, to conduct a study of the feasibility of modifying the
financial systems to record and report prior year disbursements at the
budget submission level.
We are sending copies of this letter to House and Senate appropriation and
authorization committees. We will also make copies available to others
upon request. In addition, this letter is available at no charge on GAO's
Web site at http://www.gao.gov. If you have any questions concerning this
letter, please contact me on (202) 512-5559. Key contributors to this
assignment were Don Snyder, Tom Pantelides, Gary Billen, Pawnee Davis,
and Nancy Benco.
Sincerely yours,
Derek B. Stewart, Director
Defense Capabilities and Management
Enclosures
Enclosure I: Scope and Methodology
To identify the reasons why the military services were not properly
conducting annual reviews of MILPERS obligation balances, we reviewed
applicable Financial Management Regulations, the services' procedures for
performing the reviews, and monthly financial reports issued by DFAS. We
reviewed the results of our prior budget justification issue papers that
were provided to the House and Senate appropriation and authorization
committees. We also interviewed Air Force, Army, Navy, and Marine Corps
comptroller officials to determine what actions they were taking to
improve their year-end review and certification process and what
limitations they were encountering in these efforts, including problems in
obtaining needed financial information from DFAS. To determine the ability
of DFAS to provide the military services with needed financial
information, we interviewed DFAS and service officials responsible for
financial information used in the review of obligations and disbursements
and reviewed existing financial reports on the status of MILPERS
appropriations and obligations. We conducted our review from August 2004
to October 2004 in accordance with generally accepted government auditing
standards. We determined that the data used in the letter are generally
reliable for the purposes for which we used them.
Enclosure II: Comments from the Department of Defense
Enclosure II: Comments from the Department of Defense
Note: Page numbers in the draft letter may differ from those in this
letter.
Enclosure II: Comments from the Department of Defense
Enclosure II: Comments from the Department of Defense
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