oversight

National Security: DOD Should Reevaluate Requirements for the Selective Service System

Published by the Government Accountability Office on 2012-06-07.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office

GAO          Report to Congressional Committees




June 2012
             NATIONAL
             SECURITY
             DOD Should
             Reevaluate
             Requirements for the
             Selective Service
             System




GAO-12-623
                                                 June 2012

                                                 NATIONAL SECURITY
                                                 DOD Should Reevaluate Requirements for the
                                                 Selective Service System
Highlights of GAO-12-623, a report to
congressional committees




Why GAO Did This Study                           What GAO Found
The Selective Service System is an               The Department of Defense (DOD) has not recently evaluated the necessity of
independent agency in the executive              the Selective Service System to meeting DOD’s future manpower requirements
branch. Its responsibilities include             for carrying out the defense strategy or reexamined time frames for inducting
maintaining a database that will enable          personnel in the event of a draft. DOD officials told GAO that the Selective
it to provide manpower to DOD in a               Service System provides a low-cost insurance policy in case a draft is ever
national emergency, managing a                   necessary. The Selective Service System maintains a structure that would help
program for conscientious objectors to           ensure the equity and credibility of a draft. For example, the Selective Service
satisfy their obligations through a              System manages the registration of males aged 18 through 25 and maintains no-
program of civilian service, and
                                                 cost agreements with organizations that would offer alternative service to
ensuring the capability to register and
                                                 conscientious objectors. The Selective Service System also has unpaid
induct medical personnel if directed to
do so. Section 597 of the National
                                                 volunteers who could be activated as soon as a draft is enacted to review claims
Defense Authorization Act for Fiscal             for deferment. However, DOD has not used the draft since 1973, and because of
Year 2012 (Pub. L. No. 112-81)                   its reliance and emphasis on the all-volunteer force, DOD has not reevaluated
requires that GAO assess the military            requirements for the Selective Service System since 1994, although significant
necessity of the Selective Service               changes to the national security environment have occurred since that time.
System and examine alternatives to its           Periodically reevaluating an agency’s requirements is critical to helping ensure
current structure. Specifically, GAO (1)         that resources are appropriately matched to requirements that represent today’s
determined the extent to which DOD               environment. Selective Service System officials expressed concern that, as
has evaluated the necessity of the               currently resourced, they cannot meet DOD’s requirements to deliver inductees
Selective Service System to meeting              without jeopardizing the fairness and equity of the draft. However, the lack of an
DOD’s future manpower requirements               updated requirement from DOD presents challenges to policymakers for
beyond the all-volunteer force and (2)           determining whether the Selective Service System is properly resourced or
reviewed the fiscal and national                 necessary.
security considerations of various
alternatives to the Selective Service            Restructuring or disestablishing the Selective Service System would require
System. GAO reviewed legislation,                consideration of various fiscal and national security implications. GAO reviewed
analyzed relevant documents, verified            data on costs and savings associated with maintaining the Selective Service
cost data provided by the Selective              System’s current operations, operating in a deep standby mode with active
Service System, and interviewed DOD,             registration, and disestablishing the Selective Service System altogether.
Office of Management and Budget,
and Selective Service System officials.          Estimated Costs and Savings of Current Operations and Alternatives
                                                  Dollars in millions
What GAO Recommends                                                                  Maintaining current     Deep standby
                                                                                             operations    with registration   Disestablishment
GAO recommends that DOD (1)                       Estimated first-year savings                       $0                $4.8               $17.9
evaluate its requirements for the
                                                  Estimated recurring savings                        $0                $6.6               $24.4
Selective Service System in light of              Estimated budget after
recent strategic guidance and (2)                 implementation                                  $24.4               $17.8                  $0
establish a process of periodically              Source: Selective Service System.
reevaluating these requirements. In
                                                 Note: Numbers may not add up due to rounding.
written comments on a draft of this
report, DOD agreed with the
recommendations.                                 If Congress disestablishes the Selective Service System it would need to amend
                                                 the Military Selective Service Act and potentially other laws involving the
                                                 Selective Service System. There are also limitations that would need to be
                                                 considered if Selective Service System functions were transferred to another
                                                 agency. Selective Service System officials said that while other databases could
View GAO-12-623. For more information,           be used for a registration database, these databases might not lead to a fair and
contact Brenda S. Farrell at (202) 512-3604 or
farrellb@gao.gov.                                equitable draft because they would not be as complete and would therefore put
                                                 some portions of the population at a higher risk of being drafted than others.
                                                                                                  United States Government Accountability Office
Contents


Letter                                                                                                    1
               Background                                                                                2
               DOD Has Not Evaluated the Necessity of the Selective Service
                 System Since 1994                                                                       4
               Restructuring or Disestablishing the Selective Service System
                 Requires Consideration of Fiscal and National Security
                 Implications                                                                             9
               Conclusions                                                                               15
               Recommendations for Executive Action                                                      16
               Agency Comments and Our Evaluation                                                        16

Appendix I     Scope and Methodology                                                                     19



Appendix II    Comments from the Department of Defense                                                   21



Appendix III   Comments from the Selective Service System                                                23



Appendix IV    GAO Contact and Staff Acknowledgments                                                     24



Table
               Table 1: Estimated Costs and Savings of Current Operations and
                        Alternatives to the Selective Service System                                     10




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               Page i                                                        GAO-12-623 National Security
United States Government Accountability Office
Washington, DC 20548




                                   June 7, 2012

                                   Congressional Committees

                                   Under the Military Selective Service Act, 1 the Selective Service System is
                                   an independent agency within the executive branch of the federal
                                   government. 2 Its responsibilities include maintaining a registration
                                   database that will enable it to provide untrained manpower to the
                                   Department of Defense (DOD) in the event of a national emergency,
                                   managing a program for conscientious objectors to satisfy their
                                   obligations through a program of alternative civilian service, and ensuring
                                   the capability to register and induct medical personnel if directed to do so.

                                   We conducted this review in response to the mandate in section 597 of
                                   the National Defense Authorization Act for Fiscal Year 2012, 3 which
                                   requires us to assess the military necessity of the Selective Service
                                   System and examine various alternatives to its current structure.
                                   Specifically, we (1) determined the extent to which DOD has evaluated
                                   the necessity of the Selective Service System to meeting the
                                   department’s future manpower requirements in excess of the all-volunteer
                                   force and (2) reviewed the fiscal and national security considerations of
                                   various alternatives to the Selective Service System, including
                                   disestablishing the agency, reducing its current capacity, or having its
                                   functions performed or database maintained by another organization. Our
                                   review did not assess whether or not the Selective Service System should
                                   be restructured or disestablished, as this is ultimately a policy decision for
                                   Congress.

                                   For our first objective, to determine the extent to which DOD has
                                   evaluated the necessity of the Selective Service System to meeting
                                   DOD’s future manpower requirements in excess of the all-volunteer force,
                                   we analyzed documents and guidance on DOD’s manpower requirements
                                   for the Selective Service System and interviewed DOD and Selective
                                   Service System officials on the role and necessity of the Selective Service



                                   1
                                    50 U.S.C. App. §§ 451—473.
                                   2
                                    50 U.S.C. App. § 460(a).
                                   3
                                    Pub. L. No. 112-81 (2011).




                                   Page 1                                               GAO-12-623 National Security
             System to meeting DOD’s requirements. We also determined whether
             and how often DOD evaluates its requirements for the Selective Service
             System. For our second objective, to review the fiscal and national
             security considerations of various alternatives to the Selective Service
             System, we requested that officials from the Selective Service System
             identify the estimated costs, savings, and national security implications of
             disestablishing the Selective Service System or placing it in a deep
             standby mode. 4 While we relied on data provided by Selective Service
             System officials, we examined their assumptions and verified their
             methodology in calculating the costs of termination and potential savings.
             We determined that these data were sufficiently reliable for our purpose
             of providing an estimate of the costs of alternatives to the Selective
             Service System’s current structure. We interviewed DOD and Selective
             Service System officials to determine whether there are comparable
             databases or other agencies, including DOD, that could perform the
             Selective Service System’s functions. We also asked them to identify any
             factors and limitations that might affect the costs of another agency or
             database replacing the functions of the Selective Service System.

             We conducted this performance audit from February to June 2012 in
             accordance with generally accepted government auditing standards.
             Those standards require that we plan and perform the audit to obtain
             sufficient, appropriate evidence to provide a reasonable basis for our
             findings and conclusions based on our audit objectives. We believe that
             the evidence obtained provides a reasonable basis for our findings and
             conclusions based on our audit objectives. Further information on our
             scope, methodology, and data reliability assessment can be found in
             appendix I.


             The Military Selective Service Act requires virtually all male U.S. citizens
Background   worldwide and all other males residing in the United States ages 18
             through 25 to register with the Selective Service System within 30 days of
             turning 18 years of age under procedures established by a presidential
             proclamation and other rules and regulations. The Selective Service
             System currently budgets for 130 full-time civilian positions and 175 part-



             4
              Section 597 of the National Defense Authorization Act for Fiscal Year 2012 defined deep
             standby mode as the Selective Service System retaining only personnel sufficient to
             conduct necessary functions, to include maintaining the registration database.




             Page 2                                                      GAO-12-623 National Security
time Reserve Force Officers 5 in its national headquarters in Arlington,
Virginia; its Data Management Center, in Chicago, Illinois; and its three
regional headquarters, located in Chicago, Illinois; Smyrna, Georgia; and
Denver, Colorado. In 2011, the Selective Service System’s Data
Management Center added 2.2 million records to its database and sent a
series of letters to males reminding them of their obligation to register.
According to Selective Service System officials, in calendar year 2010,
their database contained approximately 16.4 million names, and the
estimated registration compliance rate was 92 percent. The Selective
Service System also carries out other peacetime activities such as
conducting public registration awareness and outreach, responding to
public inquiries about registration requirements, and providing training
and support to volunteer local board members, state directors, and
Reserve Force Officers.

The Military Selective Service Act does not currently authorize use of a
draft for the induction of persons into the armed forces. Congress and the
President would be required to enact a law authorizing a draft, were they
to deem it necessary to supplement the existing force with additional
military manpower. In the event of a draft, the Selective Service System
would be tasked with conducting a lottery and sending induction notices
to selected males to supply the personnel requested by the Secretary of
Defense. A network of over 11,000 local, district, and national board
volunteers, who are now managed by the Selective Service System,
would be activated to review and process claims for exemption,
deferment, or postponement of service. Selected males would be directed
to report to Military Entrance Processing Stations, managed by DOD, to
determine whether they are qualified for military service, and then sent to
military training centers. In addition to drafting inductees, the Selective
Service System would be responsible for providing options and managing
the program for alternative civilian service to conscientious objectors and
would also be required to induct health care specialists if necessary.




5
 Reserve Force Officers are maintained at a maximum number of 175, which includes 150
funded by the Selective Service System and 25 on loan from the military services.




Page 3                                                   GAO-12-623 National Security
                          The Selective Service System’s time frames for mobilizing inductees are
DOD Has Not               based on DOD’s recommendations developed in accordance with its
Evaluated the             manpower requirements as defined in 1994; therefore, the
                          appropriateness of these time frames to helping DOD meet its current
Necessity of the          manpower needs in excess of the current all-volunteer force is unclear.
Selective Service         Even though DOD has not used the draft since 1973, DOD officials told
System Since 1994         us that the Selective Service System provides a low-cost insurance policy
                          in case a draft is ever necessary and a structure and organization that
                          would help ensure the equity and credibility of a draft should one be
                          authorized and implemented. The Selective Service System also offers
                          capabilities that are hard to quantify in terms of dollars, including its
                          structure of unpaid volunteers who could be activated as soon as a draft
                          is implemented and its no-cost agreements with civilian organizations that
                          have agreed to supply jobs to conscientious objectors. Selective Service
                          System officials expressed concern that, as currently resourced, they
                          cannot meet DOD’s requirements to deliver inductees without
                          jeopardizing the fairness and equity of the draft. However, that
                          requirement was based on the national security environment that existed
                          in 1994. The lack of an updated requirement from DOD presents
                          challenges to policymakers for determining whether the Selective Service
                          System is properly resourced or necessary.


The Selective Service     DOD developed its manpower requirements for the Selective Service
System’s Current          System in 1994 and has not reexamined these requirements in the
Manpower Requirements     context of recent military operations and changes in the security
                          environment and national security strategy. In a 1994 memorandum 6 to
Are Based on a 1994 DOD
                          the Director of the Selective Service System, the Assistant Secretary of
Evaluation                Defense for Force Management stated that DOD expected that its active
                          and reserve forces would be sufficient for most conceivable scenarios
                          involving two Major Regional Conflicts, citing two then-current documents,
                          the 1993 Report on the Bottom-Up Review and the 1994 A National
                          Security Strategy of Engagement and Enlargement. Because of this
                          expectation, DOD recommended extending the time it would require the
                          Selective Service System to provide the first inductees from 13 days to



                          6
                           Assistant Secretary of Defense for Force Management, Memorandum for Director of
                          Selective Service System, “Updated Manpower Requirements” (Nov. 16, 1994). Other,
                          more general guidance is provided in DOD Instruction 1100.19, Wartime Manpower
                          Mobilization Planning Policies and Procedures (Feb. 20, 1986) and DOD 1100.19-H,
                          Wartime Manpower Mobilization Planning Guidance (Mar. 1990).




                          Page 4                                                   GAO-12-623 National Security
193 days after mobilization (13 days plus 6 months) and to provide
100,000 inductees from 30 days to 210 days after mobilization (30 days
plus 6 months). The Selective Service System considers this requirement
to be its most recent and official requirement from DOD. The
memorandum also stated that DOD’s position was that an all-male draft
remained valid and legal and that medical personnel continued to be the
only skilled group that would be required in conceivable contingency
scenarios. Specifically, the document states that DOD’s Health Care
Personnel Delivery System calls for the rapid postmobilization registration
of up to 3.5 million health care personnel in more than 60 specialties.
DOD also stated in its memorandum that the time for the Selective
Service System to conduct a mass registration of medical personnel
could be extended by 6 months, from 13 days to 193 days, with induction
orders to follow 3 weeks later.

DOD relies on its national defense strategy and the Quadrennial Defense
Review to identify its priority mission areas and determine its overall force
structure needs. 7 The national defense strategy provides the foundation
and strategic framework for the department’s Quadrennial Defense
Review, which is performed every 4 years. During this review, DOD is
required to define a national defense strategy and the force structure and
other elements necessary to successfully execute the range of missions
identified in that national defense strategy. Changes in the security
environment require the department and the services to reassess their
force structure requirements, including how many and what types of units
are necessary to carry out the national defense strategy. For example, as
DOD stated in its January 2012 strategic guidance, even when U.S.
forces are committed to a large-scale operation in one region, they will
need to be capable of denying the objectives of—or imposing
unacceptable costs on—an opportunistic aggressor in a second region.
Specifically, the United States will need to be prepared for an increasingly
complex set of challenges in South Asia, the Middle East, and the Asia-
Pacific region. 8

In prior work, we have emphasized the importance of agencies taking
actions to ensure that their missions are current and that their


7
 Force structure represents the numbers, size, and composition of the units that comprise
U.S. forces.
8
Sustaining U.S. Global Leadership: Priorities for 21st Century Defense (January 2012).




Page 5                                                       GAO-12-623 National Security
organizations are structured to meet those missions. We have also
reported that many agencies find themselves encumbered with structures
and processes rooted in the past and designed to meet the demands of
earlier times. 9 Further, we have stated that high-performing organizations
stay alert to emerging mission demands and remain open to reevaluating
their human capital practices to meet emerging agency needs. 10 Changes
in the security environment and defense strategy represent junctures at
which DOD can systematically reevaluate service personnel levels to
determine whether they are consistent with strategic objectives.

While DOD officials stated that the 1994 manpower requirement may still
be valid, without an updated assessment of requirements for the
Selective Service System, policymakers cannot be certain whether the
resources to support the Selective Service System are necessary to meet
DOD’s manpower needs, whether the Selective Service System is
prepared to supply the skills most critical to DOD in the 21st century, or
whether the Selective Service System is necessary at all. In a letter to
GAO dated April 16, 2012, the Deputy Assistant Secretary for Military
Personnel Policy stated that determining the military necessity for the
Selective Service System and its registration of young men is a complex
issue that requires significant examination not possible during the period
of GAO’s review. 11 However, DOD does recognize that such an
examination is prudent. The Deputy Assistant Secretary noted that, while
the military necessity of the Selective Service System in the 21st century
has yet to be determined, the department recognizes that there are
benefits to the continuation of the Selective Service System.




9
 GAO, Executive Guide: Effectively Implementing the Government Performance and
Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996).
10
  GAO, A Model of Strategic Human Capital Management, GAO-02-373SP (Washington,
D.C.: Mar. 15, 2002).
11
  Section 597 of the National Defense Authorization Act for Fiscal Year 2012, dated
December 2011, required GAO to provide a report containing the results of our study to
the Committees on Armed Services of the Senate and House of Representatives no later
than May 1, 2012. To satisfy this mandate, we provided a draft of this report to the
Committees on that date.




Page 6                                                     GAO-12-623 National Security
Selective Service System      According to official spokespersons for the Selective Service System, the
Said It Is Not Resourced to   agency is not currently resourced to meet DOD’s requirement for it to
Meet DOD’s Requirements       deliver the first inductees in 193 days and 100,000 inductees in 210 days,
                              without jeopardizing the fairness and equity of the draft. However, DOD
but Provides a Structure      officials believe that the Selective Service System provides a low-cost
That Could Be Used for a      insurance policy in case a draft is ever necessary. The Selective Service
Fair and Equitable Draft      System also provides benefits that would help to ensure a draft was fair
                              and equitable. Specifically, Selective Service System officials stated that
                              since fiscal year 1997, the agency has undergone various cuts and
                              attained efficiencies in an attempt to meet DOD’s manpower
                              requirements. The Selective Service System officials said that due to
                              reductions in the number of personnel available to set up area offices
                              across the country, it now estimates it could not deliver the first inductees
                              until 285 days after mobilization. In fiscal year 1997, the Selective Service
                              System’s budget was $22.9 million (in then-year dollars), or $31.5 million
                              in fiscal year 2013 dollars. Since then, the agency’s annual budget has
                              declined steadily in constant dollars, and its requested budget for fiscal
                              year 2013 was $24.4 million. 12

                              According to the Selective Service System’s fiscal year 2011 Annual
                              Report, maintaining acceptable registration compliance rates of at least
                              90 percent is key to the agency’s ability to conduct a fair and equitable
                              draft, should it be necessary. Maintaining a high compliance rate,
                              Selective Service System officials believe, helps to ensure that the
                              highest possible number of eligible men are targeted equally. Within its
                              available budget, the Selective Service System is able to maintain
                              registration compliance rates of 69 percent for 18-year-old males, 89
                              percent for 19-year-old males, and 96 percent for 20- through 25-year-old
                              males. 13 The Selective Service System estimates that over the past few
                              years, a larger portion of the registration process has become automated
                              because many state drivers’ license programs now require registration
                              with the Selective Service System as a prerequisite, and the Selective
                              Service System offers internet and telephone registration options.
                              However, Selective Service System’s data-entry staff also input over


                              12
                                Constant dollars measure the value of purchased goods and services at price levels that
                              are the same as the reference year. Constant dollars do not contain any adjustments for
                              inflationary changes that have occurred or are forecast to occur outside the reference
                              year.
                              13
                               Once a man reaches his 26th birthday, his name is dropped from the Selective Service
                              System’s list of possible draftees.




                              Page 7                                                      GAO-12-623 National Security
712,000 transactions each year, including manual registrations, registrant
file updates, compliance additions and updates, post office returns, and
miscellaneous forms. The Data Management Center also serves as the
agency’s national call center, which the public contacts to verify
registrations that are needed to be eligible for benefits and programs
linked to this registration, such as student loans and government jobs. In
addition, the Selective Service System undertakes general national
outreach and public awareness initiatives to publicize the requirement for
males to register. These efforts have included convention exhibits, public
service announcements, high school publicity kits, focus group studies,
and outreach meetings. The Selective Service System also conducts
outreach visits to areas of low registration compliance.

In addition to registration, the Selective Service System structure helps to
ensure that a draft would be fair and equitable. For example, it maintains
a structure that could be activated as soon as a draft is implemented to
conduct nationwide local review boards to determine draftees’ eligibility
for deferments. The Selective Service System’s three regional offices are
responsible for maintaining this board structure and making sure that
personnel are trained to perform their assigned tasks. Each state and
territory has a part-time state director who is compensated for an average
of up to 12 duty days per year. In 2011, the Selective Service System
also relied on 175 Reserve Force Officers from all branches of the military
services. These part-time officers perform peacetime and preparedness
tasks, such as training civilian board members, and function as field
contacts for state and local agencies and the public. The largest
component of the Selective Service System’s workforce is approximately
11,000 uncompensated men and women. According to Selective Service
System officials, these men and women are selected to be
representatives of the geographic area in which they reside and are
trained to serve as volunteer local, district, and national appeal board
members. If a draft were to occur, these trained volunteers would decide
the classification status of men seeking exceptions or deferments based
on conscientious objection, hardship to dependents, their status as
ministers or ministerial students, or any other reason. Selective Service
System officials believe that having local board members representative
of the geographic areas in which they reside helps to ensure that these
board members would make fair and equitable decisions.

If a draft occurred, the Selective Service System is also required to
manage a 2-year program of alternative civilian service for conscientious
objectors. The Selective Service System maintains no-cost agreements
with civilian organizations that, in the event of a draft, have agreed to


Page 8                                             GAO-12-623 National Security
                               supply jobs to conscientious objectors who oppose any form of military
                               service, even in a noncombat capacity. To be prepared to implement an
                               alternative service program for registrants classified as conscientious
                               objectors, the Selective Service System conducts outreach to various
                               civilian employers, such as the Methuselah Foundation and the
                               Mennonite Mission Network, to arrange memoranda of agreement for
                               these organizations to be prepared to offer alternative service to up to
                               30,000 conscientious objectors should a draft be necessary.


                               Restructuring or disestablishing the Selective Service System would
Restructuring or               require consideration of various fiscal and national security implications,
Disestablishing the            some of which may be difficult to quantify. We reviewed estimated costs
                               and savings for two alternatives to the current structure of the Selective
Selective Service              Service System: (1) placing it in a deep standby mode where active
System Requires                registration is maintained and (2) disestablishing the agency. In addition
                               to the potential costs and savings of these alternatives, other factors, with
Consideration of               both tangible and intangible costs and benefits, may need to be
Fiscal and National            considered if either alternative were pursued. We identified factors that
Security Implications          may affect costs and various considerations and limitations that may
                               affect whether another agency or database could perform the functions of
                               the Selective Service System while maintaining the capability to perform a
                               fair and equitable draft.


Options for Disestablishing    Officials from the Selective Service System provided details on the
or Restructuring the           personnel and resources required for each of the alternatives we
Selective Service System       reviewed, as well as their estimated cost savings (see table 1). The
                               Selective Service System estimates were based on the assumption that
Differ in Cost, Savings, and   either alternative would be fully implemented in fiscal year 2013, and
Personnel Requirements         officials based their estimates on their fiscal year 2013 requested budget.
                               Most of the estimated cost savings result from reductions in the numbers
                               of civilian and Reserve Force Officer personnel for the two alternatives we
                               examined.




                               Page 9                                              GAO-12-623 National Security
Table 1: Estimated Costs and Savings of Current Operations and Alternatives to the
Selective Service System

 Dollars in millions
                                   Maintaining current  Deep standby
                                           operations with registration Disestablishment
 Personnel required
       Civilian (full-time,                         130                     93                      0
       paid)
       Reserve Force                                150                      0                      0
       Officers (part-time,
       paid)
       Reserve Force                                  25                     0                      0
       Officers (part-time,
       unpaid)
       State directors (part-                         56                     0                      0
       time, paid)
       Civilian board                            11,000                      0                      0
       members (unpaid)
 Estimated first-year                                 $0                  $4.8                 $17.9
 savings after termination
 costs are subtracted
 Estimated recurring                                  $0                  $6.6                 $24.4
 annual savings
 Estimated budget after                           $24.4                 $17.8                      $0
 implementation
Source: Selective Service System

Notes: Numbers may not add up due to rounding.
The figures in this table are based on Selective Service System’s estimates of the number of
personnel required and potential costs and savings for the agency to be put in a deep standby mode
or disestablished. These estimates are based on the assumption that a decision to restructure or
disestablish the Selective Service System would be made in the first quarter of the fiscal year and
completed by the end of the fiscal year. The budgets identified in the table correspond with the
estimated budgets after the scenario is implemented.
The Selective Service System’s current budget authorizes 130 civilian full-time equivalent positions.
Three of those authorized positions represent the funds necessary to pay the part-time salaries of the
56 state directors.
The potential savings identified in both the deep standby with registration and disestablishment
scenarios assume approximately $2.6 million in savings associated with dismissing the part-time paid
Reserve Force Officers. These savings may not be realized if these positions are absorbed by the
Department of Defense.


As shown in table 1, if the Selective Service System were placed in a
deep standby mode and maintained its registration program and
database, Selective Service System officials estimated that the first-year
cost savings would be approximately $4.8 million, with subsequent annual
savings of approximately $6.6 million. Selective Service System officials



Page 10                                                              GAO-12-623 National Security
estimated that costs for closing the regional offices, severance pay, and
other termination costs would be $1.8 million. The Selective Service
System estimates it would require a budget of $17.8 million and 93 full-
time civilian personnel at the national headquarters and Data
Management Center to continue inputting and processing registrations,
maintain registration awareness and compliance, and facilitate plans to
reconstitute the agency if needed. The estimates assume that the
Selective Service System would reduce its civilian workforce by 37
positions, would no longer employ Reserve Force Officers or state
directors, and would reduce its physical infrastructure costs by closing its
three regional offices.

According to Selective Service System officials, disestablishing the
agency would produce first-year cost savings of approximately $17.9
million and subsequent annual savings of $24.4 million. This scenario
assumes that all full-time civilians, Reserve Force Officers, and state
directors would be terminated or dismissed, and the agency
headquarters, three regional headquarters, and data management center
would be closed. Selective Service System officials estimated that costs
for closing the agency and terminating employees and contracts would
total approximately $6.5 million in the first year. In both of the alternatives
presented in table 1, the 11,000 civilian volunteer board members would
be dismissed, eliminating the volunteer board infrastructure currently in
place to review claims for deferring or postponing military service.

Selective Service System officials also identified the estimated time and
potential resources required to reestablish the agency to its current
operations should either of these options be pursued. 14 Selective Service
System officials estimated that if the agency were in a deep standby
mode or disestablished, it would cost approximately $6.6 and $28
million, 15 respectively, to restore the agency to its current operating
capacity. Officials estimated that if the agency were put in a deep standby
mode with registration, it would take approximately 18 months to rehire
and train essential civilian and Reserve Force Officer personnel,


14
  The Selective Service System’s estimates for the time required to reconstitute the
agency to the current status quo are based on its experiences transitioning from deep
standby to full operations in 1980.
15
  Selective Service System officials estimated that if the agency were disestablished, they
would require their fiscal year 2013 estimated budget of $24.4 million plus an additional
$3.6 million to build an information technology system for the registration database.




Page 11                                                       GAO-12-623 National Security
reestablish regional offices, and appoint state directors and civilian
volunteer board members. If the agency were disestablished, officials
estimated it would take an additional 6 months—or a total of
approximately 2 years—to perform mass registrations, reconstitute the
Data Management Center and regional offices, build the necessary
information technology infrastructure, and rehire and train personnel.

Selective Service System officials also provided estimates for the time
and resources required to perform a draft from its current operations if the
agency were in deep standby or disestablished. According to Selective
Service System officials, they have no previous experience transitioning
from disestablishment or a standby mode to draft operations. While their
estimates are loosely based on the agency’s mobilization plans, officials
noted that their plans have not recently been updated and do not reflect
their current staffing or budget. To perform a draft from its current
operating status, Selective Service System officials said that they would
require approximately $465 million to hire the full-time civilian personnel
necessary to populate the field structure by staffing area and alternative
service offices and district and local boards. If either deep standby or
disestablishment were pursued and a draft became necessary, Selective
Service System officials said they would need funds in addition to the
$465 million it would currently require to perform a draft. Selective Service
System officials estimated that if the agency were in a standby mode or
disestablished, they would require approximately 830 days and 920 days,
respectively, to provide DOD with inductees.

In addition to the potential costs and savings for each option, officials
from the Selective Service System and DOD identified other factors that
would need to be considered if the agency were disestablished or placed
in a deep standby mode. Officials reaffirmed several benefits that they
stated had been previously identified in a 1994 National Security Council
recommendation to maintain the Selective Service System and the
registration program. For example, DOD and Selective Service System
officials said that the presence of a registration system and the Selective
Service System demonstrates a feeling of resolve on the part of the
United States to potential adversaries. Officials also stated that, as fewer
citizens have direct contact with military service, registering with the
Selective Service System may be the only link some young men will have
to military service and the all-volunteer force. Selective Service System
officials noted that the Selective Service System and registration
requirement provide a hedge against unforeseen threats. Officials from
DOD also cited some secondary recruiting benefits they receive from the
Selective Service System. DOD relies on the Selective Service System to


Page 12                                             GAO-12-623 National Security
                              mail out recruiting pamphlets in conjunction with the registration materials
                              the agency routinely sends to new registrants. DOD officials told us that
                              using the Selective Service System to mail these materials costs
                              approximately $370,000 a year, which is significantly less than the
                              department would spend on postage to mail the recruiting materials
                              separately and which results in approximately 60,000 recruiting leads a
                              year. In addition, DOD officials said that DOD relies heavily on the
                              Selective Service System’s database to help populate its recruiting and
                              marketing database at no cost to the department.

                              Other costs and considerations may need to be evaluated as well. A
                              number of federal and state programs require registration as a
                              prerequisite, such as state drivers’ licenses and identification cards,
                              federal student aid programs, U.S. citizenship, federally sponsored job
                              training, and government employment. Selective Service System officials
                              said there could be costs to remove language from forms and program
                              materials stating that registering with the Selective Service System is a
                              prerequisite to qualifying for these programs. Furthermore, Selective
                              Service System officials said that agreements with civilian agencies to
                              provide alternative civilian service for conscientious objectors would be
                              terminated if registration were discontinued or the agency were
                              disestablished, and reinstituting these agreements in the event of a draft
                              would take time. Terminating the Selective Service System would also
                              require amending the Military Selective Service Act and potentially other
                              laws involving the Selective Service System.

Transferring Selective        Selective Service System and DOD officials identified factors that should
Service System’s Functions    be considered if the functions of the Selective Service System were to be
to Another Agency Could       performed by another federal or state agency or with another database.
                              We were unable to identify specific costs associated with these options
Affect the Independence       because, according to officials from DOD and the Selective Service
and Fairness of a Draft and   System, there is no database that is comparable to or as complete as the
May Not Be Cost-Efficient     Selective Service System’s database. However, officials did identify
                              several factors and limitations that could affect the costs and feasibility of
                              having the Selective Service System’s functions performed by another
                              entity.

                              Officials from the Selective Service System identified several databases
                              and agencies that currently help populate their registration database. For
                              example, Selective Service System officials said they have agreements




                              Page 13                                              GAO-12-623 National Security
with the Social Security Administration and the American Association of
Motor Vehicles to supply names of 18- through 25-year-olds 16 who have
registered social security numbers or who apply for drivers’ licenses, at a
cost of $14,200 and $42,177 a year, respectively. Selective Service
System officials also said they rely on the U.S. Census Bureau to provide
a breakdown of the total number of men aged 18 through 25 by state and
county, which the Selective Service System uses to determine its overall
registration compliance rate. Selective Service System officials agreed
that other agencies’ databases, like those of the Social Security
Administration and the American Association of Motor Vehicles, could be
used or combined to populate a registration database but noted that a
draft using these systems might not be fair and equitable because these
databases would target certain portions of the pool of possible inductees
but not others. For example, if a draft were performed using only names
in the Social Security Administration’s database, immigrant men residing
in the United States who do not have social security numbers would not
have the same likelihood of being drafted as male U.S. citizens would.
Selective Service System officials also stated that there could be costs
associated with combining other databases to achieve the compliance
rate of the Selective Service System’s database. The Selective Service
System database represents 92 percent of the eligible population, and
Selective Service System officials said they rely on a number of sources
to maintain a high registration compliance rate and have established a
process that gives everyone an equal chance of being selected. The
Selective Service System therefore believes it can perform a fair and
equitable draft of the population and said that other databases, unless
similarly combined, could not replicate the completeness of the Selective
Service System database.

DOD and Selective Service System officials also expressed concern with
having another federal agency perform the Selective Service System’s
functions. Selective Service System officials said that any transfer of their
responsibilities to DOD or another federal agency would raise
independence concerns with respect to ensuring that a draft would be fair




16
  Though 18- through 25-year-olds are required to register, once a man reaches his 26th
birthday, his name is dropped from the Selective Service System’s list of possible
draftees.




Page 14                                                     GAO-12-623 National Security
              and equitable. 17 For example, according to Selective Service System
              officials, the independence of the agency helps to ensure that
              conscientious objector and pacifist communities will comply with
              registration requirements because the public trusts that the registration
              and induction process is performed fairly. DOD officials said that a
              significant evaluation would need to be performed to determine the costs
              and feasibility of the department taking on the Selective Service System’s
              tasks and that they are unable to identify the potential costs for the
              department to assume the responsibilities of the Selective Service
              System. DOD officials were able to provide the approximate costs to
              maintain the department’s recruiting and marketing database, but they
              emphasized that this database would be inappropriate to use as a
              replacement for the Selective Service System’s database because the
              Joint Advertising Market Research and Studies office relies on third-party
              data to populate its database, which is used strictly for the purpose of
              performing recruiting and market research. Officials from DOD’s Joint
              Advertising Market Research and Studies office indicated that their office
              currently spends approximately $2.8 million a year to operate and
              maintain their database of recruiting and marketing names and that it
              would cost an additional $3 million to replace the names it receives from
              the Selective Service System free of charge, more than doubling DOD’s
              operating costs for this database. In addition, DOD and Selective Service
              System officials stated that they are uncertain whether any savings would
              be realized by transferring the Selective Service System’s function to
              DOD or any other federal agency. Officials said the same number of
              personnel and resources would likely be required, and according to
              Selective Service System officials, there could be additional costs
              involved in having another agency learn how to recreate the components
              of the Selective Service System.


              While the Selective Service System states that it is not resourced to
Conclusions   provide first inductees within 193 days of mobilization and 100,000
              inductees within 210 days, DOD has not reevaluated this requirement
              since 1994. Since that time, the security environment and the national
              security strategy have changed significantly. Without an updated
              assessment by DOD of its specific requirements for the Selective Service


              17
                In addition, Congress declared in the Military Selective Service Act that, as a matter of
              policy, “the Selective Service System should remain administratively independent of any
              other agency, including the Department of Defense.” 50 U.S.C. App. § 451(f).




              Page 15                                                        GAO-12-623 National Security
                      System, it is unclear whether DOD would need 100,000 inductees in 210
                      days or even whether draftees would play any role in a military
                      mobilization. Further, while DOD officials believe that the Selective
                      Service System provides a low-cost insurance policy and benefits DOD in
                      other ways—some that are hard to quantify—determining the value of
                      these benefits is ultimately a policy decision for Congress, as is the
                      determination of the cost and benefit trade-offs of the various alternatives
                      to reducing the agency or transferring its functions. A reevaluation of the
                      department’s manpower needs for the Selective Service System in light of
                      current national security plans would better position Congress to make an
                      informed decision about the necessity of the Selective Service System or
                      any other alternatives that might substitute for it.


                      To help ensure that DOD and Congress have visibility over the necessity
Recommendations for   of the Selective Service System to meeting DOD’s needs, we recommend
Executive Action      that the Secretary of Defense direct the Under Secretary of Defense for
                      Personnel and Readiness to take the following two actions:

                          (1) evaluate DOD’s requirements for the Selective Service System in
                          light of recent strategic guidance and report the results of this
                          evaluation to Congress and
                          (2) establish a process of periodically reevaluating DOD’s
                          requirements for the Selective Service System in light of changing
                          threats, operating environments, and strategic guidance.

                      In commenting on a draft of this report, DOD agreed with our
Agency Comments       recommendations and noted its plans for implementation. Specifically,
and Our Evaluation    DOD concurred with our first recommendation—to evaluate DOD’s
                      requirements for the Selective Service System to reflect recent strategic
                      guidance and report the results of its evaluation to Congress. The
                      department stated that the Office of the Under Secretary of Defense for
                      Personnel and Readiness, in coordination with the Joint Staff and the
                      services, will perform an analysis of DOD’s manpower requirements for
                      the Selective Service System, with an anticipated completion date of
                      December 1, 2012. DOD also concurred with our second
                      recommendation—to establish a process to periodically reevaluate DOD’s
                      requirements for the Selective Service System in light of changing
                      threats, operating environments, and strategic guidance. The department
                      stated that it will establish a process to review the mission and
                      requirements for the Selective Service System during its reevaluation of




                      Page 16                                            GAO-12-623 National Security
its current requirements for the Selective Service System. DOD’s
comments are reprinted in appendix II.

We also provided a draft of this report to the Selective Service System for
comment. In its written comments, the Selective Service System noted its
support of DOD’s views of the Selective Service System. Specifically, it
cited the Secretary of Defense’s 2011 testimony in support of maintaining
registration as a mechanism to ensure the department is prepared for an
unexpected event. The Selective Service System’s comments are
reprinted in appendix III. The Selective Service System also provided
technical comments, which we incorporated as appropriate. We also
provided the Office of Management and Budget a draft, but we did not
receive any comments.


We are sending copies of this report to appropriate congressional
committees; the Secretary of Defense; the Under Secretary of Defense
for Personnel and Readiness; and the Director of the Selective Service.
We will also make copies available to other interested parties upon
request. In addition, the report will be available at no charge on the GAO
website at http://www.gao.gov. If you have any questions about this
report, please contact me at (202) 512-3604 or farrellb@gao.gov. Major
contributors to this report are listed in appendix IV.




Brenda S. Farrell
Director, Defense Capabilities and Management




Page 17                                            GAO-12-623 National Security
List of Committees

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

The Honorable Howard “Buck” McKeon
Chairman
The Honorable Adam Smith
Ranking Member
Committee on Armed Services
House of Representatives




Page 18                              GAO-12-623 National Security
Appendix I: Scope and Methodology
             Appendix I: Scope and Methodology




             To determine the extent to which the Department of Defense (DOD) has
             evaluated the necessity of the Selective Service System to meeting
             DOD’s future manpower requirements in excess of the all-volunteer force,
             we analyzed documentation and information obtained from interviews
             with relevant officials from the Office of the Under Secretary of Defense
             for Personnel and Readiness, Office of Management and Budget, and
             Selective Service System. To determine DOD’s manpower requirements,
             we reviewed DOD guidance and documents, including guidance on
             wartime manpower mobilization procedures and mobilization
             requirements. We also analyzed Selective Service System annual reports
             and budget justification documents, as well as input provided by the
             Selective Service System to the Office of Management and Budget. We
             reviewed relevant legislation establishing the Selective Service System
             and registration requirements in title 50 of the United States Code. We
             obtained DOD and Selective Service System officials’ perspectives on the
             role of the Selective Service System, as well as the Selective Service’s
             ability to meet its current need for inductees as defined by DOD’s
             manpower mobilization requirements. To obtain criteria for how frequently
             agencies should reevaluate their missions, we consulted our body of work
             on this subject. 1

             To review the fiscal and national security considerations of various
             alternatives to the Selective Service System, we obtained cost estimates
             from Selective Service System officials for two scenarios involving
             reducing or eliminating the Selective Service System: (1) disestablishing
             the Selective Service System and (2) placing the agency in a standby
             mode while having it continue to register potential draftees. We
             interviewed Selective Service System officials to identify their
             assumptions and sources for calculating the costs to implement these two
             scenarios. To assess the reliability of their cost estimates, we gathered
             and analyzed the agency’s budget documents to verify their calculations
             and assumptions and provided updates to the estimates for the Selective
             Service System to review. To assess the reliability of computer-processed
             data used to estimate costs, we interviewed Selective Service System



             1
              GAO, Executive Guide: Effectively Implementing the Government Performance and
             Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996); Model of Strategic Human
             Capital Management, GAO-02-373SP (Washington, D.C.: Mar. 15, 2002); and Military
             Personnel: DOD Needs to Conduct a Data-Driven Analysis of Active Military Personnel
             Levels Required to Implement the Defense Strategy, GAO-05-200 (Washington, D.C.:
             Feb. 1, 2005).




             Page 19                                                 GAO-12-623 National Security
Appendix I: Scope and Methodology




officials and obtained documentation from the Department of the Interior
to confirm the data and internal controls used in the system. We
determined that the data were sufficiently reliable for the purposes of this
audit. We also interviewed DOD and Selective Service System officials to
identify and describe federal or state agencies or comparable databases
that could replace the Selective Service System’s registration database.
We obtained DOD and Selective Service System officials’ perspectives
about the considerations and potential limitations involved in using
another agency or database, as well as factors that could affect the cost
and feasibility of another agency or database being used to perform the
functions of the Selective Service System. We also reviewed GAO’s
previous reports on the Selective Service System. 2

We conducted this performance audit from February to June 2012 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.




2
 GAO, Selective Service: Cost and Implications of Two Alternatives to the Present
System, GAO/NSIAD-97-225 (Washington, D.C.: Sept. 20, 1997); Gender Issues:
Changes Would Be Needed to Expand Selective Service Registration to Women,
GAO/NSIAD-98-199 (Washington, D.C.: June 30, 1998); and Weaknesses in the Selective
Service System’s Emergency Registration Plan, FPCD-79-89 (Washington, D.C.: Aug. 29,
1979).




Page 20                                                  GAO-12-623 National Security
Appendix II: Comments from the Department
             Appendix II: Comments from the Department
             of Defense



of Defense




             Page 21                                     GAO-12-623 National Security
Appendix II: Comments from the Department
of Defense




Page 22                                     GAO-12-623 National Security
Appendix III: Comments from the Selective
              Appendix III: Comments from the Selective
              Service System



Service System




              Page 23                                     GAO-12-623 National Security
Appendix IV: GAO Contact and Staff
                  Appendix IV: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Brenda S. Farrell, (202) 512-3604 or farrellB@gao.gov.
GAO Contact
                  In addition to the contact above, Margaret Best, Assistant Director,
Acknowledgments   Melissa Blanco, Greg Marchand, Charles Perdue, Meghan Perez, Bev
                  Schladt, and Erik Wilkins-McKee made key contributions to this report.




(351699)
                  Page 24                                          GAO-12-623 National Security
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