(AFI) 44-157, Medical Evaluation Boards - Air Force Freedom of ...

DEUTSCHER TONKÜNSTLERVERBAND - Landesverband Bremen e.V.56.Bremer Hausmusikwoche 2005Samstag,12. November 2005, 17 00 UhrHochschule für Künste, Dechanatsstrasse 13-152. Konzert: Bunter Kammermusiknachmittag1.2.3.4.5.6.7.8.9.10.11.Beteiligte Lehrkräfte des Tonkünstlerverbandes Bremen: Birte Steffen und Maren ScherenbergVerantwortliche Lehrkraft des Tonkünstlerverbandes Bremen: Maren Scherenberg

Tab ALong-Term Medical Profilesprovide a method to effectively perform this task. Further, because the reevaluationdates were not recorded in the automated AF Forms 422, personnel had todevelop local procedures, such as Excel databases, and manually track the dates,a method prone to human error. For example, Kirtland AFB personnel used anExcel database to track members on a long-term medical profile; however, weidentified seven reevaluations that were overdue from 1 month to 7 years.Impact. As the Air Force reduces the number of Airmen while maintaining a high AEFdeployment tempo, management officials should ensure all members with severe medicalduty assignment limitations are timely evaluated for retention or separation to effectivelymanage the total force and identify all Airmen available to support the AEF mission.Recommendation A.1. AF/SG should:a. Revise the automated AF Form 422 to include a section for medical officials torecord reevaluation dates.b. Revise AFI 44-157 to include standard procedures to track members and theirreevaluation dates. Additionally, AF/SG should require MTF commanders to periodicallyreview and identify members on long-term medical profiles and schedule reevaluationsas necessary.c. Direct MTF commanders to schedule and perform reevaluations for all overduemembers identified during the audit.Management Comments. AF/SG concurred with intent and stated:a. “AF/SG has coordinated with the Air Force Personnel Center; long termmedical profile re-evaluation interval and tracking is mandated by AFPC/DPAMM viathe Review in Lieu Of (RILO). RILO previously had no tracking mechanism prior toassumption of RILO tracking by AFPC/DPAMM. AFPC/DPAMM sends RILO notificationvia MTF Physical Evaluation Board Liaison Officer (PEBLO) who notifies PrimaryCare Managers (PCMs) of the requirement to complete a RILO and tracks to completion.The Deployment Availability Working Group (DAWG, which includes SGP and SGH),will track progress as well. The AF Form 422 has been revised, but does not have a functionthat indicates RILO dates. Open, Estimated Completion Date: 1 August 2007.b. “Same as A.1.a. above; will incorporate into new regulation currently in draft.AF/SG will require MTF commanders to monthly review and identify members on longtermmedical profiles and schedule reevaluations as necessary. Open, Estimated CompletionDate: 1 August 2007.c. “AFI 41-210, Patient Administration Functions, 22 March 2006, directs PCMs tocomplete RILOs when due. AFPC/DPAMM reports significant progress in reducing the2

Tab ALong-Term Duty Assignment Limitationsbacklog of overdue RILO cases since they have begun to track. The DAWG providestracking of the overdue RILOs and then reports via AF Form 895, Annual Medical Certificate,and then to the Executive Committee to ensure MTF/CC visibility. Open, EstimatedCompletion Date: 1 August 2007.”Potential Monetary Benefit (PMB) Recommendation A.1.: “Concur. We agree that nopotential monetary benefit will occur.”Evaluation of Management Comments. Management comments addressed the issues andmanagement’s proposed alternative actions should correct the problem identified in the auditresults.3

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Tab BShort-Term Medical ProfilesSYNOPSISMedical officials did not properly report and document short-term medical profiles. Specifically,nearly 6,000 active duty members on medical profiles were incorrectly reportedas world-wide deployable, and medical personnel did not timely report Airmen requiringmedical evaluation board reviews. Further, review of 222 members on a medical profiledisclosed documentation errors, including Privacy Act violations. Inaccurate reportingand documenting of short-term medical profiles occurred because officials had not establishedan automated interface to transfer medical profile data to the deployment data system,and AF Forms 422 did not adequately capture all required data. Medical profile datamust be properly reported and documented to identify all deployment eligible personnel,prevent deploying medically ineligible personnel, and avoid individual privacy right violations.BACKGROUNDAir Force medical officials use AF Form 422 to document health information that mayimpact safety or a member’s ability to accomplish the mission. Specifically, a medicalofficial enters codes into AF Form 422 identifying a member as eligible for deploymentworld-wide (“W”) or ineligible for deployment (“T”). A member with a severe injury orillness is assigned code “4T” (temporary medical profile), preventing them from deployingor changing temporary or permanent duty stations while either recovering or awaitingfurther medical evaluation. Further, a member in a short-term medical profile status for12 months (consecutively or cumulatively) is required to undergo a medical evaluationboard to return to duty; and some diagnoses, such as asthma or diabetes, require a memberimmediately undergo a medical evaluation board review.Because of patient privacy concerns, entries in the “Diagnosis” section of AF Form 422are not printable. However, entries documented in the “Restrictions” and “Remarks” sectionsare readily visible when printed in hardcopy. Medical personnel use the informationin AF Form 422 to update the Military Personnel Data System (MilPDS) and notifyunit commanders on changes to a member’s medical status. According to AFI 48-123,Volume 2, Medical Examinations and Standards, Volume 2-Accession, Retention, andAdministration, 5 June 2006, medical personnel must provide MPF personnel a monthlyupdate for all members on short-term medical profiles. Additionally, medical personnelare required to reconcile PIMR to MilPDS monthly to ensure the data is accurate andcoordinate with MPF officials to correct inaccuracies.5

Tab BShort-Term Medical ProfilesAUDIT RESULTS 2 – SHORT-TERM MEDICAL PROFILESCondition. Medical officials did not properly report and document short-term medicalprofiles. Specifically:• Profile Reporting. Nearly 6,000 active duty members on medical profiles wereincorrectly reported in MilPDS as world-wide deployable, and medical personneldid not timely report Airmen requiring a medical evaluation board review.• Deployment Reporting. Comparison of medical profiles in PIMR andMilPDS for all active duty members assigned a short-term medical profilerevealed 5,985 (45 percent) members were incorrectly reported in MilPDS asworld-wide deployable. Specifically, PIMR showed 13,369 members on ashort-term medical profile while MilPDS only showed 8,192. For example,PIMR reported 763 members pregnant (a deployment limitation), while at thesame time MilPDS listed the same members as world-wide deployable.• Medical Evaluation Board Reporting. A random sample of 222 membersfrom 11 MTFs disclosed medical personnel did not timely report 22 memberson short-term medical profiles requiring medical evaluation board action. The22 members were either in a short-term medical profile over 12 months or hada diagnosis warranting immediate medical evaluation board processing. 2 Forexample, Luke AFB medical officials took 17 months to initiate medicalevaluation board action for an Airman diagnosed with asthma, a medical conditionrequiring immediate board evaluation.• Profile Documenting. For the same sample of 222 members, 65 (29 percent)members had 127 documentation errors 3 on the AF Forms 422. These errorsincluded patient privacy violations, incorrect world-wide qualification status,and/or missing diagnosis information (Table 1).2 Some of these members were overdue evaluation board processing for up to 44 months.3 Each time a member visits a healthcare provider a new AF Form 422 is prepared. Consequently, membersmay have more than one AF Form 422.6

Tab BShort-Term Medical ProfilesPatient PrivacyViolationsAF Forms 422 With:IncorrectWorld-WideQualificationStatusLocationMembersReviewedNo DiagnosisTotalCharleston AFB 20 2 0 4 6Edwards AFB 20 11 2 4 17Goodfellow AFB 20 3 0 0 3Grand Forks AFB 20 8 1 0 9Kirtland AFB 21 2 0 1 3Little Rock AFB 20 0 2 0 2Luke AFB 20 43 1 7 51McChord AFB 21 1 0 3 4McGuire AFB 20 0 0 0 0Minot AFB 20 9 2 0 11Shaw AFB 20 8 2 11 21Totals 222 87 10 30 127Table 1. Short-Term Medical Profile Documentation Errors.Specifically, 87 forms improperly disclosed diagnosis information in the “Remarks”or “Restriction” sections of the forms, violating Federal privacy laws. 4 For example,health care providers inappropriately described members’ medical condition in thenarrative portions (unrestricted) of the AF Form 422 rather than the diagnosis section(restricted), allowing non-medical personnel 5 access to private medical information.Another 10 forms inaccurately identified the member as world-wide deployable.Although unlikely commanders or other interested personnel would rely solely on thehard-copy AF Form 422, these errors could cause unnecessary deployment delays andconfusion on the member’s medical status. Finally, 30 forms did not include themedical care provider’s diagnosis. As a result, medical personnel performing followupcare could not quickly and easily determine the member’s medical history.Cause. Inaccurate reporting and documenting of short-term medical profiles occurredbecause officials had not established an automated interface to transfer medical data tothe deployment data system and did not establish adequate AF Form 422 processing controls.• Automated Data Interface. AF/SG personnel did not coordinate with theAir Force Personnel Center to automate medical profile data transfer from PIMRto MilPDS. Consequently, medical personnel had to either hand-carry, a waste of4 The Health Insurance Portability and Accountability Act (HIPAA) of 1996 extends safeguards to an individual’sright to privacy in regards to medical information. Except for medical personnel who have a needto know, only commanders and their appointed designees may review information about the physical ormental health of an individual as it relates to the proper execution of the military mission.5 Non-medical personnel include individuals in the unit or the MPF.7

Tab BShort-Term Medical Profilesmanpower, or mail the forms to the MPF, unnecessarily delaying data input andincreasing the potential for misplaced forms. Further, this process required MPFofficials to manually input medical data into MilPDS, increasing the potential fordata entry errors. In addition, medical officials at 5 of 11 MTFs did not manuallyreconcile PIMR and MilPDS data for accuracy.• AF Form 422 Controls. AF/SG personnel did not design the automatedAF Form 422 to include the date short-term medical profiles began. Additionally,the form’s instructions did not incorporate Federal privacy laws (HIPAA) informationand did not require profile officers to verify forms were properly completed.Impact. Medical profile data must be properly reported and documented to identify alldeployment eligible personnel, prevent deploying medically ineligible personnel, and toavoid individual privacy right violations.Recommendation B.1. AF/SG should:a. Coordinate with the Air Force Personnel Center to automate medical profile datatransfer from PIMR to MilPDS. In the interim, AF/SG should reiterate to MTF commandersthe importance of tracking and reconciling medical profile data.b. Revise the automated AF Form 422 and related instructions to include the dateshort-term medical profiles begin and incorporate Federal privacy laws (HIPAA) information.c. Direct MTF commanders to initiate medical evaluation board actions for all membersidentified during the audit with short-term medical profile status for over 12 monthsor with a diagnosis warranting immediate board actions.Management Comments. AF/SG concurred and stated:a. “AF/SG has coordinated automated data transfer of Assignment AvailabilityCodes (AAC) from PIMR to MilPDS. Expect full Air Force functionality after final testing.Completed, Completion Date: 4 April 2007.b. “AF/SG has implemented the new AF Form 469 to replace AF Form 422. Startand release date for all duty limiting conditions is clearly annotated and business caserules prevent issuance of AF Form 469 with any release date that violates guidance. Thenew form is HIPAA compliant and reviewed twice prior to issue to ensure no Privacy Actinformation is released. Open, Partially Completed, Estimated Completion Date:1 August 2007.c. “AF/SG has implemented two measures to ensure members do not exceed8

Tab BShort-Term Medical Profiles12 months on a temporary profile (AAC 31). The first is the automated business caserules in PIMR that limit the duration of a temporary profile to 12 months and automaticallychange to MEB required (AAC 37) at 12 months. Secondly, the DAWG reviews allAAC 31 cases at the 10-month period to ensure that they will be expeditiously processedat the 12-month time frame when they change to MEB status. Finally, the DAWG ischarged with monitoring the AHLTA database for diagnosis which requires immediateMEB. Open. Partially Completed, Estimated Completion Date: 1 August 2007.”Potential Monetary Benefit (PMB) Recommendation B.1.: “Concur. We agree that nopotential monetary benefit will occur.”Evaluation of Management Comments. Management comments addressed the issuesraised in the finding, and management actions planned should correct the problem.9

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Audit Scope andPrior Audit CoverageAUDIT SCOPEAudit Coverage. We performed audit work at 11 judgmentally selected MTFs (AppendixII). To obtain a representative cross section of hospitals and clinics from the fourlargest major commands, we judgmentally selected two hospitals (one from Air CombatCommand, one from Air Education and Training Command), and nine clinics (one fromAir Combat Command, two from Air Education and Training Command, two fromAir Force Materiel Command and four from Air Mobility Command). We performed theaudit from July through December 2006 and reviewed data and documents, such asAF Forms 422 and medical records, dated from March 1998 through December 2006.We issued management a draft report in March 2007.To determine whether medical officials effectively managed long-term and short-termmedical profiles, we performed the following:• Long-Term Medical Profiles. To determine whether medical officials providedadequate oversight of members with long-term medical profiles, we obtained a listof all members on long-term medical profiles from MilPDS as of 18 July 2006.From this list, we randomly selected members on long-term medical profiles andcompared the reevaluation dates to determine if reevaluations were accomplishedtimely. We primarily interviewed medical officials such as medical techniciansand healthcare providers responsible for tracking, processing, and reporting thereevaluations; however, we also interviewed unit commanders, military personnelflight officials, and unit deployment managers.• Short-Term Medical Profiles. To determine whether medical officials accuratelyreported and documented short-term medical profiles, we selected and reviewed arandom sample of AF Forms 422 from PIMR as of 23 July 2006 for accuracy andcompleteness. We also verified the current medical status was valid and necessaryinformation was reported to unit commanders and deployment managers.We also interviewed selected MPF personnel responsible for preparing, processing,and using short-term medical profiles.Sampling Methodology. We used the following sampling and Computer AssistedAuditing Tools and Techniques to conduct this review.• Sampling. To accomplish this audit, we used random sampling methods to selectlong-term and short-term medical profiles for review. Specifically:• Long-Term Medical Profiles. For each location selected, we obtained thetotal number of members on long-term profiles. Then we randomly selected11 Appendix I

Audit Scope andPrior Audit Coverage20 members and 5 alternates from the total population of members on longtermmedical profiles in MilPDS as of 18 July 2006. We used the alternates ifthe originally selected member’s medical records were not locally maintained.• Short-Term Medical Profiles. For each location selected, we obtained thetotal number of members on short-term profiles. Then we randomly selected20 members and 5 alternates from the total population of members on a shorttermmedical profile in the PIMR system as of 23 July 2006.• Computer Assisted Auditing Tools and Techniques. We used ACL data analysissoftware to extract location populations and compare MilPDS and PIMR data forboth long-term and short-term medical profiles at the 11 locations reviewed. Specifically,we joined the two files, based on a personal identifier, to determinewhether members were listed in both systems.Data Reliability. Although we relied on computer generated data from the PIMR systemand MilPDS to support our audit results, we did not evaluate the systems’ generaland application controls. While our comparison of PIMR and MilPDS assignment dataidentified significant errors that cast doubt on the data’s validity, our review of supportingdata, such as patient medical records and local databases, and comparison of MilPDSdata to manual records such as AF Forms 422, were sufficiently reliable to support ouraudit conclusions and recommendations.Auditing Standards. We accomplished audit work in accordance with generallyaccepted government auditing standards and, accordingly, included tests of internal controlsas considered necessary under the circumstances. Specifically, we tested controlsfor documenting, recording, and executing transactions and events such as preparing,processing, reviewing, reconciling, and reporting medical profiles (AF Forms 422) andreviewing, reporting and maintaining long-term and short-term medical profiles.PRIOR AUDIT COVERAGEWe did not identify any Air Force Audit Agency, DoD Inspector General, or GeneralAccountability Office reports issued within the past 5 years that addressed the same orsimilar objectives as this audit.Appendix I 12

Locations Audited/Reports IssuedOrganization/LocationInstallation-LevelReports IssuedAir Combat Command5th Medical GroupF2007-0017-FBN000Minot AFB ND 17 November 200620th Medical GroupF2007-0022-FDM000Shaw AFB SC 10 January 2007Air Education and Training Command17th Medical GroupF2007-0022-FBS000Goodfellow AFB TX 20 February 200756th Medical GroupF2007-0021-FBS000Luke AFB AZ 15 February 2007314th Medical GroupF2007-0042-FBL000Little Rock AFB AR 22 February 2007Air Force Materiel Command95th Medical GroupF2007-0026-FCI000Edwards AFB CA 2 April 2007377th Medical GroupF2007-0011-FBM000Kirtland AFB NM 13 February 2007Air Mobility Command62d Medical GroupF2007-0050-FBN000McChord AFB WA 3 April 2007305th Medical GroupF2007-0006-FDN000McGuire AFB NJ 11 December 200613 Appendix II

Points of ContactHealth Care and Security Division (AFAA/SPH)Support and Personnel Audits Directorate2509 Kennedy CircleBrooks City-Base TX 78235-5116Phillip K. Gaddy, Associate DirectorDSN 240-3673Commercial (210) 536-3673Cheryl A. Bowden, Program ManagerMary L. Jacobs, Audit ManagerWe accomplished this audit under project number F2006-FD2000-0109.000.15 Appendix III

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Final Report DistributionSAF/OSSAF/USSAF/FMSAF/IGSAF/LLSAF/MRSAF/PASAF/XC, AF/A6AF/CCAF/CVAF/CVAAF/A1AF/A8AF/REAF/SGNGB/CFACCAETCAFIAAFMAAFMCAFOSIAFRCAFSOCAFSPCAIAAMCANGPACAFUSAFAUSAFEUnits/Orgs AuditedAU LibraryDoD ComptrollerOMBFREEDOM OF INFORMATION ACTThe disclosure/denial authority prescribed in AFPD 65-3 will make all decisions relativeto the release of this report to the public.17 Appendix IV

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To request copies of this report or to suggest audit topicsfor future audits, contact the Operations Directorate at(703) 696-7913 (DSN 426-7913) or E-mail toreports@pentagon.af.mil. Certain government users maydownload copies of audit reports from our home page atwww.afaa.hq.af.mil/. Finally, you may mail requests to:Air Force Audit AgencyOperations Directorate1126 Air Force PentagonWashington DC 20330-1126