Inspection Trends from 3rd Quarter, Fiscal Year 2019
Commandant of the Marine Corps “Top Five” Priority of Effort
- Prohibited Activities and Conduct
- Sexual Assault Prevention and Response
- Substance Abuse Prevention
- Suicide Prevention
Substance Abuse Prevention Policy
Sexual Assault Prevention and Response
Law Enforcement Operations
Functional Area Trends & Best Practices
Aircrew Training (3500.14):
- Marine-Sierra Hotel Aviation Readiness Program (M-SHARP) and Training and Readiness Program Management: Ensuring execution of training events and their associating qualifications and designations are accurately reflected in M-SHARP.
- Lack of oversight of the M-SHARP program and/or no individual designated as the M-SHARP Implementation Officer per the Aviation Program Manual.
- Aircrew Performance Records (APR) Management: Ensuring the APRs are up-to-date and complete for all aircrew training events.
- Discrepancies between training records and naval Air Training and Operating Procedures Standardization (NATOPS) jackets: Ensuring specific training events, qualifications, designations, match between an individuals’ APR and NATOPS.
- Implementing Marine Corps Training of the unit into the Marine Corps Training Information Management System (MCTIMS) accurately.
- Lack of formal anti-terrorism training for command anti-terrorism officers.
Assistance and Investigations (5370):
- Substantiated subject(s) in system when no investigation was conducted & vice versa - no findings after an investigation.
- Investigating Prohibited Activities and Conduct or other command-specific matters.
- Not properly notifying individuals that they are the subject of an IG investigation.
- Not properly protecting the confidentiality of the complainant and witnesses.
- Lack of analysis in the Hotline Completion Reports.
- Improperly written allegations (who; did what; in violation of what; when).
Aviation Operations Administration (3700):
- All Aviation Operation Specialists assigned to the unit have not been assigned a specific Program of Instruction.
- All Aviation Operations Specialists assigned to the unit are not utilizing Marine-Sierra Hotel Aviation Readiness Program (M-SHARP) to log and track their Training and Readiness events.
- Pilots are not signing all pages of the logbook on which flight entries have been made.
- The Commanding Officer or authorized deputy is required to sign the page of the last entry at the end of the fiscal year.
- A monthly flight audit board is required to ensure that all requirements are met for hazardous duty incentive pay, allocations not exceeded, and flight hour minimums.
- Originator timeliness.
- Units not screening for duplicate material.
- Opening/closing sentences are incorrect.
- Incorrect date used for retirement awards.
- Approving/managing permissions are incomplete and/or present a conflict of interest.
Body Composition and Military Appearance Program (6110):
- Selective assignments, some senior enlisted and officers outside of height/weight standards are not being placed on the body composition program, while junior Marines are typically immediately assigned.
- Improper calculation of circumference values.
Career Planning (1040):
- Examination of the interview management system and/Career Planning Contact Records reveals that the Commanding Officer is not making reenlistment recommendations and assigning appropriate reenlistment eligibility codes. Mainly RE-4B drugs.
- The interview management system and/or Career Planning Contact Records show overdue and/or missed interviews, including EAS interviews.
- Review of completed NAVMC 11537 and 11537A (Reenlistment Extension and Lateral Move (RELM) Request) reveal that the command is not accurately completing each section, as applicable by First Term Alignment Program (FTAP) and or Subsequent Term Alignment Program (STAP) category.
- Career Planner has additional duties that either compromise the Career Planner's position or require the preponderance of their time.
Cyber Security Management (5239):
- Failure to complete and/or update System Authorization Access Request (SAAR) forms within prescribed timelines.
- Use of equipment beyond its Authorized to Operate (ATO) date.
- Lack of a trained and appointed Cyber Security Workforce Program Manager.
- Lack of an emergency contingency plan.
Defense Travel System (4650):
- Improper permissions management, appointments made by individuals without proper authority, assignment of permissions without a DD Form 577 on file and not maintaining separation of duties when appointing Defense Travel Administrators.
- Lead/Organizational Defense Travel Administrators are not extracting, reconciling, and maintaining the Completed Traveler Information List Report.
- Lead/Organizational Defense Travel Administrator are not providing Defense Travel Administrator and/or traveler training and maintaining documentation of completed training.
- Failure to submit travel claims within the 5-day requirement.
Government Travel Charge Card Program (4600):
- Check in/out procedures are inadequate; Agency Program Coordinator is not physically checking Marines in/out.
- Extracting, working, and maintaining the Account Activity Report and Aging Analysis Summary.
- Statements of Understanding, Travel Card 101 training certificates and annual refresher training is not maintained and/or documented.
- Failure to separate approval authorities within the same routing chain (i.e. utilizing the same individual).
- Failure to retain payment records per the current records retention schedule (10 years).
- Failure to properly categorize lines of accounting for Unit Travel Charge Card.
- Failure to properly store and secure Unit Travel Charge Cards.
- Failure to utilize delinquency reports and/or issue delinquency letters.
- Improperly closing accounts or failure to close accounts for departed personnel.
Health Services (6000):
- Medical personnel continue to incorrectly calculating readiness by reporting both full and partially medical readiness percentages.
- Lack of Corpsman Competency Training.
- Units are not ensuring completion of all applicable Deployment Health Assessments. (This is a functional area checklist item that does not count against overall readiness percentage as determined by Medical Regulating Reporting System (MRRS) business rules.)
- Most Units are struggling in meeting the requirement of Total Force Medically Ready (TFMR) metric at or above 90%.
- Units are not ensuring completion of the annual Preventive Health Assessment (PHA), and are not being conducted within one month of birth month. Not meeting this requirement has a cascading effect on the ability to perform PFT/CFT.
- Unit Health Services sections are frequently lacking appropriate written documentation showing that staff members are knowledgeable of command health service policies, procedures, and specific job responsibilities.
- A number of units have Health Services staff who are expired or do not have proper documentation to prove compliance with Tactical Combat Casualty Care (TCCC).
Information & Personnel Security (5510.3):
- Commands generally do not properly and effectively implement the Continuous Evaluation Program of legal matters as required by Chapter 10, SECNAV M-5510.3, DoN Personnel Security Program Manual. This includes reporting all available derogatory information and required information such as a positive urinalysis and a permanent change of station.
- Classified Military Information (CMI) created internal to the Marine Corps is not properly marked as required.
- Improper access authorization due to Joint Personnel Adjudication System (JPAS) inaccuracies, personnel missing required background investigations, personnel with revoked/denied clearance are retaining access. This includes missing DD254 and Visit Requests for contractors.
- Improper security reviews for public information and the inappropriate marking of classified materials.
- Assigning temporary access/temporary interim clearance to individuals who have withdrawn eligibility.
- SF 700 and SF 312 Forms not properly prepared, processed, and/or posted.
- Lack of required background investigations and/or out-of-scope security investigations for personnel with access to classified materials.
- Lack of a Continuous Evaluation Program, Emergency Action Plan, and/or Emergency Destruction Supplement; this includes the means to conduct an emergency destruction.
- Failure to properly check secured spaces every 4 hrs.
Intelligence Oversight (3800):
- Training records are typically incomplete and 3 years are not captured on file.
Legal Administration (5800.16):
- Establishment, maintenance, and completeness of 1900 and 5800 series files.
- Incomplete administrative investigations: lack of higher headquarters endorsement, investigations not meeting established timelines and/or lack of requests for extension identified in the investigative report, and photographs and videos in the command investigation not being properly marked.
- Unit Punishment Book UCMJ articles entered in item 1 do not include date, time and place of the alleged offense.
- Non-judicial punishment (NJP) imposed did not include all required language such as the limits of imposed restriction or whether the restriction or extra duties were “with” or “without” suspension from duty.
- Including the reduction of the Marine Corps Martial Arts Program (MCMAP) belt as a punishment item. MCMAP belt reduction is not an authorized punishment that can be imposed at NJP.
- Specific terms of the suspension are not being annotated to include the specific punishment suspended, the length of the suspension, and the terms for the automatic remission of the suspended punishment.
Limited Duty (1900.2):
- This cross-functional program is not being effectively managed by many units.
- Various entities within a unit are not coordinating to ensure personnel on limited duty are accurately tracked, re-assigned, and removed from limited duty.
Martial Arts (1500.59):
- Mental and Character tie-ins are being skipped.
Operations Security (3070):
- Commands are not conducting adequate threat assessments. Each command must assess threats and then publish a Critical Information List (CIL) based on the intent and capability of the threat.
- Lack of a comprehensive OPSEC plans that can support operational plans, execute orders, and other planning efforts. Doctrinally, the Marine Corps Planning Process requires Tab C (Operations Security) to Appendix 3 (Information Operations) to Annex C (Operations) to be completed.
- Increased collaboration is required between security disciplines to develop a comprehensive OPSEC plan.
Performance Evaluation System (1610):
- Failure to submit fitness reports on time.
- Failure to identify Marines in-zone for upcoming promotion boards.
- Failure to identify and correct date gaps.
- Failure to submit directed by CMC and/or grade change report (courts martial, NJP, etc.).
- “RDNT” for PFT/CFT are not recorded for adversity.
Physical Fitness (6100):
- Best Practice: Marking weights on Marines’ hands for the Maneuver under Fire event of the Combat Fitness Test to ensure that Marines carry someone within 10 pounds of their own weight.
- Lack of safety compliance; Risk Assessment Worksheets are not being completed correctly.
- All personnel taking a PFT/CFT must have a current Periodic Health Assessment.
- PFT/CFT not being conducted properly, lack of corrections being made.
Physical Security (5530):
- No Command standard operating procedure.
- Unit plans are not usually integrated with the higher headquarters or the installation level plan. This is very common with tenant commands aboard other service installations.
- Failure to return Corrective Action Reports of Law Enforcement inspections of restricted areas.
- Lack of an active Security Education Program and Access Control Program.
- Failure to properly complete Arms, Ammunition, and Explosives screening packages.
- Lack of demilitarized certifications for ceremonial/display weapons.
Postal Affairs (5110):
- There are no chain of custody/receipts (proof of delivery) for accountable mail from the mail clerk to an authorized agent; the authorized agent must designated in writing by the Commanding Officer.
- Missing information on personal accountable mail forms.
- Improper use of forms for official and/or accountable mail.
- Unauthorized personnel handling daily mail.
- Holding mail beyond authorized timelines.
Prohibited Activities and Conduct (5354.1):
- Best Practices:
(1) Example Battalion, Squadron-Level PAC Policy Guidance
(2) Example MSC-Level PAC Policy Guidance
Records, Reports, and Directives Management (5210):
- Commands have not established a file plan to capture all records managed within the command.
- Lack of a Vital Records Program, specifically, the unit Continuation of Operations Plan (COOP).
- Lack of a Reports Management Program regarding reporting requirements.
- Failure to review, update, or cancel unit directives within mandated timelines.
- Lack of open and close dates on digital files, destruction and/or retention guidance, and improper use of SSICs resulting in improper storage/destruction of files.
- Commands may find best practices at the Records Management Knowledge Site (RMKS); link provided in question 0104 of the 5210 checklist.
Request Mast (1700.23):
- Commanders accepting matters at Mast that involve Military Justice.
- Lack of tracking system for reprisals.
- Lack of evidence of any command training.
Best Practice: Commanders publishing their safety policy and mission statements within the required 30 days and ground safety officers attending the required safety training within 90 days of appointment.
Unit Level Trends:
(1) Quarterly safety councils not being conducted or documented.
(2) Quarterly facility inspections not conducted and documented by collateral duty GSO/GSM.
(3) Commands are not developing and implementing required safety programs (e.g. traffic safety program, motorcycle, hearing conservation, LASER, etc.).
(4) Command does not report mishaps via the Web Enabled Safety System (WESS).
(5) Lack of tracking and reporting Hearing Threshold shifts.
(6) Motorcycle club activity is deficient with poor tracking and validation of required motorcycle training (Motorcycle clubs not conducting quarterly meetings and/or not planning rides).
(7) Lack of supervisor training. Military and Civilian supervisors are not receiving initial Supervisor Safety Awareness training and Supervisor Safety Refresher training annually, thereafter. The training provides an overview of the Command safety program, mishap investigation and reporting, supervisor responsibility to train their subordinates, identify operations and personnel at risk to occupational health hazards. In addition, in some cases, GSOs are not receiving proper guidance of whom to contact to schedule this training. OSHA requires minimum 4 hour supervisory training for civilian supervisors or Marines who do not have above training.
Higher Headquarters Trends:
(1) Not establishing or updating their comprehensive Safety and Occupational Health program that implements written local orders/guidance and incorporates all activities and units under its control.
(2) Failure to maintain up-to-date policies and directives with USMC updates/changes.
(3) Lack of clearly defined roles between inspected commands and HHQ/adjacent units.
(4) Failure to conduct annual safety self-assessments, semi-annual safety stand downs, quarterly safety inspections and council meetings, and climate surveys.
Sexual Assault Prevention and Response (1752):
- Administration of SAPR program lack of compliance with reporting procedures.
- Command SOP information contradicts with the SAPR order, or is missing critical information; Commands require a comprehensive standard operating procedure to include response protocols.
- Improper appointment letters citing incorrect authorities, missing certifications, etc.
- Units are not maintaining certification of uniformed victim advocates (UVAs), and the UVAs lack continuing education (16 hours of every 12 months following appointment).
- No documentation of the Command Resource Brief with the Installation Sexual Assault Response Coordinator (SARC); this must be completed by Commanding Officer & Sergeant Major within 30 days of arriving at the command.
- Failure of Commanders to attend Case Management Group meetings.
- Lack of minimum required number of UVAs based on unit size.
- Best Practices:
(1) Sample Policy Letter
(2) Sample SOP
(3) SARC Appointment Letter Template
(4) SAPR VA Appointment Letter Template
Substance Abuse (5300):
- Not testing appointed SACOs, UPCs, and Observers monthly.
- Not complying with the requirement to test 10% of the total unit population (randomly) each month.
- Not testing Marines within 72 hours of checking-in from PCS orders or those returning from leave in excess of seven days.
- Not testing all Marines at least once annually.
- Not providing Supervisory Level Substance Abuse Program training for officers and SNCOs annually.
- Improper urinalyses authorizations, to include missing authorization letters.
- Failure to maintain training records and case files.
- Failure to perform proper procedures during the conduct of a urinalysis.
Suicide Prevention Program (1720):
- Lack of written guidelines, standard operating procedures, policy letters, etc.
- Lack of follow-on action for suicide attempts and follow-on care for families.
- Failure to complete annual training.
Supply, Consumer-level (4400.15):
- Failure to complete annual fiscal year “wall-to-wall” inventory.
- Failure to collect personal effects when required (TAD, separation, etc.).
Transition Readiness Program (1700.31):
- Best Practice Resources:
- Lack of Attendance and Timeliness at the Personal Readiness Seminar (within 90 days of arrival to unit).
- Timeliness on attendance at the Transition Readiness Seminar (NLT 180 days prior) & the Capstone (NLT 90 days prior).
- Application of the Transition Readiness Seminar - TA Codes upon completion of Transition & TZ Code upon completion of Capstone.
Unit, Personal, & Family Readiness (1754.9):
- Best Practice:
(1) Utilize the Inspection Guide (July 2019) to assist in the management of a UPFRP.
(2) “Welcome Aboard” process/brief for new-joins and families conducted by the command team.
- Family Readiness Command Team Training is not being conducted for or attended by all members of the Family Readiness Command Team.
- Training certificates for the DRC/URC (formerly known as “FRO”) are missing.
- Incomplete or non-existent turnover binders.
- Contact Authorization forms (NAVMC 11654) not collected/maintained.
- Volunteer Agreement Forms (DD Form 2793), volunteer appointment letters, and/or volunteer applications (NAVMC 11653) are missing.
- Training certificates for the appointed volunteers are missing.
Unit Readiness (3000):
- CBRNE Assessments are often inaccurate and calculated wrong.
- MOS Fill not being completed.
- Insufficient or only generic override justifications being provided.
Unit Training Management (1553.3):
- Non-compliance with meeting all requirements for Commander's Training Guidance.
- Non-compliance with requirement to maintain a risk management document or worksheet for all training events.
- Non-compliance with requirement for pre-requisite training for Training Safety Officers and High-Risk Training Safety Officers.
- Non-compliance with meeting all requirements for Training Plans.
- Non-compliance with requirement to document all training (including mission essential task lists based) in the Marine Corps Training Information Management System (MCTIMS) Calendar.
- Non-compliance with requirement to upload completed performance evaluation checklists (PECLs) to the documents tab in MCTIMS Calendar for all completed and evaluated training events.
Victims & Witness Assistance (5800.14):
- Failure to maintain rosters used to verify unit-wide training was accomplished.
- Inability to produce training materials used to train personnel of the command.
Voting Assistance (1742):
- Lack of familiarity with the www.FVAP.gov website and metrics reporting requirements.
- Failure to conduct annual training and maintain documentation.
- Lack of well-advertised, easily accessible office open during normal working hours, with properly posted and up-to-date information.