Something very important is happening tomorrow. Tomorrow is the deadline for commenting on the proposed changes to the Department of Defense’s (DoD) Exceptional Family Member Program (EFMP). The DoD is making some important changes to the EFMP program, and they need YOUR input. So far, there have only been 44 comments received. There is still time. We can do better.
So, what is EFMP?
To support Families with special needs, the Exceptional Family Member Program (EFMP) was created in the early 1980’s. It was designed to be a comprehensive, coordinated, multi-agency program that provides community support, housing, medical, educational, and personnel services to military Families with an exceptional family member. Military Families have members with special needs, including spouses, children, or dependent parents who require special medical or educational services.
The Exceptional Family Member Program has three components:
- Identification and enrollment of a family member with special medical or educational needs.
- Assignment coordination to determine the availability of services at the projected duty station.
- Support to help families identify and access programs and services.
Who should enroll in the program?
Family members with special medical or educational needs should enroll in the Exceptional Family Member Program. This includes spouses, children and dependent adults who:
- Require special medical services for a chronic condition such as asthma, attention deficit disorder, diabetes, multiple sclerosis, etc.
- Receive ongoing services from a medical specialist.
- Have significant behavioral health concerns.
- Receive early intervention or special education services through an individualized education program or individualized family service plan.
The current system
- Current regulations require all service Branches to develop and implement instructions and procedures to families who apply for EFMP. This has led to variations in service delivery, interpretations of policy and in what supports are available to families. While all Branches use the same forms to determine eligibility, the way these forms are used can vary greatly across the services. This makes it difficult for a family who is stationed at a different Branch Installation to have paperwork completed and determinations made. It should be required that all Branches provide the same implementation and supports. Only then can families have fair and equal access to EFMP services.
- It is DoD policy that the EFMP program identifies family members with special needs, enrolls sponsors in the program, and participates in the coordination of assignments for active duty Service members in order for the special needs of family members to be considered during the assignment process. Active duty Service members whose families include a member with special needs must enroll in the EFMP to ensure their family members’ special needs are considered during the assignment coordination.
The changes are extensive, this is just a sampling. Please refer to the document here for more information.
So what are the DoD’s proposed changes?
The DoD is proposing changes that will streamline the process for EFMP families to get the support they need. This proposed rule would:
- Establish the Office of Community Support for Military Families with Special Needs.
- It would be housed within the Office of the Under Secretary of Defense for Personnel and Readiness.
- It would improve DoD oversight and support around the world for military families with special needs through the development of appropriate policies and support for families in obtaining services and referrals.
- The Office of Community Support for Military Families with Special Needs would be responsible for developing an EFMP policy that addresses the development and implementation of a community support program across the Services, and expand coordination of assignments for military families with special needs within and outside the United States.
- Refine criteria for identifying families with special needs. Individuals who meet one or more of the criteria in this section will be identified as a family member with special medical needs:
- Potentially life-threatening conditions or chronic (duration of 6 months or longer) medical or physical conditions requiring follow-up care from a primary care manager more than once a year or specialty care.
- Current and chronic (duration of 6 months or longer) mental health condition; inpatient or intensive outpatient mental health service within the last 5 years; or intensive mental health services required at the present time.
- A diagnosis of asthma or other respiratory-related diagnosis with chronic recurring symptoms that involves one or more of the following: (i) Scheduled use of inhaled or oral anti-inflammatory agents. (ii) History of emergency room use for acute asthma exacerbations or other respiratory related diagnosis within the last year. (iii) History of one or more hospitalizations for asthma, or other respiratory-related diagnosis within the past 5 years.
- A diagnosis of attention deficit disorder or attention deficit hyperactivity disorder that involves one or more of the following
- A chronic condition that requires: (i) Adaptive equipment. (ii) Assistive technology devices or services. (iii) Environmental or architectural considerations.
- Special Educational Needs. Family members of active duty Service members (regardless of location) and civilian employees appointed to an overseas location eligible for enrollment in a DoDEA school that have an IFSP or an IEP.
- Establish requirement for the Office of Community Support for Military Families with Special Needs:
- Submit an annual report to Congress pursuant to their activities, including identification of gaps in services for military families with special needs and actions being taken or planned to address such gaps.
- Consult with the Secretaries of the Military Departments, as appropriate, to ensure the development, implementation, and monitoring of an effective EFMP across DoD, in accordance with this part.
- Requires the Military Services and DoD Education Activity (DoDEA) to notify the office of additions, deletions, or substitutions to the locations of special education in overseas military communities.
- Convenes a meeting at least once a year to review implementation.
- Ensures that there is a medical case management program to support military families with special medical needs.
- Establish requirements for the Secretaries of the Military Departments:
- Establish guidance consistent with this rule and ensure leadership oversight at all levels of military command for implementation, monitoring, and evaluation.
- Program, budget, and allocate sufficient funds and other resources, including staffing, to meet the policy objectives.
- Establish an EFMP within their Department that includes identification and enrollment, assignment coordination, and family support services components; and promote collaboration between the three components.
- Ensure that when a family member of an active duty Service member is identified within a military treatment facility with a medical condition that meets criteria, that the Service member is referred to the Service-specific EFMP point of contact.
- Guidance on coordinating assignments of active duty Service members who have a family member with special needs.
- Family member travel at government expense overseas may be denied when an active duty Service member has a family member with special medical needs and the services to meet those needs are unavailable in a duty location.
- Active duty service members may not be denied consideration for an essential duty assignment overseas solely because they have children who are or may be eligible for special education services. They will receive the same consideration for travel at government expense to any duty location as families without such members.
- Provision of family support services.
- Provide information and referral to military families with special needs.
- Provide assistance, including nonclinical case management to families of active duty Service members.
- Refer families who have serious or complicated medical issues to the military treatment facility to request medical case management.
- Conduct ongoing outreach with military units, individuals and their families, other service providers, and military and community organizations to promote an understanding of the EFMP and to encourage families with special needs to seek support services when needed.
- Provide assistance before, during and after relocation, including coordination of services with the gaining installation’s EFMP family support services program.
- Educate and provide assistance to Service members and their families about EFMP family support services, the enrollment and assignment coordination process, resources, and other topics as appropriate.
- Family support services may include respite care services for family members regardless of the age of the family member
Why the changes are important?
These changes have been advocated for by grassroots organizations for years. Particularly the coordination of care and the seamless integration of services regardless of branch. I am the mother of two special needs children. When my husband was active duty for the Guard, my sons had adequate care through EFMP and ECHO. The process was long, and it took almost 9 months to get them through the application process. We were on a base of a sister branch, not our own. This complicated matters. Sadly, we were only on the program for three months, then my husband returned from Active duty. My sons were then removed from the program. We had to start the process of hunting for services all over again. We had to start from square one. In the meantime, my son’s did experience some regression. Luckily, the school system stepped in to help, but in the summer those services were gone as well. The changes here could go a long way towards helping our special needs families in the military.
What does this mean?
- The pros – There will be greater consistency for families, regardless of branch, and there will be greater coordination and support. Additionally, there are clearer guidelines and reporting requirements that help ensure that there is follow through regardless of branch of service.
- The potential risks – The regulation changes do not take into consideration different types of families and unique cases and situations. Additionally, it does not provide for Guard and Reserve families in a consistent manner. They are only considered while the member is in active duty status – so coordination and continuity of care suffers for the EFMP family member as the service members cycles from active to regular reserve duties.
- The good news – families have a chance to weigh in, let decision-makers know about your family’s situation. This is an unprecedented time, years in the making. It is time for you to share your thoughts and concerns. Make your voice heard!
What can you do about it?
- You have a chance to get involved in the process. Public comments are invited. This rulemaking is being issued as a proposed rule. DOD invites public comments on all provisions of the proposed rule. All submissions will be considered for possible revision to be included in the final rule.
- In order to provide comment, you must either send the comments via Federal Rulemaking Portal: http://www.regulations.gov/#!docketDetail;D=DOD-2011-OS-0127 , or you can mail your comments. To mail your comments use the following address:
Department of Defense,
Office of the Deputy Chief Management Officer,
Directorate of Oversight and Compliance,
Regulatory and Audit Matters Office,
9010 Defense Pentagon,
Washington, DC 20301–9010
- In both instances you will need to identify the organization name, the RIN # (0790-A182) and/or the Docket ID number (DOD-2011-OS-0127). Remember that your opinion counts. Whether you agree with a proposed change or not be sure to express your thoughts.