Comment on DOD-2008-OS-0100-0001

Role of SARC and SAPR-VA: These positions are very complex and have far reaching responsibilities. They are the backbone of the SAPR Program for DoD. With only 40 hours of training, I am concerned about how prepared these people are who are to provide the required training for others and to provide trauma-informed care and do victim safety assessments. If the backbone of the program is weak, there will be a problem with program effectiveness. Collateral misconduct: This is a major issue for victims. It has a chilling effect on reporting and is a major source of re-victimization. This rule gives a commander discretion to defer action until final disposition of the sexual assault case. This is a major problem. The victim's misconduct is generally minor compared to the assault. Deferring action on the collateral misconduct should not be optional. It should be required. Reprisal: This is also a major problem area that impacts a victim's willingness to report and follow through. There are no specifics about what that policy should be. Is DoD planning to define this more specifically or leave it up to the Services to define for themselves? It seems like there should be some standardization and consistency across the Services. Record retention: Why does the policy allow keeping records and SAFE Kits in restricted reports for only 5 years and 50 for unrestricted reports? It also says a victim can request to keep records in restricted reports for 50 years. Who will ensure a victim knows this? This time-frame difference appears to be punitive for those making restricted reports and seems to be trying to force them to change to an unrestricted report. Commander accountability: This is a major problem area. Leaving it up to the Services seems doomed to maintain the status quo, a low level of accountability. Terminology: In reporting and data collection, need clear differentiation between sexual harassment and sexual assault, not "unwanted sexual contact." See uploaded file