Comment on DOD-2009-OS-0089-0001

Priority of payment as proposed will go to those who were killed, wounded or injured in a combat zone. The DD 1607 does not include instructions to claim this priority. Personnel offices do not maintain Line of Duty (LOD) determinations nor do they maintain medical records that document injury. The rule as described and the current DD 1607 does not support DoD obtaining the required data to determine qualification for priority payment. If it is the intent of DoD to limit the priority to those awarded the Purple Heart or civilian equivalent, then the proposed rule should state as such clearly. As written, those injured in a combat zone and not eligible for the Purple Heart are not instructed to provide supporting documentation of injury. This lack of instruction will delay processing for those injured. From personal experience severe injuries requiring medical treatment or evacuation can occur due to combat operations but not due to enemy direct/indirect action. The DD 1607 should be modified to either instruct the applicant to claim priority payment and the appropriate documentation to validate the claim. A LOD and/or medical records should suffice. The LOD annotates that a Service Member was in a combat zone. Medical records do not. Utilizing the Veterans Administration (VA) disibility claim does not support claims for this program in a timely fashion. This option should be ruled out in that a Veteran's disability claim takes well over nine months even as a OEF/OIF veteran and receive priority treatment for disibility claim determination. Also, those Service Members still on Active Duty do not normally initiate a claim through the VA until discharge/retirement.