Freedom of Information/ Privacy Act Office (12-00713) CREW 1400 Eye Street, N.W. Suite 450 Washington, D.C. 20005 Dear Mr. Alcorn,

30 July 2012

This is in response to your Freedom of Information Act request of 13 March 2012 for records pertaining to U.S. Army guidance regarding the diagnosis, alternate diagnosis and benefit appeals of Traumatic Brain Injury (TBI) and Post Traumatic Stress Disorder (PTSD). (Enclosure 1) Your request was referred by the U.S. Army Freedom of Information Act Office to the Headquarters, U.S. Army Medical Command Freedom of Information Act Office for processing and response to you. This referral was received on 19 March 2012 and processed in accordance with the Freedom of Information Act, 5 United States Code (U.S.C.) § 552 and the Office of the Secretary of Defense (aS D), Memorandum for the Secretaries of the Military Departments, Subject: Withholding of Information that Personally Identifies DoD Personnel, dated September 1,2005. I apologize for the delay in responding to your request due to the need to coordinate with a number of agencies, the move to a new office facility and a backlog of requests. That review has been completed. Releasable responsive documents are enclosed. (Enclosure 2- DVD) Information is being withheld pursuant to Title 5, USC, Section 552 of the Freedom of Information Act, Exemption 4 which permits the withholding of records related to trade secrets and other confidential business information; Exemption 5 which permits an agency to withhold information under the deliberative process privilege, including the pre-decisional documents, or information that could be withheld under civil discovery, attorney-client, or attorney-work product privileges; and Exemption 6, which permits the government to withhold information about individuals when the disclosure would constitute a clearly unwarranted invasion into the personal privacy of a third person and the above referenced OSD policy memorandum intended to protect the security and privacy concerns of DoD personnel. (Enclosure 3) The Headquarters, U.S. Army Medical Command AR 15-6 Report of Investigation (ROI) of Madigan Army Medical Center (MAMC) Behavioral Health Role in the Integrated Disability Evaluation System (IDES), responsive to your request, is currently at the Department of the Army level for their review. Once finalized the ROI will be processed and coordinated with the Office of the Surgeon General/U.S. Army Medical Command Directorate of Communications for media/public release. At that time a copy of the ROI will be forwarded to you.

Because your request has been partially denied, you are advised of your right to appeal this determination to the Secretary of the Army. If you decide to appeal at this time, your appeal must be submitted within 60 days of the date of this letter. In your appeal, you must state the basis for your disagreement with the partial denial and the justification for the release of information associated with your request for this command. Your appeal should be addressed to: CDR U.S. Army Medical Command, Attention: Freedom of Information/Privacy Acts Office (MCPA), 2748 Worth Road STE 21, Fort Sam Houston, Texas 78234-6021, for forwarding, as appropriate, to the Office of the Secretary of the Army. Please enclose a copy of this letter along with your Appeal. To ensure proper processing of any appeal, the letter and the envelope should both bear the notation, "Freedom of Information Act Appeal." Should you have any questions regarding the processing of the enclosed document I may be reached at (210) 221-7826 or email


John P. Peterson Chief, Freedom of Information/ Privacy Acts Office U.S. Army Medical Command Enclosures




.f=-p-td-.-D/lo 163 PIA- -fa "7" 0300

citizens for responsibility and ethics in washington

March 13,2012
By Facsimile (703-428-6522) and Email (

FOIA Officer Freedom of Information Act Office U.S. Department of the Army 7701 Telegraph Road
Suite 144

Alexandria, VA 22315-3905 Re: Freedom of Information Act Request Dear Sir or Madam:
. . Pursuant to the Freedom of Information Act ("FOIN'), 5 U.S.C. §§ 552, et seq., and U.S. Department of Army regulations, 32 C.F.R. Part 518, Citizens for Responsibility and Ethics in Washington ("CREW") makes the following request for records.

. First Request - Traumatic Brain Injury First, CREW seeks any and all records from the U.S. Army, dating from March 19, 2003 to the present, relating to any and all guidance given to any Army staff, consultants, and/or other recipients of federal funds regarding the diagnosis of a traumatic brain injury C'TBI"), alternative diagnoses that should or could be made in lieu of diagnosing TBI, and guidance on TBI diagnoses as they relate to benefit appeals. CREW also seeks records reflecting any Army investigation of such guidance or practices during the same period. As used herein, guidance includes both formal and informal guidance, advice, and recommendations, no matter how memorialized. Please note, CREW is not seeking records about individual soldiers or individual soldier applications for benefits.
Second Request - Post Traumatic Stress Disorder

Second, CREW seeks any and all records from the U.S. Army, dating from April 18, 2009 to the present, relating to any and all guidance given to any Army staff, consultants, and/or other recipients of federal funds regarding the diagnosis of post traumatic stress disorder ("PTSD"), alternative diagnoses that should or could be made in lieu of diagnosing PTSD, and guidance on PTSD diagnoses as they relate to benefit appeals. CREW also seeks, records reflecting any Axmy investigation of such guidance or practices during the sarne period. As used herein, guidance includes both formal and informal guidance, advice, and recommendations, no

1400 Eye Street, N.W., Suite 450. Washington, D.C. 20005


202.408.5565 phone





ForA Officer March 13,2012 Page Two matter how memorialized. Please note, CREW is not seeking records about individual soldiers or individual soldier applications for benefits. Please search for responsive records regardless of format, medium, or physical characteristics. Where possible, please produce records electronically, in PDF or TIF format on a CD-ROM. We seek records of any kind, including electronic records, audiotapes, videotapes, and photographs. Our request includes any telephone messages, voice mail messages, daily agenda and calendars. Information about scheduled meetings and/or discussions, whether illperson or over the telephone. agendas for those meetings and/or discussions, participants included in those meetings and/or discussions, minutes of any such meetings and/or discussions, the topics discussed at those meetings and/or discussions, e-mail regarding meetings and/or discussions, e-mail or facsimiles sent as a result of those meetings and/or discussions, and transcripts or notes of any such meetings and/or discussions. If it is your position that any portion of the requested records is exempt from disclosure, CREW requests that you provide it with all index of those documents as required under Vaughn v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1972). As you are aware, a Vaughn index must describe each document claimed as exempt with sufficient specificity "to permit a reasoned judgment as to whether the material is actually exempt under ForA." Founding Church of Scientology v, Bell, 603 F.2d 945,949 (D.C. Cir. 1979). Moreover, the Vaughn index must "describe each document or portion thereof withheld, and for each withholding it must discuss the consequences of supplying the sought-after information." King v. us. Dep'l of Justice, 830 F.2d 210,223-24 (D.C. Cir. 1987) (emphasis added). Further, "the withholding agency must supply' a relatively detailed justification, specifically identifying the reasons why a particular exemption is relevant and correlating those claims with the particular part of a withheld document to which they apply." ld. at 224 (citing Mead Data Central v, Dep 't a/the Air Force, 566 F.2d 242,251 (D.C. Cir. 1977).


In the event that some portions of the requested records are properly exempt from disclosure, please disclose any reasonably segregable non-exempt portions of the requested records. See 5 U.S.C. § 552(b). If it is your position that a document contains non-exempt segments, but that those non-exempt segments are so dispersed throughout the document as to make segregation impossible, please state what portion of the document is non-exempt, and how the material is dispersed throughout the document. Mead Data Central, 566 F.2d at 261. Claims of nonsegregability must be made with the same degree of detail as required for claims of exemptions in a Vaughn index. If a request is denied in whole, please state specifically that it is not reasonable to segregate portions of the record for release.
Fee Waiver Request

In accordance with 5 U.S.C. § 552(a)(4)(A)(iii) and 32 C.F.R. § 518.19(d), CREW

FOIA Officer March 13,2012 Page Three requests a waiver of fees associated with processing this request for records based on the fact that a waiver is in the public interest and CREW is a member of the media. Public Interest Fee Waiver Request The subject of this request concerns the operations of the federal government and expenditures, and the disclosures will likely contribute to a better understanding of relevant government procedures by CREW and the general public in a significant way. Moreover, the request is primarily and fundamentally for non-commercial purposes. 5 U.S.C. § 552(a)(4)(A)(iii). See, e.g., McClellan Ecological v. Carlucci, 835 F.2d 1282, 1285 (9th Cir. I 987)_ Specifically, these records are likely to contribute to greater public awareness of the processes the Department of the Army employs in treating soldiers with TBI and PTSD, and the extent to which medical personnel are under pressure to make alternative, less costly diagnoses. News media reports document multiple and continuing problems with these diagnoses, including pressure within the U.S. Army to under-diagnose TBI and PTSD. For example, a recent CBS News report stated, «Diagnoses of'post-traumatic stress disorder at an Army Medical Center located at the home base of the soldier accused of fatally shooting 16 Afghan civilians has been under scrutiny by Army investigators. The forensic psychiatry unit at Madigan Army Medical Center had come under fire for reversing diagnoses ofPTSD for nearly 300 service members during the past five years. The head of Madigan Healthcare System was recently placed on administrative leave." CBS News, PTSD Diagnoses at Lewis-McChord Reexamined; March 13, 20 12 (copy attached). A recent NPR story discloses systemic problems at Lewis-McChord. Martin Kaste, Lewis~McChord Soldiers Generate Alarming Headlines, NPR News, March 13, 2012 (available at http://V\''lft=Lzf=J). NBC Nightly News with Brian Williams reported on March 12, 2012, that according to Army sources, the soldier held in the killing of 16 Afghan civilians had suffered a traumatic brain injury in Iraq several years ago. See CREW is a non-profit corporation, organized under section 501 (c)(3) of the Internal Revenue code. CREW is committed to protecting the public's right to be aware of the activities of government officials and to ensuring the integrity of those officials. CREW is dedicated to empowering citizens to have an influential voice in government decisions and in the government decision-making process. CREW uses a combination of research, litigation, and advocacy to advance its mission. The release ofinformation garnered through this request is not in CREW's financial interest. In addition, CREW will disseminate any documents it acquires from this request to the public through its own website, www.citizensforethics.ol'g, which includes links to an interactive website CREW founded that includes thousands of pages of public documents CREW has acquired through FOIA requests, and from a number of organizations in

ForA Officer March 13,2012 Page Four addition to CREW. CREW's website also contains links to thousands of pages of documents CREW acquired from multiple FOIA requests. See CREW's website also includes documents relating to CREW's FOIA litigation, Internal Revenue complaints, and Federal Election Commission complaints. Under these circumstances, CREW fully satisfies the criteria for a fee waiver.
News Media Fee Waiver Request

CREW also asks that it not be charged search or review fees for this request because CREW qualifies as a "representative of the news media" pursuant to the FOIA and 32 C.F.R. § 518.19(d). In National Sec. Archive v. U.S. Dep't of Defense, 880 F.2d 1381, 1386 (D.C. Cir. 1989), the Court of Appeals for the District of Columbia Circuit found that the National Security Archive was a representative of the news media under the FOIA. The court noted that the legislative history of the FOIA indicated the phrase "representative of the news media" was to be interpreted broadly. Id. In support, the court cited Senator Patrick Leahy: lilt is critical that the phrase 'representative of the news media' be broadly interpreted if the act is to work as expected .
. . . In fact, any person or organization which regularly publishes or disseminates in/ormation to the public __ . should qualify for waivers as a 'representative of the ne'ws media" 132 Congo Rec.

S14298 (daily ed, Sept. 30, 1986) (emphasis added). l!t


CREW routinely and systematically disseminates information to the public in several ways. First, CREW maintains a frequently visited web site. www.citizensforethics.ol'Q_ which received 45,489 page visits in February 2012. The website reports the latest developments and contains in-depth information about a variety of activities of government agencies and officials. In addition, CREW posts all of the documents it receives under the FOlA on and that site has received 1,760,457 visits to CREW's documents since April 14,2010. Second, since May 2007 CREW has published an online newsletter. CREWCuts, which currently has 16,867 subscribers. CREWCuts provides subscribers with regular updates regarding CREW's activities and information the organization has received from government entities. A complete archive of past CREWCuts is available at Third, CREW publishes a brag, Citizens blogging for responsibility and ethics in Washington, which reports on and analyzes newsworthy developments regarding government ethics and corruption. The blog, located at htt;p:/I-www.citiznesforethics.orglblog. also provides links that direct readers to other news articles and commentary on these issues. CREW's blog had 6,260 page hits in February. ' Finally, CREW has published numerous reports to educate the public about government

FOIA Officer March 13,2012 Page Five ethics and corruption. Examples include The Seemingly Intractable Problem 0/ Domestic Abuse in the Department of Defense, documenting the failure of the Department of Defense to monitor acts of domestic violence committed by soldiers, available at Based on these extensive publication activities, CREW qualifies for a fee waiver as a "representative of the news media" under the FOIA and agency regulations. If yon have any questions about this request or foresee any problems in releasing fully the requested records, please contact me at (202) 408-5565. Also, if CREW's request for a fee waiver is not granted in full, please contact me immediately upon making such determination. Please send the documents to Anne L. Weismann, Citizens for Responsibility and Ethics in Washington, 1400 Eye Street, N.W., Suite 400, Washington, D.C. 20005.

Chief Counsel Enclosure


March 12, 201211:31 AM

PTSD diagnoses at Lewis-McChord reexamined

(CBS/AP) Diagnoses of post-traumatic stress disorder at an Army Medical Center located at the home base of the soldier accused of fatally shooting 16 Afghan civilians has been under scrutiny by Army investigators.

The forensic psychiatry unit at Madigan Army Medical Center had come under fire for reversing diagnoses ofPTSD for nearly 300 service members during the past five years. The head of Madigan Healthcare System was recently placed on administrative leave. TIle Army initiated an investigation following an Army ombudsman's memo indicating that hospital officials were encouraging psychiatrists to limit diagnoses of PTSD in order to reduce costs. Madigan is Located at Joint Base Lewis-Mcohord near Tacoma, Wash., which has sent tens of thousands of soldiers to Iraq and Afghanistan. It is home base not only of the soldier accused in this weekend's shooting of civilian women and children in Afghanistan, but also Staff Sgt. Calvin Gibbs, who was recently convicted of killing Afghan civilians for sport. It's also the base of Iraq Mount Rainier National park.) "Beltway Sniper" Washington, D.C. - was War veteran Benjamin Colton Barnes, the suspect in the killing of a Park ranger on New Year's Day. (Barnes' body was later found in the John Allen Muhammad ~ executed in 2009 for killing 10 people around also stationed at Lewis-McChord.

It is unknown what, if any, role PTSD played in the case of Sunday's attack. Shooting suspect is from troubled U.S. base Afghan !'ampage: Suspect's motive a big unknown U.S. soldier held in deaths of 16 Afghans PTSD is a condition which results from experiencing or seeing a trawnatic event, such as a battlefield casualty. Symptoms can include recurrent nightmares, flashbacks, irritability and feeling distant from other people. Soldiers are often diagnosed with PTSD as they move through the Army medical system. The forensic team at Madigan was charged with making a final diagnostic review of soldiers under consideration for retirement. In 2008 the Rand Corporation had estimated that one in five veterans of fighting in Iraq or Afghanistan suffers from major depression or PTSD. The ombudsman's memo, as reported in The Seattle News" Tribune, quoted a Madigan Army psychiatrist telling a September 20 l lmeeting of medical center clinicians not to simply "rubber stamp" a soldier's PTSD diagnosis, which could allow the service member to retire with disability and lifetime health benefits ranging between $400,000 and $1.5 million. The psychiatrist stated that "we have to be good stewards of the taxpayers' dollars, II and warned PTSD diagnoses could lead to the Army and Department of Veterans Affairs going broke. In February the Seattle Times reported that the head of Madigan Healthcare System, Col. Dallas Homas, was administratively removed from command less than a year after taking over. "This is a common practice during ongoing investigations and nothing more," Maj. Gen. Phillip Volpe, head of Western Regional Medical Command, told the Associated Press. Madigan's PTSD screeners were also suspended from duty as Alroy Medical Command investigates the reversed. diagnoses. The staff at Madigan has denied they were pressured by commanders to limit PTSD diagnoses. Earlier this year 14 soldiers were re-evaluated after complaining that their PTSD diagnoses had been reversed by Madigan. (Six of the 14 had their PTSD diagnoses reinstated.) Last week, it was armounced that an additional 285 patients had been identified as having had their PTSD diagnoses reversed at Madigan since 2007. The soldiers will be invited to undergo new evaluations, either at Madigan or at other military facilities.

Study: Veterans with PTSD are more likely to get addictive pain med prescriptions Soldier Takes H,lge Risk to Get PTSD Help Army RepOlts Record Number of Suicides






1 2005

MEMORANDUM FOR SECRETARIES OF THE MILITARY DEPARTMENTS CHAIRMAN OF THE JOINT CHIEFS OF STAFF UNDER SECRETARIES OF DEFENSE ASSISTANT SECRETARIES OF DEFENSE GENERAL COUNSEL OF THE DEPARTMENT OF DEFENSE DIRECTOR, OPERATIONAL TEST AND EVALUATION INSPECTOR GENERAL OF THE DEPARTMENT OF DEFENSE ASSISTANTS TO THE SECRETARY OF DEFENSE DIRECTOR, ADMINISTRATION AND MANAGEMENT DIRECTOR, PROGRAM ANALYSIS AND EVALUATION DIRECTOR, NET ASSESSMENT DIRECTOR, FORCE TRANSFORMATION DIRECTORS OF THE DEFENSE AGENCIES DIRECTORS OF THE DOD FIELD ACTIVITIES SUBJECT: Withholding of Information that Personally Identifies DoD Personnel This guidance was previously issued on February 3, 2005, but its importance mandates that it be published again to reinforce significant security considerations. Organizations outside the Federal Government often approach DoD personnel to obtain updated contact information for their publications, which are then made available to the general public. The information sought usually includes names, job titles, organizations, phone numbers, and sometimes room numbers. The Director, Administration and Management, issued a policy memorandum on November 9, 2001 (attached) that provided greater protection of DoD personnel in the aftermath of9111 by requiring information that personally identifies DoD personnel be more carefully scrutinized and limited. Under this policy, personally identifying information may be inappropriate for inclusion in any medium available to the general public. A December 28, 2001, memorandum from the Assistant Secretary of Defense for Command, Control, Communications and Intelligence (attached) issued a policy limiting publication of personally identifying information on web sites. The following policy augments the above cited memoranda and is in effect with regard to publication of information that personally identifies DoD personnel in publications accessible by the general public. In general, release ofinfonnation on DoD personnel will be limited to the names, official titles, organizations, and telephone numbers for personnel only at the office director level or above, provided a determination is made that disclosure does not raise security or privacy concerns. No other information, including room numbers, will

OSD 17746-05

normally be released about these officials. Consistent with current policy, as delineated in the referenced memoranda issued in 2001, information on officials below the office director level may continue to be released if their positions or duties require frequent interaction with the public. Questions regarding this policy should be directed to Mr. Will Kammer, Office of Freedom of Information, at 703-696-4495.

Attachments: As Stated cc: Secretary of Defense Deputy Secretary of Defense

Howard G. Becker Deputy Director






SI, 2001

MANAGE ..... T


Withholding of Personally Identifying Information Under lhe Freedom of Information Act (pOIA)

The President hu declared a national,emergency by reason oftbe terrorist attacks on the United StatCi. In the attached memorandum, the Deputy S~ of nereue emphuizes the responsibilities all DoD pcnonnel have towards operations ICCUrityand the inaaaed risb to US military and civilian personnel, DoD operational capabilities, facilitic. and resources. All Department of Defense pel'S9Mel should have a heightened lCCurity awareness concomi:"lg their day-to-dly duties and recognition thar the incrcuod security posture will mnain a fact of life for an indermite period of time. This change in our security posture has implications for the Defense:Dcpartment's policies implementing tbe Fieedom of Infonnation Act (FOIA). Presently an DoD componcnla withhold, unclet' S USC § SS2(b)(3), the personally identifying infonnation (name, rank, duty address, official title, and information Mgarding the person'. pay) ofmilitlry and civilian personnel who arc IIsigned overseas, on board Ihip, or to sensitive or routinely deployable unitl. Names and other infonnation regarding DoD peraonnel who did not moet thcae criteria have been routinely releaaed when requested under the FOlA. Now, since DoD penonnelarc It increased rilk regardless of their duties or Ulianment to IUch • uni~ releue of nunes and other personal infonnation must be more carefully scrutinized and limi~. I have therefore detcnnined thia policy requires revision. Effective imrnodiatcly, personally identifying information (to include lilts of e-mail addrealel) in the categorica Jilted . below must be carefully conlidered and the interesla supporting withholding of the infonnation given more serious weight in the'lnalysis. Thi. information may be found to be exempt under S USC § S52(b )(6) becaUJe of the heightened interest in the penonal, privacy of DoD pcnonn~) that ilconcurrent with the increased security awareneu demanded in timea of national emergency. • Lists of personally idC!!1tifvinginformation of DoD por!Onnel: All DoD components ahall ordinarily withhold lists of names and other pcnonally identifyins infonnation of personnel currently or recently usi~cd within a particular component. unit, organization or office with the Department of Def~ in rcapanse to requC8ts ~dcr the FOIA. ,This is to include active duly military perlOlUlCl,civilian employees, contractors, members of the National Ouard and Reservcs, military dependents, and Coast Guard personnel when the eoast Ouard is operating a. a serviee in tho Navy. 1£ a particular request docs not raise


security or privacy concerns, namCI may be releiscd IS, for example, a list of a~tcndoes I meeling held more than 25 years ago. Particulu care shin be taken prior to any decision to rcJeue a lilt of names in any electronic format. . of pcrional.identifyjng inronnation about an individual is Ippropriate only if the re1eue would not raisc security or privacy concerns and hu been routinely rcleucd to the public. .


• Verification of status of Damed indiyjduals: DoD components may detennino that release

Names in documenta that don', rail into any of the JK5!C52ding gtO&orjeI: Ordinarily names of DoD personnel, other than lim of namn, mentioned in documents that are releuable under tho FOIA should not-be withbeld, but in apecilt circumstances where the releuo of I.particular name would raiae aubsbnlial security or privacy conccma, such • name may be withheld.

(b)(6) docs not fully protecl the component" or an individual's intueltl. In thiJ ClIO, pleue contact Mr. lim Hogan. Directorate ofFrecdom ofInfonnalion and Seeurity Revmv, It (703)

When' processing I FOIA

request, • DoD component may determine th,t exemption

697-4026, or DSN 227-4026.

This policy does not preclude I DoD component" disCretionary release of names and duty infonnation ofpenonncl who, by Iho nature of their position Ind duties, frequently interacl with .the public, such a& 11aglgcoCIII officm. public IfT.i" omeen, or OCher personnel designated as official command IpOkespenona ..

D. O. Cooke Director

Attachment: As stated






December Z8, ZOOl


SUBJECT: Removal of Personally Identifying Infonnation of DoD Personnel from Unclassified Web Sites In accordance with DoD 5400.7·R, "DoD Freedom of Infonnation Act Program," unclassified infonnation which may be withheld from the public by one or more Freedom ofInfonnation Act (FOIA) exemptions is considered For Official Use Only (FOUO). DoD Web Site Administration policy (www.defenseljnk.miVwebmasten), issued by Deputy Secretary of Defense memorandum, December 7, 1998, prohibits posting FOUO information to publicly accessible web sites and requires access and transmission controls on sites that do post FOUO materials (see Part V, Table 1). The attached November 9,2001, memorandum tram the Director, Administration and Management (DA&M), citing increased risks to DoD personnel, states. that personally identifying infonnation regarding all DoD personnel may be withheld by the Components under exemption.(bX6) of the FOIA, S USC §5S2. This·action makes the information which may be withheld FOUO and inappropriate for posting to most unclassified DoD web sites. Thus, a11personally identifying infonnation regarding DoD personnel now eligible to be withheld under the FOIA must be removed from publicly accessible web pages and web pages with access restricted only by domain or IP address (i.e., .mil restricted). This applies to unclassified DoD web sites regardless of domain (e.g., .com, .edu, .org, .mil, .gov) or sponsoring organization (e.g., Non-Appropriated FundlMoraJe, Welfare and



Recreations sites; DoD educational institutions). The information to be removed includes name, rank, e-mail-address, and other identifying information regarding DoD personnel, including civilians, active duty military, military family members, contractors, members of the National Guard and Reserves, and Coast Guard personnel when the Coast Guard is. operating as a service in the Navy. Rosters, directories (including telephone directories) and detailed organizational charts showing personnel are considered lists of personally identifying information. Multiple names of individuals from different organizationsllocations listed on the same document or web page constitutes a1ist. Aggregation of names across pages must specifically be considered. In particular, the fact that data can be compiled easily using , simple web searches means caution must be applied to decisions to post individual names. If aggregation of lists of names is possible across a single organization's web site/pages, that Jist should be evaluated on its merits and the individual aggregated elements treated accordingly. ' Individual names contained in documents posted on web 'siteli may be removed or left at the discretion of the Component, in accordance with the DA&M guidance. This direction does not preclude the discretionary posting of names and duty information of personnel who, by the nature of their position and duties, frequently interact with the public, such as flag/general officers, public affairs officers. or other personnel designated as official command spokespersons. Posting such information should be coordinated with the cognizant Component F01A or Public Affairs office. In keeping with the concerns stated in the referenced memorandum and in the October 18. 200 I, DepSccDef memorandum, "Operations Security Thoughout the Department of'Defense," the,posting of biographies and photographs of DoD personnel identified on public and .mil restricted web sites should also be more carefully scrutinized and limited. Sites needing to post contact infonnation for the public are encouraged to use organizational designation/title and organizational/generic position e-mail addresses (e,g.,;; Questions regarding Web Site Administration policy may be directed to Ms. Linda Brown. She can be reached at (703) 695-2289 and e-mail Questions regarding Component-specific implementation of the DA&M memorandum should be directed to the Component FOIA office'.



As stated

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