JUNIOR RESERVE OFFICERS’ TRAINING CORPS

Additional Actions Needed to Improve Oversight and Prevent Instructor Sexual Misconduct

Report to Congressional Addressees

January 2026

GAO-26-107524

Highlights of GAO-26-107524, a report to congressional addressees.

For more information, contact: Kristy E. Williams at williamsk@gao.gov.

Why This Matters

The Department of Defense (DOD) has emphasized the importance of protecting students in the Junior Reserve Officers’ Training Corps (JROTC) from instructor sexual misconduct. DOD reported more than 100 misconduct allegations from 2013—2023. Legislation established new JROTC requirements in fiscal year 2024, in part to address concerns about sexual misconduct involving instructors and students.

GAO Key Takeaways

The military services partner with high schools to provide leadership training to students through JROTC, which DOD oversees.

In response to statutory requirements, DOD developed policies and procedures to prevent sexual misconduct in JROTC and respond to misconduct allegations. We identified issues that, if addressed, would aid DOD’s efforts:

·    The standardized memorandum of agreement (MOA)—which the military services sign with school districts—incorporates seven of 10 required provisions but does not fully incorporate three (see figure). For example, the MOA does not require schools to certify that they provide student training.

·    Instructor training does not consistently address Title IX, a law prohibiting sex-based discrimination in education. This makes instructors less likely to be aware of Title IX requirements.

·    Information provided to students on how to report misconduct is unclear and could be improved.

Gaps in DOD’s oversight of JROTC programs also exist. For example, DOD guidance does not clearly define how the military services’ regional officials are expected to coordinate and communicate with partner schools. Clarifying these responsibilities would improve program oversight and better ensure students’ safety.

Note: For more details, see figure 2 in GAO-26-107524.

How GAO Did This Study

We analyzed relevant statutes, documents, and policies on DOD’s prevention of and response to sexual misconduct in JROTC; reviewed the most recent 5 years of data on allegations; visited 11 high schools with JROTC programs in four states; and interviewed school officials, instructors, and DOD officials.

What GAO Recommends

We are making 16 recommendations, including for DOD to include all requirements in the MOA; standardize instructor Title IX training; better communicate information about reporting misconduct; and clarify oversight responsibilities. DOD did not provide comments on the report.

 

 

 

 

 

ASD(M&RA)	Assistant Secretary of Defense for Manpower and Reserve Affairs
DOD	Department of Defense
DODEA	Department of Defense Education Activity
JROTC	Junior Reserve Officers’ Training Corps
MOA	memorandum of agreement
NDAA	National Defense Authorization Act
OSD	Office of the Secretary of Defense
USD(P&R)	Under Secretary of Defense for Personnel and Readiness

January 20, 2026

Congressional Addressees

The Junior Reserve Officers’ Training Corps (JROTC) is a statutorily mandated academic program funded and administered by the military services in partnership with public and private high schools.[1] The program provides the nearly 500,000 students participating in JROTC programs in nearly 3,400 high schools worldwide with an opportunity to learn about the values of citizenship and service, while engaging in activities that provide leadership training and promote character development. Given the importance of JROTC to students and their communities, the Department of Defense (DOD) has stated its commitment to the safety and well-being of all JROTC participants and to holding program personnel accountable for any misconduct.[2]

 

What Is Sexual Misconduct? For purposes of this report, we use the term sexual misconduct to encompass a range of inappropriate behaviors. Specifically, sexual misconduct includes behaviors that violate Title IX of the Education Amendments of 1972—which generally prohibits sex discrimination in entities that receive federal funding, such as public schools. These behaviors include sexual harassment, sexual assault, and stalking (Title IX covers certain other forms of sex discrimination as well, which we did not include). Sexual misconduct also includes behaviors identified by the Department of Education as “adult sexual misconduct” in a school setting, including inappropriate verbal conduct, physical conduct, and online predatory behavior. Sexual misconduct includes behaviors that range from inappropriate to illegal, as well as breaches of school district codes of conduct or professional standards. Source: GAO analysis of statute and Department of Education information.  I  GAO‑26‑107524

In a 2023 letter responding to questions from several members of Congress, the Under Secretary of Defense for Personnel and Readiness (USD(P&R)) reported 114 allegations of misconduct by instructors toward JROTC students within the previous decade.[3] Further, a 2024 DOD report identified 21 allegations of sexual misconduct against JROTC instructors in academic year 2022–2023.[4]

The National Defense Authorization Act (NDAA) for Fiscal Year 2024 established new JROTC program requirements for DOD and the military departments, in part to address concerns about DOD oversight of the program and instructor misconduct. We were asked to review JROTC oversight and alleged sexual misconduct, including the implementation of new program requirements, and to evaluate DOD’s efforts to oversee JROTC programs and address any instructor misconduct. This report assesses the extent to which the Office of the Secretary of Defense (OSD) and the military services (1) have developed and implemented policies and procedures to prevent and respond to sexual misconduct in JROTC programs, (2) have quality data on reported allegations of sexual misconduct involving JROTC instructors, and (3) oversee JROTC programs.

For our first objective, we analyzed DOD and military service policies and procedures related to the prevention of and response to sexual misconduct in JROTC and compared them to statutory requirements. Additionally, we interviewed cognizant OSD and military service officials about their perspectives and responsibilities concerning sexual misconduct prevention and response. To obtain nongeneralizable perspectives about the implementation of these policies and procedures, we visited 11 public high schools in the continental United States with JROTC programs, where we interviewed high school and school district officials and JROTC instructors.[5] We selected schools based on representation of JROTC units for each of the military services and to ensure a mix of those that had and had not reported incidents of sexual misconduct in the past 5 academic years, among other things. We compared our review of guidance and information gathered through interviews to statute, DOD guidance, our prior work on results-oriented government, and the Standards for Internal Control in the Federal Government principle related to externally communicating quality information.[6]

For our second objective, we obtained and analyzed data from the military services on reported allegations of sexual misconduct involving JROTC instructors for academic years 2019–2020 through 2023–2024. We identified any recent changes in how such data were collected and reported. We assessed the reliability of these data by interviewing cognizant officials and reviewing the data to identify mistakes, anomalies, or illogical values, and determined that these data were sufficiently reliable for purposes of examining the extent to which OSD and the military services have quality data on reported allegations of sexual misconduct involving JROTC instructors. We also interviewed knowledgeable OSD and military service officials to discuss their processes for collecting and reporting data on allegations of sexual misconduct involving JROTC instructors and reviewed related OSD and service guidance. We compared information from our analyses of military service data, documents, and testimonial evidence obtained during interviews to Standards for Internal Control in the Federal Government principles related to using and internally communicating quality information.[7]

For our third objective, we reviewed military service guidance pertaining to JROTC program oversight and procedures for conducting JROTC unit inspections and assessed the extent to which they align with DOD guidance.[8] Further, we interviewed OSD and military service officials with responsibilities for program oversight and discussed the conduct of such oversight with high school and school district officials and JROTC instructors during our site visits. We compared information from our analyses of relevant guidance and other documentation and testimonial evidence obtained during interviews to DOD guidance and Standards for Internal Control in the Federal Government related to implementing and communicating control activities and demonstrating a commitment to competence.[9] For more information on our objectives, scope, and methodology, see appendix I.

We conducted this performance audit from April 2024 to January 2026 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Background

Overview of JROTC Programs

JROTC is a statutorily mandated program established and maintained by each military department and administered by the military services in partnership with public and private high schools.[10] The purpose of JROTC is to offer participating students an immersive military learning environment and instill in them the values of citizenship, service to the United States—including an introduction to service opportunities in military, national, and public service—and personal responsibility. JROTC units currently operate in all 50 states, as well as in U.S. territories and in Department of Defense Education Activity (DODEA) high schools.[11]

The National Defense Act of 1916 first established JROTC as an Army program, and it expanded to include programs in the Navy and Air Force in 1964.[12] In academic year 2021–2022, the Air Force selected 10 of its JROTC units to convert to Space Force JROTC units. The Space Force JROTC program is integrated into the Air Force program and administered by the Air Force. The Army has the largest JROTC program, with more than 1,700 total units and over 280,000 enrolled cadets in academic year 2024–2025. Table 1 provides the number of JROTC units and estimated cadet enrollment by military service.

Military service	Number of JROTC units, academic year 2025–2026	Estimated enrolled cadets, academic year 2024–2025
Army	1,754	282,774
Navy	583	77,430
Marine Corps	248	32,000
Air Force	804	94,813
Space Force	10	1,288
Total	3,399	488,305

Source: Military service information and officials.  | GAO‑26‑107524

Note: In addition to traditional JROTC units, some of the military services also oversee National Defense Cadet Corps (NDCC) units, which are similar to JROTC units but are not federally funded. The Army had 54 NDCC units at the start of academic year 2025–2026. A Navy official stated that the Navy had 55 NDCC units. An Air Force official stated that the Air Force had three NDCC units at the start of academic year 2025–2026. Marine Corps officials stated that the Marine Corps has no NDCC units.

Overview of JROTC Program Roles and Responsibilities

The JROTC program operates through a structured chain of oversight. Within DOD, the Assistant Secretary of Defense for Manpower and Reserve Affairs (ASD(M&RA)) in the Office of the USD(P&R) is responsible for setting policy, providing guidance, and overseeing the administration of JROTC programs.[13] In addition, ASD(M&RA) is responsible for monitoring incident reports from the military services regarding allegations of instructor misconduct, including alleged Title IX violations by JROTC instructors and staff, and reporting relevant incidents to the Office for Civil Rights within the U.S. Department of Education, as appropriate.[14] In coordination with the military services, the ASD(M&RA) is also responsible for providing resources and information on the JROTC program; associated instructor responsibilities and expected conduct for prospective JROTC students and their parents, guardians, or adults responsible for the student(s); and contact information for reporting misconduct.

The military services also have responsibilities specific to their respective JROTC programs, including conducting background checks for and certifying JROTC instructors. Further, the military services are responsible for conducting in-person assessments of individual JROTC units for compliance and performance objectives on an annual basis and making any necessary reports of alleged instructor misconduct to OSD.

JROTC host schools and their respective districts are required to adhere to relevant service policies and procedures and are bound by a Memorandum of Agreement (MOA) specifying these requirements. Host schools are responsible for providing classroom space, facilities, and administrative support for their JROTC units, including hiring instructors as school district employees and monitoring their performance. Additionally, school districts are responsible for notifying the military services of misconduct allegations involving JROTC instructors. See figure 1 for further details about DOD, military service, and school and school district responsibilities.

JROTC instructors are to serve as mentors to students; school and community leaders; and informal representatives of their military service. Instructors are hired as employees of the school district with additional oversight from the military services. Instructors are required to meet certain requirements set by the parent service, as well as policies set by their host schools. Generally, schools with JROTC units employ a minimum of one officer (Senior Military Instructor) and one enlisted member (Junior Military Instructor) on staff.[15]

Recent Statutory Changes to JROTC Programs

To help increase the pool of potential JROTC instructors, the James M. Inhofe NDAA for Fiscal Year 2023 and the NDAA for Fiscal Year 2024 expanded the eligibility requirements for JROTC instructors, requiring fewer years of military service and adding certain reservists and National Guard members. Additionally, the NDAA for Fiscal Year 2024 modified the instructor pay system.[16] The NDAA for Fiscal Year 2024 also included other statutory requirements for DOD related to the establishment and maintenance of JROTC programs. These include:

·         establishing a standardized MOA to be signed by host school districts and the relevant military service, that addresses, among other things, school reporting responsibilities related to instructor misconduct and the military services’ procedures for instructor certification and oversight;

·         increasing the number of required units to 3,400–4,000;

·         changing unit probationary procedures to allow the military services to suspend units after 3 years on probation if the unit remains in noncompliance with program requirements; and

·         submitting annual reports to congressional committees on sexual misconduct in JROTC programs from 2024 through 2029.

OSD and the Services Have Policies and Procedures to Prevent and Respond to Sexual Misconduct in JROTC; Several Implementation Issues Exist

OSD and the Military Services Have Policies and Procedures to Prevent and Respond to Sexual Misconduct in JROTC Programs

OSD and the military services have developed policies and procedures to prevent and respond to sexual misconduct in JROTC programs. Specifically, DOD Instruction 1205.13 establishes policy, assigns responsibilities, and provides procedures for the organization and administration of JROTC. The instruction directs the military services to ensure that MOAs with host schools and school districts require them to report allegations of instructor misconduct to the military service, which is then responsible for reporting allegations through its chain of command.[17] The instruction also includes provisions for (1) OSD to establish a dedicated, monitored email address for the military services to report allegations of instructor misconduct, and (2) the military services to document that JROTC instructors have been informed of prohibited activities. In addition, the instruction requires that all current and prospective JROTC instructors undergo a stringent background check that is standardized across the military services, as well as periodic reinvestigations.[18]

DOD Instruction 1205.13 further includes provisions to enhance departmental efforts to address sexual misconduct in the JROTC program. For example, it requires the use of a standardized MOA between the military services and school districts, which governs how the services and schools and school districts share information, among other things.

In accordance with section 552 of the NDAA for Fiscal Year 2024, OSD published a standardized MOA in 2024, which documents the terms of the partnership between the military services, host schools, and school districts in the administration of JROTC programs, including responsibilities for monitoring instructor performance and notifying the military services of alleged instructor misconduct.[19]

In addition, OSD developed two forms that the military services are required to use in the administration of their respective JROTC programs:

1.    Student Code of Conduct and Parent/Guardian Consent Form. This form outlines program and behavior expectations for students and instructors participating in the JROTC program, including prohibited actions under Title IX and points of contact to report violations.[20]

2.    Instructor Prohibited Activities Acknowledgement. This form details the types of conduct that instructors are prohibited from engaging in, including inviting students into their homes, attending social gatherings with students on a personal basis, and forming personal, intimate or sexual relationships with students. Each JROTC instructor is required to review and sign the form before they begin teaching and annually thereafter.[21]

In addition to DOD-level guidance, each military service has developed policies and procedures for preventing and responding to sexual misconduct within its respective JROTC program.

·         The Army’s JROTC policy provides guidance for executing its JROTC program in high schools and, among other things, outlines steps to address instructor misconduct, including any misconduct of a sexual nature.[22] In 2024, the Army began updating its JROTC Program Guide for school administrators to reiterate its commitment to ensuring the safety and well-being of program participants and holding instructors accountable for any incidences of misconduct. The updates to the guide also stress the importance of coordination between Army and school personnel in these efforts, and an Army official told us in July 2025 that they expect to publish the updated guide soon.[23] Service officials told us they are in the process of updating their policy to align with the recent updates to statute.

·         The Navy’s Regulations for Citizenship Development outline expectations for JROTC instructor behavior as well as procedures for reporting misconduct, including sexual misconduct.[24] In 2024, the Navy issued a memorandum titled JROTC Adult Sexual Misconduct Policy, which applies to both the Navy and Marine Corps and defines and provides examples of sexual harassment, sexual assault, and other prohibited misconduct.[25]

·         The Marine Corps’s JROTC policy assigns responsibility for investigating alleged instructor misconduct, including sexual misconduct, and outlines the role of unit inspections in preventing and detecting sexual harassment.[26] To further address such issues, the Marine Corps has developed procedures aimed at preventing and responding to sexual misconduct. For example, in 2023, the Marine Corps revised its unit inspection protocols to ensure instructors review the service’s sexual abuse policy with the inspector or school administrator. It also requires that a Cadet Assistance email address created by the service be clearly displayed in the classroom.

·         Air Force JROTC program guidance requires instructors to maintain professional relationships with both colleagues and students, while also preserving an environment that is free from sexual harassment, assault, and other related misconduct.[27] In August 2024, the Air Force issued a memorandum outlining changes to its JROTC instructor management policies. This memorandum requires that all instructors sign the instructor prohibited conduct form, as previously mentioned, within 30 days of the start of each school year. Furthermore, the memorandum states that failure to comply with this requirement may lead to the suspension, probation, or revocation of the instructor’s certification.[28]

Several Issues Hinder the Effectiveness of DOD’s Efforts to Prevent and Respond to Sexual Misconduct Allegations in JROTC

Several issues hinder the effectiveness of DOD’s efforts to prevent sexual misconduct and respond to allegations related to such behavior. Specifically, (1) OSD’s standardized MOA with school districts does not fully align with statutory provisions; (2) training provided to JROTC instructors on Title IX varies across the services; and (3) OSD and the military services do not effectively communicate information to JROTC students on how they can report incidents of sexual misconduct.

OSD’s Standardized Memorandum of Agreement with Schools Does Not Fully Incorporate Statutory Requirements

As previously discussed, OSD developed a standardized MOA that the military services are to sign with each host school district, but the form does not incorporate all the provisions required by statute. Specifically, section 552 of the NDAA for Fiscal Year 2024 specifies 10 elements that are to be incorporated in the MOA.[29] OSD’s standardized MOA includes seven of the 10 required provisions. For example, it requires the military services to annually evaluate the operation, administration, and effectiveness of the JROTC unit and establish a process for certifying instructors, including conducting background checks. See figure 2 for a complete list of these required elements and the extent to which the MOA incorporates them.

As shown in figure 2, our assessment determined that the MOA partially incorporates the provisions for schools to notify the military services about instructor misconduct allegations and for the services to oversee certified instructors. Further, the MOA does not incorporate the requirement that host schools certify that students have received certain training on sexual assault and sexual harassment.

School notification of instructor misconduct to the military services. The MOA requires school districts to notify the cognizant military service about alleged JROTC instructor misconduct within 1 business day of initiating an investigation or taking adverse administrative action against an instructor, but this may not meet the statute’s 48-hour notification requirement if an allegation arises before or during a weekend or school holiday. Further, the MOA requires school districts to notify the military services when an investigation is initiated or any administrative or employment action is taken against an instructor, which is not consistent with the statutory requirement for schools to notify the military service of allegations of instructor misconduct.[30]

Based on the current language in the MOA, an allegation of instructor misconduct that is resolved informally and not investigated could be excluded from reporting to the military services. Army JROTC officials told us they sometimes learn of incidents the school did not report to the Army. The officials indicated this could occur when a school conducts an internal investigation without removing the instructor from the classroom and finds no evidence of misconduct.

According to an OSD official, they presume that schools investigate all allegations of instructor misconduct. Thus, they believe that the MOA’s requirement for school districts to notify the military services about initiated investigations or adverse actions against an instructor for misconduct is consistent with the statute’s mandate to report any allegation. However, we identified at least one allegation of JROTC instructor misconduct that did not result in an investigation and thus was not reported to the relevant military service.

Oversight of instructors and expiration of instructor certifications. The MOA outlines the military services’ responsibilities for overseeing their certified instructors, including a requirement for annual performance assessments and a statement about the military services’ need-to-know regarding information related to instructor performance, conduct, and employment. The MOA also states that the military services have the authority to decertify JROTC instructors if they violate any portion of the MOA. However, the MOA does not incorporate the statutorily required clause that instructor certifications expire after a maximum of 5 years, or any language related to the expiration of instructor certifications.

In addition, not all military services have processes in place for certifications to expire on a regular basis. Specifically, Navy and Marine Corps officials told us their instructor certifications expire after 3 years and 5 years, respectively. Army policy states instructor certifications expire after 5 years, while Air Force officials stated that their instructor certifications do not expire on a regular basis, as discussed later in this report. An OSD official disagreed with our assessment that the MOA has not incorporated a requirement for certifications to periodically expire, stating that the military services are responsible for developing their instructor recertification processes. However, clarifying that the services are responsible for instructor certification processes does not address the fact that the MOA does not incorporate the requirement for instructor certifications to expire after a maximum of 5 years.

School certification of certain annual training for students. Though required by statute, the MOA does not require schools to certify that they provide annual training to students on preventing, responding to, and reporting incidents of sexual harassment and sexual assault.[31] Based on our meetings with selected school officials and JROTC instructors at 11 schools, we determined that the extent to which such training is provided and the material covered varies across schools. For example, officials at one school said they provide annual training to students on topics such as sexual grooming, while officials at another school said they provide students with annual training related to recognizing sexual harassment. In contrast, officials at other schools we visited said their schools do not provide students with any training related to sexual assault or sexual harassment.

According to an OSD official, students participating in JROTC are required to review and sign a student code of conduct form, which specifies that Title IX protects students from sex discrimination, provides examples of prohibited actions, and states that students should receive training annually to ensure they are fully aware of the law.[32] According to the OSD official, JROTC instructors review the form with students and the department believes that signing the form fulfills the statutory requirement. However, informing students of their rights through a form does not align with the requirement for the MOA to require schools to certify that they have implemented annual training to inform students of methods to prevent, respond to, and report incidents of sexual harassment and sexual assault.[33]

Section 552 of the NDAA for Fiscal Year 2024 identifies 10 elements that are to be incorporated into the MOA between the military services and host school districts. However, the current MOA does not fully incorporate all 10 elements because OSD has not taken steps to ensure that included provisions fully address all statutory requirements. Without a revised MOA that includes all statutorily required elements, OSD and the military services may not receive timely notification of all allegations of instructor misconduct. Further, schools may be unaware of requirements for instructor certifications to expire. In addition, OSD and the military services will continue to lack reasonable assurance that students are receiving required and necessary training on methods to prevent, respond to, and report sexual harassment and assault. As a result, OSD and the military services risk missing opportunities to more effectively prevent and respond to alleged sexual misconduct involving JROTC instructors.

JROTC Instructor Training on Title IX Varies Across the Services

DOD guidance requires the development of a standardized Title IX Compliance Course for JROTC instructors, which instructors are to take annually.[34] Title IX of the Education Amendments Act of 1972 generally prohibits sex discrimination in federally funded entities, including public schools. This includes conduct such as sexual harassment, sexual assault, and stalking.[35]

There is no standardized list of topics that should be included in Title IX training. Each military department has opted to develop its own training curriculum, which has resulted in varying content and level of training being provided to instructors. The Departments of the Army and the Navy have developed Title IX training which they require all their JROTC instructors to complete according to Army and Navy officials.

·         Army. The Army provides training that is designed to equip instructors to articulate their understanding of Title IX’s scope and jurisdiction, identify various forms of harassment that violate Title IX, and recognize conduct that constitutes sexual harassment, among other things. Specifically, the Army’s training outlines six types of harassment that violate Title IX and includes definitions for four of these types.[36] The Army’s training also includes information on the applicability of Title IX, school responsibilities under Title IX, prohibitions against retaliation for reporting Title IX violations, and exercises that require instructors to identify whether various scenarios may qualify as Title IX violations. See table 2 for excerpts from the Army’s training that address the types of behaviors that violate Title IX.

Category of sexual harassment per Army Title IX training	Definition
Hostile environment	Unwelcome conduct determined by a reasonable person to be so severe, pervasive, and objectively offensive that it effectively denies a person equal access to the recipient’s education program or activity.
Quid pro quo	When an employee of the educational institution promises some aid, benefit, or service in exchange for another’s participation in unwelcome sexual conduct.
Sexual assault	Includes ·          Rape: having carnal knowledge of a person, without the consent of the victim, including instances where the victim is incapable of giving consent because of age or because of temporary or permanent mental or physical incapacity. There is “carnal knowledge” if there is a bodily connection with another by way of sexual intercourse. Attempted rape is included. ·          Sodomy: Oral or anal sexual intercourse with another person without the consent of the victim, including instances where the victim is incapable of giving consent because of age or because of temporary or permanent mental or physical incapacity. ·          Fondling: Touching of the private body parts of another person for the purpose of sexual gratification, without the consent of the victim, including instances where the victim is incapable of giving consent because of age or because of temporary or permanent mental or physical incapacity.
Stalking	Engaging in conduct focused on a specific person that would cause a reasonable person to ·          Fear for their safety ·          Fear for the safety of others ·          Suffer substantial emotional distress

Source: GAO analysis of Army training.  |  GAO‑26‑107524

·         Navy. The Department of the Navy’s training on sexual misconduct that is administered by the Navy and the Marine Corps includes some information on Title IX. Similar to the Army, the Navy training includes a definition of sexual harassment under Title IX, as well as the definition of sexual assault (see text box). Further, the Navy’s training covers topics such as risk factors for sexual misconduct, how to identify sexual grooming behaviors, the effects of sexual misconduct on students, and prevention strategies, among other things. While these are important topics for sexual misconduct training, the training does not explicitly link them to Title IX even though they are pertinent to the statute.

Definitions Included in the Department of the Navy’s Title IX Training for Junior Reserve Officer’s Training Corps Instructors Sexual Harassment refers to conduct on the basis of sex that satisfies one or more of the following: 1.     An employee of the [school] conditioning the provision of an aid, benefit, or service of the [school] on an individual’s participation in unwelcome sexual conduct; 2.     Unwelcome conduct, determined by a reasonable person to be so severe, pervasive, and objectively offensive that it effectively denies a person equal access to the [school]’s education program or activity; or 3.     Sexual assault, dating violence, domestic violence, or stalking. Sexual Assault includes any sexual act including rape, sodomy, sexual assault with an object, or fondling directed against another person, without consent of the victim, including instances where the victim is incapable of giving consent.

Source: GAO analysis of Department of the Navy information.  I  GAO‑26‑107524

The Air Force’s training is more limited in scope and, as of July 2025, had been provided to a subset of instructors who attended training in the summer of 2024, according to Air Force officials. Specifically, an Air Force official stated that the service conducted a brief training for 104 instructors—approximately 7 percent of its JROTC instructor population—in the summer of 2024. Air Force officials stated in July 2025 that they had revised the course and planned to provide it to another subset of JROTC instructors in the summer of 2025. These officials further stated that they intended to continue to evolve the course and eventually provide it to all Air Force JROTC instructors. However, a senior Air Force official said that the service has not yet developed and implemented a mandatory annual Title IX training course for all instructors.

Further, although the training provided in 2024 was titled “Title IX,” it included limited information on the statute. Specifically, it included excerpts from Air Force and OSD policy documents outlining instructors’ responsibilities as mandatory reporters and for ensuring a safe environment for students that is free from sexual harassment and sexual assault. However it did not address how they relate to Title IX.

The training did not include definitions of behaviors that violate Title IX, such as those provided in the Army’s and the Navy’s trainings. There was also no discussion of scenarios that could constitute Title IX violations. Rather, the training includes guidance for instructors on how to respond if they are accused of misconduct. For example, an Air Force official stated that instructors are advised to cooperate with any investigation, avoid actions that could be viewed as reprisal, and notify the Air Force of the allegation within 24 hours of learning of it. The training further advises instructors to “keep their hands to themselves” and “choose their words carefully.” Air Force officials stated that these sections of the training are designed to teach instructors to avoid or eliminate words and behaviors that could generate a negative perception or result in a complaint of sexual harassment, inappropriate touch, or verbal harassment.

DOD Instruction 1205.13 states that the Secretaries of the Military Departments, led by the Office of the USD(P&R) and in consultation with the Department of Education, are to develop, publish, and implement a standardized Title IX Compliance Course for all new JROTC instructors, with annual revalidation training required for all instructors. Moreover, our prior work on results-oriented government has identified key practices, such as defining common outcomes and clarifying roles and responsibilities, that can help facilitate decision-making.[37]

The current Title IX training provided to JROTC instructors varies across the military services because, according to an OSD official, USD(P&R), the military services, and the Department of Education have not collaborated to address the requirement to develop and administer a standardized Title IX compliance course.[38] An OSD official acknowledged the requirement and that it has not been met. Further, this official indicated that the department plans to form a working group to develop the course. However, as of July 2025, the group had not yet been formalized and OSD had not developed a timeline or specific steps for developing and implementing the course.

Military service officials likewise acknowledged that there currently is no standardized Title IX compliance course—attributing it to their lack of expertise in and the variability of Title IX requirements across different states and school districts.[39] Consequently, these officials said that they rely on individual schools to provide such training and advise instructors to consult with their school district’s Title IX coordinator for more specific guidance.

However, we found variability in the extent to which the selected schools we visited provide Title IX training. Some school officials said that they provide annual Title IX training to teachers, including JROTC instructors, while others said that they provide a professional training to teachers, but no specific training on Title IX, sexual misconduct or sexual harassment. For example, one JROTC instructor said that they are required to complete a 4-hour online training each year that covers Title IX as well as topics like suicide prevention. In contrast, another JROTC instructor said that they had never heard of Title IX until they received the new student code of conduct form developed by DOD, which references the relevant statute. Additionally, there is no federal requirement for teachers to receive Title IX training, resulting in variation across states and school districts.[40] For example, a school official in one state told us state law requires them to provide such training to all teachers, while officials in another state said no such requirement exists.

While we acknowledge that training generally falls under the jurisdiction of the military services, USD(P&R), which oversees JROTC at the DOD level, is uniquely positioned to facilitate the creation of a standardized Title IX compliance course, for example, through the proposed working group discussed previously. Specifically, by coordinating the various interests within the department and collaborating with the Department of Education to ensure the necessary expertise is applied to develop and publish a standardized Title IX compliance course, USD(P&R) will help to ensure that the military services’ JROTC instructors have access to a standardized Title IX compliance course and, by extension, consistent and complete information on Title IX. Further, by ensuring that this course is implemented, the military services will help to ensure that all JROTC instructors are familiar with Title IX regulations prohibiting sex discrimination, which may include sexual misconduct.

OSD and the Military Services Do Not Effectively Communicate How to Report Allegations of Sexual Misconduct Involving JROTC Instructors

The military services provide some information to students and their parents or guardians about students’ protections against sex discrimination and inappropriate behavior from JROTC instructors. In a 2024 briefing to Congress, OSD stated that its student code of conduct form ensures that students, parents, and guardians are informed about the responsibilities of both students and instructors and provides information for reporting misconduct. Further, OSD said the form helps foster an environment where reporting is strongly encouraged and ensures students are made aware of the resources available to them.[41] Similarly, OSD and military service officials told us they use this form to communicate information to students about their rights under Title IX and options for reporting allegations of sexual misconduct.

However, we identified several issues that limit the usefulness the student code of conduct form for communicating how to report allegations of JROTC instructor misconduct.

·         The technical and legal nature of the form’s wording makes it difficult to understand for some readers. An OSD official stated that the form uses language required by the DOD Office of the General Counsel, but some instructors we spoke with stated that the wording may create confusion about the form’s purpose. For example, the form includes multiple references to statutes as well as DOD and military service guidance documents that may be unfamiliar to students and their parents or guardians without further explanation. In one school, a JROTC instructor told us that many of their students have special education needs and read at a fifth-grade level or lower, and they were concerned that the form’s use of military jargon further complicated students’ understanding of the message it is intended to convey. Other officials described instances in which parents were hesitant to sign the form because they mistakenly thought that doing so might obligate their child to military service.

·         Information is interspersed among a variety of other unrelated content. For example, the form has a section that outlines prohibitions against inappropriate behavior between JROTC instructors and students and another that provides contact information for reporting instructor misconduct. However, these seemingly related sections are separated by four sections that contain information on multiple disparate topics, such as expectations for students’ personal grooming, physical fitness standards, and a section for parents or guardians to indicate whether they consent to photos of their child being used for JROTC advertising purposes.

·         Requirement to return the form signed means the student and parent or guardian may not have access to the contact information to report misconduct. DOD requires the student and parent or guardian to sign and return the paper form. As a result, unless they make a copy of the form prior to returning it, students and parents or guardians may not have immediate access to the contact information listed on the form for reporting instructor misconduct, should the need arise. The form summarizes students’ Title IX rights and provides information for reporting any alleged violations, including contact details for the school district’s Title IX Coordinator and the DOD and military service inspectors general offices. A military service official acknowledged this issue, stating that while some JROTC instructors post reporting information in their classroom during unit inspections, the official doubted that students would make a copy of the form or write down the information before turning it in. Because OSD relies on the form to communicate this information to students and their parents or guardians, there is no requirement to share the information in other formats, such as by posting it in classrooms.

DOD guidance requires the ASD(M&RA), under the USD(P&R), in coordination with the military services, to provide resources and information on the JROTC program; associated instructor responsibilities; expected conduct for prospective JROTC students and their parents or guardians; and contact information for reporting misconduct, including sexual misconduct.[42] Additionally, Standards for Internal Control in the Federal Government states that management should externally communicate the necessary quality information to achieve the entity’s objectives. Further, management is to select appropriate methods to externally communicate information. When selecting appropriate methods, management is to consider a variety of factors, such as the audience, the nature of the information, and the availability of information when needed.[43]

However, OSD does not effectively communicate information on students’ rights to participate in a JROTC program free from sexual misconduct and harassment and how to report allegations of JROTC instructor misconduct because the department has not developed and implemented an effective mechanism to do so. The method OSD has chosen—the student code of conduct form—does not adequately or effectively communicate this information.

While some OSD and military service officials said they believe the form adequately communicates the necessary information, others we spoke with stated it may not be the most appropriate method for communicating this information. For example, one OSD official said it would be useful to provide information to students on their rights and reporting options in a format that they can keep. Similarly, an Air Force official said they have received feedback from JROTC instructors suggesting that the section of the form containing rights and contact information be moved to a “tear off” portion that students and parents can keep. A Navy JROTC official indicated that allowing students to keep a copy of the form may be helpful, and a Marine Corps official shared that they created a classroom flyer with information on how to report misconduct, thereby addressing their concerns with the form.

The flyer includes contact information for the Marine Corps JROTC Cadet Action Line. In response to this official’s concerns about students’ access to reporting information after signing and submitting the student code of conduct form, the Marine Corps now requires all JROTC instructors to post these flyers in their classrooms (see figure 3).

Without establishing a more effective method for sharing such information, OSD lacks reasonable assurance that students and parents have reliable access to information on their rights to participate in a JROTC program free from sexual misconduct and harassment, or guidance on how to report allegations of misconduct. Consequently, students may not know how to report misconduct allegations to the military services or OSD. Furthermore, without complete reporting on such allegations, the services’ and OSD’s ability to adequately address JROTC instructor misconduct is limited.

Data on Allegations of Instructor Sexual Misconduct in JROTC Programs Are Not Comparable Across the Services

Each military service collects and reports data on allegations of instructor sexual misconduct, which the services then submit to OSD for annual reporting. In academic years 2019–2020 through 2023–2024, the military services documented 116 reported allegations of sexual misconduct involving JROTC instructors. See table 3 for further details about the services’ reported allegations for each academic year over this period.

Military service	Academic year					Total
	2019–2020	2020–2021	2021–2022	2022–2023	2023–2024
Army	9	9	15	15	16	64
Navy	4	1	3	6	11	25
Marine Corps	0	4	4	3	5	16
Air/Space Force	2	0	3	3	3	11
All services combined	15	14	25	27	35	116

Source: GAO analysis of military service data.  |  GAO‑26‑107524

Note: Data prior to the 2023–2024 academic year may be less reliable because the military services did not have a consistent method to track allegations of instructor sexual misconduct. In addition, a senior Navy official stated that Navy data prior to academic year 2022–2023 only includes allegations that resulted in decertification of the instructor; as a result, allegations that were unsubstantiated or did not result in decertification are not included. Further, as discussed in our report, the services may not have reported all allegations of sexual misconduct the same way as they may categorize allegations differently.

However, these data are inconsistent across the services and are not directly comparable as the services classify what constitutes sexual misconduct differently in their data collection. Specifically:

·         Army officials stated that they use the statutory definition of behaviors prohibited under Title IX to define sexual misconduct, which includes sexual harassment, sexual assault, and sex-based discrimination.[44]

·         According to a senior Air Force official, any allegation involving sexual harassment or sexual assault is classified as sexual misconduct. However, officials said they exercise some discretion in determining whether a particular allegation falls under this category. For example, one official said that if a complaint alleged an instructor engaged in nonsexual touching—such as touching a student on the shoulder—in a way that made the student uncomfortable, it would not be classified as sexual misconduct due to the absence of a sexual component in the behavior. Air Force officials further stated that while they consider sex-based harassment to be misconduct, they would not categorize it as sexual misconduct, even though such harassment is recognized as a prohibited behavior under Title IX. These officials stated that if the host school classified an allegation as sexual in nature, they would consider it sexual misconduct. However, they also noted that if a school did not categorize an allegation as sexual in nature but they disagreed, they would err on the side of caution and report it as sexual misconduct.

·         Navy and Marine Corps officials said they typically rely on external parties to determine if an incident should be classified as sexual misconduct. Navy officials said they recognize an allegation as sexual misconduct if the school refers it to the internal Title IX coordinator for investigation. Specifically, the officials said they generally ask schools whether a case has been referred to the Title IX coordinator when it is reported and may also consult with OSD officials if they are unsure whether the reported behavior constitutes sexual misconduct. A senior Marine Corps official said the Marine Corps reports to OSD all allegations of instructor misconduct that lead to an instructor’s removal from the classroom for any reason, providing details about each case and relying on OSD officials to determine which incidents qualify as sexual misconduct.

Furthermore, there is conflicting information about how OSD defines sexual misconduct. Specifically, while an OSD official said the department views behaviors that are prohibited under Title IX to be sexual misconduct, OSD’s annual report on sexual misconduct in JROTC for academic year 2022–2023 notes that reported allegations of sexual misconduct, sexual harassment, and sex discrimination are defined according to the policies of the respective school district. The report then aggregates all allegations into a single category labeled “allegations of sexual misconduct, harassment, and discrimination.” Furthermore, these data are presented interchangeably as “reported allegations of Title IX violations.”[45]

Standards for Internal Controls in the Federal Government states that management should use quality information—information that is appropriate, current, complete, accurate, accessible, and timely—to achieve objectives, and internally communicate necessary quality information.[46] However, the data that the military services and OSD collect and report on instructor sexual misconduct in JROTC programs are inconsistent because OSD has not clearly defined what constitutes sexual misconduct with regard to JROTC instructor behavior and communicated that definition to the military services, along with how such data should be reported.

An OSD official stated that the military services are required to submit data on sexual misconduct for the department’s annual report based on behaviors prohibited under Title IX. Further, this official stated that the definition of Title IX is provided to the services as part of a data request template they are to complete for the annual report. However, we reviewed OSD’s data request template and were not able to identify a Title IX definition or definitions of any related terms. Rather, the template directs the military services to list “all reported incidents of alleged JROTC Title IX violations,” and to categorize these allegations as “sexual misconduct,” “sexual harassment,” or “sexual discrimination” without providing definitions of these terms. Further, officials from each military service with responsibilities for collecting and reporting these data stated that they have not received definitions from OSD or other guidance that clearly articulates what types of allegations should be classified as sexual misconduct.

Without OSD providing a clear definition of sexual misconduct and guidance on how such data should be reported, the military services will continue to collect and report data based on differing interpretations of what constitutes sexual misconduct. Moreover, OSD risks under- or over-counting allegations and may communicate inaccurate information to agency leaders, Congress, and others on reported allegations of sexual misconduct involving JROTC instructors.

Gaps Exist in JROTC Program Oversight

OSD has established some mechanisms to oversee the military services’ JROTC programs, but gaps exist. First, the role of the military services’ regional oversight officials in coordinating with schools is unclear, resulting in varied approaches across the services. Second, each military service except the Air Force has defined requirements to recertify instructors at least every 5 years to ensure their continued suitability to represent the services in host schools. Finally, while the Navy, the Marine Corps, and the Air Force conduct annual in-person inspections of their JROTC units in accordance with DOD guidance, the Army has faced challenges meeting this requirement. The inspections it conducts may not include all required elements.

The Role of Military Service Regional Oversight Officials in Coordinating with Schools Is Unclear

The military services’ regional officials are expected to coordinate with schools as part of their responsibility for overseeing JROTC programs, but expectations for how this role should be carried out are unclear.[47] The military services partner with high schools to implement JROTC programs and share responsibility for unit oversight. A senior OSD official emphasized the importance of oversight officials in building relationships with high school and school district officials to facilitate effective oversight of units.

In an effort to enhance oversight of JROTC units, DOD revised its guidance in March 2024 to require that the Secretaries of the Military Departments resource JROTC headquarters, areas, regions, or brigades with staff to maintain a ratio of one oversight official to no more than 30 JROTC units or host schools. Furthermore, per the guidance, each service’s program must be adequately resourced to provide day-to-day unit oversight and evaluations, among other things.[48]

According to a senior OSD official, the required ratio of oversight officials to JROTC units is designed to facilitate closer relationships with instructors and school officials and help coordinate their shared oversight responsibilities.[49] However, this official stated that while OSD and the military services did not previously track the ratio of oversight officials to JROTC units, they estimated in 2022 it was closer to one oversight official to 96 host schools. According to the official, this made it challenging to conduct oversight responsibilities such as completing annual inspections of all units. This official stated that the new requirement resulted in an increase in the number of personnel responsible for department-wide oversight of JROTC.

The services’ use of oversight officials and their ability to achieve day-to-day oversight of JROTC units and coordination with schools varies. Navy guidance states that oversight officials are to coordinate with host schools to ensure that all hired instructors are board certified.[50] Marine Corps guidance states that oversight officials are to plan and oversee operations of JROTC units in their region and to assist school district supervisory personnel in the development and implementation of strategies supporting program success.[51] However, neither service’s guidance further details communication with schools or school districts. Army and Air Force guidance does not specify oversight officials’ responsibilities in liaising with schools.[52]

In the absence of service guidance, some oversight officials we spoke with pointed to position descriptions or performance plans and expectations as outlining their roles and responsibilities for communicating with schools. One official noted that while their service has guidance on JROTC program implementation, it does not discuss the role of oversight officials in communicating with schools.

Oversight officials also expressed differing views on what they considered to be their primary responsibilities, including how they communicated with schools. Some said their main focus should be on building relationships with JROTC units, instructors, and school administrators. In contrast, others said conducting annual inspections or working directly with units to ensure compliance with policies on the use of government property and funds were their top priorities. An oversight official from one service stated that most of their communication with school administrators occurs through JROTC instructors and that it would ideally be limited to annual unit inspections. Conversely, an oversight official from another service stated that they contact schools, administrators, and district officials daily to discuss various matters, such as upcoming competitions. A third service’s oversight official said they had created a distribution list that includes administrators from every school in their assigned area and the official sends weekly e-mails to keep them informed and to increase their interaction with the JROTC program.

During our site visits, many of the high school and school district officials we spoke with said they have little to no direct contact with the military services. Some high school officials were unable to identify a specific point of contact, instead stating they would reach out to the JROTC instructor, if necessary. Many of these officials said that most communication they receive from the military services comes through their JROTC instructor. Administrators at one school described their JROTC program and instructors as self-sufficient but stated that communication with the service could become challenging if that were not the case. An administrator from another school stated they were unsure who, if anyone, at the service they would communicate with regarding any performance concerns involving JROTC instructors. However, the administrator said they would likely want to inform the military service if they were having issues with an instructor.

We spoke to instructors during our site visits who similarly said they are the primary channel of information from the military service to the school and school districts. One instructor stated that communication between their service and school district can be challenging. The instructor further said that responsibilities such as coordinating the signing of the MOA by the school district superintendent would be better suited for regional oversight officials rather than instructors, especially when multiple schools in the district may have units. Instructors from another school expressed the need for improved communication between oversight officials and schools, stating they did not think instructors should serve as liaisons due to the lack of clear communication and guidance from their military service.

Standards for Internal Control in the Federal Government states that management should implement control activities through policies. To do this, management documents in policies the internal control responsibilities of the organization. Those in key roles for the unit may further define policies through day-to-day procedures. Additionally, management communicates policies and procedures so that personnel can implement the control activities for their assigned responsibilities.[53]

However, guidance from OSD does not clearly define baseline roles and responsibilities of oversight officials, including how they coordinate and communicate with host schools. Specifically, DOD’s guidance only specifies that the Secretaries of the military departments are to resource their JROTC programs to achieve a ratio of one oversight official to 30 schools; provide day-to-day unit oversight and evaluations; and achieve annual, in-person evaluations. An OSD official stated that they believe the military services are responsible for further defining oversight officials’ roles and responsibilities. Furthermore, the official said the military services have not requested clarifying guidance from OSD on this matter.

We recognize the importance of the military services developing their own guidance, but current military service guidance may not reflect OSD priorities for the oversight roles and responsibilities of regional JROTC oversight officials because the services have not yet received baseline guidance from OSD clarifying roles and responsibilities for these positions. Without OSD first clarifying guidance to establish a baseline of expectations for oversight officials’ roles and responsibilities, the services lack a starting point for developing such guidance. As a result, variable approaches to unit oversight, which may not match department priorities, are likely to continue. Updating service-specific guidance to align with this baseline, once established, will help clarify expectations for coordination and communication between the military services and host schools. This will further facilitate oversight and enable visibility into important issues like instructor sexual misconduct. Ultimately, improved communication between schools and the military services could result in more efficient notifications to the services if an allegation of misconduct is made against an instructor.

Military Services Have Defined Instructor Recertification Requirements, Except for the Air Force

Each service has established requirements that JROTC instructors must fulfill to be certified to teach the JROTC curriculum, such as the completion of initial training and physical examinations. DOD guidance also requires instructors to undergo background checks in accordance with applicable federal, state, and local requirements as part of the instructor certification process.[54]

However, not all services have established requirements for recertifying instructors. The recertification process enables the military services to periodically review their JROTC instructors’ credentials and endorsements to ensure their continued suitability to represent the services in host schools. The Army, Navy, and Marine Corps have defined requirements that their respective instructors must meet to be recertified to teach the JROTC curriculum, which are further discussed below.

·         Army. In line with statute, Army guidance requires instructors to be recertified every 5 years, and the Army’s JROTC Program Guide for Administrators lists training that instructors must complete to receive and maintain certification.[55] For example, instructors must complete a Resident Advanced Recertification Course once every 5 years. Additional draft guidance provided by the Army states that the required courses will also include training on sexual harassment and sexual assault prevention and response, as well as guidance on fostering appropriate relationships with students and taking suitable actions if they witness sexual misconduct by colleagues. Additionally, current guidance notes that instructors are prohibited from engaging in and tolerating fraternization or unprofessional relationships with cadets and that violations may result in probation or decertification.

·         Navy. Navy guidance outlines specific requirements for recertification, which include the submission of a narrative statement, an appraisal form, and the instructor’s last three evaluations.[56] According to this guidance, an instructor may be decertified for a number of reasons, including resigning while under investigation or to avoid an investigation; violating the school’s standards of conduct; and being convicted of or entering into a plea bargain for various offenses, such as harassment and inappropriate sexual or immoral behavior. A Navy official stated that they are in the process of updating guidance to extend the length of instructor certification from 3 to 5 years, aligning with the maximum length per statutory requirements.

·         Marine Corps. According to Marine Corps officials, instructors receive a letter upon certification stating that the certification is valid for 5 years. Approximately 1 year prior to the expiration of this certification, instructors receive another letter that outlines recertification requirements. Specifically, the recertification package must include a letter requesting recertification, a physician’s statement, proof of completed continuing education and state teacher certification, an endorsement letter from the school principal, and documentation that all required training has been completed. In particular, instructors are required to complete courses focused on best practices in teaching and learning as part of this recertification process. Instructors may be decertified if revocation of certification is in the best interest of the Marine Corps. For example, a senior Marine Corps official stated that instructors may be decertified if they resign during an ongoing misconduct investigation.

The Air Force does not generally require its JROTC instructors to be recertified. Rather, Air Force guidance states that certification remains valid while all areas of the instructor’s performance remain at a satisfactory level, annual mandatory training requirements are completed prior to deadlines, and the instructor has a current application.[57] A senior Air Force official confirmed that the service has no recertification process, noting that certification is indefinite unless an instructor engages in inappropriate, unprofessional, or egregious misconduct; or they leave the JROTC program, in which case their certification automatically expires after 5 years.

DOD guidance states that the military departments are to develop and implement JROTC instructor certification requirements.[58] Further, statute requires the military services to conduct oversight of certified instructors, including requiring that certifications expire after not more than 5 years.[59] Standards for Internal Control in the Federal Government states that management should implement control activities through policies. Management documents in policies internal control responsibilities of the organization and communicates policies and procedures so that personnel can implement the control activities for their assigned roles. Further, the standards state that management should demonstrate a commitment to recruit, develop, and retain competent individuals. As part of this, management is to establish expectations of competence for key roles and for all personnel, as such personnel need to possess and maintain a level of competence to accomplish their assigned responsibilities. Further, management is to evaluate the competence of personnel in relation to established policies.[60]

However, the Air Force has not updated guidance to reflect statutory direction that certifications generally expire after no more than 5 years or to specify requirements for such instructors to be recertified. Air Force officials stated that instructors are continuously evaluated for annual training compliance, performance, and behavior; and that if any problems arise, the instructor’s certification is automatically reviewed and could result in decertification. These officials also noted that the service desires to conduct periodic in-person recertification training but does not have funding to do so. While we acknowledge that funding is necessary for some potential aspects of a recertification process, the lack of funding does not preclude the Air Force from establishing a recertification process and associated requirements or a timeline for the expiration of certifications.

Without guidance that specifies a certification expiration timeline that is in line with statutory requirements and a process to be recertified, the Air Force lacks reasonable assurance that instructors maintain the required competence for their roles and may be unaware of information that could disqualify an instructor for continued employment, such as misconduct. A clearly defined recertification process with associated requirements, including a timeline for the expiration of certifications, will help the Air Force better fulfill its responsibility to oversee its instructors and manage risks associated with its JROTC program. Furthermore, issuing such guidance and implementing recertification requirements could enhance the Air Force’s sexual misconduct prevention efforts, such as by ensuring all instructors receive updated training on important topics at regular intervals.

Military Services Conduct Annual Unit Inspections as Required, Except for the Army

Statute requires JROTC units to be inspected by the military departments no less than once every 4 years.[61] However, DOD Instruction 1205.13 requires more frequent inspections, stating that the military departments will annually designate evaluators to conduct in-person assessments of the operation, administration, instructor performance, and general effectiveness of the JROTC program and units. Unit inspections are a key component of JROTC program oversight because, among other things, they help to ensure critical information is communicated to students, such as their right to an environment that is free from sexual misconduct. A senior OSD official described the required annual, in-person unit inspections as the most important part of JROTC oversight. Specifically, this official stated that a key part of the inspections is ensuring in-person interaction with instructors, students, and school district officials.

The Navy, Marine Corps, and Air Force report conducting annual unit inspections of their JROTC units in accordance with DOD-level guidance. Specifically:

·         In 2023, the Navy reorganized its JROTC program and required each area manager to annually conduct an inspection of every unit, with no “off-site” inspections. The inspections are to address school system program support; administration of the program; reports and records; cadet performance; college and career readiness; and special interest items, such as sexual harassment prevention.

·         Per Marine Corps guidance, oversight officials are to conduct an annual inspection or visit of units to ensure that the highest standards of instruction and administration are being maintained, as well as to provide timely assistance and corrective action as required.[62]

·         Air Force guidance states that the Director of JROTC will establish procedures to annually evaluate the operation, administration, and effectiveness of the overall JROTC program and the individual units for contractual compliance, cost, and performance objectives.[63] Officials from all three of these services stated that they are generally able to conduct annual inspections as required.[64]

However, Army officials stated that they are currently unable to annually inspect all their JROTC units, as required by DOD guidance, due to insufficient staff. Further, Army guidance requires school districts and instructors to be inspected at least once every 3 years to ensure compliance with minimum program criteria.[65] In addition, the unit inspections the Army does conduct may not include a review of all elements required by DOD guidance.

The Army Is Not Meeting Its Annual Inspection Requirement

A senior Army official said that they are working to conduct annual, in-person inspections, but have faced challenges due to the large number of JROTC units and insufficient staff to conduct annual in-person visits to every school with a JROTC unit. As of April 2024, Army data identified 66 authorized positions for oversight officials, who are responsible for more than 1,700 JROTC units dispersed across schools in all 50 states as well as in U.S. territories and international locations. The Army has structured its JROTC oversight across seven brigades, staffed by between five and 17 officials. Each brigade, led by a Brigade Chief, is responsible for overseeing between 121 and 476 schools with JROTC units in their region. Personnel within a brigade are not assigned to specific units, but instead support all units assigned to the brigade.

While the Army meets the required DOD ratio of one oversight official to 30 units when including all brigade personnel, a senior Army official stated that conducting annual unit inspections would require each official to visit around 30 schools per year. This official stated that currently this is not feasible considering school schedules, travel requirements, and competing responsibilities of the brigade staff who conduct these inspections. Army officials stated that competing responsibilities include conducting training, preparing annual reports, communicating regularly with instructors, and overseeing JROTC program logistics.

For example, officials from one Army brigade said they spend a significant amount of time organizing travel for cadets and chaperones participating in national competitions—a responsibility that must be completed by government personnel. Another brigade official said the brigade’s responsibilities have increased over time without an evaluation of whether any existing duties could be removed or revised. A senior Army official estimated that they would need a ratio closer to one oversight official for every 20 units to conduct inspections of all units annually. However, this official also said that additional staffing constraints are expected in the near term due to recent efforts to reduce the federal workforce.

The Navy, Marine Corps, and Air Force also meet DOD’s required oversight ratio of one oversight official to 30 units. However, officials from these three services stated that they have been able to meet annual unit inspection requirements. Differences across the services in their oversight structure and breadth of responsibilities could contribute to their ability to conduct required inspections. Specifically, each of the services has developed a unique structure for overseeing JROTC units (see fig. 4). In contrast to the Army’s shared approach to oversight, the other three services assign specific units to a single oversight official.

^aA senior Navy official stated in July 2025 that two supervisors had left their positions, and the official was unsure if they would be able to fill those positions. This official further stated that one oversight official in district two left their position, which resulted in a redistribution of units among the remaining oversight officials to ensure the Navy maintained the required oversight ratio of one oversight official to 30 units.

^bMarine Corps officials stated in July 2025 that the distribution of units had changed slightly. Specifically, as of July 2025, officials stated that region two had 19 units, region three had 30 units, region six had 26 units, and region eight had 31 units.

Guidance from DOD states that existing policies, procedures, and structures shall be periodically evaluated to ensure efficient and effective use of personnel resources.[66] However, the Army is unable to meet the annual unit inspection requirement because it has not evaluated its JROTC oversight structure and responsibilities to ensure that they are aligned with oversight priorities. An OSD official told us they were unaware of the difficulty the Army was experiencing in meeting this requirement, but stated that annual, in-person unit inspections are the most important part of JROTC oversight.

In July 2025, a senior Army official stated that the Army acknowledges the oversight and annual inspection requirements and noted they were in the process of implementing new command guidance to meet statutory and regulatory requirements for the safety of JROTC cadets. The official provided a draft of the command guidance that requires its seven regional brigades to dedicate an oversight official to each school—not to exceed 30 units, or schools, per official, by the end of August 2025. The draft guidance further states that beginning in September 2025, brigade commanders will report monthly on the status of annual inspections. The senior Army official also stated that additional duties reported by oversight officials will be lightened by reassigning those duties to other personnel within the brigade staff sections, and that by January 2026, each brigade will report that these additional duties have been transferred to a level that does not interfere with program oversight.

These are positive steps that may help the Army to better execute its oversight responsibilities. However, without evaluating its JROTC oversight structure and responsibilities to ensure that they are aligned with oversight priorities, the Army will be unable to ensure that it is making the most efficient and effective use of its oversight officials. As part of such an evaluation, the Army may consider the other services’ oversight structures and responsibilities. Ultimately, until it takes these steps, the Army may not have sufficient oversight of units to effectively prevent and respond to sexual misconduct within the JROTC program.

Army Unit Inspections May Not Include All Required Elements

Examples of Information JROTC Cadets and Instructors Must Acknowledge in Relevant Program Forms On the Junior Reserve Officers’ Training Corps (JROTC) Student Code of Conduct and Parent/Guardian Consent Form, students and parents/guardians acknowledge that ·       inappropriate behavior between JROTC representatives/instructors and any student/minor will not be tolerated; and ·       if there are concerns about inappropriate activities concerning either instructors or students in the program, they will immediately notify the high school administration or other points of contact identified on the form. On the JROTC Instructor Prohibited Activities Acknowledgement, instructors must acknowledge that they will not ·       develop, attempt to develop, or conduct a personal, intimate, or sexual relationship with cadets or students; ·       use grade or position, threats, pressure, or promise of return of favors or favorable treatment in an attempt to gain sexual favors from a cadet or student; ·       make sexual advances toward, or seek or accept sexual advances or favors from cadets or students; or ·       allow cadets or students into their dwelling or privately owned or rental vehicles. Source: Department of Defense Forms DD 3203 and DD 3200.  I  GAO‑26‑107524

DOD Instruction 1205.13 outlines required elements for annual unit inspections, including verifying the completion and retention of two forms—the Student Code of Conduct and Parent/Guardian Consent Form and the JROTC Instructor Prohibited Activities Acknowledgement. As previously discussed, both forms address topics related to sexual misconduct such as student rights, instructor responsibilities, and reporting points of contact (see sidebar and see appendix II for the forms reprinted in their entirety).

Each of the military services has guidance that discusses required JROTC unit inspections.[67] The Navy, Marine Corps, and Air Force have also developed checklists to further guide annual inspections, and these checklists generally include the required elements related to misconduct outlined in guidance from DOD (see table 4).

Required inspectable element	Army	Navy	Marine Corps	Air Force
Instructor Prohibited Activities forms is an inspectable item as part of the annual, in-person evaluation and its submission to the host school is a condition of certification as a JROTC instructor. Designated evaluators validate these forms as part of the instructor evaluation.	X	ü	ü	ü
Student Code of Conduct and Parent/Guardian Consent Forms are inspectable items as part of the annual, in-person evaluation and their submission to the host school is a condition of participation in the JROTC program.	X	ü	ü	ü
Memorandums of Agreement (MOA) are annually reviewed with current school leadership as part of the in-person evaluation. Designated evaluators verify and as required, recommend updates to MOAs with appropriate school district representatives.	X	ü	ü	ü

Source: GAO analysis of Department of Defense (DOD) information.  I  GAO‑26‑107524

Note: We use (X) to indicate that military service guidance and checklists do not include an inspectable element related to misconduct, and (ü) to indicate that guidance and checklists do include an element.

In addition to the inspectable elements per the guidance, these three services include other items related to instructor misconduct in their annual unit inspections. For example:

·         The Navy includes prevention of sexual harassment as a special interest item on its inspection checklist and evaluators are to note whether the unit is compliant or noncompliant.

·         The Marine Corps checklist includes a list of topics for evaluators to discuss with every instructor, including information about relationships with students, cadets, and faculty. Specifically, it states that instructors should not place themselves in compromising positions, demonstrate affection that could be misinterpreted as anything other than appropriate instructor-to-student relationships, or attend parties or gatherings that are not school sanctioned or part of the JROTC program.

·         The Air Force inspection checklist includes verifying that any allegations of instructor misconduct were reported by the school within 1 business day of the occurrence; the unit has proper security measures in place for changing areas, including checking for authorized/unauthorized audio and video recording devices; and that appropriate professional relationships exist between instructors, cadets, faculty, school administration, and service headquarters personnel.

However, Army guidance states that inspections are designed to assess teaching and learning, and the guidance does not discuss instructor misconduct or include the required elements specified in guidance from DOD. Army guidance instead includes areas for observation—such as drill, color guard, and service learning—and associated scoring worksheets. A senior Army official acknowledged that Army unit inspections may be missing items and that there is room for improvement. Without revised guidance to ensure that unit inspections include all required items, the Army cannot ensure that the units it is able to inspect each year are fully adhering to DOD requirements or the overall effectiveness of its JROTC program. Further, the Army cannot ensure that both students and instructors receive critical information on their rights and responsibilities related to sexual misconduct.

Conclusions

While DOD has stated its commitment to the safety and well-being of the nearly 500,000 students participating in JROTC programs worldwide, more than 100 allegations of sexual misconduct by instructors against students have been reported in the past decade. OSD and the military services developed policies and procedures to help prevent and respond to sexual misconduct in JROTC programs, but several issues hinder the effectiveness of these efforts. Taking steps to address these issues would better position OSD and the military services to ensure they are fully and effectively implementing their policies and procedures related to sexual misconduct in JROTC. Specifically:

·         By revising the standardized MOA to ensure that it includes all required elements, OSD and the military services can more effectively prevent and respond to sexual misconduct by instructors.

·         Developing and administering a standardized Title IX compliance course across the department will help to ensure that instructors are familiar with Title IX regulations, including those related to sexual misconduct.

·         Developing and implementing a mechanism to effectively communicate information on students’ rights and reporting will help ensure students and parents know how to report allegations of misconduct and that the department adequately addresses any misconduct.

Additionally, the military services collect and report data on sexual misconduct in their JROTC programs, but these data are not comparable across the services. Without OSD clearly defining what constitutes sexual misconduct and communicating that definition to the services along with expectations for reporting, the department cannot ensure that it is communicating accurate information on the number of reported allegations throughout the department and to Congress.

Finally, while OSD and the military services have established some mechanisms to oversee JROTC programs, gaps exist. Specifically, the role of the military services’ regional oversight officials in coordinating with schools is unclear, resulting in varied approaches to oversight and differing levels of coordination and communication between the services and host schools. Clarifying both DOD and service-level guidance to establish a baseline of expectations for oversight officials’ roles and responsibilities could help to enable visibility into instructor sexual misconduct and ensure more efficient notifications when such allegations are made.

In addition, the Air Force and the Army could take additional steps to improve oversight of their JROTC programs. For the Air Force, providing guidance on the process to recertify JROTC instructors and associated requirements, including a timeline for the expiration of instructor certifications, would give it more information on circumstances that could disqualify an instructor for continued employment, such as misconduct. For the Army, evaluating its JROTC oversight structure and responsibilities to ensure that they align with oversight priorities, as well as revising its guidance for unit inspections to ensure they include all required items, would help ensure it fully adheres to OSD requirements related to instructor sexual misconduct.

Recommendations for Executive Action

We are making a total of 16 recommendations, including five to DOD, four to the Army, four to the Navy, and three to the Air Force. Specifically:

The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Secretaries of the military departments, revises the standardized MOA with school districts to include all statutory requirements, including (1) a requirement for schools to notify the military service within 48 hours of all allegations of instructor misconduct, regardless of whether investigative or disciplinary actions are taken; (2) a requirement for schools to certify that they annually provide training to students on methods to prevent, respond to, and report sexual misconduct; and (3) a procedure for instructor certifications to expire after not more than 5 years. (Recommendation 1)

The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Secretaries of the military departments and the Commandant of the Marine Corps, and in consultation with the Department of Education, develops and publishes standardized Title IX compliance training for JROTC instructors. (Recommendation 2)

The Secretary of the Army should, once the Under Secretary of Defense for Personnel and Readiness develops and publishes standardized Title IX compliance training for JROTC instructors, implement the standardized training by administering it to new and existing instructors on an annual basis. (Recommendation 3)

The Secretary of the Navy should, once the Under Secretary of Defense for Personnel and Readiness develops and publishes standardized Title IX compliance training for JROTC instructors, implement the standardized training by administering it to new and existing instructors on an annual basis. (Recommendation 4)

The Secretary of the Air Force should, once the Under Secretary of Defense for Personnel and Readiness develops and publishes standardized Title IX compliance training for JROTC instructors, implement the standardized training by administering it to new and existing instructors on an annual basis. (Recommendation 5)

The Secretary of the Navy should ensure the Commandant of the Marine Corps, once the Under Secretary of Defense for Personnel and Readiness develops and publishes standardized Title IX compliance training for JROTC instructors, implements the standardized training by administering it to new and existing instructors on an annual basis. (Recommendation 6)

The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness, in coordination with the Secretaries of the military departments, develops and implements a mechanism to more effectively communicate information on students’ rights to participate in a JROTC program free from sexual misconduct and harassment and how to report allegations of JROTC instructor misconduct. (Recommendation 7)

The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness clearly defines what constitutes sexual misconduct with regard to tracking allegations made against JROTC instructors and communicates that definition to the military services, along with expectations for how the services should report such data. (Recommendation 8)

The Secretary of Defense should ensure that the Under Secretary of Defense for Personnel and Readiness clarifies guidance for baseline roles and responsibilities of regional oversight officials, including how they are to coordinate and communicate with host schools. (Recommendation 9)

The Secretary of the Army should, once the Under Secretary of Defense for Personnel and Readiness clarifies guidance on the baseline roles and responsibilities of regional oversight officials, update the Army’s guidance to ensure that oversight responsibilities align with DOD guidance and that these roles are properly executed. (Recommendation 10)

The Secretary of the Navy should, once the Under Secretary of Defense for Personnel and Readiness clarifies guidance on the baseline roles and responsibilities of regional oversight officials, update the Navy’s guidance to ensure that oversight responsibilities align with DOD guidance and that these roles are properly executed. (Recommendation 11)

The Secretary of the Air Force should, once the Under Secretary of Defense for Personnel and Readiness clarifies guidance on the baseline roles and responsibilities of regional oversight officials, update the Air Force’s guidance to ensure that oversight responsibilities align with DOD guidance and that these roles are properly executed. (Recommendation 12)

The Secretary of the Navy should ensure the Commandant of the Marine Corps, once the Under Secretary of Defense for Personnel and Readiness clarifies guidance on the baseline roles and responsibilities of regional oversight officials, updates the Marine Corps’s guidance to ensure that oversight responsibilities align with DOD guidance and that these roles are properly executed. (Recommendation 13)

The Secretary of the Air Force should issue guidance that establishes a process for recertification of JROTC instructors and associated requirements, including a timeline for the expiration of instructor certifications that aligns with statutory requirements. (Recommendation 14)

The Secretary of the Army should evaluate the Army’s JROTC oversight structure and responsibilities to ensure that they are aligned with oversight priorities. As part of the evaluation, the Army may consider the other services’ oversight structures and responsibilities. (Recommendation 15)

The Secretary of the Army should revise its guidance on JROTC unit inspections to ensure that it is inspecting all items required per DOD guidance, including student code of conduct forms and instructor prohibited activities forms. (Recommendation 16)

Agency Comments

We provided a draft of this report to DOD for review and comment. DOD did not provide comments on the report.

We are sending copies of this report to the appropriate congressional committees, congressional requesters, the Secretary of Defense, and the Secretaries of the Army, the Navy, and the Air Force. In addition, this report is available at no charge on the GAO website at http://www.gao.gov.

If you or members of your staff have any questions regarding this report, please contact me at williamsk@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix III.

Kristy E. Williams
Director, Defense Capabilities and Management

List of Addressees

The Honorable Roger F. Wicker
Chairman
The Honorable Jack Reed
Ranking Member
Committee on Armed Services
United States Senate

The Honorable Elizabeth Warren
Ranking Member
Subcommittee on Personnel
Committee on Armed Services
United States Senate

The Honorable Mike Rogers
Chairman
The Honorable Adam Smith
Ranking Member
Committee on Armed Services
House of Representatives

The Honorable Robert Garcia
Ranking Member
Committee on Oversight and Government Reform
House of Representatives

The Honorable Suhas Subramanyam
Ranking Member
Subcommittee on the Military and Foreign Affairs
Committee on Oversight and Government Reform
House of Representatives

The Honorable Mazie Hirono
United States Senate

The Honorable Sylvia Garcia
House of Representatives

The Honorable Chrissy M. Houlahan
House of Representatives

The Honorable Summer L. Lee
House of Representatives

The Honorable Stephen F. Lynch
House of Representatives

The Honorable Jamie Raskin
House of Representatives

This report assesses the extent to which the Office of the Secretary of Defense (OSD) and the military services (1) have developed and implemented policies and procedures to prevent and respond to sexual misconduct in Junior Reserve Officers’ Training Corps (JROTC) programs, (2) have quality data on reported allegations of sexual misconduct involving JROTC instructors, and (3) oversee JROTC programs.[68]

The Department of Defense (DOD) does not have a standard definition of sexual misconduct related to JROTC instructors. For the purposes of this report, we use the term “sexual misconduct” to encompass a range of inappropriate behaviors. Specifically, sexual misconduct for purposes of this report includes behaviors that violate Title IX of the Education Amendments of 1972—which generally prohibits sex discrimination in an educational entity that receives federal funding, such as public schools—such as sexual harassment, sexual assault, and stalking.[69] Sexual misconduct also includes behaviors identified by the Department of Education as “adult sexual misconduct” in a school setting, including inappropriate verbal conduct, physical conduct, and online predatory behavior. Sexual misconduct includes behaviors that range from inappropriate to illegal, as well as breaches of school district codes of conduct or professional standards.[70]

Methods to Assess Implementation of Policies and Procedures on Sexual Misconduct

To assess the extent to which OSD and the military services have developed and implemented policies and procedures to prevent and respond to sexual misconduct in JROTC programs, we analyzed relevant statutory requirements and DOD and military service policies. Specifically, we conducted an analysis to determine the extent to which DOD and military service guidance align with statutory requirements for implementing JROTC programs related to sexual misconduct. To conduct this analysis, we first identified relevant statutory requirements and then compared them to DOD and military service guidance to determine the extent to which they were aligned. We also compared miliary service guidance to DOD guidance to determine the extent of alignment. We searched for alignment in DOD and military service guidance through keyword searches and a review of relevant topics. We considered guidance to be aligned if all aspects of the requirement were reflected in the guidance document; partially aligned if some portion of the requirement was reflected in the guidance, though with some potential key differences; and not aligned if no portion of the requirement was reflected in the guidance or if there was a conflict between the requirement and guidance.

We also conducted an analysis to determine the extent to which OSD’s standardized memorandum of agreement (MOA) between the military services and school districts hosting JROTC units incorporated statutory requirements for such agreements. Specifically, section 552 of the National Defense Authorization Act for Fiscal Year 2024 listed several provisions to be included in the MOA. We compared the standardized MOA to these required provisions to determine the extent to which the provisions were included.

Additionally, we interviewed cognizant OSD and military service officials about their perspectives and responsibilities concerning sexual misconduct prevention and response.

Further, we interviewed high school administrators, school district officials, and JROTC instructors at a nongeneralizable sample of 11 public high schools with JROTC units in the continental United States.[71] We selected schools for site visits based on representation for each of the military services, geographic dispersion, the number of cadets enrolled, and reported incidents of sexual misconduct in the past 5 academic years (including schools with and without reported incidents). We also reviewed a list of schools that had been contacted as part of another related GAO review to reduce overlap to the extent possible. We visited schools in Florida, Kentucky, Texas, and Washington. Because we did not select locations using a statistically representative sampling method, the comments provided during our interviews with officials are nongeneralizable and therefore cannot be projected across DOD or a service, or any other JROTC units. While the information obtained was not generalizable, it provided perspectives from officials on the prevention of and response to incidents of sexual misconduct in JROTC programs.

We compared our review of guidance and information gathered through interviews to statute, DOD guidance, our prior work on results-oriented government, and Standards for Internal Control in the Federal Government. We determined that the information and communication component of internal control was relevant to this objective. Specifically, we identified the underlying principle that management should externally communicate the necessary quality information to achieve the entity’s objectives.[72]

Methods to Assess Collection and Reporting of Reported Sexual Misconduct

To assess the extent to which OSD and the military services have quality data on reported allegations of sexual misconduct involving JROTC instructors, we obtained and analyzed data from the military services on reported allegations of sexual misconduct involving JROTC instructors for academic years 2019–2020 through 2023–2024. We selected this timeframe to capture data on misconduct allegations reported in accordance with current policies and procedures as well as to identify any changes in how such data were collected and reported over this 5-year period.

To assess the reliability of these data, we interviewed OSD and military service officials with responsibilities related to collecting and reporting sexual misconduct allegations. We also reviewed the data to identify mistakes, anomalies, or illogical values and discussed these with military service officials to resolve any identified issues. We determined that these data were sufficiently reliable for examining the extent to which OSD and the military services have quality data on reported allegations of sexual misconduct involving JROTC instructors. Further, we reviewed data from DOD’s first annual report to Congress on sexual misconduct in JROTC programs in academic year 2022–2023 and compared those data with the data provided to us.[73] We identified inconsistencies across these sources and interviewed OSD and military service officials to determine the reasons for these inconsistencies.

We also interviewed knowledgeable OSD and military service officials to discuss their processes for collecting and reporting data on allegations of sexual misconduct involving JROTC instructors and reviewed related OSD and service guidance. During our visits to schools with JROTC programs, we discussed the roles and responsibilities of high school and school district officials and JROTC instructors for collecting and reporting data on allegations of sexual misconduct.

We compared information from our analyses of military service data, documents, and testimonial evidence obtained during interviews to Standards for Internal Control in the Federal Government related to quality information.[74] We determined that the information and communication component of internal control was relevant to this objective. Specifically, we identified the underlying principles that management should use quality information and internally communicate it to achieve the entity’s objectives as relevant to this objective.

Methods to Assess Oversight of JROTC Programs

To identify the extent to which OSD and the military services oversee JROTC programs, we reviewed DOD and military service guidance pertaining to JROTC program oversight. In addition, we compared DOD guidance on requirements for annual JROTC unit inspections to military service guidance, procedures, and checklists to determine the extent to which military service documentation aligns with DOD requirements.

Additionally, we interviewed JROTC regional oversight officials at each service regarding their roles and responsibilities and communication with schools. We first interviewed oversight officials from each service to understand their roles and responsibilities. We verified the oversight officials we spoke with had held their positions for at least 1 year to ensure they had sufficient experience to discuss their roles. We then selected additional oversight officials to interview from each service that were responsible for overseeing some of the JROTC units we visited as part of our previously discussed nongeneralizable site visits to 11 schools. Moreover, we gathered information on oversight procedures through interviews with JROTC instructors and school and school district officials during our site visits. Further, we interviewed OSD and military service officials about guidance for oversight officials and annual unit inspections.

We compared the information obtained from our analyses of relevant guidance and other documentation and testimonial evidence obtained during interviews to DOD guidance and Standards for Internal Control in the Federal Government.[75] We determined that the control activities and control environment components of internal control were relevant to this objective. Specifically, we identified the underlying principles that management should communicate and implement control activities through policies and demonstrate a commitment to recruit, develop, and retain competent individuals as relevant to this objective.

We conducted this performance audit from April 2024 to January 2026 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

In accordance with statute, the Department of Defense (DOD) developed and published DD Form 3202, a standardized Memorandum of Agreement that the military departments must sign with each JROTC host school. See figure 5 for the form reprinted in full.

In 2024, DOD created DD Form 3203, the Student Code of Conduct and Parent/Guardian Consent Form, to inform students and their parents and guardians of expectations, responsibilities, and prohibitions related to their participation in the JROTC program. See figure 6 for the form reprinted in full.

In 2024, DOD created DD Form 3200, the Instructor Prohibited Activities Acknowledgement, which JROTC instructors are required to sign to acknowledge their understanding of prohibited activities. See figure 7 for the form reprinted in full.

GAO Contact

Kristy E. Williams, williamsk@gao.gov

Staff Acknowledgments

In addition to the contact named above, Kimberly Mayo (Assistant Director), Angela Kaylor (Analyst in Charge), Sharon Ballinger, Vincent M. Buquicchio, Molly Callaghan, Isabel Fairclough, Serena Lo, Sarahi Robles, Anne Thomas, and Cristina Toppin made key contributions to this report.

K-12 Education: Prevention and Response to Adult Sexual Misconduct in Junior Reserve Officers’ Training Corps Programs. GAO‑25‑107670. Washington, D.C.: August 28, 2025.

National Guard Youth Challenge Program: Actions Needed to Enhance Oversight and Assess Performance. GAO‑24‑106172. Washington, D.C.: November 17, 2023.

Senior Reserve Officers’ Training Corps: Actions Needed to Better Monitor Diversity Progress. GAO‑23‑105857. Washington, D.C.: August 24, 2023.

Military Personnel: Actions Needed to Improve Evaluation and Oversight of Reserve Officers’ Training Corps Programs. GAO‑14‑93. Washington, D.C.: November 13, 2013.

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