Welcome to BLTs, (Betty Lynn's Tips), a series of notes designed by Directives Division compliance analysts to help you create and process issuances for the Department of Defense. Our goal is to help you create the best issuance possible and move it through the DoD issuances process efficiently. Whether you are drafting your first issuance or your fiftieth, these tips and tactics will save you time and trouble and give you a better understanding of issuances and the issuance process.
These tips will be posted on the DoD Directives Website so they're available to you any time you need them. The website also contains much more information on all the different types of issuances as well as the entire issuance process. I welcome your questions and recommendations for topics to cover in future BLTs. Just send your ideas to the Branch Chief's Inbox
Special thanks to OUSD(I) Policy for the idea, topics, and even some words I've stolen.
There are a couple of reasons an issuance might need to go through the formal coordination process again:
To help you decide if you need to recoordinate, go to the flowchart on the DoD Issuance website and answer the applicable questions.
If your issuance received the Directives Division presignature review, then you need to get a new DD Form 106 signed and submit a clean copy of the issuance with incorporated revisions from the presignature review to your focal point for posting and recoordination.
Include a blank DD Form 818, the revised issuance, and the signed DD Form 106. On the DD Form 106:
If the first formal coordination was contentious, consider including the adjudicated DD Form 818 from the first coordination showing Components how their comments were addressed.
If you need to recoordinate but you have not completed the Directives Division presignature review, then you need to submit your issuance package to complete that step before posting for a recoordination.
After the second round of coordination, prepare a new DD Form 818 with any comments received the second time around. Revise the issuance based on these comments. Draft an action memo that states two rounds of formal coordination were completed and identify the first and second DD Form 818s. Compile a complete list of coordinating officials; include any who did not respond to the second review with their original coordination date. If you are reissuing or changing a directive, you must also include an executive summary of changes. During the second presignature review, Directives Division will look at the second DD 818, confirm that all nonconcurs have been resolved, and make sure the action memo informs the approval authority of the two formal coordinations. Directives Division will review the issuance according to current procedures.
Have you heard about the DoD plain language program? It started over a year ago and almost everyone in the Department is subject to it.
Yes! It’s required by the Plain Writing Act of 2010.
A lot of people don’t agree. In fact, government writing in general is often so hard to understand that Congress got involved. The Plain Writing Act requires federal agencies to write their documents that the public has to use in plain language.
In DoD Instruction 5025.13, “DoD Plain Language Program,” the Director of Administration and Management decided to go a step further. Why write clearly for the public, but not do the same for our own Department? All DoD personnel should be able to read internal documents, whether they’re DoD issuances, memos, or e-mails, and clearly understand what they must do. So basically everything you write on the job should be written in plain language.
Well, the public shouldn’t be the only ones who benefit from plain language. Your fellow DoD employees should also be able to read documents without sifting through a lot of unfamiliar terms and hard to follow sentences. It’s really a matter of making the Department run more efficiently through clear communication.
When you write using plain language, your audience can understand your message and find what they need the first time they read it. Your writing:
Lots of people think plain writing is “dumbed down” writing. Not so! When you write plainly, you direct your writing to your reader. If you’re writing for a nuclear physicist, your language will be pretty technical, but still should be clear. If you’re writing a manual with instructions that a Service member with a high school diploma will need to carry out, the language will be different.
There are a lot of resources that deal with plain language. You can start with the DoD Plain Language Website. This site has style guides and training programs. You can also look at the resources available at plainlanguage.gov.
Your DoD Component may also have plain language training available for you. DoD Instruction 5025.13 requires that each Component have a plain language point of contact, and that person can help you get the training you need. If you don’t know who that is, contact our plain language inbox for help.
I will be posting more BLTs with specific tips for writing with plain language.
Before you submit your issuance to the Directives Division for a precoordination review, you need to coordinate your issuance. But wait, isn't that what the formal coordination stage is for? The answer, naturally, is "yes and no". Formal coordination (Stage 3) is when your issuance is coordinated throughout DoD. But there's one Component that doesn't coordinate during Stage 3: your own! Instead, your Component gets to have its say much earlier in the issuance process. This is called "internal coordination" because you are coordinating the issuance within your own Component. Before I go into detail, let's take a moment to learn what a "Component" is.
In correspondence you receive from Directives Division and in the various issuance standards, you'll run into the term "Component". When we're talking about Stage 1 (Development) processes, "Component" means one of the major offices within the Office of the Secretary of Defense (OSD) whose head reports directly to the Secretary and Deputy Secretary of Defense. We call these "OSD Components" (with a capital "C"). For instance, the Office of the Under Secretary of Defense for Personnel and Readiness (USD(P&R)) is an OSD Component. So are the Office of the Under Secretary of Defense for Policy and the Office of the Under Secretary of Defense for Intelligence.
How about the Office of the Assistant Secretary of Defense for Health Affairs (ASD(HA))? Is this an OSD Component? Nope. This is because the ASD(HA) is under the authority of the USD(P&R). How about the Defense Logistics Agency? DLA isn't an OSD Component either, because it's under the authority of the Under Secretary of Defense for Acquisition, Technology, and Logistics.
So, when we tell you to circulate your draft issuance throughout your Component to agencies and directorates with an interest or equity in your topic, we are talking about your entire OSD Component—that is, if you are in an office under the ASD(HA), you must coordinate not just within Health Affairs, but with any offices or agencies in the Office of the USD(P&R) that might be affected by this policy. This input is important early in the process. In our example of USD(P&R), the Offices for Reserve Affairs and Military Family Policy might have responsibilities or interest in the policy being established, but because they're under the originating Component (USD(P&R)) they wouldn't participate during Stage 3 (formal coordination). This is why it's vital that offices under the originating OSD Component are consulted during Stage 1. In addition, we need to see what your entire Component considers the "final" version of your issuance when we do our review in Stage 2 (Precoordination)!
Each individual Component determines the procedures for acquiring internal coordination. Components may use CATMS or a similar program to coordinate on draft issuances. We recommend you have responders use the DD Form 818, "Comment Matrix for DoD Issuances," to submit and justify comments. How much time you give your agencies and offices to review is up to you, but consider the number of reviewers, the size of the document, and the importance of getting Component consensus on the issuance.
When you fill out the draft DD Form 106 before submitting for Stage 2 review, don't forget to check the "Internal Coordination" box to indicate that internal coordination has been completed.
Another activity that will help make your issuance stronger is "informal coordination." This optional coordination is different from internal coordination. You might consult with agencies and offices outside of your OSD Component at the action officer level to get feedback and suggestions when writing a new issuance or revising a current one. For instance, if the policy is going to impact the Services, informally discussing your proposed policy with your peers in the Army, Navy, Air Force, Marine Corps, and Joint Staff might bring up issues you didn't anticipate. This is called "informal coordination" because we don't track this coordination and you don't have to prove that it was completed. It is completely optional, but we highly recommend it. In addition to helping draft a strong policy, working with outside agencies during issuance development will pave the way for acceptance once the document reaches Stage 3. Remember, informal coordination does not take the place of a response from these agencies during formal coordination!
If you're going to informally coordinate, we also recommend you use the DD Form 818 to keep your comments standard. Informal coordination should also be completed before the issuance is sent to us at Stage 2.
Both of these Stage 1 activities are vital to publishing DoD issuances that establish strong policy, provide clear guidance, clarify procedures, and delineate responsibilities for all concerned.
Directives Division revised the DD Form 818, "Comment Matrix for DoD Issuances," to provide new features for coordinators and action officers working with issuances. The clearer, streamlined instructions outline the roles for both the coordinators and for the collectors of the comments. The drop-down menus, sorting features, and automatic numbering will make some of your duties easier.
The classification and originator adjudication columns each have drop down menus - no more doubt about what's supposed to go in the column. The commenter column also requests specific suggestions for modifying the issuance from the commenter.
There are no more “types” of comments, but instead a box to check if this comment is the basis of a nonconcur. If several comments make up the basis of the nonconcur, then they should all be marked.
Sorting the table by page and paragraph numbers after all comments are consolidated will make your job easier.
You can use automatic comment numbering after your comments are compiled - no more having to correct comment numbers when updating or correcting the DD 818!
Finally, the coordinator’s signature is part of the DD 818 now, so that there is no disconnect from the coordination and the comments submitted. Be aware, however that once the DD 818 is signed, you cannot change the comment matrix without invalidating the signature.
Watch the DD 818 video demonstration
Okay, you've answered all the What, Why, Who, Where, and How (See May 2012's BLT) for your issuance and now you are ready to put pen to paper (or finger to keyboard).
Before you do anything else (do not pass Go!, do not collect $200)—go to the DoD Issuances website and download a new template for your issuance. (If you are in ODCMO and you’re working on a charter for DepSecDef signature, use this one.) Even if you are reissuing a document, always start with the latest template.
The template is a "blank" document with all the formatting set up for you. Requirements change and standards are modified, so it's always best to download the template directly from the website. While you're on the website, copy the accompanying Directives Division standard to your desktop for reference. The template shows you how your document should look; the standards tell you what you should say, how you should say it, and where in the document it belongs.
Writing clearly is not only good business communications, it's required by law (see the Plain Writing Act of 2010). Keep the basics in mind when working on your issuance:
Organize the material. We learned in school to use an outline, and it's still a valuable tool. Plan what you're going to discuss and what order makes sense (keeping in mind basic issuance standard requirements) and stick with it. It's very easy to lose track when your document's large or requests for changes are flying at you from all directions. If during the writing process it becomes clear the issuance needs to go in a different direction, rework your outline. This may seem like "busy work," but it will serve you well in the long run.
Keep sentences short. Form subparagraphs if necessary. Limit sentences to one thought. A good goal is to keep them below 20 words.
Use parallel grammar construction. If you're listing items that must be included in a report and a, b, and c are nouns, d must also be a noun.
|Example: Not||Example: But|
|Quarterly reports must include:||Quarterly reports must include:|
|a. Name of Component||a. Name of Component|
|b. Dates covered||b. Dates covered|
|c. Theater of operation||c. Theater of operation|
|d. Summarize the major events||d. A summary of the major events|
Use active voice. Active voice means the sentence has an actor (subject) committing an action (verb). Instead of the typical bureaucratic, "reports shall be submitted quarterly by all installation commanders," start with the actors: "Installation commanders will submit quarterly reports."
Eliminate helping verbs in sentences. Helping verbs are usually a form of the verb "to be". Instead of "the committees will be meeting monthly" say "the committees meet monthly." Instead of "the Assistant Secretary of Defense will be responsible for ensuring all agencies comply" say "the Assistant Secretary of Defense ensures all agencies comply"
|Don’t use six words when three will do:|
|in order to||to|
|in the event that||if|
|on the occasion of||when|
|Use everyday words, not legalese or jargon:|
|herewith is||here is|
|Avoid turning verbs into nouns:|
|conduct an investigation||investigate|
|convene a meeting||meet|
What do you need to know to develop a new issuance? There is a short answer and a longer one.
The short answer is simple: follow guidelines laid out in DoD Instruction (DoDI) 5025.01 as the authoritative guide for the mechanics of developing, coordinating, and issuing a new policy.
The longer answer requires answering several familiar questions: Why? What? Who? How? and When?
Why? In most cases, you develop a new issuance to fill an identified policy gap or to implement:
Why Tip: The E.O.s, laws, decisions, or policies virtually always drive the Purpose, Applicability, and Policy sections of a new DoD Directive or Instruction. That said, DoD issuances are directive in nature and must cite the authority to issue policy, but you should not include detailed history of how the policy was developed or why it's needed.
What? What needs to be done (or not done)? What goals and objectives am I (or DoD) trying to accomplish? This determination focuses the Policy section in the new document. Be sure to do your homework to verify that these policies are new (not established elsewhere). What parameters are being established, and for whom? What should the reader know and do after reading the issuance? Does that fit with your Why?
Who? You can usually identify the major stakeholders based on the originating decision or policy gap and what needs to be done. Who does the policy affect the most? What organizations can make the what happen? This is a good start toward determining the organizations to be named in the Responsibilities section.
Who Tip: Do not copy responsibilities from charters, other DoD policies, or from agency or Service issuances. They may not be appropriate for your issuance and they may be out of date.
How and When? Directives primarily address what. Instructions and Manuals may also address what in terms of implementing policy, but they routinely discuss how and when in terms of procedures. These are as detailed as necessary to make the guidance useful to those who must execute it.
How and When Tip: Always develop procedures in conjunction with those who must carry them out.
It sounds simple, and in most cases it is when you work through the questions systematically. That leads to:
A final Tip: When beginning to develop an issuance, go to the writing guide, templates, and standards provided on the DoD Directives Website (http://www.dtic.mil/whs/directives/corres/writing/process_index.html) for the latest and greatest guidance on the issuances development process.
Keep in Mind: Issuances set boundaries, assign responsibilities, and clarify relationships so organizations and people can operate legally and effectively. If your document does those three things, it will be worth all the time and effort you invest.
Stay tuned: Part 2 will address grammar and writing tools for issuance developers.
Formal coordination on your issuance closed more than a month ago. Your supervisor and others are anxious to see forward progress on this policy. You have been working with a coordinator to resolve a non-concur but have been unsuccessful. Can you move forward?
The short answer is yes, you can. While generally you want to address all comments during formal coordination and try to satisfy concerns of everyone with equity in your issuance, sometimes it is just impossible to make everyone happy.
If you as the action officer made a good faith effort to resolve the coordinating component's concerns, you may move the issuance forward with a non-concur. If you have been working with your OSD Component’s legal office, you may consult with them about any legal aspects of the unresolved issue. You can always consult with the DoD Office of General Counsel. Your Component focal point can help you find an appropriate source.
After formal coordination is completed, you prepare a presignature package to send to WHS Directives Division for review. One of the things included in the presignature package is an action memo requesting the Head of the Component approve publication of the issuance. The action memo is where you make a case for approving the issuance over the objection of the non-concurring component. You should explain the efforts made to address the comments, your reasons for not accepting the proposed changes, and any legal opinion obtained about the issue. Generally you will request the approval authority approve the issuance over the objection of the non-concurring component.
Sometimes through informal negotiations you are able to satisfy a non-concurring component's issues but have not received an official withdrawal of their non-concur. Again, you do not need to wait until official paperwork can be processed. In the action memo, note that Component Z non-concurred at formal coordination, state what efforts were made and changes incorporated to address the concerns, and the informal approval received from the commenter.
The point of the action memo is to be sure the Component head is aware of all issues, especially non-concurs, and how they were addressed before approving the issuance. If a non-concur is withdrawn between the presignature review and approval, the action memo can be modified to reflect current status before being sent up for approval. The person approving issuances needs to be fully aware of any outstanding issues and efforts made to resolve them. But a stubborn component or delayed paperwork does not have to prevent your issuance from moving forward.
Is your policy languishing somewhere in the process as your supervisor rails at you for the apparent inactivity?
To keep from making your own contribution to the cycle of frustration, save yourself some time by avoiding these Five Classic Process Mistakes when navigating the coordination process:
Policy development is a collaborative venture. You have important equities, but so do others. Don't ignore theirs. If you fail to do solid informal socialization of your policy concept before finalizing your draft, you invite criticism that you will have to deal with formally later. That eats up valuable time. Acknowledging and defusing criticism up front reduces non-concurs and significantly streamlines the formal comment adjudication process.
Washington Headquarters Services Directives Division (DD) employs and trains professional analysts with strong editing skills. They have one goal: to review your policy so that it conforms to DoD standards and is understandable to the reader. If your analyst doesn't understand what you are trying to say, many others won't either. Rejecting a DD change should be rare practice. Consult with your analyst of record if you have concerns.
Once you submit your draft for precoordination review, you have established your baseline. The draft that comes back to you from DD must be used throughout the subsequent coordination process. That version has been amended to meet DoD issuance standards, and all subsequent changes as a result of comments must be posted to that version (and any updates your analyst makes to that version at LOR or Portal review). Using a different version (or versions!) after pre-coordination is a time-devouring disaster!
During formal coordination, comments from DoD Components are often received over several weeks. As soon as a critical comment or non-concur is received, engagement becomes the word of the day. The sooner you begin working to understand and resolve the commenter's concern, the more likely you are to meet your adjudication timeline. Additionally, do not hesitate to raise the really hard issues to your supervisor. Criticals are the hardest; work them first, not last!
The attorneys get multiple shots at every issuance to make sure we're on sound legal foundations. Changing the document after a legal review and before the next process step invalidates the legal review! For example, if you receive legal comments from a legally objectionable review, make the appropriate changes, and submit THAT revision for formal coordination. DO NOT make changes the attorneys did not ask for. Otherwise, you will pay for it in time to "re-chop."
The equities of other DoD Components are not irritants to be grudgingly accommodated, but an essential part of the process to ensure that policy developed effectively serves the entire Department of Defense.
You've been tasked with reviewing a DoD Issuance that affects your division, component, team, or agency. Something in the responsibilities, procedures, or requirements is just not (a) feasible, (b) economical, (c) healthy, (d) or smart. You say "This must be changed!" and provide a comment. Just to make sure that the action officer for the issuance will take your comment seriously and make the change that you require, you label the comment "critical".
Not so fast! Before you load your critical comment into the SD 818, Comment Matrix, you need to see what DoD policy has to say about the criteria for critical comments. Not just any comment can be designated as critical. Critical comments are those that:
So before you designate your comments as critical, check them against the above criteria to see if they really are. Keep in mind that if you submit even one critical comment, your Component must automatically nonconcur with the issuance. Marking a comment "substantive" rather than "critical" does not mean it will be overlooked. All comments submitted in coordination must be adjudicated.
If, based on the criteria, you still believe your comment qualifies as critical, specify what needs to be done to satisfy your component's concerns. For example, a comment that is tagged as "critical," but simply says, "how are you going to address the security issues created by this database?" makes it difficult for the action officer to address the comment in a concrete way. Suggest new language, request deletion of certain phrases, or specify precisely what needs to be added or subtracted to satisfy your concerns. That way the action officer has an opportunity to accept your comment and thereby satisfy the nonconcur without requiring additional emails, memos, or re-signed SD 106s.
While a critical comment is an automatic nonconcur, several substantive comments can also result in a nonconcur. If your comments don't meet the criteria for critical but you are concerned about several issues, you may submit substantive comments with a nonconcur. This then requires the action officer to address the issues submitted in the comments and satisfy the coordinator's concerns enough to get the nonconcur withdrawn. If you specify which substantive comments led to the nonconcur, it is considered automatically revoked if the AO accepts the comments and makes the required changes to the issuance. Everyone saves time and effort!
DoD Directives (DoDDs) are "big picture" issuances signed by the SecDef or DepSecDef. They establish DoD policy, assign responsibilities, and delegate authority to DoD Components. DoDDs do not contain procedures. There are two types of Directives: direct oversight and chartering. In almost all cases, the Directive you write will be a direct oversight Directive, that is, one that includes activities that require SecDef or DepSecDef oversight. Direct oversight Directives contain:
Chartering Directives, or charters, establish the mission, responsibilities, functions, relationships, and delegated authorities of the Head of an OSD Component; an OSD Presidentially-Appointed, Senate-Confirmed Official; or the Head of another major DoD or OSD Component. They have names such as "Deputy Secretary of Defense" or "Under Secretary of Defense for Policy." These are usually developed exclusively by the Office of Organizational and Management Planning, or O&MP. If you think your issuance should be a charter, you should contact O&MP first.
Directive Type Memorandums (DTMs) are issued ONLY for time-sensitive policy actions that cannot wait for a Directive or Instruction to be coordinated and published. DTMs may establish policy and assign responsibilities, or they may implement policies and responsibilities established in existing Directives or Instructions. Think hard before using this one; while DTMs move through the issuance process faster than other types of issuances, DTMs are effective for only 180 days from the date signed. The other issuances are valid for 5 years. The policy or procedures established in DTMs must be incorporated into another DoD issuance by the expiration date. DTMs requiring SecDef or DepSecDef direct oversight must be signed at that level, but OSD Component Heads or their Principal Deputies may issue DTMs within the scope of their charters.
DoD Instructions (DoDIs) are usually signed by a PSA (e.g., an Under Secretary of Defense or Assistant Secretary of Defense). They can establish or implement policy, and they provide general procedures. Policy Instructions allow the PSA to establish policy and procedures for activities within his or her chartered responsibilities. Be sure to cite your Component's charter as a reference in your Instruction. The charter gives the authority to publish your Instruction. Non-policy Instructions implement policy established in either a Directive or a policy Instruction, which must be cited as a reference in the Instruction. Policy Instructions are signed by the PSA; non-policy Instructions can be signed by the Component Head, the Principal Deputy, or other officials authorized by the charter.
DoD Manuals (DoDMs) implement or supplement policy established in a Directive or Policy Instruction and must cite either as a reference in the DoDM. Manuals usually focus on procedures for managing activities or systems. A Manual may summarize policy that has been established elsewhere, but cannot establish policy. DoDMs are often issued in multiple volumes. Manuals are signed by OSD Component Heads, Principal Deputies, or other OSD officials as authorized by their charters.
Administrative Instructions provide guidance on administrative matters related to implementing policy established in DoDDs or DoDIs that focus on administration of the DoD Components in the National Capital Region. Most AIs impact only Components that are serviced by WHS, but they can also apply to all Components.
The Plain Writing Act of 2010 and DoD Instruction 5025.13 require DoD issuances to be written in “plain language.” Okay, but what does that really mean?
Plain language advocates writing concise, clear sentences that contain one idea. However, readers of DoD documents can be confused by too much jargon and too many acronyms. Overuse of either one makes your issuance impenetrable to new employees, colleagues from other offices, interested taxpayers, or even co-workers who have to quickly process information that may look like a coded message.
Although there is probably at least one “veteran” in your office who understands what “RTB NLT 0800Z” means, most probably have to mentally translate this phrase before they can understand it. Your reader wastes valuable time trying to decode acronyms rather than understand direction.
Plain writing standards advocate establishing and using acronyms only when they will be used more than 5 times in a document. Although DoD issuance standards are not this strict - and we do require that all acronyms other than “DoD”, “OSD”, and “U.S.” be established - it is a useful guide. Establishing an acronym for a term that’s only used a few times won’t simplify your issuance. Regardless of how familiar an acronym is to you, some of your readers have never seen it before; even if you’ve defined it, they don’t quickly understand it. Remember, your issuance is written for them, not you.
Jargon are specialized words that make it hard for readers outside of your discipline to understand your meaning. While it might seem like everyone you know understands exactly what that 18-letter long word means, your readers may be better served by a more common word. Like using acronyms, we don’t always realize that words we use every day are jargon. To break out of this cognitive trap, here’s an example of jargon from a non-DoD source to get an outsider’s perspective on how jargon can make things unreadable:
When boiled down, this means the author wants to use a survey to see if the non-faculty staff at a college is taking courses. This is a much plainer way of putting the thought, and is much more readable. The reader of a jargon-free issuance will better understand what they are supposed to do compared to someone who has to decode it using the Glossary.
There are going to be times when a technical term is absolutely required because the specificity demands it. Most of the time, however, using jargon for its own sake is unnecessary.
To stretch a familiar metaphor, overusing acronyms and jargon makes your readers lose sight of the forest, not for the trees, but to examine the bark with a microscope. Taking the time to remove excessive acronyms and unnecessary jargon from your writing at the beginning of the process will make your issuances easier to read and implement.
Additional resources on plain language are available at the DoD Plain Language Website (http://www.dtic.mil/whs/directives/plainlanguage.html) and at plainlanguage.gov.