GAO Report Underscores Need to Halt MTF Restructuring

GAO Report Underscores Need to Halt MTF Restructuring
Courtesy photo via Air Force

A recently released Government Accountability Office (GAO) report highlights numerous shortfalls with DoD’s plan for restructuring military treatment facilities (MTFs), including insufficient analysis – based on incomplete and/or inaccurate information – of the availability of high quality civilian medical care for impacted beneficiaries.


The report underscores MOAA’s objections to moving forward with MTF restructuring at this time and builds on our sense of urgency in asking Congress to include additional reporting requirements and congressional oversight in the FY 2021 National Defense Authorization Act (NDAA).


MOAA already has contacted Armed Services Committee staff in both the House and Senate, and we are drafting a letter to committee leadership in both chambers outlining our concerns.


For the last several months, MOAA has urged Congress to include a provision in the FY 2021 NDAA to suspend MTF downsizing and medical billet cuts. The issue was the centerpiece of our successful virtual Storming the Hill campaign, which mobilized thousands of MOAA members to contact their elected officials.


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We also have continued a dialog with Defense Health Agency (DHA) leaders to ensure beneficiary access to high quality care is considered throughout the MTF restructuring process. And next week, MOAA President and CEO Lt. Gen. Dana Atkins, USAF (Ret), will attend a Military and Veteran Service Organization Executive Session with senior leaders from the DHA and the services’ medical departments, where he will discuss MOAA’s concerns about the GAO report’s findings and urge further analysis and mitigation planning before any beneficiary care is eliminated from military facilities. MOAA’s top priority is ensuring beneficiaries maintain access to high quality health care.


Background on MHS Reform

With the FY 2017 NDAA, Congress directed DoD to reform the military health system (MHS), including both TRICARE and the direct care system of military hospitals and clinics. Congress’ goals were increased efficiencies, an enhanced focus on military medical provider readiness, and improved patient satisfaction across the MHS.


Earlier this year, as directed by Congress, DoD released its plan for rightsizing the direct care system. The plan recommended downsizing or closing 48 MTFs and would impact approximately 200,000 beneficiaries who receive care at those military hospitals and clinics. As part of the MHS reform process, Congress directed GAO to review DoD’s plan.


GAO Findings

GAO found DoD’s MTF restructuring analysis was based, in part, on incomplete and inaccurate information. MOAA has been told the analysis of impacted MTFs will continue during the implementation phase. That is encouraging, but we are concerned about the lack of reporting requirements and formal congressional oversight during implementation.


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After reviewing the GAO report, MOAA has the following concerns about MTF restructuring:

  • DoD’s analysis of civilian health care availability was limited and based on potentially faulty assumptions. This could lead to problems for beneficiaries moved out of MTFs who must find care elsewhere. Among the issues highlighted in the report:
    • Significant problems with determining civilian care availability. The plan based this availability only on the presence of providers in the local market – it did not look at whether those providers were accepting new patients and/or new TRICARE patients. The accuracy of the provider directory was not verified, and the plan assumed all civilian providers are of sufficient quality.
    • Inaccurate information in drive-time access-to-care assessments. These assessments did not account for traffic, including bridges and tunnels that create traffic chokepoints.
    • Flawed logic predicting provider growth. The plan assumes the supply of providers in impacted markets will increase over time, but recent research suggests there will be a nationwide shortfall of physicians by 2032.


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  • The plan’s analysis of cost effectiveness is limited and possibly flawed. This means MTF restructuring could result in higher-than-expected costs to DoD and subsequent calls for higher TRICARE fees for beneficiaries. Among the issues:
    • When calculating cost of MTF care, DoD included full cost of military medical personnel salaries even though military personnel who staff MTFs sometimes spend half or more of their time contributing to other military work activities.
    • The plan assumes no change to TRICARE reimbursement rates, even though future increases likely will be required to attract new, quality network providers as reliance on purchased care for beneficiaries increases.


  • The plan focused on MTFs’ support to combat casualty and physicians’ readiness, and only conducted limited assessments on the readiness impact to military primary care physicians and nonphysician medical providers including nurses, physician assistants, and enlisted medical and surgical specialists.
    • The plan does not evaluate the readiness benefits of primary care graduate medical education (GME) programs and non-GME training to MTFs. DoD states the impact on GME and non-GME training programs will be addressed in the implementation phase. GME and non-GME training programs conducted within MTFs are critical to the uniformed provider pipeline.


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  • DoD does not have a process for monitoring restructuring transitions to address challenges. Yet, the MHS plans to complete restructuring actions by Oct. 1, 2025.

  • DoD plans to reverse or slow an MTF transition if needed to address any challenges that arise with ensuring patients’ ability to access health care, the GAO report states. However, DoD’s plan does not discuss conditions that would warrant slowing or reversing an MTF’s restructure, or how the need for such an adjustment would be determined.


As the FY 2021 NDAA markup begins this week, MOAA continues to fight for an MHS reform process that ensures all military beneficiaries maintain access to high quality health care. Do you have concerns about your ability to access civilian medical care in your area? If so, please share them with MOAA by emailing


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About the Author

Karen Ruedisueli
Karen Ruedisueli

Ruedisueli is MOAA’s Director of Government Relations for Health Affairs and also serves as co-chair of The Military Coalition’s (TMC) Health Care Committee. She spent six years with the National Military Family Association, advocating for families of the uniformed services with a focus on health care and military caregivers.