Letter to William Mansell, Director of the Defense Travel Management Office - Young, Donnelly, Banks Call for Reevaluation of Military Housing Pay for Servicemembers in Ft. Wayne

Letter

Dear Mr. Mansell:

We are writing to ask that you reevaluate and consider increasing the basic allowance for housing (BAH) for the Fort Wayne, Indiana, Military Housing Area (MHA), IN097, consistent with United States law and public policy.

It has come to our attention that data informing the current housing allowance rates in the Fort Wayne area do not accurately reflect current housing costs to more than 200 Hoosier servicemembers and their families.

We understand that the Defense Travel Management Office (DTMO) employs a contractor to collect annual data to determine the market price of rental housing in a given area and that there are a variety of sources for this data, including real estate professionals, rental listings, military housing offices (MHO), and local installation leadership. We are concerned that in the case of IN097 the data submitted to DTMO were inaccurate or incomplete over the course of several years, and as a result, BAH has not met DTMO's goal of providing fair housing allowances that cover the costs of housing in the private sector.[1]

DTMO must have accurate and complete data to determine rates across a variety of housing types associated with various ranks. However, in the case of IN097 it appears insufficient data were submitted to make a fair determination for 2017 BAH. For example, of the 158 units surveyed for the 2017 rate determination, the target for data collection on three and four bedroom homes should have been at least 30 dwellings each, yet data available from prior years shows no such dwellings submitted. Based on information gathered by the 122nd Fighter Wing, there is a significant variance between the rates paid to servicemembers in the ranks of W3 to O7, which are the ranks for which DTMO uses three and four bedroom homes to calculate appropriate BAH rates.

Furthermore, since 2003, the Fort Wayne area has experienced significant development in formerly rural areas. However, 76 of the 97 census tract zones included in the data on this region supplied through the local military housing office had not been updated between 2003 and 2017. In fact, only five of the 97 tracts were updated at all between 2012 and 2017. As you know, updates based on factors like local family incomes, costs, and crime rates are essential to determining what census tracts to include or exclude in DTMO's BAH rate calculations based on Department of Defense standards for housing units and areas that are "suitable and appropriate."[2]

We are concerned that past inadequacies on the part of the MHO have resulted in a pattern of flawed data that has informed lower than appropriate BAH rates for the Fort Wayne MHA for years, continuing to this day. We are confident that appropriate consultation with local installation leadership would have rectified these errors in the past and can do so going forward. However, it is our understanding that the 122nd Fighter Wing had not been consulted on BAH rates in recent memory until this past year, and was only added into the process after a forceful effort on their part to gain access to information.

Given the significant impact BAH has on the lives of the Active Guard and Reserve (AGR) servicemembers in Fort Wayne, it is deeply troubling that the local installation leadership had to go to such great lengths to receive the data used to determine compensation for the men and women under its command. It is even more troubling that despite the involvement of organizations in the MHA to provide data into DTMO's 2018 process via the MHO portal, the updated rates still do not appear to fully align with the information provided. DTMO's rate calculations do not appear consistent with the appropriate determination based on the data available to the installation leadership and public information regarding DTMO's rate computations.

Based on the information we have seen, we believe it is imperative that you promptly reevaluate the housing allowance rates for the Fort Wayne area in line with applicable U.S. law and public policy. Consistent with DTMO's standards for local input in the data collection process, data compiled by the 122nd Fighter Wing should be appropriately considered in your review. We ask that you take up this matter as soon as possible and inform us of any change to your rate determination, providing us with the data on which your decision is based.

Furthermore, we ask that you immediately provide all requested information, consistent with applicable U.S. law and public policy, related to the 2018 rate determination for IN097 and direct appropriate subject matter experts to meet with leadership of the 122nd Fighter Wing within 30 days to discuss the 2018 rates in full. Specifically, we ask that you provide a copy of source data and calculations used to determine the current BAH rates. Information available to the 122nd Fighter Wing through DTMO's BAH primer and the approved data submitted through the MHO portal does not justify the numbers assigned to IN097 for its BAH rates in 2018. After the 122nd Fighter Wing has had time to review the data and calculations provided, we ask that the appropriate DTMO personnel meet with them to discuss discrepancies and answer questions.

Finally, it seems possible that the lack of appropriate communication with the local installation in this case is due to structural and organizational differences between active component and reserve component units and installations. The 122nd Fighter Wing is a unit of the Indiana Air National Guard. Given the significant number of servicemembers on AGR status nationally who rely on BAH just like their Active Duty counterparts, it is essential that DTMO seek out and receive input from active and reserve component units alike.

As such, we urge you to circulate guidance throughout DTMO to ensure that command leadership of National Guard and Reserve units with servicemembers receiving BAH are consulted every year in your annual data collection process. Please inform us of your decision on this request and provide a copy of any guidance circulated as a result.

Thank you for your service and leadership. We have every confidence that as a veteran and dedicated civil servant yourself, you are committed to the goal of ensuring servicemembers receive fair compensation and benefits in return for all they sacrifice for our nation. We appreciate your personal attention to this matter and look forward to your response. If we can be of any assistance, please do not hesitate to contact me.

Sincerely,

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