Commentary | June 4, 2021

COVID-19: Reserve demobilization guidance

COVID-19 response orders are currently funded under the CARES Act. The period of availability of these funds will expire on Sept. 30, 2021. All reservists currently on active duty in support of COVID-19 response requirements must either be demobilized by that date or transitioned to a new funding string provided by COMDT (CG-8).

The order-issuing authority is responsible for ensuring the member is demobilized in the Direct Access Mobilization Module (DAMOB) with an accurate departure date, in addition to the administrative demobilization and RELAD procedures.

This article provides guidance for units and Servicing Personnel Offices (SPOs) on common issues and questions identified during the Release from Active Duty (RELAD) process for reservists recalled to active duty under § 12302 or § 12301(d) (contingency Active Duty for Operational Support (ADOS)) of REF (A) as authorized by REF (B) and REF (C). 

For purposes of entitlements and benefits, COVID-19 response is considered a contingency operation.

Involuntary mobilization limits
Reservists may be involuntarily recalled under § 12302 of REF (A) as authorized by REF (B) and REF (C) for a maximum of 365 days; there are no exceptions to the 365 day limitation without individual waivers from the Secretary of Homeland Security. RELAD process requires a 60-day notification when practical prior to RELAD in accordance with (IAW) chapter 3 of REF (D). If members approach their 365-day involuntary mobilization limit and volunteer to remain on active duty in support of the COVID-19 operations, they may be issued new voluntary contingency ADOS-AC orders under § 12301(d) of REF (A).

Members should expect to RELAD on their end of orders date, or date specified by the command when the mission completion date occurs before the original orders end date.

All RELAD procedures, including the utilization of accrued leave, must be complete prior to departure. 

When practicable, the member should be provided 60 days’ notification of early RELAD, however, in the event where 60 days is not practicable, members must have minimum of 30 days’ notice to allow SPOs time to complete all transactions.

Accrued Leave
Accrued leave will be treated IAW chapter 10.A of REF (E). The 60-day career limitation for selling leave does not apply to leave accrued while serving in support of a contingency operation.

Personnel with accrued leave have the options of selling unused leave IAW REF (D), taking transitional leave, carrying leave forward to a future active duty period, or a combination thereof.

Leave balances will remain subject to the established fiscal year carryover limitations of REF (F) which announced National Emergency Special Leave Accrual (SLA). Reserve members are reminded that they can only use carried over leave on future orders of 30 days or more.

Orders under § 12302 authority of REF (A) cannot be extended beyond 365 days under any circumstances, including for the use of leave.

Order modification for individuals pending disciplinary proceedings
Individuals pending disciplinary proceedings under the Uniform Code of Military Justice (UCMJ) may be retained on active duty without their consent, as provided by Rule 202(c) of REF (G) and § 802(d) (Art. 2, UCMJ) of REF (A), pending resolution of allegations. Members ordered to active duty under § 12302 of REF (A) whose recall status changes for administrative reasons must have their orders modified on or before completing 365 days, to reflect that they no longer serve under the provisions of involuntary orders under § 12302 of REF (A). Commands must notify commander PSC (RPM) and FORCECOM (FC-1) for coordination and consultation as soon as possible.

Retired pay
A reservist who performs 90 days of active duty will have their eligibility age for receipt of retired pay reduced below 60 years of age by three months for each aggregate of 90 days for which the member performs active duty in any two consecutive fiscal years. The eligibility age may not be reduced below 50 years of age for any reason. Policy and additional information can be found at: https://militarypay.defense.gov/Pay/Retirement/Reserve.aspx.

Required paperwork and counseling
All reservists who RELAD must meet certain separation requirements prior to RELAD.

  1. Members must submit a CG-2045 Career Intentions Worksheet to their Admin shop upon notification of their RELAD and no later than 45 days prior to the actual RELAD date. Timely submission of this worksheet is the best way to ensure there are no pay issues. For questions, see chapters 3 and 10 of REF (D).
  2. All reservists recalled to active duty in support of COVID-19 operations, for any length of time, are entitled to a Certificate of Release or Discharge from Active Duty (DD Form 214) upon RELAD.
  3. DD Form 214s for reservists who RELAD from being recalled in support of COVID-19 response should be completed IAW chapters 3 and 10 of REF (D).
  4. A Limited Health Assessment (LHA) - also known as the Limited Periodic Health Assessment - and/or a Separation History and Physical Examination (SHPE) must be completed via a face-to-face visit within 30 days prior to separation date from active duty IAW REF (D) and REF (I). (See Medical Evaluation section below for more details.)
  5. If not completed in last 6 months as part of Periodic Health Assessment (PHA) or other assessment, a Mental Health Assessment (MHA) must be completed.
  6. All personnel must also be provided minimum separation counseling prior to RELAD per chapters 3 and 10 of REF (D), including the following programs
  • Servicemembers Group Life Insurance (SGLI)
  • Uniform Services Employment and Reemployment Rights Act (USERRA)
  • Transitional Assistance Management Program (TAMP)
  • TRICARE Reserve Select (TRS)
  • TRICARE Dental Program (TDP)
  • Post 9/11 GI Bill (Chapter 33)
  • BAH/CONUS COLA Entitlements
  • Dwell period

7. Members who have served 90 days or more supporting COVID-19 response should receive readiness and resiliency training and benefits information via coordination with the CG Yellow Ribbon Reintegration Program (CG YRRP).

Medical evaluations
All reservists who RELAD must meet certain separation requirements prior to RELAD to include a medical examination per REF (H).

A Limited Health Assessment (LHA) - also known as the Limited Periodic Health Assessment - and/or a Separation History and Physical Examination (SHPE) must be completed via a face-to-face visit within 30 days prior to separation date from active duty IAW REF (D) and REF (I).

If not completed in last 6 months as part of Periodic Health Assessment (PHA) or other assessment, a Mental Health Assessment (MHA) must be completed.

Reservists must complete a SHPE when separating after 180 days or more of continuous service on orders, or when separating with greater than 30 days of continuous service on orders in support of a contingency operation.

Reservists must complete a LHA when separating after short-term ADOS under § 12301(d) of REF (A).

Any illness, injury, or disease must be documented in the reservist’s health record, and if necessary, a Line of Duty (LOD) determination will be made IAW REF (J).

If a reservist RELADs prior to completing the required SHPE, PSC-RPM-3 must be contacted immediately for coordination and issuance of orders under § 12301(h) of REF (A) for the period of medical evaluation.

Post-Deployment Health Assessment (PDHA) DD Form 2796 and Post-Deployment Health Re-Assessment (PDHRA) DD Form 2900. For COVID-19 mobilization, completion of the PDHA and the PDHRA are not required. COMDT (CG-11) may add additional COVID-19 deployment-specific requirements.

Medical Holds/Notice of Eligibility (NOE)

Any illness, injury, or disease must be documented in the reservist’s health record, and if necessary, a LOD determination will be made IAW REF (J).

With approval from PSC-RPM-3, members meeting LOD criteria must have their involuntary orders under § 12302 of REF (A) terminated (change actual end date of orders) and must be issued voluntary orders under § 12301(h) of REF (A), for medical treatment under this provision.

Orders under § 12301(h) of REF (A) will remain in effect, pending resolution of the medical issue and/or completion of the physical disability evaluation board process IAW REF (K).

Reservists who elect to stay on voluntary orders for medical treatment must remain at a Coast Guard unit with the capacity and expertise to swiftly manage their case to conclusion in proximity to appropriate medical facilities and professionals. For specific guidance, contact PSC-RPM-3.

Reservists who elect RELAD must have their medical concerns fully documented in their medical records prior to release. The reservist’s permanent duty station must request a NOE authorizing health care at a military or civilian facility from PSC-RPM-3 through the servicing district (Dxr). 

Commands must work with DXR/RFRS staff to complete LOD and initial request package for medical hold and NOE for final authorization from PSC-RPM-3. A monthly update is required by the responsible clinic until the reservist has been determined available for full duty (AFFD) or separated/retired IAW the process detailed within REF (K). 

Further guidance for Medical Holds and NOE's, to include templates and additional information, can be found in chapter 6 of REF (L) and the PSC-RPM-3 portal site at:
https://cglink.uscg.mil/3b33b612.

IDT, ADT-AT policy relaxation
Members who have served more than three months of involuntary active duty under § 12302 of REF (A) may participate in, but are not required to, resume IDT in the first 60 calendar days following RELAD. Reservists who recently RELAD must resume IDT within 90
days of their RELAD. These members may participate in, but are not required to perform, ADT-AT in the first six months following RELAD.

While this policy relaxes participation standards for these reservists, nothing in this policy relieves members of the requirement to earn 50 points in an anniversary year. Members are still responsible for earning 50 retirement points in order to be credited with a satisfactory year towards a reserve retirement per § 12732 of REF (A).

Resources

  • ALCOAST 210/21 - JUN 2021 COVID-19: RESERVE DEMOBILIZATION GUIDANCE FOR COVID-19
  • For PSC-RPM-3 questions: ARL-SMB-CGPSC-RPM-Reserve-Medical@uscg.mil
  • For questions on Reserve policy and execution standards: HQS-DG-LST-CG-R55@uscg.mil 
  • For questions on General workforce policy standards: HQS-Policyandstandards@uscg.mil
  • For questions on the CG Yellow Ribbon Reintegration Program: HQS-DG-LST-CG-R-yellowribbon@uscg.mil

References
A. Title 10, United States Code
B. Executive Order 13912 of 27 Mar 2020
C. COMDT COGARD WASHINGTON DC 250932 SEP 20/ALCOAST 363/20
D. Personnel & Pay Procedures Manual, PPCINST M1000.2 (series)
E. Coast Guard Pay Manual, COMDTINST M7220.29 (series)
F. COMDT COGARD WASHINGTON DC 011348Z JUN 21/ACN 055/21
G. Manual for Courts-Martial United States (2019 ed.)
H. Coast Guard Medical Manual, COMDTINST M6000.1 (series)
I. The Separation History and Physical Examination (SHPE) for the
DoD Separation Health Assessment (SHA) Program, DoDI 6040.46
J. Administrative Investigations Manual, COMDTINST M5830.1 (series)
K. Physical Disability Evaluation System, COMDTINST M1850.2 (series)
L. Reserve Policy Manual, COMDTINST M1001.28 (series)