A System Few Understand: Why FAP IDCs Face Rising Scrutiny and Calls for Reform

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The Fort Drum Family Advocacy Program hosts the annual Domestic Violence Awareness Month 5K on Oct. 2 to bring the community together for a good cause. In addition to receiving medals, runners could also find information about FAP resources. Photo by Mike Strasser, Fort Drum Garrison Public Affairs. Source: DVIDS

What the Family Advocacy Program and Incident Determination Committees Are Designed to Do

The Department of Defense’s Family Advocacy Program (FAP) is the military’s central system for addressing domestic abuse and child abuse involving service members and their families. Under federal regulation, FAP is responsible for the prevention, identification, evaluation, treatment, and reporting of family violence across the military services. Its administrative structure includes mandatory reporting processes, treatment programs for victims and offenders, and a central registry used to track maltreatment trends throughout the force. 

A central component of this system is the Incident Determination Committee (IDC). The IDC is a multidisciplinary installation-level team charged with reviewing every allegation of domestic abuse or child abuse reported to FAP. Its task is to determine, based on available evidence, whether the allegation “meets criteria” under DoD definitions. If it does, the incident is entered into the FAP Central Registry. If it does not, the case is closed at the administrative level. DoD policy describes this determination, called the Incident Status Determination, as the mechanism for deciding which cases become part of the department’s long-term records. 

In congressional testimony, DoD officials explained that when a servicemember or family member makes an unrestricted report of domestic or child abuse, military law enforcement conducts the criminal investigation, and that process is separate from FAP’s clinical assessment. The department emphasized that FAP’s role is to provide assessment, treatment, and coordination, while commanders, legal offices, and military law enforcement determine what criminal or disciplinary actions are appropriate. 

DoD guidance further states that IDC meetings are intended to be administrative and not disciplinary, and therefore, the due-process protections associated with Uniform Code of Military Justice proceedings do not apply. A 2024 GAO review notes DoD officials require IDC decision letters to explain this distinction by informing service members that an IDC “is not a disciplinary proceeding.” 

The Evidence-Based Framework DoD Says It Uses

According to DoD, the IDC process is built around standardized tools developed by researchers at New York University. These include the Decision Tree Algorithm, which guides IDC members through a structured series of questions to determine whether the allegation meets DoD definitions of abuse, and the Incident Severity Scale, which categorizes the seriousness of the incident once it has been substantiated. The Pentagon told Congress these tools ensure consistent, evidence-based decision-making across installations. 

Service-level guidance, including the Coast Guard’s FAP instruction, identifies entities such as the Coast Guard Investigative Service, legal program offices, and other command authorities as part of the broader framework that handles reporting, investigation, and oversight of family-violence matters. These authorities become involved under specified circumstances — particularly when an incident triggers a law-enforcement investigation or legal review — rather than as an integrated part of every IDC meeting. For the Marine Corps, local command-level orders illustrate how installations implement DoD FAP standards. One such order outlines procedural requirements for case management, case packet review, and the maintenance of incident records within the installation’s Family Advocacy Program. These requirements do not create a separate investigative role but instead reflect administrative implementation at the installation level. 

For the Navy, installation-specific instructions similarly implement FAP guidance in accordance with DoD standards. For example, Naval Station Guantánamo Bay outlines the responsibilities of its Family Advocacy Program, including notification procedures, case documentation, and coordinator duties, demonstrating how individual Navy installations apply and operationalize the broader DoD FAP framework. 

On paper, the system is clinical, structured, and narrowly tailored. In practice, critics argue the process has grown into something far more consequential – and far less transparent.

Where the Concerns Begin: Lack of Due Process and Lack of Access

A significant portion of the recent scrutiny comes from servicemembers, advocates, and scholars who argue that IDCs function as de facto adjudicatory bodies without accompanying due process protections.

A detailed analysis published in the Military Law Review by Erhan Bedestani examines the due process issues inherent in FAP’s predecessor (the Case Review Committee) and its successor, the IDC. The article notes that between 2014 and 2023, FAP IDCs reviewed 141,344 abuse allegations and found that 70,130 of them “met criteria,” yet DoD does not track how often those administrative determinations contributed to separation, loss of promotion eligibility, or other career-ending outcomes. The author argues that when a process can materially affect a service member’s livelihood, family structure, and retirement benefits, constitutional protections must follow. 

Walk the Talk Foundation, a nonprofit focused on transparency and accountability in military systems, has published several analyses examining how FAP IDCs operate in practice. Their reports highlight recurring structural issues including limited procedural safeguards, opaque decision-making, and the long-term consequences of administrative “met criteria” findings – all based on policy reviews, case studies, and contributions from military experts. A 2024 article by retired Army lieutenant colonels Francesca Graham and Erhan Bedestani states that neither alleged victims nor alleged offenders are allowed to attend IDC hearings, legal counsel is not permitted in determination meetings, no cross-examination is possible, and no complete transcript or recording is produced, even though findings may influence custody decisions, civilian court proceedings, and military separations. 

The same article argues that the IDC’s determinations enter a DoD-wide registry that can impact security clearances, family court outcomes, and eligibility for certain civilian jobs. While DoD regulations authorize restricted sharing of FAP records under certain conditions, Walk the Talk argues the system allows long-term retention and use of administrative findings in ways most service members do not understand.

Another Walk the Talk publication – a November 2025 first-person account titled Systemic Mistrust – describes how one officer who voluntarily sought counseling later learned their clinical notes had been used in an IDC-style process without their knowledge, leading to misclassification as an offender. The account describes the experience as a breach of both trust and procedural fairness.

The Fort Bragg ACS Family Advocacy Program hosted a special event. Photo by Jason Ragucci. Source: DVIDS

The Central Registry Connection and Why It Matters

Under DoD policy, the IDC is the gateway for determining what enters the FAP Central Registry. This registry is not public, but it is accessible within DoD and is used for analysis, reporting, and some background check processes. DoD’s 2019 testimony emphasized that every allegation must be reviewed by the IDC and that only “meet criteria” incidents are entered. 

The numbers reported to Congress demonstrate how often IDCs shape official statistics. In Fiscal Year 2018 alone, DoD recorded more than 15,000 alleged spouse-abuse cases, roughly half of which met criteria, plus 1,670 incidents of intimate-partner abuse. Each of those determinations passed through an IDC. (DoD testimony, 2019)

Walk the Talk argues that the retention of these entries, combined with the blurred line between clinical and adjudicatory functions, creates a system where administrative findings can shadow a person throughout military and post-military life without opportunities for direct rebuttal.

Real-World Impact and Recent Reporting

Investigative journalism has also shed light on the effects of IDC-related decisions. A 2024 Military.com investigation into military childcare centers found cases where incidents were reviewed slowly or opaquely, and noted at least one example in which an IDC concluded the reported behavior did not meet abuse criteria. The report described a process that left some parents feeling excluded from crucial decisions about their own children. 

Military.com has also reported on the complicated dynamics that domestic violence survivors face when navigating base systems, including fears of financial instability and career impacts when reporting abuse. 

A Growing Consensus: The System Needs Revision

Between academic critiques, advocacy reporting, and firsthand accounts, the central criticism is consistent: IDC decisions have outgrown the procedural framework originally built for them. Bedestani’s academic work argues servicemembers facing potential separation, custody impacts, or reputational harm deserve due process protections closer to those found in administrative law or Title IX proceedings. Walk the Talk Foundation argues clinical staff should not render determinations with such significant downstream effects.

While no major reforms have yet been enacted across DoD, the combination of congressional interest, increasing advocacy, and emerging media attention indicates the system is likely to come under deeper scrutiny in the coming years.

For now, the IDC remains a system few outside the military understand, and one whose decisions carry consequences far beyond its administrative label.

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