Requirement to enter AKO E-Mail

Q: Does the recent requirement to enter the AKO e-mail address apply only to reports on active Army personnel?

A: YES. Reports for USAR/AGR and NG personnel are not processed at EREC so the requirement to enter the AKO e-mail addresses do not apply to those reports

Q: What should I do if Part IIId is filled with special emphasis data and there is no room for the e-mail addresses?

A: In light of the new requirement to add the e-mail addresses on the 3d line of Part IIId, raters need to know and understand that they have two lines available to enter areas of special emphasis. The rater should choose which areas are the most important that will fit on the two lines. The 3d line is specifically reserved for e-mail addresses.

Q: The example in MILPER Message 02-114 shows a unit e-mail address for an active duty officer (the senior rater). Does this mean that there is an option?

A: NO!! The example in the MILPER Message was shown for format purposes in those instances when a AKO e-mail address is simply not available and the rating official must use a unit e-mail address or even a personal e-mail address. It is only an option when an AKO e-mail address is not available. Also, the example shows the entire e-mail address when the unit or personal e-mail is used. For AKO Addresses you do NOT enter the last portion of the e-mail address (after the @ sign) but for all other e-mail addresses you do.

Gaps between Rating Periods

Q: Looking at the regulation for AERs, there is no specific information about how much of a gap can be between the last evaluation for NCOs and the beginning of the report (AER). For officers, every day has to be accounted for, for NCOs there is no specific information about it. Can you give me some type of guidance on this matter.

A: There can be NO GAP between rating periods. Every month must be accounted for. The AER covers the actual period of the course attended. However, the NCO's next evaluation must cover any additional time. For example, an NCO's last NCO-ER had an end month of Apr 01. He went to ANCOC beginning in June and the course ran from 6 Jun to 5 September. He will get an AER for the ANCOC period (exact dates of the course). He goes on leave (en route to his next duty station) from 6 Sep to 2 Oct. He signs in to his new unit on 3 Oct 01. His next NCO-ER will have a BEGIN date of May 01 (2001 05) and go through Apr 02 (2002 04). It will reflect one month of nonrated time for lack of rater qualification (May 01); three months of nonrated time for school - covered by AER (Jun-Aug); and one month of nonrated time for intransit (Sep 01). He will have a total of 7 rated months on that report but the period covered is 12 (all inclusive).

Q: I have a NCO that recently arrived in the unit. Her last NCO-ER was March 2000. Since that time she has been in the hospital, in school, on recruiting duty, then released due to medical reasons, and now here in our unit. Since she has not had a report in two years, am I responsible for completing a report and covering all of that time?

A: YES. You, as the current rater, would complete a ANNUAL report as soon as the NCO has 90 rated days under your supervision. The report would cover the period from 2000 04 THRU 2002 03. The rated months would be '3' and the non-rated codes would be S, R, Q, P, I. This would then get the NCO's record up-to-date with no gaps in the reporting periods.

Counseling NOT required for APFT "Needs Improvement"

Q: I have a NCO that arrived in the unit less than six months ago and he failed the APFT three months later. Now he is getting a Change of Rater NCO-ER and the rater annotated the failure on the report and gave a 'needs improvement' rating. However, the rated NCO states that since the rater never counseled him on the APFT failure, he can not render a 'needs improvement' rating. Is this true?

A: This is absolutely NOT true. Passing the APFT is an Army-wide requirement and failure to do so means the NCO has failed to meet a basic military standard. While there may sometimes be contributing factors and mitigating circumstances, the absence of counseling is most definitely not one of them. There is no NCO in the Army that can say he/she is not aware of the requirement to pass the APFT. Therefore, whether the NCO was counseled on the failure or not, it is still a failure to meet standards and therefore the rater may opt to render a 'needs improvement' rating on the NCO-ER.

APFT Scores

Q: I am somewhat confused with the new change regarding the use of the numerical score. It is no longer required to use the score but to say that the soldier 'received the physical fitness badge'. If the soldier continuously scores 300 and above, could we still use the score if we choose to? It wouldn't seem right to say that the soldier received the physical fitness badge every year if you are only issued the badge once. Please advise.

A: It is acceptable to use the score but it is not required.

Pass, Fail, or Profile

Q: Please provide the definition of PASS, FAIL, and PROFILE IAW AR 623-205, 6-14, Part IVc, APFT entry. Here's the issue: I have soldiers who are getting profiles to avoid road marches, company runs and any unit activity that is not oriented towards the APFT. Such profiles, temporary and permanent, are having a negative effect on readiness and unit Esprit de Corps. Is the block APFT marked 'PASS' or 'PROFILE'? The soldier has achieved a 'GO' not a score. I have one soldier that has a permanent profile which says 'run at own pace and distance'. This soldier is able to take a regular APFT and receive a score. Is the block APFT marked 'PASS' or 'PROFILE'? The soldier has a 'GO' yet not met the overall objective of the Army Physical Fitness Program.

A: The purpose of the NCO-ER is not to make an issue on one specific area over another. Sometimes rating officials have certain biases and prejudices towards soldiers with profiles. The system is designed to ensure fairness across the board to soldiers who have legitimate physical problems but still perform/meet minimum basic standards. When an NCO takes the APFT and passes, then PASS is indicated on the NCO-ER. If the NCO has a profile that does not hinder taking the APFT then it is not an issue for the NCO-ER in that section. If the command has an issue with the soldier's overall fitness and ability to perform in the unit, then that is more appropriately resolved through the MMRB/MEB/PEB process. It is not something to play out on the NCO-ER. Too often rating officials use the NCO-ER as a punishment tool when an NCO can not run 5 or 10 miles on the company/battalion runs. The APFT is the required standard. That also applies to soldiers who take alternate events (such as 2-1/2 mile walk, bike, or swim). The appropriate entry on the NCO-ER is PASS, not 'GO'. If the command is concerned about the validity of the profile issued, I recommend contacting the medical authorities for follow-up and clarification.

Failure to Meet APFT Standards before receiving Profile

Q: A NCO took an APFT in Jan 01 and failed. Before the 90 day window was up for the retest, the soldier received a profile (Apr 01) preventing the retest. The recovery period for the profile extended beyond the end date of end of the NCO-ER. Should the entry in Part IVc be 'FAIL' with comment that says something to the effect Soldier unable to retake failed APFT due to profile or should it read 'PROFILE?'

A: Unfortunately for the NCO, you must report 'FAIL' since that is the latest report he has on file and it was within the past 12 months. However, you should also indicate in the remarks that he was unable to take the retest due to temporary profile. The entry would be something like this:

FAIL 0101 HT/WT Yes (or NO)

o soldier failed the 2-mile run event on the APFT; did not retest yet due to temporary profile

(you must indicate what event(s) he failed)

Correcting Administrative Data on a Submitted Report

Q: Last month one of my NCOs reviewed his OMPF and noticed that a previously submitted NCO-ER had his SSN and DOR incorrect. The NCO did sign the report and it is now on his file. How can this be corrected?

A: The rated NCO's signature on the NCO-ER indicates that he reviewed and verified the administrative data on the NCO-ER, to include all information in Part I of the report, the counseling dates, the height/weight/APFT data, and certify that all of that information is correct/accurate. Failing to notice an incorrect SSN and DOR on the report means the NCO did not thoroughly review the report as his signature indicates. Nevertheless, there are procedures in place to correct the discrepancy but the NCO must submit an administrative appeal. The procedures for doing so are outlined in AR 623-205. Additional guidance/assistance may be obtained at the local S1/PSB and/or by contacting EREC personnel. The EREC POC is: Ms. Wanda Willis at DSN: 699-3684.

90-Day Rating Requirement

Q: I have a NCO that reported to the unit on 6 May 01. Due to some internal problems/issues, the NCO was moved to another section effective 30 Jul 01 and a change of rater report initiated. The NCO now states that the report was illegal because the rater did not have 90 rated days to render the report. Computing from May to July is three months so the report was submitted and processed. Please advise.

A: The rated NCO is correct. 90 rated days is the minimum standard for a rater to render a change-of-rater report (except in a designated short-tour area). From 6 May through 30 July, both dates inclusive, it is only 86 days. Therefore the 90 day minimum was not met and the report should not have been rendered. The time should have been reflected as non-rated time on the NCO's next NCO-ER with a non-rated code of 'Q'. Since the NCO-ER is already on file at EREC, an appeal must be submitted in order to have it removed.

Q: The minimal amount of time for a report to be rendered is 90 days, unless of course they are deployed. Now the real question is whether that's 90 'rated' days or just 90 days under the rater. I remember a message about this but could not remember if it was rated days or just 90 days.

A: It is 90 rated days.

Proper Format for Report Code

Q: What is the proper way to enter the report code on the NCO-ER? For example, if it's an ANNUAL report, is it '02' or just '2'?

A: The report codes are all single digit. Therefore for an ANNUAL report, the code 2 should be entered.

NCO achievements while attending NCOES

Q: Can events/actions/accomplishments during ANCOC (or any other school) be used on the NCO-ER?

A: The period of school attendance is non-rated on the NCO-ER and events/actions during non-rated periods are not covered on the NCO-ER. Further, if a AER was issued, then the information is contained on the AER.

Capitalizing names on the NCOER

Q: The regulation states that the rated NCO's name will be entered in ALL CAPS in Part I of the NCO-ER. Does this also apply to the rating officials in Part II? Also, can you clarify the use of capitalization in the bullet comments?

A: As you stated in your question, the regulation states the rated NCO's name in Part Ia will be entered in ALL CAPS. There is no other requirement to enter names in all caps on the NCO-ER. Therefore, the names of the rating officials may be entered in Upper/Lower case or ALL CAPS. It does not matter as long as they are consistent in all three blocks (IIa, b and d). As for the bullet comments, CAPS will not be used at the beginning of the bullet. As stated in AR 623-205, bullet comments are not sentences and therefore should not be capitalized. Some rating officials search for loopholes and play on words by stating that the regulation says 'should not' instead of 'will not'. Again, I encourage all rating officials to act responsibility and comply with the regulatory guidance without trying to find ways around it.

NCO's or NCOs?--Possessive vs. Plural

Q: What is the proper way to enter the plural version of common abbreviations such as NCO, NCO-ER? Should it be NCO's or NCOs?

A: The correct way is NCOs and NCO-ERs. When you used the apostrophe, you are indicating the possessive tense. For example: the NCO's first name is Ralph. When you are talking numbers, there should be no apostrophe but a small 's' following the abbreviation. For example: there are six NCOs in this section.

Rater Unavailable?

Q: If one or more of the rating officials have either left the unit and/or deployed and are not available to personally sign the NCO-ER, is it acceptable to enter the statement: 'rater unavailable for signature'?

A: Absolutely not. While there is no requirement for the rated NCO to sign the report for it to be processed, all of the rating officials must sign in order for the report to be valid and accepted for processing. If a rating official left without signing a report, the unit must make every effort to reach the individual and forward the report for signature. Without the signature of the rating officials there is no other way to verify the validity of the report.

Visually Centering Bullets

Q: Is there a prohibition on visually centering bullet comments in part IV of the NCOER? For example, I wish to place just one bullet in part IVc. Instead of writing the bullet at the top of the box just under the APFT data, I would like to skip a few spaces and center the bullet in the box. Please advise.

A: Although the regulation does not specifically 'prohibit' visually centering the bullet comment, it is preferable to start all bullet comments in the same location - at the top of the designated block. This provides consistency throughout the report. It does not matter if there is only one bullet comment in the block, placing it at the top is still the desired location.

Administrative Changes without Rater Approval

Q: I received an NCO-ER that was processed through the PSB and later returned to the unit for changes (inconsistencies). I was not notified that changes were made on the report until I went to check my records and was informed that the S-1 NCO had made changes to the NCO-ER and resubmitted it without informing me of the changes. The change that was made involved whiting out the square 'among the best' that the rater had marked originally and marking the square 'fully capable'. The original NCOER was completed on a computer and had a distinctive X mark. The altered version that was sent the second time clearly has a typewriter X (the X's do not match).Is this legal?

A: This is certainly NOT the way NCO-ER processing should be done. Personnel folks in the S-1 or at the PSB are NOT authorized to alter reports. If the rater or senior rater elects to change something in his/her portion of the report, he/she must do that on their own. Also, the rated soldier should be notified when there is such a change. You should contact the rater on the report and find out if he/she authorized a change. If so, then there is not much you can do about it because the only problem here is that the rater didn't tell you about it. However, if the rater did NOT authorize the change, then you need to get that in writing - a statement signed by the rater plus a copy of the original report that was signed before the change. That then can be used as a case against the individual that changed it as well as for you to submit a appeal. It is a rather small correction and with a statement from the rater and a copy of the original report, you may be able to get this corrected quickly. However, you need to contact the appeals folks at EREC to be certain.

Duty MOS vs. Primary MOS

Q: I have a question about the Duty MOS - is it the MOS that the soldier holds or is it the MOS that the position is slotted in?

A: The duty MOS is the MOS that the individual is actually working in - not the one that he/she is slotted in on the MTOE/TDA. Sometimes the position on the books is just to have the individual slotted someplace. The duty MOS and duty description that is placed on the NCO-ER should be the one that the NCO is actually working on a daily basis, regardless of what the PMOS is or the position on the books.

Q: In reference to Part IIIb. - DUTY MOSC, the regulation states to enter the duty MOSC with at least five, but no more than nine characters. My question is this? What is the Duty MOSC? Is it the actual MOS held by the NCO, or is it the MOS that relates to the duty position title? For example, a NCO with a PMOS of 68H3OX1 (aircraft pneudrualics repairer) is working as the BN retention NCO, then Part III Principle Duty Title would be Battalion Retention NCO, but what would the DMOSC be, 68H or 79S? If it parallels duty MOS, what do you do for someone like the training NCO, something every unit has, but there is no complimentary MOS?

A: The Duty MOSC is the MOS for the actual duty/title that the NCO is performing, irregardless of what the NCO's PMOS is. For a soldier who is performing duty as a Retention NCO, the duty MOS would be 79S4O (if he is a SFC). The PMOS is at the top of the NCO-ER in the Administrative Data area (Part I). Sometimes it is the same as the duty MOS but in many cases it is not. There are a number of soldiers who work outside of their PMOS.

The NCOER Appeals Process

Q: I have an active duty SFC that received a bad NCO-ER back in 9404 while stationed in Germany. I know the appeal process according to the regulation is within 5 years and the NCO did submit a appeal back in 1995. However, the appeal was denied. QMP notification happened next and the NCO appealed that and it was approved. The NCO then tried going through the Army Board for Correction of Military Records to get the NCO-ER removed and that was denied. Is there any other recourse we can take? This is an outstanding NCO and all of the other NCO-ERs on the NCO's record are great. I am just trying to figure out how I can help this soldier make MSG. Having read the entire packet and the circumstances regarding the one bad NCO-ER, I am more than convinced that the NCO got hosed, for a lack of a better term.

A: Unfortunately, the NCO has no other recourse at this point. The appeals process contains provisions to resubmit the appeal if it was initially denied due to lack of sufficient evidence/documentation to support her claims of injustice. There is no evidence that the NCO did this, but obviously chose to go directly to the ABCMR - which is the final step in the appeals process. They are usually more lenient but once the ABCMR denies the appeal, there is no other recourse. The other issue is time. The statute of limitations has expired so they wouldn't even consider another appeal at this point anyway. I spoke to EREC about this also and they cited a recent example where another NCO submitted an appeal after the statute of limitations and it was returned without action. That NCO then submitted a congressional asking for an exception to policy but that, too, was denied because there was no sufficient justification (prolonged hospitalization or deployment that prevented timely submission). 5 years is a long time so after that point, it's almost impossible to get a successful appeal. Based on additional information in your inquiry, it appears that the NCO may have come up short in putting the appeal together and maybe that contributed to the two denials. The good part is that the QMP appeal was approved. It is possible to overcome ONE bad NCO-ER and still get promoted - particularly if it was that long ago.

Maintaining a Copy of a Previous NCOER

Q: As a rule of thumb, I like to see the last NCO-ER of any soldier I rate. This ensures that I don't repeat any bullets or that I don't make any administrative errors that could conflict with his/her last NCO-ER. However, my PAC informs me that I can't maintain any old NCO-ER on file? They cited something about personal in nature. Am I violating any regulation by maintaining my own copy of the rated NCO's last NCO-ER?

A: You are not authorized to request or maintain a copy of a NCO's last evaluation report unless YOU were the rater. If you rated the individual, then you always have the option of keeping a copy of the report YOU rendered. However, if the individual is recently assigned to you and you want a copy of his last NCO-ER rendered by some other rating officials, that is not authorized. You repeating a bullet that someone in a completely different rating chain included on the last report is not a problem or issue. Actually, if that was to happen without you knowing it, then it just validates what the previous rater stated. As for administrative data, there are ample resources to verify that data without getting it from the last NCO-ER. As for the end date of the last report, you can always call the IVRS line at DSN 221-3732 to find out the end date of the last report on file and that serves as verification of the new report FROM date.

Guidance for Senior Raters

Q: Currently, many of our senior leaders in the company are in debate over the acceptability of certain Senior Rater Comments and I solicit your leadership and guidance in this matter. The situation deals with SGTs and the standard line comments Promote now and Select for next higher NCOES now. It is understood that these comments are necessary for Senior NCO Promotion boards but do they really benefit the E-5 team leader, when promotion to the next higher grade is dependent on the soldier's individual initiative? I hope I clearly articulated this concern. Is there any place I can research this or can you shed some light on this subject?

A: It is 'required' that senior raters address potential on ALL NCO-ERs. The specific wording that's used is up to that rating official. Potential consists of more than just promotion. It also includes schools, future assignments, and long-term advancement potential. Yes, the immediate concern is the soldier's potential for immediate advancement but rating officials should also comment on long-term potential. For example, a hard-charging, energetic and highly motivated SGT/E5 may have the following comment on his NCO-ER in the potential area:

o demonstrates exceptional initiative and potential for rapid advancement to senior NCO level

He may not even be promotable to SSG yet, but the rating official may see the POTENTIAL in that individual. The same holds true for other NCOs. Another example:

o a top-notch NCO - clearly a future command sergeant major

Civilians Rating NCOs

Q: According to AR 623-205 par 3-5(2b), states that a GS-6 appointed by the Commander can rate a NCO if a military supervisor is not available when that civilian is in the best position to evaluate that NCOs performance. What the regulation does not state is what rank must that NCO be in order for the GS-6 to rate him/her. Is their a regulation that shows what the equivalence rating between GS and Enlisted/Officers. For Example: Can a GS-06 rate a SFC?

A: The answer is YES, a GS-06 CAN rate a SFC. There is no specific regulatory guidance regarding rank limitations for civilians rating NCOs. However, as a general rule, a GS-06 would rate an E5 or E6; normally it would be at least a GS-07 rating SFC. Normally you don't see GS-06 rating SFC unless the GS-06 is specifically assigned to a supervisory position and that SFC is one of the NCOs in that section. Since a SFC is a SENIOR NCO, you normally have your more senior civilians rating them. Again, the real key though is if that individual is appointed by the commander as the supervisor and is listed as such on the rating scheme.

Report Consistency

Q: An NCO has two excellence and three success blocks checked on the evaluation. The rater marks 'fully capable' and the senior rater checks the '2' block in both performance and potential. AR 623-205, para 6-15a(2) and c(1) indicates that this is a rating discrepancy. A '2' rating is a strong recommendation for promotion whereas 'fully capable' means promote if allocations are available. Please advise.

A: In the example cited above, there are two potential problems with the rating. First of all, the rater gave two excellence and three success ratings - that usually fits among the best. Although there is nothing in the regulation that dictates this, it will likely send a 'mixed' message. In other words, how can he have two justifiable excellence ratings and three success ratings and only be considered 'fully capable'. Normally you see 'fully capable' checked when there are all success ratings or maybe one excellence check. Very rarely do you see an instance when the NCO receives two excellence marks but is only rated fully capable. The second concern (about the senior rater giving a '2' while the rater rates 'fully capable') is not as big of an issue. In reality the senior rater's markings are more consistent with the other markings on the rater's evaluation (that of 2 excellence and 3 success checks). As you know, the senior rater's markings are mostly 'subjective' anyway but in this instance, it validates the 2 excellence and 3 success markings; but again - leaves a question about the 'fully capable' check mark. The highest senior rater marking of '1' is reserved for your absolute best and although a '2' is a very good mark and a strong recommendation for promotion, it is a drop-off from the '1' rating.

Documenting Misconduct

Q: The After Action Review from the SFC selection board indicated that raters should mention a DUI offense on the NCO-ER. What is the right thing to do?

A: If an NCO receives a DUI, it should be specifically mentioned on the NCO-ER. You can not mention any disciplinary action (such as article 15, letter of reprimand) but you can mention the offense that led to that action. Therefore, specifically stating the fact is acceptable and encouraged. For example:

o NCO exercised poor judgment by operating a motor vehicle while under the influence of alcohol

o NCO was cited for driving with blood alcohol content of 1.6 - well above the legal limit of .08

Q: I am reviewing an NCO-ER where the rater made reference to an allegation on an informal investigation. Is this a legal comment?

A: In accordance with AR 623-205, paragraph s 6-5 and 6-6, no reference can be made to unverified derogatory information. An allegation in an information investigation is not verification of an offense - only if the NCO is charged and subsequently found guilty/liable. Rating officials may not reference investigations - ongoing or completed. However, they may mention misconduct that is verified and proven as a result of an investigation.

Permanent Profile and MMRB results

Q: The local PSB keeps returning a NCO-ER on an NCO with a permanent profile because it did not have a copy of the MMRB results attached. Is this now required?

A: When an NCO has a profile, the rater will indicate such by entering PROFILE and the date of the profile in place of the APFT data. Additionally, a bullet comment is required that indicates whether the profile adversely affects duty performance. No other information or documents are required. A copy of the profile or the MMRB results are NOT required. The signatures of the rater and rated NCO on the NCO-ER are sufficient verification of accuracy. Further, there can be NO attachments to the NCO-ER when it is processed other than a reviewer's statement of non-concurrence or a memorandum of relief (when the relief for cause is directed by someone other than the rater or senior rater).

Rating Chain Validity

Q: I have been given an NCO-ER that does not reflect the correct rating officials. Should I sign it? If I refuse, what are my options? I also have some issues with the actual rating.

A: If there are some questions in your mind about the validity of the rating officials, you should raise that issue with your chain of command immediately. Your signature on the evaluation indicates that you agree that the rating officials are correct in accordance with the published rating scheme. If that is not the case, you need to get it resolved. If you have issues regarding the fairness/correctness of the actual evaluation, it is within your right to request - in writing - a commander's inquiry. If you request a commander's inquiry, the commander is then obligated (not a choice) to appoint an investigating officer (senior to the rating officials) to look into your allegations of injustice/unfairness. Once the investigating officer completes his report, he then forwards those findings back to the commander who will render a decision on the action, then forward the completed inquiry - with ALL attachments (sworn statements, etc.) to this office at DA HRC, along with the original NCO-ER. The original NCO-ER is NOT to be processed until after the commander's inquiry is completed and then it is forwarded to this office, NOT to EREC. The correct/exact address is: Cdr, DA HRC, ATTN: AHRC-MSE (SGM Everette), 200 Stovall Street, Alexandria, VA 22332.

Complete the Record NCOERs

Q: I am looking for information concerning Compete the Record reports. Is there any direct link I can go to for this?

A: There are no direct links regarding this subject specifically. There is a reference to it in the NCO-ER regulation (AR 623-205. In short, the complete the record evaluation report is only done for those individuals in the zone of consideration for promotion consideration as announced in a HQDA message. Under the recently revised NCO-ER regulation, the rated NCO must have served in the same position for a minimum of 90 rated days with the same rater AND has not been previously rated in this position. The previous requirement was six months in the position and that is no longer in effect. The primary purpose of the complete the record report is to give the rated NCO a report on file for the position he is current serving in to allow the board to see how he is performing currently. In short, it is to 'round out' the file so the board sees a complete picture. However, the CTR Report is an 'optional' report and the absence of one can NOT be used as a basis for a stand-by advisory board.

Relief for Cause (Pending Investigation)

Q: I have a NCO who is suspended pending formal investigation. He is charged with several things, including DUI. When should the Relief for Cause report be done?

A: The Relief for Cause report should be done AFTER the investigation is complete and the NCO is found guilty. If it is done before that and for some reason he is cleared (sometimes it happens on a technicality) then you will have to un-do everything you're done. Also, once he is found guilty of the charges, then you have certain, unquestionable bullets to use (clear, concise, accurate - always the key). Right now while he is on suspension, he gets no report until investigation is complete.

Date Formats on the NCOER

Q: With the implementation of the new NCO-ER form (DA 2166-8), it requires a 4-digit year in the FROM and THRU dates in Parts Ih. Does this also apply for the THRU date at the top of page two of the form; and what about the counseling and APFT dates?

A: The THRU date at the top of page two of DA 2166-8 will be entered with a 4-digit year. For example, November 2001 will be entered as 2001 11. However, there is NO CHANGE to the formats for counseling and APFT dates. You will continue to use the same format used on DA Form 2166-7.

Promotable NCO rating nonpromotable NCO of same Rank

Q: I have two sergeants first class and one of them was recently selected for promotion (on the newly released MSG list). The one that was not selected is senior to the SFC(P) by DOR. In view of their promotable status, can the junior NCO serve as the rater for the other one?

A: The quick answer is no. One of the fundamentals of the military is that seniority must be respected. As such, requests for junior NCOs to rate other NCOs who are senior to them by DOR are routinely disapproved. However, there is an exception. If the SFC(P) is serving in a valid E-8 position and is frocked they can then serve as the rater for the SFC. However, if both NCOs are serving in SFC positions, the junior NCO, regardless of him/her being promotable, cannot rate the senior SFC until such time as they pin on the MSG stripes and becomes senior by rank. Another unique situation is when a senior, non-promotable SFC is designated as rater to a SFC(P) after the SFC(P) was selected for promotion. It is clear that the SFC(P) will become senior as soon as the new stripes are pinned on so this rating change, although technically legal, is strongly discouraged and does not constitute good management practice.

Number of spaces after bullet

Q: After the small 'o' that begins each bullet comment, should there be one space or two?

A: Space on the NCO-ER is limited, so one space is recommended. However, the key thing is consistency throughout the report. The rater should not start one bullet with just one space and another with two spaces.

Bullet Comments vs. Sentences

Q: Are periods at the end of bullets okay and what about capitalizing the first letter of the first word in each bullet?

A: Remember that these are bullet comments, not sentences. Therefore, the first letter of the first word should NOT be capitalized. Also, there should be no periods at the end of the bullet comment. This is clarified in the 17 December 2001 version of AR 623-205. Another common issue has to do with indenting the second line of a two-line bullet comment. The preferred method is to start the second line directly under the first letter of the first line. However, reports are accepted if the second line is started under the small 'o' as long as there is consistency throughout the report.

Can Junior CSM rate Senior SGM?

Q: Can a CSM rate a SGM who has more time-in-grade? I know that a CSM out-ranks a SGM based on position but according to the guidance in the regulation, the 1SG or CSM must be senior in pay grade or date of rank. It states nothing about position.

A: The CSM cannot rate a SGM unless he is senior by date of rank. There are exceptions to the policy but they must be requested in writing to DA HRC (AHRC-MSE). As a general rule, we routinely disapprove such requests unless there are clearly special circumstances outlined in the request that are out of the ordinary.

Dating the NCOER

Q: Is there any regulatory or policy guidance on dating NCO-ERs? The MILPOs want the dates left blank. I say that we should be dating them when they are signed (just as we do for OERs).

A: The PSB (or MILPO) cannot dictate to rating officials on whether or not to date the NCO-ERs. A lot of PSBs ask for the dates to be left blank so they (the PSB folks) can ensure the dates are in sequence and not before the authorized signature date. However, as long as rating officials understand the rules for when they can be dated, it is always best for the rating officials to date the reports. The rule for dates on the NCO-ER is simple: for annual reports, they cannot be dated until the first day of the month following the end month of the report. For example, if the end month is June then the report cannot be signed/dated until 1 July, etc. The same applies for complete the record reports. For change of rater reports, they can be signed and dated anytime during the month in which the change occurs.

Nine-Character MOS Format

Q: I need your assistance in clarifying the sixth through ninth characters on NCO-ERs. I spoke with your predecessors in the past about the 5fifh character, and we all agreed that the fifth character should contain the letter O and not a zero. However, now the MILPO is starting to return NCO-ERs because the sixth through ninth characters are incorrect. In AR 614-200 it states the sixth and seventh characters should be ZZ if the soldier doesn't have an ASI and eighth and ninth characters should be YY if the soldiers aren't qualified in a language. Is there any new guidance pending, or what is correct?

A: AR 623-205 is the governing regulation for NCO-ERs. An example would be a NCO with an ASI but no language: 71L3OE3OO. Another one with both: 71L2OF5FR. You are correct about the fifth character of the MOS: it is a letter - therefore, if there is no SQI, then you use the letter O. However, if there is no ASI or language identifier, only a five digit MOS is required on the NCO-ER so there is no need in placing 00OO at the end of the PMOS.

Time Limitation for Reviewer

Q: I have a question on how to process an NCO-ER. We are getting guidance from the PSB that if the reviewer departs on PCS, we can't state that he is 'not available for signature.' The regulation isn't clear on this. What are my options?

A: There are no time limitations for the reviewer. If the original reviewer has PCS'd, then the replacement would be the reviewer. For example, if the rater is the company commander, and the senior rater is the battalion commander, and the reviewer is the Brigade Commander, and the Bde Cdr PCS's, then the new Bde Cdr would become the reviewer effective immediately and he/she can sign the report even if he/she has only been in the position for one Day. The 90 and 60 day limitations apply only to rater and senior rater.

APFT Excellence

Q: What score on the APFT constitutes an excellence on the NCO-ER (overall score of 290 and above, 280 and above etc.)? Also, how many points must be scored in each event (90 or above, 80 or above, etc.) for an excellence on the NCO-ER?

A: The rule is 270 and above with at least 90 in each event. That qualifies for a physical fitness badge and an excellence bullet on the NCO-ER.

Within body fat standards of AR 600-9

Q: I have a soldier who needed to be taped to make the weight requirement (and yes, once taped he is within standards). He insists that the comment of within body fat standards of AR 600-9 is not required anymore on the NCO-ER. I have done extensive follow up on this and the conclusion is the same, that the regulation did not change. However, many soldiers believe that there is a message out there that changes this requirement. Please advise.

A: Once a soldier meets the tape, the statement is not required on the NCO-ER anymore. That was put out in MILPER Message 98-044. It is also now included in the new regulation. In the meantime, if the soldier meets body fat standards, you cannot state it on the NCO-ER anymore. You just indicate the NCO's HT/WT and 'YES.'

Success for failing to meet body fat Standards?

Q: I have a NCO who currently has a profile which prohibits him from taking the APFT. The problem is he is over the weight screening table and does not meet the body fat standards. The NCO-ER indicates 72/232 'NO' and a bullet comment indicating that a doctor has evaluated weight as medical disorder and treatment is pending. The rater checked the 'success' box. The unit has not put the soldier in a weight control program due to the medical condition and states they will not mark 'Needs Improvement.' Is the bullet comment acceptable and can the NCO be rated as 'success?'

A: The correct entry is '72/232 NO.' The bullet should state something to the effect as the following:

o soldier has a confirmed medical disorder which resulted in the overweight condition; soldier is not currently enrolled in an overweight program due to medical diagnosis

As far as whether to check 'SUCCESS' or 'NEEDS IMPROVEMENT,' that is the rater's call. If the rater feels strongly that the only reason for the overweight is the medical condition, then he may elect to check 'SUCCESS.' However, the 'NO' must remain in the top portion with the bullet comment explaining it.

Best Bullet Comments Begin with action verbs

Q: AR 623-205, para 6-12c, 'Narrative rules for part IV' bullet comments' states Best bullets start with action words (verbs) or possessive pronouns (his/her); avoid using the NCO's name or the personal pronouns he/she. Based on this, should we reject NCO-ER's that use the NCO's name or he/she?

A: As stated in the regulation, the 'best' bullets start with action verbs. Although the preference is to not use 'he/she' or personal names, the NCO-ER would not be rejected by EREC for that. It is always best to encourage rating officials to comply with regulatory guidance and every effort should be made to ensure reports are well written and consistent. However, often you will encounter rating officials (such as in your case) who refuse to change the bullet comments to delete personal pronouns. The report would still be processed at EREC. The rated NCO is not to blame for the failure on the rating officials' part. I would encourage you to continue to drive home the point in the regulation and have your chain of command get involved to ensure compliance. Once you have taken it as far as you can go, then don't hold the report up any longer fighting a losing battle.