A version of this article by Jeremy L. Hilton, co-founder of the TRICARE for Kids Coalition, originally appeared on LinkedIn. It does not reflect official policies or positions of DoD or any other federal agency. It has been republished with permission from the author.

In 2018, MOAA shared the story of Taylor Kracht, a military child who lost access to her DoD benefits upon turning 21, despite being fully incapacitated and dependent on others for her care.

Taylor wasn't alone.

As more stories emerged due to an apparent change in policy, the TRICARE for Kids Coalition began advocating for reform. Their efforts, combined with growing concern from lawmakers and military families led to the 2020 U.S. Government Accountability Office (GAO) report titled Actions Needed to Improve Management and Oversight of Dependency Determinations for Incapacitated Adult Children (GAO-20-335).

The findings were stark:

• Fragmented policies
• Inconsistent eligibility determinations
• Inadequate oversight
• The discriminatory “Family Unit Rule,” in which military children with disabilities were counted as half a person.

These inconsistencies had profound implications: loss of TRICARE access, military base privileges, and eligibility for the Exceptional Family Member Program (EFMP). They also introduced emotional and financial strain for military families already navigating complex caregiving challenges.

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In response to these systemic gaps and flaws, DoD on April 28 issued policy guidance in the form of DOD Instruction 1342.30, Dependency Determinations for Incapacitated Adult Children, a significant step toward standardizing and improving how our most vulnerable military children are evaluated for continued benefits eligibility across the military services.

Highlights of the new DoD instruction:

• Clarifies medical and financial eligibility criteria
• Encourages standardization across services
• Reinforces oversight roles
• Families can now submit annual tax returns instead of collecting a year’s worth of receipts — reducing burden on both families and the DoD.
• Establishes a portal (still in development) allowing “for the submission, tracking, and management of INCAP applications to include information related to financial and medical status of INCAPs.”
• Acknowledges the burden on families, calling for better communication, transparency, and simplified redetermination processes, including streamlining how families are notified and supported.
  
  

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Why This Matters

For too long, military families caring for incapacitated adult children have had to navigate an opaque, uneven system. These families shoulder extraordinary burdens — emotionally, physically, and financially — while supporting servicemembers and veterans who contribute directly to national defense, military readiness, resilience, and recruiting.

This instruction is a welcome acknowledgment that dependency policy must serve the needs of all families equally and justly — regardless of branch, location, or bureaucracy.

Final Thoughts

GAO-20-335 was a wake-up call. It shouldn't take this long for DoD to respond to the needs of some its most vulnerable children. This and similar issues should be a top priority, not a five-year priority. The DoD's updated Instruction is a first — but not final — step toward reform. Continued attention, accountability, and collaboration with families and advocacy groups will be essential to fully align practice with policy, particularly as the services implement this instruction. Already, advocates are noting ways to improve the instruction. I hope DoD listens and puts into place a feedback mechanism allowing for improvements.

For every military family, active duty or retired, managing the care of an incapacitated adult child, consistency isn’t a luxury — it’s a lifeline.