6.3 Army Substance Abuse Program (ASAP) and SUDCC (AR 600-85)

Army Substance Abuse Program (ASAP) and SUDCC (AR 600-85)

Core Doctrine: Substance abuse policy within the United States Army is governed by Army Regulation 600-85 (Substance Use Disorder in the Army). The Army's substance abuse framework is designed to strengthen the fitness, discipline, and combat readiness of the total force by preventing substance misuse, identifying high-risk individuals early, restoring rehabilitable Soldiers to full duty status, and administratively separating those who fail to uphold military standards.

---

1. Regulatory Framework and the ASAP/SUDCC Structural Split

Historically, all substance abuse functions—prevention, education, biochemical testing, clinical evaluation, and rehabilitation—were consolidated under the installation Army Substance Abuse Program (ASAP). To align military behavioral healthcare with clinical accreditation standards and improve patient privacy, the Department of the Army restructured the program into two distinct operational branches:

   ARMY SUBSTANCE ABUSE PROGRAM (ASAP)     SUBSTANCE USE DISORDER CLINICAL CARE (SUDCC)
   (Installation Garrison / G-1 / DHR)     (Defense Health Agency / MEDCOM)
   ───────────────────────────────────     ───────────────────────────────────────────
   • Non-Clinical Prevention & Education   • Clinical Healthcare & Evaluation
   • Coordinates Urinalysis Testing        • Medical Detoxification & Outpatient Therapy
   • Trains Unit Prevention Leaders (UPL)  • Intensive Outpatient & Inpatient Care
   • Risk Reduction Assessment Tracking    • Case Management & Rehabilitation Progress
   • Civilian Employee Assistance (EAP)    • Medical Determination of Rehab Failure

ASAP Responsibilities (Non-Clinical Garrison Operations)

• Oversight: Operates under the installation Directorate of Human Resources (DHR) and garrison command.
• Scope: Non-clinical prevention education, suicide/substance integration, unit risk inventory surveys, and installation drug testing coordination.
• UPL Management: Certifies and inspects unit-level Unit Prevention Leaders (UPLs).
• Civilian Support: Provides counseling and referral for Department of the Army civilian employees through the Employee Assistance Program (EAP).

SUDCC Responsibilities (Clinical Medical Treatment)

• Oversight: Operates under the Defense Health Agency (DHA) and local Military Treatment Facilities (MTFs) / Embedded Behavioral Health (EBH) clinics.
• Scope: Formal clinical intake, medical substance use disorder diagnosis, evidence-based individual and group psychotherapy, intensive outpatient therapy, and medical detoxification coordination.
• Command Advising: Advises unit commanders on the clinical progress, prognosis, duty limitations, and potential rehabilitation failure of enrolled Soldiers.

---

2. The Five Methods of Identification and Referral

Under AR 600-85, Soldiers with substance use disorders enter the clinical evaluation and administrative system through one of five distinct identification pathways:

1. Voluntary Self-Referral

• Mechanism: The Soldier independently identifies that they have an alcohol or drug problem and voluntarily approaches their unit commander, First Sergeant, a military healthcare provider, or a chaplain for assistance.
• Crucial Timing Benchmark: To qualify as a valid self-referral, the Soldier must seek help prior to being notified of a pending urinalysis inspection, prior to being apprehended by law enforcement for substance misconduct, and prior to an official investigation.
• The Limited Use Policy: Self-referrals are protected under AR 600-85, Chapter 4 (Limited Use Policy). Under this policy, admissions of substance use made by a Soldier during self-referral and clinical treatment cannot be used against the Soldier in court-martial proceedings under the UCMJ, nor can they be used to characterize an administrative discharge as less than Honorable.

2. Command Referral

• Mechanism: The commander identifies observable indicators of substance misuse, including declining duty performance, recurring tardiness, disheveled appearance, odor of alcohol during duty hours, erratic emotional behavior, or domestic turmoil.
• Execution: The commander executes a formal written referral using DA Form 8003 (Substance Use Disorder Clinical Care Referral). Attendance at the initial SUDCC screening is mandatory. The commander maintains close liaison with the clinical case manager.

3. Biochemical Testing (Urinalysis / Breathalyzer)

• Mechanism: Identification through laboratory confirmation of illicit drug metabolites or elevated blood alcohol concentration (BAC) above legal limits.
• Collection Types: Random inspections, 100% unit sweeps, commander-directed testing, probable cause searches, or medical testing.

4. Apprehension / Law Enforcement

• Mechanism: Identification resulting from military or civilian law enforcement action, such as driving under the influence (DUI/DWI), public intoxication, domestic assault involving alcohol, or illicit drug possession.
• Mandatory Action: Military police immediately notify the Soldier's commander, who must refer the Soldier to SUDCC within 5 business days and initiate mandatory administrative flagging.

5. Medical Referral

• Mechanism: A military medical provider identifies substance dependence, intoxication, or organ damage during routine clinical encounters, emergency room visits, or post-operative care.

---

3. Urinalysis Testing Procedures & Chain of Custody

Biochemical testing via urinalysis is the Army's primary deterrent against illegal drug use. Testing is conducted under the legal authority of the Military Rules of Evidence (MRE 313 - Inspections and Inventories).

   UPL VERIFIES ROSTER & DONOR ID
         │
         ▼
   OBSERVER MAINTAINS DIRECT EYE CONTACT WITH STREAM
         │
         ▼
   DONOR CAPS BOTTLE & APPLIES TAMPER TAPE
         │
         ▼
   DONOR & OBSERVER SIGN DD FORM 2624 (CHAIN OF CUSTODY)
         │
         ▼
   SPECIMEN STORED IN LOCKED UPL SAFE
         │
         ▼
   SECURE TRANSPORT TO FORENSIC TESTING LAB (AFMES)

Unit Prevention Leader (UPL) Standards

• Must be an NCO in the rank of Sergeant (E-5) through Sergeant First Class (E-7) or an Officer.
• Formally appointed on written command orders as the Primary or Alternate UPL.
• Must successfully graduate from the formal installation UPL certification course.
• Responsible for maintaining testing equipment, safeguarding collection supplies, generating random rosters, managing collection stations, and preserving an unbroken chain of custody.

Observer Responsibilities: The Non-Negotiable Standard

Promotion boards place extreme emphasis on the duties of the urinalysis collection observer. Procedural flaws at the collection point can lead to the suppression of positive drug evidence at trial.

• Same-Gender Requirement: Observers must be noncommissioned officers or officers of the same biological gender as the donor.
• Direct, Unobstructed Eye Contact: The observer must maintain uninterrupted visual observation of the urine stream leaving the donor's body and entering the collection bottle. Observers are strictly prohibited from standing outside the stall, looking away, or waiting outside the restroom.
• Inspection for Tampering: The observer must verify that the donor's hands are clean, that sleeves are rolled up to the elbow, that outer garments are removed, and that no concealed bottles, prosthetic devices, adulterants, or chemical diluents are present.

Chain of Custody & Documentation

• DD Form 2624 (Specimen Custody Document - Drug Testing): The legal document recording every individual who handles, inspects, or transfers the urine specimens. Any gap in signature dates, missing barcodes, or broken seals destroys the legal chain of custody.
• Packaging & Security: The donor places the specimen bottle in front of the UPL, places tamper-evident tape across the cap, and initials the tape. Specimens are boxed, sealed with evidence tape, and locked in a secure, bolted safe with access strictly limited to appointed UPLs until shipped directly to a certified Armed Forces Medical Examiner System (AFMES) or DoD forensic laboratory.

---

4. Administrative and Disciplinary Consequences

The Army maintains an uncompromising stance regarding illegal controlled substances and severe alcohol misconduct.

Mandatory Initiation of Administrative Separation for Drug Offenses

Under AR 600-85 and AR 635-200 (Active Duty Enlisted Administrative Separations), commanders are regulatory mandated to initiate administrative separation processing for any Soldier who:

1. Tests positive for illicit drugs on a forensic urinalysis (including synthetic cannabinoids/THC, synthetic cathinones/bath salts, opioids, cocaine, and methamphetamine).
2. Unlawfully possesses, uses, sells, distributes, or manufactures illegal drugs or controlled substances.
3. Unlawfully uses or distributes prescription narcotics without a valid military medical prescription.

Board Clarification: "Mandatory Initiation" vs. "Mandatory Discharge": Commanders must initiate separation proceedings; however, the separation authority (typically the brigade commander or GCMCA) retains legal discretion regarding whether the Soldier is actually separated or retained, as well as the characterization of service (Honorable, General Under Honorable Conditions, or Under Other Than Honorable Conditions [UOTHC]).

Alcohol Misconduct Triggers

• Two-Incident Rule: Any Soldier who commits two serious alcohol-related incidents (such as DUIs, public intoxication, alcohol-related domestic violence, or assaults) within a 12-month period must be processed for administrative separation.
• Rehabilitation Failure: If a Soldier enrolled in SUDCC is evaluated by clinical providers as a "rehabilitation failure" due to failure to attend mandatory appointments, recurrent drinking while in treatment, or refusal to cooperate, the commander must initiate administrative separation.

Comparison Table: Identification Pathways & Legal Protections