The DA Form 4856 is a written “record” of the counseling session and should be completed during or immediately after a counseling session; however, we have never found a “timetable for completion” from any FM or AR that would substantiate this other than what is on the form already. 

The guidance that we have been given and continue to pass on, is to date the DA Form 4856 (under Date of Counseling) with the date the actual counseling session took place.  The signature blocks on the back have a place to annotate the date the 4856 is signed.  This infers that the Date of Counseling and the date the 4856 is signed could be different dates.  This allows for some flexibility to properly annotate the session on a DA Form 4856 if one is not available at the time of the counseling session.

There is no regulation stating that counseling session must be recorded on a DA Form 4856 although most unit counseling SOP’s require it.  A counseling session can be recorded on regular paper, a cardboard box or anything you want to use. The critical piece of the counseling is the content of the session, not the form.  If a DA Form 4856 is unavailable at the time of counseling, the session could be recorded in a notebook, journal, leaders book, etc. and be transferred to a 4856 later when one becomes available.  The important thing is to record the content of session at the time of counseling so nothing is forgotten or omitted should it have to transferred later to a 4856.   The leader should also have the counseled soldier sign wherever they recorded the counseling to eliminate any “Hey, I don’t remember you saying that!” rebuttals.  The leader should also annotate in the counseling that a 4856 was not available at the time of counseling, how it was recorded during the session, and that it will be transferred to a DA Form 4856 later when one becomes available.  Granted, this is not the preferred method but if done properly it is just as effective.

Please keep in mind that interpretation is everything and some commands may interpret this differently so we would recommend a thorough perusal of the units counseling SOP for further guidance on this matter. If your unit does not have a Counseling SOP we have included a sample of ours in Counsel Quick Volume 2.