Can a counseling statement be written by someone other than the counselor?

I don’t know of any regulation that directly prevents this; however, I would not consider this to be the correct, or most effective, course of action. From my own professional experience, I think that the individual preparing the counseling statement should be the one administering the counseling session.

Appropriate exceptions

Inexperienced NCO: One exception to this would be a situation in which the counselor is significantly challenged when it comes to preparing or writing a counseling statement; in this case, the challenged leader should attempt to prepare the counseling and  have his superior review the counseling document. The superior should then use this as an opportunity to mentor the junior leader, providing instruction on how to properly prepare a counseling statement.

Dual leader observation: Your OIC may have observed an issue in the presence of your NCOIC that he or she would like to address in a counseling session. In this situation, it would be appropriate for your NCOIC to prepare a counseling statement and review it with the OIC, meaning that the OIC would provide input for the counseling statement.

Officer-only observation: Your OIC may observe an issue for which the NCOIC was not present. Later, the OIC may direct the NCOIC to conduct the counseling. In this situation, the best course of action may be unclear. It would depend on specific details of each given issue. I would, however, suggest that the best course of action may be for the OIC to prepare the counseling and give it to the Soldier directly. Having the NCOIC provide the counseling in a situation like this may add an unnecessary level of confusion to the issue, since the NCO was not present.

For example, let’s say the OIC states that you were disrespectful to him, and he or she wants you counseled. There are two appropriate options:

1. The OIC may address the issue in a counseling session, and the issue may be handled in the presence of the NCOIC.
2. The OIC may direct the NCOIC to conduct the counseling based on the information provided by the OIC.  The NCOIC may counsel you, but the information would be solely based on the information provided by the OIC.  If the issue was elevated for legal action, there could be an issue, as the NCOIC is not familiar with every detail of the situation.  This would be a less effective course of action.

Counseling is Leader Business

Some officers may be apprehensive to give a Soldier a counseling statement as they may see this as venturing into NCO business; however, there are situations in which an officer should conduct the counseling session. The example above, regarding disrespect to the OIC, is a perfect example of when an Officer could and should be directly involved.

For more on this subject, see the following article:  NCO Business vs Officer Business vs Leader Business.