RECORD OF PROCEEDINGS AIR FORCE BOARD FOR CORRECTION OF MILITARY RECORDS IN THE MATTER OF: DOCKET NUMBER: BC-2014-01287 COUNSEL: NONE HEARING DESIRED: NO APPLICANT REQUESTS THAT: Her narrative reason for separation of personality disorder be changed. APPLICANT CONTENDS THAT: Her evaluation by the service psychologist was incorrect and her diagnosis of personality disorder was unjust. She has been seen by two psychologists over a period of two years and has been advised that she does not have a personality disorder; but, that she suffers from Post-Traumatic Stress Disorder (PTSD) and Military Sexual Trauma (MST). The applicant’s complete submission, with attachments, is at Exhibit A. STATEMENT OF FACTS: On 16 Aug 00, the applicant initially entered the Regular Air Force for period of four years. On 20 Oct 03, the squadron commander notified the applicant of administrative discharge action for conditions that interfere with military service: mental disorders. The specific reasons for the proposed action noted during her mental health evaluation, was that on or about 15 Oct 03, the applicant was diagnosed with Adjustment Disorder with symptoms of both Anxiety and Depression, acute; moderate symptoms due to ongoing stress of upcoming deployment, routine labs within normal limits; Axis II, there was not enough evidence to support a diagnosis of a personality disorder at that time, however she displayed some character traits which made working in a military environment difficult: including resistance to authority, need for respect and appreciation, and independence. Based on the results of formal psychological testing, as described in the Diagnostic and Statistical Manual of Mental Disorders (DSM-IV), it was determined that these disorders significantly impaired her ability to function effectively in the military. On that same date, the applicant acknowledged receipt of the notification of discharge and was advised of her right to consult with legal counsel and submit statements in her own behalf. On 3 Nov 03, the discharge authority approved her separation with an honorable discharge, without probation and rehabilitation. On 17 Nov 03, the applicant was furnished an honorable discharge, and was credited with 3 years, 3 months, and 2 days of active service. AIR FORCE EVALUATION: The BCMR Medical Consultant recommends denial of the applicant's petition to change the narrative reason for discharge to a medical due to PTSD. The Consultant does recommend changing the narrative reason for discharge to Secretarial Authority. The Medical Consultant is aware that reducing, eliminating, and prosecuting MST are high among Congressional and Department of Defense priorities. Likewise, the Consultant is aware that individuals suffering from MST may not disclose the assault at the time of occurrence due to self-blame, fear, embarrassment, or other reasons. Thus, the Consultant does not find it unusual the applicant has not presented service medical or administrative evidence of the occurrence nor reported any symptoms diagnostic of PTSD secondary to MST during her military service. The applicant's expressed fear of embarking on another deployment, as repeatedly disclosed in the service mental health summary, is not reflective of PTSD due to MST as the cause for career termination. Operating under Title 10, United States Code (U.S.C.), the Military Department can, by law, only assign compensation for a medical condition that cause career termination; and then only to the degree present at the time of separation. The Department of Veterans Affairs (DVA), operating under Title 38, is authorized to offer compensation for any medical condition with an established nexus with military service, without regard to its impact upon a member's fitness to serve, the narrative reason for discharge, nor the length of time passed since discharge or when the diagnosis was made. The rating may also be adjusted as the condition may change over the lifetime of the veteran. Nevertheless, the display of Personality Disorder on the applicant's DD Form 214, the previous administrative default designation, is clearly an error which is likely to have adversely affected the applicant's social and occupational opportunities wherever displayed or disclosure of this document has been required. Thus, the Medical Consultant recommends changing the narrative reason for discharge to Secretarial Authority. The complete BCMR Medical Consultant evaluation is at Exhibit C. APPLICANT'S REVIEW OF AIR FORCE EVALUATION: A copy of the Air Force evaluation was forwarded to the applicant on 23 Dec 14 for review and comment within 30 days (Exhibit D). As of this date, no response has been received by this office. ADDITIONAL AIR FORCE EVALUATION: The Clinical Psychology Consultant recommends changing the applicant’s narrative reason for separation to Adjustment Disorder with the corresponding separation code of JFY, or Secretarial Authority with appropriate separation code. However, the Clinical Psychology Consultant does not recommend supplanting her administrative discharge with a medical retirement. The Clinical Psychology Consultant is aware that historical personnel processes lumped adjustment disorders into the same category as personality disorders when listing a narrative reason for separation. This is no longer the case as adjustment disorders serve as a narrative reason with a unique separation code (JFY). The applicant’s narrative reason for separation on her DD Form 214 is listed as Personality Disorder even though discharge recommendations from the mental health provider and squadron commander recommend separation on the basis of an Adjustment Disorder. Thus, it appears neither the narrative reason nor the separation code accurately reflect the condition that triggered her discharge. This may constitute an error unless remedied. The Clinical Psychology Consultant is aware of military regulations governing the Disability Evaluation System (DES) and finds these relevant to the applicant’s current requests. IAW DoDI 1332.38 (in effect at the time of the applicant’s discharge) in order for the applicant to have been entered into the DES for a potential medical separation she must have met criteria listed in Enclosure 3 Part 2 of the regulation. The Clinical Psychology Consultant reminds the applicant that the Military Department operates under Title 10, United States Code (U.S.C.), and must base its actions upon evidence available at the “snapshot” in time of final military disposition. This Consultant observes that documentation supplied for this case does not support the presence of a mental health condition meeting criteria for initiating DES processing as listed in DoDI 1332.38. The DVA, operating under a different set of laws (Title 38, U.S.C.) with a different purpose, is authorized to offer service connection and compensation for any medical condition for which it has established a nexus with military service regardless of the narrative reason for separation or the length of time transpired since discharge. The DVA is even permitted to adjust ratings based on progression of a mental disorder as time transpires. Therefore, post-service DVA ratings do not equate to a Military Department decision that a mental health condition rendered a Service member unfit for continued military service at the time of discharge. Barring evidence to the contrary that is contemporaneous with the applicant’s administrative separation, there was no error or injustice in the disposition of the applicant’s case. The complete Clinical Psychology Consultant evaluation is at Exhibit E. APPLICANT'S REVIEW OF THE ADDITIONAL AIR FORCE EVALUATION: A copy of the Air Force evaluation was forwarded to the applicant on 7 Jul 15 for review and comment within 30 days (Exhibit F). As of this date, no response has been received by this office. THE BOARD CONCLUDES THAT: 1. The applicant has exhausted all remedies provided by existing law or regulations. 2. The application was timely filed. 3. Sufficient relevant evidence has been presented to demonstrate the existence of an error or injustice warranting corrective action. We note the applicant’s narrative reason and separation code assigned at the time of her discharge was appropriate; nonetheless, the Department of Defense has since established additional, more specific SPD identifiers to more clearly delineate mental disorders. The applicant was diagnosed with an Adjustment Disorder rather than a Personality Disorder; however, the diagnosis of Personality Disorder was likely chosen as the printed narrative reason for discharge as a matter of administrative policy at the time rather than a determination that it represented the diagnostic reason for the applicant’s inability to perform her military duties. Since Adjustment Disorder was not available as a valid narrative reason during the period in question, we agree with the opinions of both the BCMR Medical Consultant and the BCMR Psychology Consultant to change the applicant’s narrative reason for separation. In our view, we are more inclined with the approach of changing the applicant’s reason for separation to “Secretarial Authority” along with the corresponding SPD code of “KFF,” as recommended by the BCMR Medical Consultant. Therefore, we recommend the applicant’s record be corrected as indicated below. THE BOARD RECOMMENDS THAT: The pertinent military records of the Department of the Air Force relating to the APPLICANT be corrected to show that on 17 Nov 03, she was discharged under the provisions of AFI 36-3208, (Secretarial Authority), with a Separation Code of “KFF.” The following members of the Board considered AFBCMR Docket Number BC-2014-01287 in Executive Session on 27 Aug 15 under the provisions of AFI 36-2603: , Panel Chair , Member , Member All members voted to correct the records as recommended. The following documentary evidence was considered: Exhibit A. DD Form 149, dated 23 Dec 13, w/atchs. Exhibit B. Pertinent Excerpts from Personnel Records. Exhibit C. Letter, BCMR Medical Consultant, dated 12 Dec 14. Exhibit D. Letter, SAF/MRBR, dated 23 Dec 14. Exhibit E. Letter, BCMR Psychology Consultant, dated 24 Jun 15. Exhibit F. Letter, SAF/MRBR, dated 7 Jul 15.