1. Applicant’s Name: a. Application Date: 26 April 2021 b. Date Received: 26 April 2021 c. Counsel: None 2. REQUEST, ISSUES, BOARD TYPE, AND DECISION: a. Applicant’s Requests and Issues: The current characterization of service for the period under review is general (under honorable conditions). The applicant requests an upgrade to honorable. The applicant seeks relief contending, in effect, being rated 90 percent disabled by the Department of Veterans Affairs (VA). The applicant was diagnosed with 50 percent disability by the VA on 5 May 2015, the day after the discharge. The applicant believes the PTSD along with the undiagnosed mild traumatic brain injury (mTBI) contributed to the applicant being investigated. The Army denied the applicant’s appeal approximately three years ago, although the applicant had PTSD and TBI. The applicant would like the medical retirement reinstated as it is appropriate. The applicant experienced racial discrimination, medical neglect, and emotional abuse. The applicant should have been admitted to the Warrior Treatment Unit for all medical appointments. The applicant did not receive hospital treatment, specialized PTSD treatment, or a medical board as required for PTSD and TBI diagnoses. The Army agreed to review all decisions based on a court settlement in 2020 or 2021. The applicant requests a medical board, denied at the discharge, which contributed to the worsening of the conditions. b. Board Type and Decision: In a records review conducted on 25 April 2023, and by a 5-0 vote, the Board denied the request upon finding the separation was both proper and equitable. Please see Section 9 of this document for more detail regarding the Board’s decision. (Board member names available upon request) 3. DISCHARGE DETAILS: a. Reason / Authority / Codes / Characterization: Unacceptable Conduct / AR 600-8-24, Paragraph 4-2b / JNC / General (Under Honorable Conditions) b. Date of Discharge: 4 May 2015 c. Separation Facts: (1) Date of Notification of Intent to Separate: 5 June 2014 (2) Basis for Separation: The applicant was informed to show cause for retention on active duty under the provisions of AR 600-8-24, paragraphs 4-2a for substandard performance; 4-2b (8) for misconduct, moral, or professional dereliction, conduct unbecoming of an officer, and 4-2c (5) for receiving derogatory information filed in the Army Military Human Resource Record (AMHRR) in accordance with AR 600-37, because of the following reasons: Derogatory activity resulting in a General Officer Memorandum of Reprimand, dated 20 December 2013, which was filed in the applicant’s AMHRR for: The applicant engaged in off-duty employment without prior permission from the USA MEDDAC-AK Commander; The applicant departed the appointed place of duty without the proper authority; The applicant established a hostile work environment; and The applicant allowed material to be presented at a medical conference without having the presentation properly approved by superiors. Conduct unbecoming an officer, AR 600-8-24 as indicated by the above-referenced GOMOR. The applicant had six referred “(R)” Officer Evaluation Reports for the periods of 5 November 2006 – 4 November 2007, 18 December 2008 – 17 September 2009, 18 September 2009 – 11 February 2010, 11 February 2010 – 6 October 2010, 1 June 2012 – 15 November 2012, and 16 November 2012 – 10 June 2013, which were filed in the applicant’s AMHRR. As a result, the applicant was identified by the FY13, Major, Medical Specialist Corps, Promotion Selection Board to show cause for retention on active duty. (3) Legal Consultation Date: The applicant waived legal counsel. (4) Board of Inquiry (BOI): On 11 September 2014, the applicant was notified to appear before a Show Cause Board and advised of rights. On 20 October 2014, a Board of Inquiry convened, and the applicant did not appear before the board and refused to be represented by counsel. The board recommended the applicant’s discharge with characterization of service of under other than honorable conditions. On 6 January 2015, the GOSCA approved, with exceptions, the findings, and recommendations of the board of inquiry. (5) GOSCA Recommendation Date / Characterization: On 6 January 2015, the GOSCA recommended the applicant be involuntarily eliminated from service. / General (Under Honorable Conditions) (6) DA Board of Review for Eliminations: On 17 April 2015, the Army Board of Review for Eliminations considered the GOSCA’s request to involuntary separate the applicant for unacceptable conduct in accordance with AR 600-8-24, Chapter 4-2b. (7) Separation Decision Date / Characterization: 17 April 2015 / General (Under Honorable Conditions) 4. SERVICE DETAILS: a. Date / Period of Appointment: 13 September 2005 / Indefinite / The period under review began when the applicant was ordered to active duty on 24 June 2005, with a service obligation of 36 months. b. Age at Appointment: / Education: 39 / Master of Social Work, Master of Education c. Highest Grade Achieved / MOS / Total Service: O-3 / 67D 9B Behavioral Sciences, 73A Social Worker / 9 years, 10 months, 11 days d. Prior Service / Characterizations: USAR, 24 June 2005 – 12 September 2005 / NA e. Overseas Service / Combat Service: Germany, Korea, SWA / Iraq (3 August 2006 – 5 November 2007; 28 January 2007 – 15 April 2008; 17 April 2010 – 3 May 2011) f. Awards and Decorations: ICM-5CS, ARCOM-3, NDSM-BSS, KSM, GWOTSM, ASR, OSR-6 g. Performance Ratings: 28 September 2005 – 25 January 2006 / Best Qualified 26 January 2006 – 7 July 2006 / Best Qualified 8 July 2006 – 4 November 2006 / Best Qualified 5 November 2006 – 4 November 2007 / Best Qualified (R) 5 November 2007 – 17 April 2008 / Best Qualified 18 April 2008 – 17 September 2008 / Best Qualified 18 September 2008 – 17 September 2009 / Fully Qualified (R) 18 September 2009 – 11 February 2010 / Fully Qualified (R) 11 February 2010 – 6 October 2010 / Best Qualified (R) 7 October 2010 – 30 April 2011 / Best Qualified 28 August 2011 – 1 June 2012 / Best Qualified 1 June 2012 – 15 November 2012 / Fully Qualified (R) 16 November 2012 – 10 June 2013 / Fully Qualified (R) 11 June 2013 – 10 June 2014 / Highly Qualified h. Disciplinary Action(s) / Evidentiary Record: Developmental Counseling Form, dated 4 September 2013, for unsatisfactory performance by disobeying a directive. Informal AR 15-6 Investigation Findings and Recommendations, dated 23 September 2013, reflects the investigating officer found: The applicant created a hostile work environment within the clinic by taking retribution against personnel for bringing behavioral health issues to the attention of higher authority. The applicant was given explicit instructions (direct order) not to participate / present information at a civilian medical gathering at the University of Alaska, Anchorage (UAA). On 3 September 2013, the applicant participated in and/or presented information at a civilian medical gathering at the UAA. The applicant distributed written materials to the participants at medical gathering explicitly or implicitly suggesting sponsorship of materials or endorsement by the Army. Contracted providers employed within the Department of Behavioral Health to participate in the medical gathering. The Contracting Representative did not authorize participation. The applicant is employed by the UAA and did not have documented approval. General Officer Memorandum Of Reprimand, dated 20 December 2013, reflects on 23 September 2013, an Army Regulation 15-6 Investigation, investigating officer found the applicant: Engaged in off-duty employment without prior permission from the Commander, U.S. Army Medical Activity – Alaska; Departed the appointed place of duty without proper authority; Established a hostile working environment for employees within the Behavioral Health Department; and Allowed material to be presented at a medical conference without having the presentation properly approved by superiors. Formal AR 15-6 Investigation Findings and Recommendations, dated 20 October 2014, reflects the board of inquiry found the applicant did have derogatory information filed in the applicant’s AMHRR; did have misconduct, to wit: General Officer Memorandum of Reprimand, dated 20 December 2013, which was filed in the applicant’s AMHRR; and did have substandard performance of duty, to wit: six referred Officer Evaluation Reports. i. Lost Time / Mode of Return: None j. Behavioral Health Condition(s): (1) Applicant provided: The Department of Veterans Affairs benefits letter, dated 26 October 2015, reflecting the applicant was rated 50 percent disability for PTSD (also claimed as dysthymic disorder, depressive neurosis, depression, adjustment disorder with depressed mood, anxiety disorder, primary snoring, and insomnia); 0 percent for residuals of traumatic brain injury with mild expressive aphasia and anomia (also claimed as decreased concentrating ability, cognitive communication disorder, dysphasia, history of concussion, late effect intracranial injury, and memory lapse and loss); and received a 90 percent combined rating. (2) AMHRR Listed: Report of Medical Examination, dated 4 December 2014, the examining medical physician noted in the summary of defects and diagnoses section: Post concussive syndrome, dysthymia, and PTSD. Report of Mental Status Evaluation, dated 3 March 2015, reflects the applicant was unfit for duty because of a personality disorder or other mental condition which did not amount to a medical disability. The applicant could understand and participate in administrative proceedings. The applicant had been screened for PTSD with positive results and mTBI with negative results. The conditions were either not present or did not meet AR 40-501 criteria for a medical evaluation board. The command was advised to consider the influence of these conditions. The applicant was diagnosed with: Persistent Depressive Disorder (Dysthymia) and TBI resulting in mild cognitive impairment. Servicemember treated in the TBI Clinic. Psychiatric Screening attached. 5. APPLICANT-PROVIDED EVIDENCE: Two DD Forms 149; DD Form 214; VA Benefits letter. 6. POST SERVICE ACCOMPLISHMENTS: None submitted with the application. 7. STATUTORY, REGULATORY AND POLICY REFERENCE(S): a. Section 1553, Title 10, United States Code (Review of Discharge or Dismissal) provides for the creation, composition, and scope of review conducted by a Discharge Review Board(s) within established governing standards. As amended by Sections 521 and 525 of the National Defense Authorization Act for Fiscal Year 2020, 10 USC 1553 provides specific guidance to the Military Boards for Correction of Military/Naval Records and Discharge Review Boards when considering discharge upgrade requests by Veterans claiming Post Traumatic Stress Disorder (PTSD), Traumatic Brain Injury (TBI), sexual trauma, intimate partner violence (IPV), or spousal abuse, as a basis for discharge review. The amended guidance provides that Boards will include, as a voting board member, a physician trained in mental health disorders, a clinical psychologist, or a psychiatrist when the discharge upgrade claim asserts a mental health condition, including PTSD, TBI, sexual trauma, IPV, or spousal abuse, as a basis for the discharge. Further, the guidance provides that Military Boards for Correction of Military/Naval Records and Discharge Review Boards will develop and provide specialized training specific to sexual trauma, IPV, spousal abuse, as well as the various responses of individuals to trauma. b. Multiple Department of Defense Policy Guidance Memoranda published between 2014 and 2018. The documents are commonly referred to by the signatory authorities’ last names (2014 Secretary of Defense Guidance [Hagel memo], 2016 Acting Principal Deputy Under Secretary of Defense for Personnel and Readiness [Carson memo], 2017 Official Performing the Duties of the Under Secretary of Defense for Personnel and Readiness [Kurta memo], and 2018 Under Secretary of Defense for Personnel and Readiness [Wilkie memo]. (1) Individually and collectively, these documents provide further clarification to the Military Discharge Review Boards and Boards for Correction of Military/Naval Records when considering requests by Veterans for modification of their discharge due to mental health conditions, including PTSD; TBI; sexual assault; or sexual harassment. Liberal consideration will be given to Veterans petitioning for discharge relief when the application for relief is based in whole or in part on matters relating to mental health conditions, including PTSD; TBI; sexual assault; or sexual harassment. Special consideration will be given to Department of Veterans Affairs (VA) determinations that document a mental health condition, including PTSD; TBI; or sexual assault/harassment potentially contributed to the circumstances resulting in a less than honorable discharge characterization. Special consideration will also be given in cases where a civilian provider confers diagnoses of a mental health condition, including PTSD; TBI; or sexual assault/harassment if the case records contain narratives supporting symptomatology at the time of service or when any other evidence which may reasonably indicate that a mental health condition, including PTSD; TBI; or sexual assault/harassment existed at the time of discharge might have mitigated the misconduct that caused a discharge of lesser characterization. (2) Conditions documented in the service record that can reasonably be determined to have existed at the time of discharge will be considered to have existed at the time of discharge. In cases in which a mental health condition, including PTSD; TBI; or sexual assault/harassment may be reasonably determined to have existed at the time of discharge, those conditions will be considered potential mitigating factors in the misconduct that caused the characterization of service in question. All Boards will exercise caution in weighing evidence of mitigation in cases in which serious misconduct precipitated a discharge with a less than Honorable characterization of service. Potentially mitigating evidence of the existence of undiagnosed combat related PTSD, PTSD-related conditions due to TBI or sexual assault/harassment as causative factors in the misconduct resulting in discharge will be carefully weighed against the severity of the misconduct. PTSD is not a likely cause of premeditated misconduct. Caution shall be exercised in weighing evidence of mitigation in all cases of misconduct by carefully considering the likely causal relationship of symptoms to the misconduct. c. Army Regulation 15-180 (Army Discharge Review Board), sets forth the policies and procedures under which the Army Discharge Review Board is authorized to review the character, reason, and authority of any Servicemember discharged from active military service within 15 years of the Servicemember’s date of discharge. Additionally, it prescribes actions and composition of the Army Discharge Review Board under Public Law 95-126; Section 1553, Title 10 United States Code; and Department of Defense Directive 1332.41 and Instruction 1332.28. d. Army Regulation 600-8-24, Officer Transfers and Discharges, sets forth the basic authority for the separation of commissioned and warrant officers. (1) Paragraph 1-23, provides the authorized types of characterization of service or description of separation. (2) Paragraph 1-23a, states an officer will normally receive an honorable characterization of service when the quality of the officer’s service has met the standards of acceptable conduct and performance of duty, or the final revocation of a security clearance under DODI 5200.02 and AR 380-67 for reasons that do not involve acts of misconduct for an officer. (3) Paragraph 1-23b, states an officer will normally receive a general (under honorable conditions) characterization of service when the officer’s military record is satisfactory but not sufficiently meritorious to warrant an honorable discharge. A separation under general (under honorable conditions) normally appropriate when an officer: Submits an unqualified resignation; Separated based on misconduct; discharged for physical disability resulting from intentional misconduct or neglect; and, for final revocation of a security clearance. (4) Chapter 4 outlines the policy and procedure for the elimination of officers from the active Army for substandard performance of duty. (5) Paragraph 4-2b, prescribes for the elimination of an officer for misconduct, moral or professional dereliction, or in the interests of national security. (6) Paragraph 4-20a (previously 4-24a), states an officer identified for elimination may, at any time during or prior to the final action in the elimination case elect one of the following options: (1) Submit a resignation in lieu of elimination; (2) request a discharge in lieu of elimination; and (3) Apply for retirement in lieu of elimination if otherwise eligible. e. Army Regulation 635-5-1 (Separation Program Designator (SPD) Codes) provides the specific authorities (regulatory or directive), reasons for separating Soldiers from active duty, and the SPD codes to be entered on the DD Form 214. It identifies the SPD code of “JNC” as the appropriate code to assign commissioned officers who are discharged under the provisions of Army Regulation 600-8-24, Chapter 4-2b, unacceptable conduct. 8. SUMMARY OF FACT(S): The Army Discharge Review Board considers applications for upgrade as instructed by Department of Defense Instruction 1332.28. The applicant requests an upgrade to honorable. The applicant’s Army Military Human Resources Record (AMHRR), the issues, and documents submitted with the application were carefully reviewed. The applicant contends the narrative reason for the discharge needs changed. The applicant was separated under the provisions of Chapter 4, paragraph 4-2b, AR 600-8-24 with a general (under honorable conditions) discharge. The narrative reason specified by Army Regulations for a discharge under this paragraph is “Unacceptable Conduct,” and the separation code is “JNC.” Army Regulation 635-8, Separation Processing and Documents, governs preparation of the DD Form 214 and dictates the entry of the narrative reason for separation, entered in block 28 and separation code, entered in block 26 of the form, will be exactly as listed in tables 2-2 or 2-3 of AR 635-5-1, Separation Program Designator (SPD) Codes. The regulation further stipulates no deviation is authorized. There is no provision for any other reason to be entered under this regulation. The applicant contends PTSD and undiagnosed mTBI affected behavior which ultimately led to the discharge. The applicant provided a copy of VA benefits letter, reflecting the applicant was rated 50 percent disability for PTSD; 0 percent for residuals of traumatic brain injury with mild expressive aphasia and anomia; and received a 90 percent combined rating. The applicant’s AMHRR shows the applicant underwent a medical examination on 4 December 2014, reflecting the examining medical physician noted in the summary of defects and diagnoses section: Post concussive syndrome, dysthymia, and PTSD. The applicant underwent a mental status evaluation (MSE) on 3 March 2015, which indicates the applicant was unfit for duty because of a personality disorder or other mental condition which did not amount to a medical disability. The applicant could understand and participate in administrative proceedings. The applicant had been screened for PTSD with positive results and mTBI with negative results. The applicant was diagnosed with: Persistent Depressive Disorder (Dysthymia) and TBI resulting in mild cognitive impairment. Servicemember was treated in the TBI clinic. The MSE and medical examination were considered by the separation authority. The applicant contends discrimination by members of the chain of command, emotional abuse, and medical neglect, which contributed to the mental health conditions becoming worse. There is no evidence in the AMHRR the applicant sought assistance or reported the discrimination, abuse, or neglect. The applicant contends being denied a medical evaluation board at the time of the discharge. The AMHRR is void of any evidence the applicant was referred to a medical evaluation board. The applicant’s AMHRR does not contain any indication or evidence of arbitrary or capricious actions by the command. The applicant requests a medical evaluation board and medical retirement. The applicant’s request does not fall within this board’s purview. The applicant may apply to the Army Board for Correction of Military Records (ABCMR), using the enclosed DD Form 149 regarding this matter. A DD Form 149 may also be obtained from a Veterans’ Service Organization. The applicant contends the Army denied the applicant’s appeal approximately three years ago although the applicant had PTSD and TBI. The applicant’s case will be considered De Novo under the Secretary of the Army and Kennedy Agreement of Settlement, wherein PTSD TBI will be considered by the Board, as possible mitigating factors. 9. BOARD DISCUSSION AND DETERMINATION: a. As directed by the 2017 memo signed by A.M. Kurta, the board considered the following factors: (1) Did the applicant have a condition or experience that may excuse or mitigate the discharge? Yes. The Board's Medical Advisor, a voting member, reviewed the applicant's DOD and VA health records, applicant's statement, and/or civilian provider documentation and found that the applicant has the following potentially-mitigating diagnoses/experiences: Depression, PTSD and TBI. (2) Did the condition exist or experience occur during military service? Yes. The Board's Medical Advisor found compelling evidence for depression, PTSD, and TBI at the time of service. (3) Does the condition or experience actually excuse or mitigate the discharge? Partial. The Board's Medical Advisor applied liberal consideration and opined that applicant has multiple relevant diagnoses at time of service to include PTSD, mild TBI, and depression diagnosed as dysthymic disorder/persistent depressive disorder. There is evidence to support partial mitigation. PTSD is often associated with avoidance and as such mitigates the incident of leaving place of duty without permission; although records suggest in this case it appeared purposeful and outside typical PTSD-associated avoidance, mitigation is being granted under liberal consideration guidelines. Neither PTSD, depression, nor the degree of TBI suggested by her medical records would result in the inability to differentiate between right and wrong and adhere to the right; there is no evidence to support mitigation for offenses to include creating a hostile work environment, engaging in off duty employment without permission, and allowing material to be presented without prior approval of superiors. (4) Does the condition or experience outweigh the discharge? No. After applying liberal consideration to the evidence, including the Board Medical Advisor opine, the Board determined that while the applicant’s BH conditions mitigate leaving place of duty without proper authority, the available evidence did not support a conclusion that the applicant’s Depression, PTSD and TBI outweighed the medically unmitigated basis for applicant’s separation – creating a hostile work environment, engaging in off duty employment without permission, and allowing material to be presented without prior approval of superiors – for the aforementioned reasons. b. Response to Contention(s): (1) The applicant contends the narrative reason for the discharge needs changed. The Board considerd this conteniton and determined that the applicant was properly separated under the provisions of Chapter 4, paragraph 4-2b, AR 600-8-24. The narrative reason specified by Army Regulations for a discharge under this paragraph is “Unacceptable Conduct,” and the separation code is “JNC.” Army Regulation 635-8, Separation Processing and Documents, governs preparation of the DD Form 214 and dictates the entry of the narrative reason for separation, and the Board found insufficient mitigating factors to warrant deviation from the regulation. (2) The applicant contends PTSD and undiagnosed mTBI affected behavior which ultimately led to the discharge. The Board considered this contention and determined that while the applicant’s BH conditions mitigate leaving place of duty without proper authority, the available evidence did not support a conclusion that the applicant’s Depression, PTSD and TBI outweighed the medically unmitigated basis for applicant’s separation – creating a hostile work environment, engaging in off duty employment without permission, and allowing material to be presented without prior approval of superiors. Thus, the discharge is proper and equitable. (3) The applicant contends discrimination by members of the chain of command, emotional abuse, and medical neglect, which contributed to the mental health conditions becoming worse. The Board considered this contention and the applicant’s assertion of unfair treatment, however the Board determined that there is insufficient evidence of said diagnoses in official or medical records, and the applicant did not provide supporting documentation by a qualified medical professional to provide merit to the claim. Ultimately, the Board determined that the assertion alone did not outweigh the basis of separation due to the nature of the offenses. (4) The applicant contends being denied a medical evaluation board at the time of the discharge, and now requests a medical evaluation board and medical retirement. The Board determined that the applicant’s requested change to the DD Form 214 does not fall within the purview of the ADRB. The applicant may apply to the Army Board for Correction of Military Records (ABCMR), using a DD Form 149 regarding this matter. A DD Form 149 may be obtained from a Veterans’ Service Organization (5) The applicant contends the Army improperly denied the applicant’s appeal approximately three years ago although the applicant had PTSD and TBI. The Board considered this contention. The applicant’s case was considered De Novo under the Secretary of the Army and Kennedy Agreement of Settlement, wherein PTSD TBI was considered by the Board as possible mitigating factors. After such review, the Board determined that while the applicant’s BH conditions mitigate leaving place of duty without proper authority, the available evidence did not support a conclusion that the applicant’s Depression, PTSD and TBI outweighed the medically unmitigated basis for applicant’s separation – creating a hostile work environment, engaging in off duty employment without permission, and allowing material to be presented without prior approval of superiors. Thus, the discharge is proper and equitable. c. The Board determined that the discharge is, at this time, proper and equitable, in light of the current evidence of record. However, the applicant may request a personal appearance hearing to address the issues before the Board. The applicant is responsible for satisfying the burden of proof and providing documents or other evidence sufficient to support the applicant’s contention(s) that the discharge was improper or inequitable. d. Rationale for Decision: (1) The Board voted not to change the applicant’s characterization of service because, while the applicant’s BH conditions mitigate leaving place of duty without proper authority, the available evidence did not support a conclusion that the applicant’s Depression, PTSD and TBI outweighed the medically unmitigated basis for applicant’s separation – creating a hostile work environment, engaging in off duty employment without permission, and allowing material to be presented without prior approval of superiors. The Board further considered the applicant’s contentions and found there is insufficient evidence of any arbitrary or capricious action taken by Command resulting in any inequity or impropriety. The discharge was consistent with the procedural and substantive requirements of the regulation, was within the discretion of the separation authority, and the applicant was provided full administrative due process. Therefore, the applicant’s GD was proper and equitable as the applicant’s misconduct fell below that level of meritorious service warranted for an upgrade to HD. (2) The Board voted not to change the applicant’s reason for discharge or accompanying SPD code under the same pretexts, as the reason the applicant was discharged was both proper and equitable. (3) The RE code will not change, as the current code is consistent with the procedural and substantive requirements of the regulation. ? 10. BOARD ACTION DIRECTED: a. Issue a New DD-214 / Separation Order: No b. Change Characterization to: No Change c. Change Reason / SPD Code to: No Change d. Change RE Code to: No Change e. Change Authority to: No Change Authenticating Official: Legend: AWOL – Absent Without Leave AMHRR – Army Military Human Resource Record BCD – Bad Conduct Discharge BH – Behavioral Health CG – Company Grade Article 15 CID – Criminal Investigation Division ELS – Entry Level Status FG – Field Grade Article 15 GD – General Discharge HS – High School HD – Honorable Discharge IADT – Initial Active Duty Training MP – Military Police MST – Military Sexual Trauma N/A – Not applicable NCO – Noncommissioned Officer NIF – Not in File NOS – Not Otherwise Specified OAD – Ordered to Active Duty OBH (I) – Other Behavioral Health (Issues) OMPF – Official Military Personnel File PTSD – Post-Traumatic Stress Disorder RE – Re-entry SCM – Summary Court Martial SPCM – Special Court Martial SPD – Separation Program Designator TBI – Traumatic Brain Injury UNC – Uncharacterized Discharge UOTHC – Under Other Than Honorable Conditions VA – Department of Veterans Affairs ARMY DISCHARGE REVIEW BOARD CASE REPORT AND DIRECTIVE AR20210002125 1