POSTTRAUMATIC STRESS DISORDER (PTSD)

Summary

The veteran, who served in the Army Reserve on active duty for training (ACDUTRA) and inactive duty for training (INACDUTRA) from March 2013 to September 2013, appeals the denial of service connection for posttraumatic stress disorder (PTSD) and schizoaffective disorder (claimed as schizophrenia). The Board denied service connection for PTSD, finding no current diagnosis based on the persuasive weight of the evidence. The VA examiner diagnosed schizoaffective disorder and opined that the veteran's symptoms did not meet the criteria for PTSD. The Board found the VA examiner's opinion probative, noting that lay individuals are not competent to diagnose psychiatric conditions. The Board denied service connection for schizoaffective disorder, finding no in-service injury or disease during ACDUTRA. The evidence showed the condition was first noticed during INACDUTRA, and service connection for diseases is only permitted during ACDUTRA, not INACDUTRA. The Board also noted that the veteran's behavior was first noticed during INACDUTRA, and the evidence suggested a six-month history of developing symptoms prior to that period, indicating the condition did not manifest during ACDUTRA. The Board concluded that the veteran did not meet the criteria for veteran status for purposes of service connection for a disease, and therefore, direct service connection was denied.

Rationale

No current diagnosis of PTSD; VA examiner opined symptoms did not meet PTSD criteria; Lay person not competent to diagnose psychiatric disability

Full Decision Text

Citation Nr: A26036692
Decision Date: 04/21/26	Archive Date: 04/21/26

DOCKET NO. 251012-598402
DATE: April 21, 2026

ORDER

Service connection for posttraumatic stress disorder (PTSD) is denied.  

Service connection for schizoaffective disorder (claimed as schizophrenia) is denied.

FINDINGS OF FACT

1.  There is no current diagnosis of PTSD.

2.  The evidence shows a current diagnosis of schizoaffective disorder.

3.  The appellant did not become disabled due to schizoaffective disorder in the line of duty during a period of active duty for training (ACDUTRA) or inactive duty for training (INACDUTRA).   

CONCLUSIONS OF LAW

1.  The criteria for service connection for PTSD are not met.  38 U.S.C. §§ 1110, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.304.

2.  The criteria for service connection for schizoaffective disorder are not met.   38 U.S.C.A. §§ 1110, 5107; 38 C.F.R. §§ 3.102, 3.303, 3.304.  

REASONS AND BASES FOR FINDINGS AND CONCLUSIONS

The appellant served on ACDUTRA from March 2013 to September 2013, and also had periods of inactive duty for training (INACDUTRA).

This matter comes before the Board of Veterans' Appeals (Board) on appeal from March 2025 (schizophrenia) and April 2025 (PTSD) rating decisions issued by a Department of Veterans Affairs (VA) Agency of Original Jurisdiction (AOJ).  

In the October 2025 VA Form 10182, the appellant timely appealed these decisions to the Board by requesting the Direct Review docket; therefore, the Board may only consider the evidence of record at the time of the March 2025 and April 2025 AOJ decisions on appeal.  38 C.F.R. § 20.301.  Any evidence submitted after the March 2025 and April 2025 AOJ decisions cannot be considered by the Board.  38 C.F.R. §§ 20.300, 20.301, 20.801.  

The Board notes that, in the October 2025 VA Form 10182, the Veteran purportedly identified two rating decisions on appeal, dated December 2015 and November 2017, and listed disagreement with the denial of service connection for schizophrenia in both decisions.  The VA Form 10182 is untimely as to both decisions; thus, the Board is construing the October 2025 VA Form 10182 as an appeal of the March 2025 and April 2025 rating decisions as they are the most recent merits decisions that are timely to the VA Form 10182 and allow the Board to consider the most developed record.  See Terry v. McDonough, 37 Vet. App. 1 (2023).  

If the appellant would like VA to consider any evidence that was submitted that the Board could not consider, the Veteran may file a Supplemental Claim (VA Form 20-0995) and submit or identify this evidence.  38 C.F.R. § 3.2501.  If the evidence is new and relevant, VA will issue another decision on the claim, considering the new evidence in addition to the evidence previously considered.  Id.  Specific instructions for filing a Supplemental Claim are included with this decision. 

Service Connection Legal Authority

Service connection can be granted for a disability resulting from a disease or injury incurred in or aggravated by active service.  38 U.S.C. §§ 1110, 1131; 38 C.F.R. § 3.303(a).  Service connection may be granted for any disease diagnosed after discharge when all the evidence, including that pertinent to service, establishes that the disease was incurred in service.  38 C.F.R. § 3.303(d).  Service connection generally requires competent evidence of: (1) a current disability, (2) an in-service incurrence or aggravation of a disease or injury, and (3) a nexus between the claimed in-service disease or injury and the current disability.

As noted above, the appellant served on periods of ACDUTRA and INACDUTRA.  Active military, naval, or air service includes any period of ACDUTRA during which the individual concerned was disabled or died from a disease or injury incurred in or aggravated in the line of duty, or any period of INACDUTRA during which the individual concerned was disabled
 disease was incurred in service.  38 C.F.R. § 3.303(d).  Service connection generally requires competent evidence of: (1) a current disability, (2) an in-service incurrence or aggravation of a disease or injury, and (3) a nexus between the claimed in-service disease or injury and the current disability.

As noted above, the appellant served on periods of ACDUTRA and INACDUTRA.  Active military, naval, or air service includes any period of ACDUTRA during which the individual concerned was disabled or died from a disease or injury incurred in or aggravated in the line of duty, or any period of INACDUTRA during which the individual concerned was disabled or died from injury incurred in or aggravated in the line of duty.  38 U.S.C. § 101(21), (24); 38 C.F.R. § 3.6(a), (d); Biggins v. Derwinski, 1 Vet. App. 474, 477-78 (1991).  ACDUTRA is, generally, full-time duty in the Armed Forces performed by reserves for training purposes.  38 C.F.R. § 3.6(c)(1).  Accordingly, service connection may be granted for disability resulting from disease or injury incurred in, or aggravated, while performing ACDUTRA, or from injury incurred or aggravated while performing INACDUTRA.

When all the evidence is assembled, VA is responsible for determining whether the evidence supports the claim or is in relative equipoise, with the veteran prevailing in either event, or whether the persuasive weight of the evidence is against a claim, in which case, the claim is denied.  See 38 U.S.C. § 5107; 38 C.F.R. § 3.102; see also Lynch v. McDonough, 21 F.4th 776, 781-82 (Fed. Cir. 2021) (en banc) (only when the evidence persuasively favors one side or another is the benefit of the doubt doctrine not for application).

1.  Service connection for PTSD is denied.

The appellant appeals for service connection for what she believes is PTSD, contending that symptoms of schizophrenia, anxiety, stress, and depression she experienced during basic training and reserve weekends caused her to develop PTSD.  

After a review of all the lay and medical evidence of record, the Board finds that the persuasive weight of the evidence is against finding a current diagnosis of PTSD.  PTSD has specific criteria that must be met to grant service connection.  See 38 C.F.R. § 3.304(f).  Service connection for PTSD requires medical evidence diagnosing the condition in accordance with § 4.125(a) of Chapter 38 of the Code of Federal Regulations, a link, established by medical evidence, between current symptoms and an in-service stressor, and credible supporting evidence that the claimed in-service stressor occurred.  38 C.F.R. § 3.304(f).

After review of the record, interview, and an examination, the March 2025 VA examiner opined that the symptoms did not meet the diagnostic criteria for PTSD under DSM-5 criteria and, alternatively, diagnosed schizoaffective disorder.  The March 2025 VA examiner has medical expertise and training in the area of mental disabilities, had adequate facts and data on which to base the medical opinion, and provided sound rationale for the medical opinion.  For these reasons, the Board finds that the March 2025 VA medical determination that there is no current PTSD diagnosis is of probative value.  

The appellant, as a lay person, is competent to report many psychiatric symptoms she experiences at any given time; however, she is not competent to diagnose a psychiatric disability because making a psychiatric diagnosis requires medical expertise in the area of psychiatric disorders and falls outside the realm of common knowledge of a lay person.  See Young v. McDonald, 766 F.3d 1348, 1353 (Fed. Cir. 2014) (holding that "PTSD is not the type of medical condition that lay evidence... is competent and sufficient to identify"). 

The DSM-5 cautions that it was "not sufficient to simply check off the symptoms in the diagnostic criteria to make a mental disorder diagnosis."  Rather, clinical training is required "to recognize when the combination of predisposing, precipitating, perpetuating, and protective factors has resulted in a psychopathological condition in which physical signs and symptoms exceed normal ranges."  The "purpose of DSM-5 is to assist trained clinicians in the diagnosis" of various mental disorders.  Consequently, the appellant's purported lay opinion attributing the current psychiatric symptoms to a diagnosis of PTSD  is of no probative value.

Thus, the persuasive weight of the evidence is against finding
 type of medical condition that lay evidence... is competent and sufficient to identify"). 

The DSM-5 cautions that it was "not sufficient to simply check off the symptoms in the diagnostic criteria to make a mental disorder diagnosis."  Rather, clinical training is required "to recognize when the combination of predisposing, precipitating, perpetuating, and protective factors has resulted in a psychopathological condition in which physical signs and symptoms exceed normal ranges."  The "purpose of DSM-5 is to assist trained clinicians in the diagnosis" of various mental disorders.  Consequently, the appellant's purported lay opinion attributing the current psychiatric symptoms to a diagnosis of PTSD  is of no probative value.

Thus, the persuasive weight of the evidence is against finding that there is a current PTSD diagnosis.  The only current psychiatric diagnosis is schizoaffective disorder, which the Board will address in this decision.  Consequently, the Board finds that the appeal for service connection for PTSD must be denied.  See 38 U.S.C. § 5107; 38 C.F.R. § 3.102.

2.  Service connection for schizoaffective disorder (claimed as schizophrenia) is denied.

The appellant also appeals for service connection for schizophrenia, contending that she felt a "wave of bad energy" during a training exercise on a drill weekend and started feeling symptoms of schizophrenia.  See January 2025 Veteran's Lay Statement.  She further stated generally that physical pain, headaches, hardships, anxiety, memory loss, and depression caused the schizophrenia.  Id.  The Board notes that the evidence reflects a current diagnosis of schizoaffective disorder.  See March 2025 VA Examination   

After a review of all the lay and medical evidence, the Board finds that the persuasive weight of the evidence is against a finding of an in-service psychological injury or disease during ACDUTRA, and against a finding of an in-service injury during a period of INACDUTRA.  One of the benefits administered by VA that is reserved specifically for veterans is disability compensation.   Accordingly, in order to establish entitlement to disability compensation benefits, the appellant must first establish "veteran" status.  See Dingess v. Nicholson, 19 Vet. App. 473, 484 (2006) (status as a "veteran" is one of the five elements of a claim for service-connection benefits).  The DD Form 214 reflects that the appellant only had periods of ACDUTRA and INACDUTRA.  See DD Form 214 (entry 28, narrative reason for separation, "release from active duty training").  

While service on active duty alone is sufficient to meet the statutory definition of a veteran, service on ACDUTRA (or INACDUTRA), without more, will not suffice to give one "veteran" status.  Donnellan v. Shinseki, 24 Vet. App. 167, 172 (2020). Notably, active duty is defined as full-time duty in the Armed Forces, other than ACDUTRA, or service as a cadet or midshipman at a Military Academy.  See 38 U.S.C. § 101(21); 38 C.F.R. § 3.6(b).  Thus, ACDUTRA is a distinct type of service from active duty service.  38 C.F.R. § 3.6(c)(1). 

No presumptions attach (including soundness, aggravation, or presumptive diseases under service connection) unless "veteran" status is attained.  Where, as here, the appellant did not serve for any period of time on active duty, service connection must be established for a disability on a direct basis first, without the aid of presumptions, in order to achieve "veteran" status and be entitled to compensation.  Paulson v. Brown, 7 Vet. App. 466, 470 (1995).

Generally, for disability resulting from personal injury suffered or disease contracted in the line of duty, in the active military, naval, or air service, compensation will be paid to any "veteran" discharged or released under conditions other than dishonorable from the period of service in which such injury or disease was incurred, or preexisting injury or disease was aggravated.  38 U.S.C. §§ 1110, 1131.  

Active military, naval, or air service is defined as (1) active duty; (2) any period of ACDUTRA during which the individual concerned was disabled or died from a disease or injury incurred or aggravated in the line of duty; (3) any period of INACDUTRA in which the individual concerned was disabled or died from an injury incurred or aggravated in line of duty, or from an acute myocardial inf
, compensation will be paid to any "veteran" discharged or released under conditions other than dishonorable from the period of service in which such injury or disease was incurred, or preexisting injury or disease was aggravated.  38 U.S.C. §§ 1110, 1131.  

Active military, naval, or air service is defined as (1) active duty; (2) any period of ACDUTRA during which the individual concerned was disabled or died from a disease or injury incurred or aggravated in the line of duty; (3) any period of INACDUTRA in which the individual concerned was disabled or died from an injury incurred or aggravated in line of duty, or from an acute myocardial infarction, a cardiac arrest, or a cerebrovascular accident occurring during such training.  See 38 U.S.C. § 101(24); 38 C.F.R. § 3.6(a).  This means, as pertinent to the facts of this case, service connection may be granted for disability resulting from disease or injury incurred in, or aggravated, while performing ACDUTRA.  Service connection for INACDUTRA is permitted only for injuries, not diseases, incurred or aggravated in the line of duty.  See Brooks v. Brown, 5 Vet. App. 484, 485 (1993).  

Service treatment records reflect that during a drill weekend in September 2014, which is a period of INACDUTRA, fellow reserves members noticed the appellant's strange behavior and she was sent to the emergency department.  At the emergency room, the appellant reported paranoia about bombs being in cellphones and about her food being poisoned.  The appellant's sergeant reported that the appellant had become more socially withdrawn in the prior six months and left Army camp to live in a shelter.  The appellant was admitted to a hospital for treatment.  She later reported hospitalizations for schizophrenia again in 2015 and 2016.  The service treatment records note that the appellant reported behavioral health history dating back to childhood, to include anorexia and panic disorder.  A permanent profile was eventually generated.        

The persuasive weight of the evidence is against a finding of an in-service psychological injury or disease during ACDUTRA.  The service treatment and personnel records do not show treatment or documentation of any psychological injury, disease, or even symptoms during any period of ACDUTRA.  An April 2014 periodic health assessment, which is after any period of ACDUTRA, reflects the appellant denied any mental health concerns; thus, the Board places greater reliability on the account given closest to time of service than to the appellant's more recent claim that her mental health was affected by rigorous training, weapons training, or the treatment by her peers during basic training.  

The appellant's more recent statements made while pursuing the claim for compensation are inconsistent with service personnel records and service treatment record evidence, and are also inconsistent with other evidence, so are not credible.  As a result, because the Veteran did not become disabled due to an injury or disease incurred in line of duty during a period of ACDUTRA, "veteran" status does not attach, and service connection for schizoaffective disorder, or for aggravation of schizoaffective disorder, is not warranted.  As such, there is no in-service injury or disease to which the later diagnosed schizoaffective disorder could be directly related; therefore, direct service connection during a period of ACDUTRA must be denied.  

The evidence of record reflects that the mental health issues were first noticed during a drill weekend in September 2014, which is a period of INACDUTRA; thus, during this period, only an "injury" incurred in the line of duty may be service connected.  See Brooks v. Brown, 5 Vet. App. at 485.  Because schizophrenia or schizoaffective disorder is a "disease" and not an "injury," service connection cannot be granted for the schizophrenia or schizoaffective disorder that was identified or diagnosed during a period of INACDUTRA.  See 38 C.F.R. § 3.309(a) (schizophrenia disorder is a considered a "psychosis" recognized as a "chronic disease").  VA's General Counsel has interpreted that it was the intention of Congress when it defined active service in 38 U.S.C. § 101(24) to exclude INACDUTRA during which a member was disabled or died due to nontraumatic incurrence or aggravation of a disease process.  See VAOPGCPREC 86-90.  

Moreover, as the evidence shows a six month history of developing symptoms before the INACDUTRA period when the appellant's behavior resulted in concern and hospitalization, the evidence does
UTRA.  See 38 C.F.R. § 3.309(a) (schizophrenia disorder is a considered a "psychosis" recognized as a "chronic disease").  VA's General Counsel has interpreted that it was the intention of Congress when it defined active service in 38 U.S.C. § 101(24) to exclude INACDUTRA during which a member was disabled or died due to nontraumatic incurrence or aggravation of a disease process.  See VAOPGCPREC 86-90.  

Moreover, as the evidence shows a six month history of developing symptoms before the INACDUTRA period when the appellant's behavior resulted in concern and hospitalization, the evidence does not show a schizophrenic break during INACDUTRA or ACDUTRA period. As a result, the criteria for service connection for schizoaffective disorder, claimed as schizophrenia, have not been met; therefore, the appeal must be denied.

 

 

J. PARKER

Veterans Law Judge

Board of Veterans' Appeals

Attorney for the Board	Prairie, N. R.

The Board's decision in this case is binding only with respect to the instant matter decided. This decision is not precedential and does not establish VA policies or interpretations of general applicability. 38 C.F.R. § 20.1303.