Comment on DOD-2008-OS-0124-0001

In response to the rule implementing the Sexual Assault Prevention and Response (SAPR) Program : I am grateful for the opportunity to comment on the rule implementing SAPR that became effective on January 27, 2012 and I thank you in advance for taking the time to read my submission. I am currently a registered nurse and a student at the University of Minnesota in the family nurse practitioner program. While I am pleased with the rule overall, I have a number of suggestions that I believe would strengthen it. I am more than pleased with the rule’s general language, specifically sections 103.2 (Applicability) and 103.3 (Definitions). The inclusion of National Guard and Reserve members who are sexually assaulted during active service, as well as inactive duty training is crucial. In addition, establishing the applicability of military dependents, DoD civilian employees, DoD contractor personnel, and service members who are on active duty but were victims of sexual assault prior to enlistment helps to maintain the DoD’s policy of victim support. With regard to the Definitions section, the rule is clear and thorough in its definitions of consent and personal identifiable information. It is critical that a person who is a victim of sexual assault be assured that identifying information, which includes name, physical characteristics, position, rank, organization, or “other information” that could be used to identify the person will be protected. The use of threats and intimidation or abuse of authority are known to be ways in which a sexual assault has been perpetrated, and I applaud the inclusion of this in the definition of sexual assault. Section 103.4 on Policy is also commendable in that it makes clear the DoD’s policy to treat a victim of sexual assault as a priority and consider the case an emergency. Specifically, this section describes that medical intervention is necessary to prevent: loss of life, sexually transmitted infections, pregnancy, and psycho