This is an interesting case. There appears to be conflicting components in 635-200.
Extract of AR 635-200
Para 1-26 – prevents retention beyond ETS for administrative separation without DA approval.
QMP, para 19-2b. stipulates that the QMP is not intended to be a substitute for other warranted separations. “The QMP is not intended as a substitute, and does not relieve commanders of the responsibility, for initiation of separation proceedings under other provisions of this regulation when required or appropriate.”
While para 19-12a. stipulates that once the QMP is approved, the discharge will occur 90 days after pre-separation counseling. “…Such discharge will occur 90 days after the Soldier receives pre-separation counseling as required by law (10 USC 1142), which may be scheduled before a final determination of discharge has been made or as soon as possible after a final determination has been made.”