Kennedy v. Wilkie, No. 19-0256 (Argued August 18, 2020 Decided December 9, 2020); what constitutes a “rule” under the APA; definition of “VA issue” under § 3.114(a); VA Fast Letter 13-04 does not constitute a “law” or “VA issue approved by the Secretary or by the Secretary’s direction” under 38 C.F.R. § 3.114(a); VA Fast Letter 13-04 does not qualify as a law or VA issue;
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