KAREN LeCRAFT HENDERSON, Circuit Judge, concurring. I write separately because I believe that the United States Department of Health and Human Services (HHS) violated the Administrative 'Procedure Act, 5 U.S.C. § 706 (2)(A), in two ways rather than one: in denying the physicians medical malpractice liability coverage under the Federal Tort Claims Act (FTCA), <span class…
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