FARLEY, Associate Judge: The issue before the Court is whether the Department of Veterans Affairs (VA) was required by the Administrative Procedure Act (APA) and its own policies and regulations to give notice of and an opportunity to comment on the deletion of paragraph 50.13(b) of its Adjudication Procedure Manual, M21-1. The Court concludes that paragraph 50.13(b) was substantive in nature and affected the rights of the app…
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