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How is the AMA Actually Working?

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Maura Black: Hi, everyone. Thank you so much for joining us today for our CCK live discussion. My name is Maura Black, I am joined today by Christine Clemens and Courtney Ross, we are all attorneys at CCK. Today, we are going to be speaking about an AMA update and what is actually going on with the AMA at VA. The AMA, for those of you who may not know, refers to the Appeals Modernization Act. And this is an act that is extremely prevalent nowadays in the practice of VA law because it corresponds to a complete change in VA’s appeal system that went into effect in February of 2019. So, since February of 2019, any new claims that have been filed or decided since February 2019, have been in the new system. So, from the practitioner’s perspective, we have been learning a lot about how this new system works as we actively represent veterans and their dependents in cases that are in the AMA posture.

We also have experience dealing with cases in the old reform or the pre-reform appeal system would which we will call the legacy system, and the new appeal system and sort of how the two are going on at the same time, in some cases, how some clients find themselves sort of in both places at once. So, it has posed a lot of interesting challenges. And in addition, it is given us a nice opportunity to gather data about how the AMA is really working and affecting veterans who are pursuing claims and appeals at this time.

So that’s sort of the overview and our perspective. We are now over two years into the AMA. And I think we have learned a lot about it as time has gone on. So, we wanted to give you all an update today regarding the issues that we have been seeing and sharing the information that we have been collecting. I want to start with you first, Courtney, one of the things that we are going to spend a good amount of time talking about today is actually backlogs and delays, which is almost always a part of the discussion when it comes to the practice of VA law. But with AMA, in particular, we have been seeing some unique delay and backlog concerns. So, can you start us off by talking about a couple of those examples? And I will probably ask the same question of you, Christine, in a few minutes, because there is definitely a lot to dig into.

Courtney Ross: Yeah, absolutely. So, I think VA’s intention with passing AMA and implementing AMA was to address a lot of the backlog that existed in the old system are the legacy system. And their intention was certainly to create a more efficient system. But I think what we have seen in practice over the last two years is that’s not exactly how things are working out, at least not just yet. And the new system and as you mentioned more under AMA, VA does have these pockets of backlog, backlogs with claims and appeals that are starting to grow. And I think some of the factors that are involved in creating the backlog are related to the pandemic that we’ve all been living through this last year, where VA has had to put a pause on a number of their own processes because of the pandemic. And I think other I think just AMA itself and the kind of the all of both VA and practitioners navigating AMA and this new system, I think has contributed to the backlog as well. It is in practice; I think a lot more confusing than maybe VA anticipated. There are multiple review options, every time you receive a decision, there is a lot of room for human error, especially if you are not well trained on AMA or do not really understand some of the nuances of it just yet. And I think we have also seen varying standards and requirements when VA is adjudicating AMA appeals or claims. And I think this has contributed to some of the backlog issues we have seen as well. So, there’s inconsistency, I think, with processing centers and regional offices and how they are handling claims or appeals that they received. So, some are rows are really quick in terms of issuing decisions in AMA and others are very slow.

The other thing to think about here, too, is that there is still a lot of legacy appeals pending, as you mentioned, Maura. More so at the board of veterans appeals, the board’s trying to focus and prioritize on excuse me handling those legacy appeals. And that is resulting a lot of remands from the board that are still in legacy, which requires the arrows to still handle development that the board’s requiring of them when the appeal is remanded. And so, the VA is trying to still handle legacy appeals while handling and navigating through AMA. And I think all of that has contributed to the inconsistencies that we are seeing in terms of the appeals being dedicated and why we are starting to see these pockets of backlogs start to build up in this AMA world that we are still transitioning into

Maura: And it has definitely been difficult to track trends. I think because of what you mentioned, Courtney is really important. And we’ve all noticed this to be the case. The inconsistency has been a real hurdle for clients and veterans who are pursuing claims and appeals to understand what is really going on with the system because we do have some regional offices that we are noticing that are really on top of things, even pandemic related things did not seem to faze them a whole lot. And then there are others that are definitely behind. So, it is tricky. And then the processing centers thrown in that are handling a whole number of things. We know the national work queue sort of gets involved and picks up on things in a way that is difficult to track. So, it has definitely been challenging, not just from an AMA perspective, but from a pandemic perspective, too. And one of the things that has been particularly problematic, at least in my experience, and Christine, you can weigh in more on this is really the development side of things. So as Courtney mentioned, a lot of cases are pending at the regional office, and even cases that are remanded by the board of veteran’s appeals are remanded for development for the regional office to conduct and the development backlogs are a really significant concern. So, Christine, can you talk to us about what kinds of issues you have been seeing in terms of RO delays for development-type tasks?

Christine Clemens: Absolutely. So, veterans filing claims often, what they need to do is substantiate their claim, and VA will help them do that. But in looking at AMA, it is hard to look at it in a vacuum. The pandemic has certainly, as you mentioned, you have mentioned, contributed to delays in VA being able to obtain records for veterans, the National Personnel Records Center, in particular, has had some extreme delays where they were shut down. My understanding is they were shut down for a while. They are now back up and running and have been for some time, but they are only at approximately a 10% capacity. Now, I do notice has gotten some attention from Congress, and they should soon be up to a 25% capacity. But what this means is that any veteran who is filing a claim who needs to have service records to substantiate their claim, whether it is their 201 files, or their service treatment records, is having to wait to even get those kinds of essential records.

So that is certainly hindering filing of initial claims, appeals, and development needed to adjudicate those claims. I mentioned the limited number of people who are there actually physically in the center, they have prioritized requests. So, for example, requests for burials are being prioritized above VA claims adjudication. But currently, as many as 487,000 records requests remain unfilled. So right now, we will see if that 25% capacity makes a big difference. But really, while we are in the thick of things with this pandemic, I think there’s light at the end of the tunnel. But it may not come soon enough for a number of veterans. I think the other thing that is waiting that veterans are waiting on further development are examination’s view will schedule these Compensation and Pension examinations. And they have moved away from having their own providers at the VA medical centers providing these examinations I know we have had; we have a number of CCK lives that address the topic of examinations and the current status on exams. So those resources are out there for anyone who is interested in getting more specifics.

But initially, what happened is that in-person exams were delayed due to COVID. VA still trying to play catch up. They have a number of contract providers who they have begun to utilize and expanded, utilizing these providers, but they are still trying to get people and some examinations have been completed via telehealth, but not all examinations can be completed via telehealth there are some that need to be completed in person. VA has also conducted some Ace examinations, which is essentially records review exam. But the number of people who are waiting for these exams versus the capacity to perform those examinations has not really lined up. So that is another reason that people have been waiting and are sort of stuck in this what we call development backlog. And frankly, VA has a duty to assist veterans and part of that duty. And in a lot of cases is obtaining these examinations for veterans to see if they can grant service connection based on what a veteran’s disability is. And they need a medical provider to identify that whether the condition is related to service. And that is something that usually they need a medical provider to weigh in on. And the VA cannot make decisions on these cases until they have completed this development. So, some of these cases are just in a holding pattern until VA is able to complete that development. We have also seen a claims backlog. So, this has increased over 100,000 claims since COVID. began. Now, that means that we are at over 200,000 claims that are pending, VA is working, they have been working this whole time to adjudicate claims. But for the reasons I have just discussed, I think we are just seeing, it has just taken longer for them to do that processing.

And then the other thing that you mentioned, is there are a high number of remains from the legacy system, the previous appeal system that are still being worked on. And a number of those remains require the same kind of development that the claims that I previously mentioned, are waiting on. So those examinations, they are waiting on records, either from National Personnel Records Center or the JSRRC, which is the army and Joint Services Records Research Center. They are having similar delay issues and personnel staffing issues during the pandemic. So, unfortunately, these cases are just waiting. Like I said, as part of this duty to assist.

Maura: We have more information to come in a few minutes about how AMA is actually substantively functioning. And that was a lot of a pretty long list of sorts of doom and gloom, lots and lots of backlogs, which I think we know from our experience, and from what we have heard from others that are living this, but it has been very, very difficult for people who are waiting on the adjudication of their claims and appeals to sort of really come to grips with the delay right now. It is definitely a tough time for sure. But as Christina and Courtney had mentioned, we have definitely been keeping in tune to the extent that we can with how things are going to be sort of progressing now that people are slowly trickling back to work, at least in some fashion, at VA at the records, research centers and things like that. I do have one backlog area that I want to touch on before I turn it over to Courtney to sort of move into the how is AMA functioning as a system, sort of what are the more substantive legal procedural issues that we have been seeing, which is definitely good stuff. But we did not want to give everyone information about these backlogs, because it is relevant to how AMA is being rolled out and the experience of people who have pending claims and appeals. So, the last backlog item, my guess, although I am sure that we have a couple more hidden at the end is related to the Board of veterans appeals male backlog. And this is an interesting one that actually has had pretty significant effects, at least on our practice. And I know among people who are waiting on decisions from the board, the board is experiencing what I understand to be more than a one-month mail backlog, I want to say it is closer to the two- or three-month mark. And so, this is a delay that is affecting the board’s ability to intake and process mail that it receives.

So, this affects a number of things that affects your submission of evidence and arguments in support of an appeal at the board. It is taking longer for the board to receive those materials. And we have seen instances where the board will issue a decision. And then a few weeks later receive the mail that was sent prior to the date of the decision. But the problem is that the decision does not contemplate the submission of evidence and argument that was made because it has been sitting sort of in this male backlog that takes some time to go through. So that has been a basis for needing to appeal or move to vacate board decisions if they are not predicated on all of the records and evidence favorable to the veteran’s position that we have had to deal with and it has been definitely frustrating I think for veterans who are reading a board decision and are realizing that the board decision was not predicated on everything that they submitted. So that is something to be aware of. And another area where the board mail delay affects pending appeals is when veterans elect to opt a legacy case into one of the board review lanes. So, we have materials on this on our website and previous videos, if you want to read up on some of the more specifics about the lane choices and the dockets at the board, you can find our materials at CCK dash law.com. But essentially, if a veteran receives a statement of the case or supplemental statement of the case, in the old legacy appeal system, they have the ability to opt that issue into the AMA. And one of their choices can include the board review lanes or the board review dockets. And what is happening is that it is taking the board so long to recognize the opt-in sort of that the regional office and the board are suffering from communication issues, lines are getting crossed. And the entity that should not have jurisdiction is working on the issue. Whereas the board who should have jurisdiction is not even aware that it has jurisdiction because they are not aware of the mail that has been sitting there. So that is proven to be pretty difficult. It definitely creates extra layers of work for people who are pressing appeals.

So, we wanted to make you all aware that if you are noticing some sort of issue if your E-benefits is not being updated in a timely fashion to reflect the submission of a board appeal, it is likely that that is because the appeal is still sitting in the mail. No word on when this will resolve. But I think we have heard in recent weeks, that the board is working on editing, modifying improving their mail intake procedure. So, if we have any significant updates on that, we will definitely share them with you all. But as promised, we are going to move into more of the meat and potatoes stuff. So, Courtney, can you start us off by telling us a little bit about your experience with sort of how AMA is substantively being handled by the regional offices and any areas for concern or issues that we’ve kind of had to push up against in our practice?

Courtney:Yeah, absolutely. So, to echo what I said before, despite these in tension with the new system, as far as simplifying the process, and helping to alleviate some of the problems in the previous system, AMA, I think in practice has turned out to be a much more complicated system than anyone really actually realized. And I want to talk about confusion about VA forms because I think that this helps to illustrate some of the challenges that we have seen on a frequent and regular basis in AMA cases. So, VA requires very specific forms for anything that a veteran is trying to accomplish in their case. And there are specific forms for appeals that are still pending in legacy. And there are different sets of forms for appeals that are pending an AMA. There are also different sets of forms for if you are filing a claim it whether you are filing a claim for a condition that you have previously claimed it has been denied, or whether you are filing a claim for an issue, where this is the first time that you are doing so. And what I mean by that is I will use an example I think to help illustrate it. VA requires VA for five to six, for cases where a veteran filing a claim for a condition where they have never filed for it before. So, let us say service connection for PTSD. First time the veterans filing for service connection for PTSD never been previously filed. VA Form 526 is the correct form to use. It is also the correct form to use if a veteran is already service-connected for PTSD, and wants to file for an increased rating.

Again, VA Form 526 is the form that our understanding is the correct form to use. Separately, a veteran is required to file a supplemental claim form if they are filing for a condition that they previously filed for. It was denied by VA. It was never appealed, the claim stream died. And so essentially, they are trying to reopen that claim with new and relevant evidence. Now, there is a separate claim form the supplemental claim form that is required for that. So, what we have seen in practice day-to-day is that there is a lot of again inconsistencies across the rows and the processing centers. As far as understanding which forms are correct for these different scenarios. We have seen a lot of cases where the five to six is correctly submitted, and VA rejects it saying that it is actually a supplemental claim that is needed. I want to highlight again that oftentimes incorrect. We have also seen it the opposite where a supplemental claim is submitted in VA says that the incorrect form it is a five to six that is needed. And I will give an example again, I think to highlight this, a case where a veteran filed a claim for sleep apnea service connection for See Batman had never filed for sleep apnea before, was claiming it as secondary to his already service-connected PTSD.

So again, the issue, the condition that he was actually seeking service connection for with sleep apnea has never claimed it. The theory with which he thought service connection was warranted was developed secondary with PTSD. So, the five to six is the correct form to use here because that AR has never filed for service connection for sleep apnea before. It was submitted to VA, VA rejects it just because it was picked up on that PTSD was included on the face on the secondary theory, and said that because PTSD had previously been claimed, it was actually the supplemental claim form that is needed and that is incorrect. But the point in talking about the confusion with the claims, and using examples to highlight that is that, in practice, this is happening so frequently, that it is essentially creating this entirely new layer of appeals or back and forth with VA, to get these things corrected. So, it is creating additional layer of work for practitioners, and also for veterans who may not be represented and are trying to navigate this new system. It is not only decisions that they might receive now, but it is these letters rejecting claims or appeals erroneously. And so, it really complicates the procedural process overall. And it is not happening frequently, I think that is important to stay as well.

The other complicating factor in the AMA, as far as forms is that a notice of disagreement is one thing in legacy in the old system, and a notice of disagreement form is one thing in the old legacy system. The term notice of disagreement in a notice of disagreement form is also used in AMA and the new system, but they are different forms. And so, what we have seen is some confusion among veterans where they submit a notice of disagreement, but it is the wrong notice of disagreement form. And so, in VA has refused to accept, let us say, in an AMA appeal, the veteran accidentally submits the legacy NOD. VA refuses to accept that NOD and now the veteran has to figure out how to navigate overcoming that and whether they can submit a corrected form. And so, it is caused a lot of confusion. And like I said, this additional layer of needing to figure out how to respond and navigate these new procedural challenges. The other thing that we have seen really frequently, in this new world, too, I mentioned before that a supplemental claim, can be used, or a supplemental claim form is required by VA to reopen a claim with new and relevant evidence outside the one-year appeal period in AMA, so in that way, you are thinking about it as a claim that you are filing to basically start the claim stream from over.

The supplemental claim is also used as an appeal in AMA, and what makes it extra confusing is that it is the same exact form that is used, whether you are filing it within a year of a rating decision, so that you are continuing the claim stream. And it is meant as an appeal of that decision, or you are filing it outside of a year rating decision. And it is meant to reopen a previously denied claim. So, what we have seen a lot in cases, as a result of that is, when VA does grant, the issue in the supplemental claim lane, is very frequently only granted back to the date of the supplemental claim form, because VA is just taking it as a new supplemental claim, rather than viewing it as an appeal, a timely appeal of a decision. And so, this is also creating another extra layer fairly consistently in cases because you are now almost, I do not want to say in almost every case, but in a large percentage of cases, going to have to appeal the effective date, there’s kind of an expectation that VA is going to get it wrong if it is granted from the supplemental claim appeal. And so again, this is just creating an additional expectation of having to planning to have to file the student additional appeal is adding essentially to the wait time for veterans to end up with the resolution of a grant of service connection with the correct effective date. And so, again, it is I think, VA and practitioners and veterans are all trying to figure out how to navigate this new system. And it is important to be aware of these procedural challenges and to anticipate them so that you can plan how to respond accordingly as they come up.

Maura: I completely agree that the unfortunate reality is that a lot of issues that in legacy were not issues because the system was it was not working. For VA, which is why it was revised, and it did remove a lot of unnecessary steps in the appeals process. But the flip side that we have seen is that it, it does not take just one appeal to get everything that you are seeking. Sometimes it takes two. And sometimes it takes even more than that. And that is incredibly frustrating, I am sure for people who are going through the system. Courtney and I were just reviewing the case today. I do not know if you have had a chance to look at it yet, Courtney. But I just sent you a case today where that exact issue with the supplemental claim and date of claim question came up, and the veteran was initially granted a rating but only as of the date of the supplemental claim. Our office submitted an argument explaining why the supplemental claim appeal was an appeal that kept the initial claim and appellate status. And so, the date of the supplemental claim was not the date of claim, we laid that out in an argument, we outlined the procedural history, we appeal the case to the board. And we just got a board decision saying that the supplemental claim is the date of claim, which is wrong. And we have argued an outline why that is not the case.

And I can only imagine that it is really frustrating for people to be on the receiving end of those decisions, who are not really understanding how to put forth the argument to VA about how their own system is supposed to work. So definitely, to Courtney’s point, these things, unfortunately, do need to be anticipated, we do have to hurdle, these problems, more often than not, I agree probably in a lot of cases, maybe a majority of cases, in terms of a small issue here and there coming up the big another substantive area that is proven to be tricky, challenging, and at the very least a learning opportunity for all of us. Christine has been the legacy AMA intersection. And sort of what happens in this new system, where cases are still being worked in the old system, and how that plays out, and what choices veterans have. So, can you talk to us about some of the opt-in issues that we have been seeing and how those have played out?

Christine: Certainly, so I think one thing that is important for everyone to keep in mind, we have been really focusing on AMA, but the AMA and legacy systems are operating simultaneously, depending on when a veteran filed a claim when a veteran filed an appeal. And they could be in both systems at the same time on different claims. And so that can be really confusing. They cannot be in two systems at the same time on the same plane.

But as you mentioned, there are sometimes communication issues between the board of veterans appeals and the regional offices. And sometimes these cases have been going on for so long, that veterans themselves are not really sure which system they are in. So that creates sort of another layer here. Veterans at certain points in the legacy system are allowed to opt into this new system into the AMA. And you mentioned earlier, some of the mailing issues that are that we are seeing at the board of veterans appeals, where somebody is trying to opt-in from the legacy system into the AMA, and the board’s maybe not getting that notice in time, maybe they are not uploading evidence timely. The form that you file to opt-in from after a statement of the case or a supplemental statement of the case, which is legacy documents. Depends, you are not sending it to one set place anymore. Where you send it depends on what you are electing to do. If you want the regional office to consider your appeal, then you are going to select from the supplemental claim option or the higher-level review option. And those get filed with the regional offices through the evidence intake center. But if you want the board to hear the appeal in the new system that gets filed directly with the board, and it is really just a checkbox that a veteran selects on a form within a new system form. So those can be missed. But if a veteran wants to be in the new system, and they are eligible to be in it, they can make sure that that they get into it. So even if let us say the board issues a decision in the legacy system, but the veteran correctly opted into the new system.

The veteran can push to have their case heard in the new system in the lane or option they selected. So that is something that is important to know. One of the things that we do here that I think is really helpful within the new system and kind of keeping track of where are in the legacy system and in the new system is, we have access to our clients’ files through VA systems. And it is particularly useful to see when VA receives claims when VA receives appeals. And whether they are classifying it appropriately. If they are not, we reach out to the regional offices or to the board, depending on where the case is trying to get those issues resolved before a decision or incorrect decision gets made. So that is one of the benefits to certainly to working with somebody who is accredited, who has access to VA systems on the cases. And I think that is one of the things that keeps coming up in our discussion today. And certainly, any discussions I have ever had about ama is this system was designed was meant was intended to be a simpler system for veterans. And we are just finding in practice that it is not, there are more choices. But when a veteran can choose to opt into a certain lane and what they can submit, and the timing of when they can submit it is all very particular is different within this new system than it was in the old system. And so, I think it is really important that especially within the new system, that the veterans have competent, accredited representatives, either an accredited attorney accredited agent, or they are working with a veteran service organization because they are trained to assist veterans through this process. And I think it is a very difficult system for people to go through on their own. So, I think that is really one of the things that has been really critical, I think for our clients is us being able to figure out where things are, what they are going and knowing and explaining that some of this there is a learning curve with certainly with VA duplicators. And, and I think that we are probably going to be experiencing that for quite some time.

Maura: I want to end by going through if either of you have any practical tips for people who find themselves maybe stumped or confused by some ama issues, Christine mentioned the importance of working with a representative. And I would have to imagine that that is beneficial across the board, just because we see new things virtually every day that we have not seen before, that are sort of a byproduct of ama confusion, often confusion from legacy, the posture of different claims, and the two different systems that some sometimes causes issues. So, do either of you have any thoughts, kind of closing thoughts about what people can do to put themselves in a better position or things that you have noticed, sort of traps that you have noticed and been able to successfully navigate before?

Courtney:I have a couple of thoughts. One, I think for veterans who are trying to navigate the AMA system, keep in mind that the rules for submission of evidence, and the timing of appeals is very different than it was in the legacy system. And it is also varies depending on which review option you select. And so, I think it is really critically, especially if you are not represented by if you do not have representation, to really make sure you understand which review option you are selecting, and what the rules of evidence submission are in that lane. Because you want to make sure if you are submitting anything, as far as evidence or development to VA, the VA has to consider it. And they might not have to depending on when you submit it. So, I think that is really important. I know we have resources about those specific rules on our website. And we have done many videos about it on so you can find those on our YouTube channel as well. But I think that is really important. I think the other thing that is just to kind of echo what I said earlier is to anticipate some of these problems and challenges that you are going to face. And kind of just prepare. And by that, I mean, this will not always work based on the case example more engaged, but to the extent that you can kind of lay it out to VA in advance. So, we will use the supplemental claim effective date issue that we talked about, as an example. Knowing that that is it, there is a high likelihood that they are going to grant the wrong effective date, to the extent that you can lay it out in an argument or a cover letter when you are submitting that supplemental claim as to why the effective date should be not the date of this form, but whatever would be appropriate in the case to try to get ahead of it. I think that that that is a good practical tip as well.

Maura: I think one of the messages that I would like people to take away from this today is, it is tough, but do not give up. In this process, you may hear ‘no’, a lot of times before you hear Yes, and it does not mean that yes is not the right answer. And it does not mean that it is not possible, it just might mean that there are some hurdles that you have to jump through. To get to that, yes. So, if you see something in a decision where it says that you submitted evidence, but VA could not accept it, because of the timing of when it was submitted, that does not mean that you give up on submitting that evidence, try to get it into the record. So, I want to make sure that people are not, are not so discouraged from the process. There are a lot of people out there who are competent, and qualified, and accredited by VA, to handle these kinds of cases, who are willing to help you. And so, if you want help, ask for help. There is nothing wrong with doing that. But I think just knowing that it can be a long process, but it can be rewarding at the end. It is something that is another thing that I hope people take away from it does not mean that they are not deserving. And so, I certainly want every veteran and every, every survivor family member to get the benefits there. They have worked for what they have earned and they are entitled to. And I think the one thing that is advantageous about the AMA is that a veteran can keep trying, as long as they do it within the appeal period, they can keep trying, and ultimately preserve their, their effective date, as long as they can show that on the date when they first got benefits, that they were entitled to them. And that is very possible. We see clients getting huge retroactive awards when we are finally able to convince VA, that they should have gotten them all along. So, stick with it, is what I would say.

I completely agree. And I think the only thing that I would add, although it is a little bit redundant, of what you both have already said, is to carefully read the mail that you get from VA. This kind of cuts both ways, because sometimes the mail that we see from VA is totally wrong, especially as it pertains to newer AMA issues. In some of the examples that Courtney gave, VA will invite you to file a certain claim on a certain form, even if they are wrong about the type of form that they need. But that being said, be mindful of the mail that you receive, because appeal rejection letters, claim rejection letters, those can really stick if you are not careful. If VA is asking you for a particular form, and I think they are more form picky than ever before, just because there are so many options now with the forms. And they are kind of limited to working off of the right forms only. It is better to be aware if they think that they need a certain type of form, to be submitted to work your case because you might find that some time is passing and they are not actively doing anything with it. And it might be because they believe they cannot proceed until they have something from you or the correct form. And you will know about that through the mail. And any mail that you do not understand I completely agree with Christine’s point, seek some assistance.

There are people out there who are accredited that have been dealing with these issues that can be helpful. Having a second opinion is really helpful too. Sometimes we bounce ideas off all the time, not just sometimes because the things that we are seeing are really strange and confusing. But we are getting through it. We hope that everything that we discussed today was helpful. I know we brought up some more negative points earlier in the video. But that is all for the purpose of providing some context so that hopefully you can all better anticipate and understand where VA is at.

And as promised, we will bring any new information to you all as we have it, any other further updates about AMA, I am sure that we will be discussing them in the future. So, thank you, Christine and Courtney, for contributing today. And thank you all for joining us and we will see you soon.