PER CURIAM:
Federal law provides honorably discharged veterans with certain educational assistance benefits, see 38 U.S.C. § 1661(a) (1982), which must be used within ten years of discharge from the armed services, see 38 U.S.C. § 1662(a)(1). However, an extension of the limitation period is given to any veteran who is unable to use his educational benefits within ten years “because of a physical or mental disability which was not the result of such veteran’s own willful misconduct.” Id. Appellee James P. McKelvey successfully argued before the District Court that the Veterans’ Administration violated § 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794 (1982), in determining that his disability of alcoholism was attributable to his own “willful misconduct” and that he was therefore ineligible for an extension of the limitation period. See McKelvey v. Walters, 596 F.Supp. 1317, 1323-24 (D.D.C.1984). Two issues are presented by the VA’s appeal: Does 38 U.S.C. § 211(a) (1982) deprive us of jurisdiction to review the VA’s decision? If not, has the VA violated the Rehabilitation Act in determining that all alcoholism (except that which is the result of an acquired psychiatric disorder) is caused by “willful misconduct” within the meaning of the exception to the limitation extension?
I
A
The G.I. Bill has for many years granted to each honorably discharged veteran certain educational assistance benefits which must be used in the ten years following the veteran’s last discharge or release from active duty. See 38 U.S.C. §§ 1661(a), 1662(a)(1). In 1977, Congress amended the statute to extend the limitation period for those veterans who were unable to use their educational benefits during that period “because of a physical or mental disability which was not the result of [their] own willful misconduct.” Pub.L.No. 95-202, tit. II, § 203(a)(1), 91 Stat. 1433, 1439 (1977) (codified at 38 U.S.C. § 1662(a)(1) (1982)). The “willful misconduct” qualification was not a new concept; the same limitation was already contained in a number of previously enacted veterans benefit provisions. See [197]*19738 U.S.C. § 105 (definition of injury or disease occurring “in line of duty”); 38 U.S.C. § 310 (disability compensation for injuries suffered or diseases contracted “in line of duty”); 38 U.S.C. § 410 (dependency and indemnity compensation); 38 U.S.C. § 521 (non-service connected disability payments).
The VA regulations and interpretations which the VA applied in the present case are the same as those in effect when the 1977 provision was enacted. The regulations define “willful misconduct” in general as “an act involving conscious wrongdoing or known prohibited action____ It involves deliberate or intentional wrongdoing with knowledge of or wanton and reckless disregard of its probable consequences.” 38 C.F.R. § 3.1(n)(l) (1985). With respect to alcoholism in particular the regulations provide:
(2) Alcoholism. The simple drinking of alcoholic beverage is not of itself willful misconduct. The deliberate drinking of a known poisonous substance or under conditions which would raise a presumption to that effect will be considered willful misconduct. If, in the drinking of a beverage to enjoy its intoxicating effects, intoxication results approximately [sic] and immediately in disability or death, the disability or death will be considered the result of the person’s willful misconduct. Organic diseases and disabilities which are a secondary result of the chronic use of alcohol as a beverage, whether out of compulsion or otherwise, will not be considered of willful misconduct origin.
38 C.F.R. § 3.301(c)(2) (1985). The VA’s longstanding interpretation of these provisions is that the disease of alcoholism is a result of willful misconduct unless it is “secondary to and a manifestation of an acquired psychiatric disorder.” Administrator’s Decision, Veterans’ Administration No. 988, Interpretation of the Term “Willful Misconduct” as Related to the Residuals of Chronic Alcoholism at 1 (Aug. 13, 1964). The type of alcoholism regarded by the VA as not the result of willful misconduct is referred to as “secondary,” while willful alcoholism is labeled “primary.” See id. The VA treats drug addiction substantially the same as alcoholism. See 38 C.F.R. § 3.301(c)(3).
B
McKelvey served on active duty with the United States Army from September 1963 to September 1966. In the nine-year period following his discharge, McKelvey was hospitalized repeatedly for alcoholism and associated problems. He has not had a drink since May 10, 1975.
In November of 1977, more than ten years after his discharge, McKelvey applied for educational assistance benefits, asserting that his alcoholism had prevented him from using the benefits earlier. The VA denied the application. On review before the Board of Veterans Appeals, McKelvey attempted to prove that his alcoholism was “secondary,” but the Board found “no evidence that an acquired psychiatric disease preceded [McKelvey’s] alcoholism.” In the Appeal of James P. McKelvey, No. 79-04 991, Findings and Decision at 6 (Aug. 6,1980) (“1980 Decision”). As the VA regulations required it to do in the absence of such evidence, the Board sustained the determination that McKelvey’s alcoholism was “willful” and that McKelvey was therefore not entitled to an extension.
McKelvey filed suit in the District Court for the District of Columbia, asserting that the willful misconduct regulation (38 C.F.R. § 3.301(c)(2)) was arbitrary and outside of the VA’s statutory authority; that the VA’s treatment of alcoholism was illegal under § 504 of the Rehabilitation Act; and that he had been denied his rights under the due process and equal protection clauses of the fifth amendment. The District Court, after concluding that 38 U.S.C. § 211(a) did not bar review of the VA’s action, see McKelvey, 596 F.Supp. at 1320-21, held that § 3.301(c)(2) represented an entirely reasonable construction of the “willful misconduct” provision of 38 U.S.C. § 1662(a)(1), see id. at 1321-23, but that it violated § 504 of the Rehabilitation Act by discriminating on the basis of the handicap [198]*198of primary alcoholism. The regulation would be lawful, it said, if the government could show a “substantial justification” for the discrimination. Id. at 1324. The court found the government’s asserted justification that primary alcoholism “is a voluntary handicap” to be “superficially plausible,” but rejected it on the belief that under § 3.301(c)(2) primary alcoholism is deemed involuntary (i.e., is classified as secondary alcoholism) once it results in further disability. Id. The Court invalidated 38 C.F.R. § 3.301(c)(2) and ordered the VA to determine anew whether McKelvey suffered a disability attributable to his own willful misconduct within the meaning of 38 U.S.C. § 1662(a)(1). Id. at 1325. The VA appeals.
II
38 U.S.C. 211(a), in pertinent part, provides:
[T]he decisions of the Administrator on any question of law or fact under any law administered by the Veterans’ Administration providing benefits for veterans and their dependents or survivors shall be final and conclusive and no other official or any court of the United States shall have power or jurisdiction to review any such decision by an action in the nature of mandamus or otherwise.
This court has not yet reached a definitive decision on the breadth of this no-review provision.1 Because of the unusual, perhaps sui generis, posture of this case, we need not and do not essay such a decision today. Rather, we hold that § 211(a) does not preclude review in the unusual situation present here: the VA itself had never decided the question McKelvey’s Rehabilitation Act plea raises until that question was posed for adjudication before this court.
Section 211(a)’s preclusion of review depends, at a minimum, on the satisfaction of this condition: the petitioner’s claim must have been resolved by an actual “decision of the Administrator.” See Johnson v. Robison, 415 U.S. 361, 367, 94 S.Ct. 1160, 1165, 39 L.Ed.2d 389 (1974). At the time of the initiation of this suit, the Administrator had made no decision concerning the impact of the Rehabilitation Act on McKelvey’s time extension application. Therefore, in its initial brief on appeal to this court, the VA maintained that § 211 did not block review. Specifically, the VA told us:
McKelvey did not make a Rehabilitation Act claim before the Board of Veterans Appeals; and it is not clear that the Board would have had authority to consider such a claim had he made it. We do not read 38 U.S.C. § 211(a) to preclude judicial review of a point that the Veterans Administration never considered and, under existing regulations, probably had no authority to consider.
Brief for Appellants at 9-10 n. 1.
At oral argument this court, on its own motion, invited the parties to submit supplemental briefs on three questions: whether the VA had authority to consider the Rehabilitation Act claim; if it did, what was the impact of that Act on McKelvey’s time extension application; and whether § 211(a) precluded this court from undertaking judicial review in this case. Re[199]*199sponding to our request, the VA asserted that it does have the authority to consider the effect of the Rehabilitation Act on McKelvey’s time extension application. The VA’s supplemental brief featured a letter composed in light of the court’s inquiries by the General Counsel of the VA. The General Counsel’s letter announced for the first time the VA’s official position: the Rehabilitation Act does not invalidate the view that “primary” alcoholism is in all cases “willful misconduct.” This letter, the VA ultimately argues, fundamentally changes the situation in the present case. The VA has now spoken, it has made a decision on the point of law on which McKelvey’s case turns. Because the element earlier missing has lately been supplied, the VA concludes, § 211(a) now leaps into play to bar review of the VA decision just made. See Supplemental Brief for Appellants at 5.
This “switched off, then on” interpretation of § 211(a) would place the VA in a remarkable position. The interpretation would allow the VA to try out judicial review risk free. The agency could allow a challenge to its action to proceed in the district court secure in the knowledge that if the VA lost there, it could retroactively shield the action from judicial review.
Under the VA’s interpretation, § 211(a) did not bar review on July 19, 1983, when McKelvey filed his Rehabilitation Act-grounded claim with the district court, because the VA had made no decision concerning that Act at that time; nor did the statute bar review on October 19, 1984, when the district court issued its judgment against the VA; nor on December 30,1984, when the VA chose to appeal that judgment; nor even on November 26, 1985, when, after full briefing by both parties, this court heard oral argument on the VA’s appeal. But throughout this two and one-half year judicial proceeding, the VA now argues, it has held a trump card up its sleeve: even after the parties and two courts have expended the resources necessary for full and fair litigation, the VA, simply by releasing an official pronouncement on the matter sub judice, can preempt the judicial process, and convert the District Court’s judgment into a declaration that merely advises, but does not control the agency.
We are confident that Congress never envisioned such a gambit when it provided that veterans benefits claims should start and finish at the administrative level without coming to court at all. Section 211(a)’s application is to be determined firmly and finally as of the date that plaintiff commences litigation, so that a district court may issue a judgment that will not later be set aside by an executive agency’s fiat. By the VA’s own admission, because it had left a potentially dispositive question undecided, § 211(a) did not bar court adjudication when McKelvey lodged his claim in this case. We therefore have jurisdiction to hear this appeal.
We emphasize, however, the narrowness of our holding. We do not, for example, pass on whether § 211(a) precludes review of veterans’ benefit regulations to determine whether they exceed the VA’s statutory authority. Cf. Wayne State University v. Cleland, 590 F.2d 627, 632 (6th Cir. 1978) (no preclusion); University of Maryland v. Cleland, 621 F.2d 98 (4th Cir.1980) (same); Evergreen State College v. Cleland, 621 F.2d 1002 (9th Cir.1980) (same); Merged Area X (Education) v. Cleland, 604 F.2d 1075 (8th Cir.1979) (same). Indeed, we do not anticipate another occasion to review a VA order on the basis that supports our review today. The VA has now determined it does have authority to decide on the effect and applicability of federal statutes other than veterans’ legislation when the agency acts on benefits claims. We therefore expect that the VA will not again regard as outside the arsenal of law it applies any potentially relevant congressional enactment.
Ill
We can dispose of one of the government's points on appeal summarily. It was not until 1978 — one year after Congress enacted the extension of the ten-year [200]*200limitation period that is the subject of this suit — that the Rehabilitation Act was amended to make § 504 applicable to federal agencies in the administration of programs of financial assistance. See Rehabilitation, Comprehensive Services, and Developmental Disabilities Amendments of 1978, Pub.L. No. 95-602, § 119, 92 Stat. 2955, 2982. Since that 1978 amendment, the Senate has on four occasions passed bills to provide that alcoholism shall not be considered “willful misconduct” for the purposes of 38 U.S.C. § 1662(a)(1). None of the bills passed the House. See S.REP. NO. 604, 98th Cong., 2d Sess. 39 (1984), U.S.Code Cong. & Admin.News 1984, pp. 4479, 4503. The VA argues that this “subsequent legislative history” proves that § 504 does not prevent it from treating most alcoholism as willful misconduct. As the Supreme Court and this court have repeatedly remarked, the views of later Congresses as to the meaning of enactments by their predecessors are of very little, if any, significance. See United States v. Clark, 445 U.S. 23, 33 n. 9, 100 S.Ct. 895, 902 n. 9, 63 L.Ed.2d 171 (1980); United States v. Southwestern Cable Co., 392 U.S. 157, 170, 88 S.Ct. 1994, 2001, 20 L.Ed.2d 1001 (1968); Rainwater v. United States, 356 U.S. 590, 593-94, 78 S.Ct. 946, 949, 2 L.Ed.2d 996 (1958); AFGE, Locals 225, et al. v. FLRA, 712 F.2d 640, 647 & n. 29 (D.C.Cir.1983).
We have considerable difficulty, however, understanding why § 504 is by its terms applicable here. It provides as follows:
No otherwise qualified handicapped individual ... shall, solely by reason of his handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance or under any program or activity conducted by any Executive agency....
29 U.S.C. § 794. According to McKelvey, and the District Court, the VA has discriminated against McKelvey “solely by reason of his handicap” within the meaning of this provision. McKelvey concedes that a regulation would not violate § 504 if it granted a particular benefit (such as an extension from an otherwise applicable limitation period) to all or a particular class of handicapped individuals, but excluded those whose handicap resulted from their own willful misconduct. The “discrimination” under such a scheme would be on the basis of conduct, not on the basis of handicap. Presumably, then, McKelvey would not object to a VA regulation that stated nothing more than, “Those alcoholics whose alcoholism is attributable to their own willful misconduct are ineligible for educational benefits extensions.” Such a regulation would do no more than restate, in the context of the particular handicap of alcoholism, the concededly valid distinction made in 38 U.S.C. § 1662(a)(1).
The essence of McKelvey’s § 504 claim, therefore, is disagreement with the VA’s conclusion that primary alcoholics— i.e., those alcoholics whose condition is not the result of an acquired psychiatric disease — suffer from a willfully caused handicap. It seems to us, however, that the agency’s conclusion is a reasonable one, which is all that is needed to sustain it.2 “At the time of the enactment of 38 U.S.C. § 1662 in 1977, there was, and even presently there is, much controversy as to the nature and cause of alcoholism.” Burns v. Nimmo, 545 F.Supp. 544, 546 (N.D.Iowa 1982). McKelvey asserts that “[t]he medical world has recognized that alcohol abuse is generally outside of the individual’s control,” Brief for Appellee at 5 n. 1; but the VA points to a substantial body of medical [201]*201literature that even contests the proposition that alcoholism is a disease, much less that it is a disease for which the victim bears no responsibility, see Brief for Appellants at 18-19 n. 4. Even on the basis of medical opinion alone, it seems to us the agency’s position has the necessary minimum support. But it is in any case seriously doubtful whether the statutory test of “willful misconduct” — any more than the test for insanity in criminal prosecutions, see United States v. Brawner, 471 F.2d 969, 981-83 (D.C.Cir.1972) (en banc)— calls for invocation of a medical judgment as opposed to application of general societal perceptions regarding personal responsibility. On the basis of the latter criterion, we would find it impossible to deem unreasonable the VA’s assessment that only a psychiatric disorder can prevent alcoholism from being the consequence of “willful misconduct.” It is suggestive of general societal perceptions that the Veterans’ Affairs Committee of the Senate (to take a particularly pertinent example of societal attitudes) expressed the belief that alcoholism and drug addiction “are to some extent within [the veteran’s] control,” S. Rep. No. 314, 96th Cong., 1st Sess. 26 (1979). It is immaterial whether or not such attitudes are correct; the point is that it was within the bounds of reasonable interpretation of the statute for the agency to reflect them. The consequence of McKelvey's interpretation, it should be noted, is not merely to make the limitation extension available to a person who has brought his alcoholism under control; but to make monetary benefits payable to alcoholics who show no sign of, and have no intention of, improving their condition.3 In sum: It is initially the VA’s responsibility, and not ours, to determine what is “willful misconduct.” We cannot say that the resolution here is unsupported by substantial evidence or otherwise arbitrary. We conclude, therefore, that since the agency’s application of 38 C.F.R. § 3.301(c)(2) is a permissible means of discriminating among those suffering from alcoholism on the basis of their conduct, McKelvey’s § 504 claim is without merit.
The contrary conclusion of the District Court is based on several erroneous premises.4 The court held that “the willful mis[202]*202conduct regulation discriminates against McKelvey on the basis of his handicap: primary alcoholism.” McKelvey, 596 F.Supp. at 1323. But in the VA’s terminological scheme, “primary” is merely another way of saying “willful.” “Primary alcoholism” is not a distinct handicap; “primary” and “secondary” are labels the VA uses to express its conclusion about which of those suffering from the single handicap of alcoholism5 do so because of their own willful misconduct. Under the District Court’s reasoning, the VA could not lawfully deny extensions to veterans paralyzed because of their reckless driving because to do so would be to discriminate on the basis of the “handicap” of “willful paralysis.” It is certainly true that primary (or willful) alcoholics are discriminated against, but that discrimination is based upon conduct, not upon a distinct “handicap” called “primary alcoholism.”
The District Court further objected that “[t]he Board’s interpretation of the regulation precluded it from considering relevant evidence which was causally related to [McKelvey’s] handicap.” McKelvey, 596 F.Supp. at 1323. In the District Court’s view, such “relevant evidence” included the age at which McKelvey started drinking and evidence that his father and brother were alcoholics. But, as we have held above, the VA has reasonably determined that such evidence is not “relevant” to the issue of whether a particular veteran’s alcoholism is attributable to willful misconduct. The questions so effortlessly decided by the District Court are the subject of controversy within the field of medicine and within what might be termed the arena of popular moral philosophy. The VA, in a reasonable exercise of its discretion, embraced the views of one side in those controversies. The District Court acted improperly in substituting its own judgment.
Finally, the District Court found that all alcoholics were discriminated against because those suffering from other handicaps “unlike alcoholics, are not required to prove the existence of a secondary disease in order to escape a finding of willful misconduct with respect to their primary condition.” McKelvey, 596 F.Supp. at 1324. That conclusion was based upon the District Court’s belief that, once primary alcoholism results in a secondary disability (e.g., cirrhosis), not only does the VA not consider the secondary disability to have been caused by “willful misconduct,” but it also reclassifies the primary alcoholism as secondary — i.e., not caused by willful misconduct. The latter part of this belief is simply wrong. Disabilities that result from primary alcoholism are not deemed a product of “willful misconduct,” but the alcoholism which caused them is. This is clear not only from the text of § 3.301(c)(2) but from the opinions of the Board of Veterans Appeals. See 1980 Decision at 6; In the Appeal of James P. McKelvey, No. 79-04 991, Findings and Decision (Reconsideration) at 4 (Feb. 23,1982). Thus, alcoholics, just like every other handicapped veteran, are merely required to prove that their disability is not attributable to willful misconduct.
It might be argued, however, that even if McKelvey has not been discriminated against in the application of substantive criteria, he has suffered “procedural” discrimination. Unlike those suffering from every other handicap (except drug addiction), alcoholics do not receive completely “individualized” consideration [203]*203of whether their handicap resulted from willful misconduct. Instead, the VA has established an irrebutable presumption that all persons suffering from this particular handicap do so as a result of their own misconduct, unless they can prove an underlying psychiatric disability. We think such a claim of “procedural” discrimination must fail. Disparate treatment does not necessarily constitute the invidious “discrimination” outlawed by the Rehabilitation Act; disparate treatment that has a substantial justification is lawful.' See New York State Ass’n for Retarded Children, Inc. v. Carey, 612 F.2d 644, 649-50 (2d Cir.1979); Pinkerton v. Moye, 509 F.Supp. 107, 114 (W.D.Va.1981). Were the VA to promulgate a regulation requiring those claiming paralysis to submit to medical examination, but not requiring such examination for those claiming disability on the basis of loss of limbs, it would be absurd to think that the Rehabilitation Act was violated. It is no discrimination, in other words, to establish for various disabilities the sorts of procedures that are distinctively appropriate. Alcoholism, unlike any other disability except drug addiction (which has been subjected to the same procedural presumption), is self-inflicted — whether or not the self-infliction can be considered “willful.” It is therefore feasible for alcoholism, as it is not for all other disabilities except drug addiction, to make a generalized determination that willfulness exists unless there is established the singular exculpation for self-infliction (psychiatric disorder) that the agency has chosen to acknowledge. Since we have approved the substance of that determination, it would insult common sense to require the agency to make it repetitiously, by consistently denying non-psychiatric defenses in individual adjudications instead of precluding them generically, as it has, by rulemaking. Cf. NLRB v. Bell Aerospace Co., 416 U.S. 267, 290-95, 94 S.Ct. 1757, 1769-72, 40 L.Ed.2d 134 (1974); SEC v. Chenery Corp., 332 U.S. 194, 202-03, 67 S.Ct. 1575, 1580, 91 L.Ed. 1995 (1947).
******
The decision of the District Court is reversed and the case is remanded for consideration of McKelvey’s constitutional claims.
So ordered.