ESCHBACH, Circuit Judge.
The primary question presented in this appeal is whether there is an implied private right of action under § 501(b) of the Comprehensive Older Americans Act Amendments of 1978, as amended in 1981, that would allow an "existing" service provider to obtain judicial review of an administrative decision denying the provider's application for a grant of federal funds and awarding the grant to another provider. For the reasons stated below...
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