system: You are a legal assistant. Answer concisely and accurately. When legal text is provided, rely on it and do not invent facts.

user: Read the case excerpt and choose the best holding from the options. Case excerpt: see also Howard v. Gober, 220 F.3d 1341, 1344 (Fed.Cir.2000) (Board remand does not constitute a final decision that may be appealed (citing 38 C.F.R. § 20.1100(b) (1999))). 2 . Although frequently used both by VA and the Court, the term "formal claim” is not defined by statute or regulation. As far as the Court can determine, the use of this term flows from 38 C.F.R. § 3.160(b), which defines an "original claim” as "An initial formal application on a form prescribed by the Secretary,” and referring to 38 C.F.R. §§ 3.151 (Claims for disability benefits) and 3.152 (Claims for death benefits). See also Nor iled in situations in which the Secretary’s own regulations specify that the formal application form contemplated by § 3.155(a) is not necessary. See, e.g., Norris, 12 Vet.App. at 417 (<HOLDING>); 38 C.F.R. § 3.154 ("VA may accept as a claim Options: A. holding without applying the doctrine of judicial estoppel that the plaintiff who made sworn statements of total disability in a social security disability application and then testified at her deposition that she was not totally disabled failed to raise a genuine issue of material fact as to whether she was a qualified individual with a disability within the meaning of the ada B. holding that a totally disabled claimant whose preexisting osteoarthritis was temporarily aggravated by her employment was entitled to temporary total disability benefits but not permanent total disability benefits because there was no causal connection between the temporary aggravation and the permanent disability C. holding that debtors situation did not have a certainty of hopelessness because his only disability was from a back injury which he attributed a 20 disability rating and a significant problem for the debtor was his negative attitude toward obtaining employment D. holding that a medical opinion is adequate where it is based upon the veterans medical history examinations and the also describes the disability in sufficient detail E. holding that where the claimant was already serviceconnected for a psychiatric disability and a medical record indicated that his conditioned worsened no formal application for a total disability rating based on individual unemployability was required because 1 a total disability rating based on individual unemployability is simply another way to get a 100 rating and 2 3157a provides that medical examinations that show a worsening of an already serviceconnected condition are themselves informal claims for increases

assistant: The best answer is E. holding that where the claimant was already serviceconnected for a psychiatric disability and a medical record indicated that his conditioned worsened no formal application for a total disability rating based on individual unemployability was required because 1 a total disability rating based on individual unemployability is simply another way to get a 100 rating and 2 3157a provides that medical examinations that show a worsening of an already serviceconnected condition are themselves informal claims for increases