What is the test for determining whether a primary alcoholic is a primary alcoholic to be denied educational benefits under the Rehabilitation Act?

The last question, however, called for a decision under the Rehabilitation Act. "A decision of law or fact 'under' a statute is made by the Administrator in the interpretation or application of a particular provision of the statute to a particular set of facts." Johnson v. Robison, 415 U.S. 361, 367, 94 S.Ct. 1160, 1166, 39 L.Ed.2d 389 (1974). Traynor's Rehabilitation Act challenge involved the facts (1) that 38 U.S.C. Sec. 1662(a)(1) denies extended educational benefits to a veteran whose disability resulted from his own willful misconduct, and (2) that the VA alcoholism regulations provide that primary alcoholism is willful misconduct and that primary alcoholics are ipso facto to be denied extended educational benefits. The challenge required a decision as to whether the Rehabilitation Act prohibits this combination of facts--i.e., a decision under the Rehabilitation Act.