#brainwound

PRESS RELEASE

Monday, 15 June 2026, TreatNOW.org, Washington, DC

The TreatNOW Coalition today released a Report to coincide with PTSD Awareness Month. The Case for HBOT (Hyperbaric Oxygen Therapy) as a VA Standard of Care Indication for TBI and PTSD, together with a companion piece on VA/DOD Interventions for TBI/PTSD, lay out specifics about the two decade medical doldrums in the VA/DOD.

The FDA last approved a drug for PTSD in 2001 — the same year as 9/11. None have been approved for TBI. In the 24 years since, while the VA has treated over 500,000 veterans with TBI and millions with PTSD, not a single new pharmacological treatment has been approved for the condition. Every drug the VA prescribes beyond sertraline and paroxetine is off-label. Both approved drugs carry FDA black box warnings for suicidal ideation and work only modestly better than placebo — and not at all reliably in combat veterans.

The VA's Booklet on PTSD continues the illusion that PTSD is a Mental Health problem alone, with no mention of the physical damage that may underlie PTSD symptoms. Thus, the Clinical Practice Guidelines (CPGs) in place for co-occurring Traumatic Brain Injury (TBI) and Posttraumatic Stress Disorder (PTSD) emphasize better screening, careful medication management, and the use of trauma-focused psychotherapies. On the issue of a brain wound, the CPGs are silent.

As of June 2026, the VA library contains more than 30 active CPGs spanning mental health, rehabilitation, pain management, and chronic disease — none of which mention brain wounding, none include HBOT as a standard-of-care recommendation for TBI or PTSD, and none identify any FDA-approved pharmacological treatment for TBI; there aren't any. And, characteristically, both DoD and the VA hang on to woeful formularies and practices that cost more and fail to dent the suicide rate's upward trend. Something has to change.

Here is a quick Summary of what the TreatNOW Coalition recommends in this 12th year recognition of PTSD Awareness Month, a period that saw total suicides increase from 88,229 to over 160,000, an average of over 6,387 Veteran suicides every year.

Every day, between 17 and 22 American veterans die by suicide. That number has barely moved in twenty years — despite billions spent on VA mental health programming. We are here today to tell you why, and to tell you what will change it.

TBI and PTSD are not primarily psychiatric conditions. They can be and generally are brain wounds — physical injuries to living tissue that can be seen on MRI, measured on PET scan, and, critically, healed. The VA's current treatment model — pharmaceuticals, psychotherapy, coping strategies — cannot heal a physical wound. No antidepressant restores a shredded axon. No benzodiazepine rebuilds a hypoperfused hippocampus. The suicide rate will probably not move until we treat the wound itself.

Hyperbaric Oxygen Therapy does exactly that. Under pressure, oxygen dissolves directly into plasma and reaches metabolically starved neurons that red blood cells can no longer reach. It triggers angiogenesis — the growth of new blood vessels into damaged tissue — documented in human brains on perfusion MRI. It regenerates white matter fiber tracts, confirmed by DTI imaging. It mobilizes stem cells from bone marrow. It reduces neuroinflammation. These are not theories. They are peer-reviewed findings, in randomized controlled trials, in veterans — published in the Journal of Clinical Psychiatry, PLOS ONE, and Frontiers in Neuroscience.

The Israeli government — whose military sees the same blast injuries, the same PTSD, the same suicide risk — has recognized this evidence. Israel's Ministry of Defense now funds HBOT for veterans. The Sagol Center in Be'er Ya'akov treats 350 patients daily, with documented 68% significant improvement rates and PTSD remission lasting two years and beyond. Congressman Greg Murphy, himself a physician, asked the obvious question when he saw these results: "Why the hell are we not doing this in the United States? . . . . I believe it is medical malpractice not to offer this to our Veterans."

The VA's answer has been inertia. But here is the cost of that inertia — in numbers this Congress controls.

Our Brain Drain analysis quantifies the annual burden of untreated TBI and PTSD veterans at $118 billion per year — across disability compensation, VA healthcare, pharmaceutical costs, lost productivity, homelessness, incarceration, suicide, and ten other categories. There are 877,450 Iraq and Afghanistan veterans languishing in this condition right now.

The one-time cost to treat every one of them with a full HBOT course: $19.7 billion — less than one-half of one percent of the forty-year lifetime burden of doing nothing. The VA recoups that investment in under seven years at even the most conservative outcome assumptions. Dr. Paul Harch's clinical data shows 50% reduction in psychoactive medication use following treatment. Ten of twelve veterans with active suicidal ideation in his trial resolved that ideation entirely.

Here is the legal absurdity the Congress should understand: the VA already reimburses HBOT — for carbon monoxide poisoning (and 14 other conditions). The mechanism is identical. CO poisoning starves neurons of oxygen by blocking hemoglobin and mitochondrial enzyme function. Blast TBI does the same thing through different means. We treat one. We deny the other. That distinction is not medicine. It is policy inertia with a body count.

The TreatNOW Coalition has already returned more than 33,000 patients to work, school, and active duty — pro bono — using this therapy. Among them: over 12,500 veterans, including more than 700 Special Operations Warriors. We know it works. The peer-reviewed science shows it works. The only institution that has not acted is the U.S. Government.

The ask is straightforward: Pay for HBOT treatments in TreatNOW Coalition clinics and hospitals. Authorize pilot programs at Innovative Therapies Centers of Excellence under the PATH Caucus framework. Amend CMS NCD 20.29 to include chronic TBI with documented metabolic dysfunction. Mandate neuroimaging-based outcome tracking. The evidence is there. The precedent is there. The fiscal case is unambiguous.

Too many veterans will die by suicide today. The question before this Congress is whether the number will be different tomorrow.

The answer, of course, is to do the right thing: TreatNOW

Our knowledge of brain wounds and how to heal them has “exploded” in the last decade. The medical universe is mired in old notions about the brain and how to heal brain wounds. We can help in their education by allowing and funding State hospitals and clinics to use HBOT to heal TBI/PTSD while Congress and the VA and DoD catch up.

HBOT Heals Brains, Stops Suicides, Restores Lives. TreatNOW

THE BIG PICTURE: In less than a year, two separate juries — one in South Carolina, one in Texas — have now handed the NCAA massive CTE verdicts totaling $158 million combined. With the NCAA calling CTE "hypothetical" even as juries deliver nine-figure verdicts, the floodgates for similar lawsuits appear to be opening wide.

Veterans and their families with undiagnosed or misdiagnosed Traumatic Brain Injuries (TBI) are in a similar boat as NCAA athletes suffering debilitating concussion symptoms. Two recent legal cases involving former college football players diagnosed with dementia and chronic traumatic encephalopathy (CTE) display close parallels.

The first case, Geathers v. NCAA, involved Robert Geathers, a defensive end for the South Carolina State Bulldogs from 1977 to 1980. In 2017, almost forty years after his college athletic career, Geathers was diagnosed with dementia, while also presenting signs consistent with chronic traumatic encephalopathy (CTE), a debilitating brain condition linked to repeated head injury. Physicians who testified at the trial said Geathers displays symptoms of CTE, which currently can only be diagnosed posthumously.

In April 2019, Geathers and his wife Debra filed a negligence and fraud action against the NCAA. The central argument alleged that the NCAA had been aware of the potential dangers of concussions and CTE since as early as the 1930s, pointing to a 1933 NCAA medical handbook which included references to "concussion management plans." Their attorney, prominent civil rights lawyer Bakari Sellers, told jurors: "All of the information they knew, they withheld. Their job was to keep the boys safe." He also argued the NCAA particularly failed to warn coaches and players at HBCUs like South Carolina State.

A South Carolina jury found the NCAA negligent for failing to warn Geathers about the long-term risks of concussions. The jury awarded $10 million to Robert Geathers and $8 million to his wife, Debra, for loss of consortium — a total of $18 million — following the civil trial in Orangeburg County. The jury believed the NCAA had actionable knowledge of concussion risks but failed to act.

The jury specifically determined that the NCAA:

- Unreasonably increased the risk of harm of head impacts to Robert Geathers beyond the risks inherent to playing football - Voluntarily assumed duties to protect his health and safety, and negligently breached those duties

NCAA spokesperson Greg Johnson said the organization disagreed with the verdict and was "prepared to pursue our rights on post-trial motions and on appeal, if necessary." Johnson pointed out that "the NCAA has prevailed in every other jury trial around the country on these issues."

The NCAA's trial attorney argued that Robert Geathers has several other health conditions that could explain his dementia-like symptoms, and that the NCAA's football rules committee is composed of representatives of member schools who could propose rule changes. "There's going to be head-hits. That's inherent to the game. You can't take head-hits out of football," he said in closing arguments.

The second case was brought in Dallas, Texas by the family of 1950s SMU football player J.T. Davis. In the case of Davis v. NCAA, Cause No. CC-20-01121-D, a jury last month returned a verdict of $30 million dollars compensatory damages, and $110 million punitive damages. The jury agreed with the plaintiff's family that NCAA leadership was aware of the long-term consequences of repetitive head trauma in football, including CTE, and did not warn players such as Mr. Davis. Plaintiffs further alleged that the NCAA did not follow a provision of its own constitution requiring it to study sports. Trial exhibits introduced by plaintiffs included internal NCAA documents which, plaintiffs argued, indicated that NCAA medical experts had information dating back to the 1930s regarding progressive neurodegenerative disease in college football players.

At trial, the NCAA argued that there is a lack of evidence that CTE is caused by repeated head hits and disputed that CTE causes symptoms. The NCAA stated that CTE is a "hypothetical" disease, despite incriminating internal communications that addressed CTE-related clinical symptoms and the risk profile of college football players.

Net net, for the first and second times, juries no longer bought the NCAA' decades long assertions that they didn't know, there was no evidence, and it wasn't their fault that players were being negatively impacted from their football years. Important to note that their position has been eroding over the years as Dr. Ann McKee's science on CTE in Boston shows the results of examining the brains of 202 former American football players: 99% of NFL players examined had CTE, 91% of college players, and 21% of high school players.

Legal quibbling is the last redoubt of institutions and corporations about to smell the roses and acknowledge what the common man and science have already proved.

The VA and DoD have similar dilemmas. They have sponsored research, developed elaborate data bases and longitudinal studies, invested heavily in facilities, staffing, firing and hiring, and continuing research into BLAST and effects of firing personal weapons. Unfortunately, nowhere in any of the studies about treatment do the VA or DoD consult their own textbook of "old" Common Practice Guidelines. The figure below tells them a way forward in their continuing search for better and more effective treatments to help heal brain wounds.

What the "Algorithm for the evaluation of neurological abnormalities in a blast casualty" spells out clearly as the "Definitive Therapy" for BLAST injury is Hyperbaric Oxygen Therapy.

Now one could argue that this chart is outdated, or that BLAST injury is not the same as a concussion, or that we now know what they didn't at the time. That is demonstrably true. But what we have learned in the last decades is that BLAST is so much worse than what we knew at the time, and that it strikes service members in a vast array of ways relative to particular lines of work. Artillery, mortars, EOD, jet pilots, heavy weapons, SOF, breechers, shoot room instructors. The list continues to grow.

Thus, the negligence in NOT using HBOT, a known and effective intervention for BLAST injury, is causing more and more victims to go without known treatments, thus prolonging brain and personal deterioration.

Given all that, let's connect some dots:

- BLAST and one-time and/or constant banging of the head can lead to brain wounds. - Brain-wounding has been shown to lead, in some cases, to CTE. - Painful and debilitating symptoms accompany brain wounds and have been observed in patients later found to have CTE. - Not all brain wounds lead to CTE, but some significant percentage of those studied do have CTE. - The NCAA and the NFL and many other leagues worldwide continue to contest the connection of brain wounds to CTE and other neurological and behavioral and psychological deterioration in players. - The VA and DoD have a suicide epidemic that is increasingly tied to actions taken -- and not taken -- by their own medical personnel. - Scientific, peer-reviewed research connects BLAST damage to brain wounds, TBI, PTSD, and CTE. - Institutional medicine denies "proof" that Hyperbaric Oxygen Therapy helps heal brain wounds, diminishes suicidal ideation, and improves Quality of Life in service members and other victims of brain wounding from Concussion/TBI/PTSD/BLAST. - Decades-old published medical advice to the NCAA and from Army Medicine argue for enhanced care for concussed patients, and in the case of Army Medicine, declare the definitive treatment for BLAST injury is HBOT. - No military or institutional medical organization uses HBOT for brain wounds, and even goes to lengths to denigrate the science and warn against the risk of HBOT, despite scientific, clinical, anecdotal and evidence-based practice to the contrary. - The NCAA, DoD, and the NFL have teamed up to study all of this, and we can count on published research that will advance what we know about damage, and causes, and symptom reduction. But we can predict that the path they are on will do little to advance brain wound healing. - The research into psychedelics and other alternative therapies should continue in the hope that they will prove effective at brain wound healing but that future is in the future following great cost, multiple setbacks, and controversy about the drugging of America. - HBOT is available today. 14 states have legislated its use. 12,500 successes and restored Quality of Life with Veterans suffering brain wounds in over 180 clinics nationwide.

Message to the NCAA, the NFL, all professional sports teams and moms and dads. Start using and studying the effects of HBOT on brain wounds. Enough research exists already that proves HBOT is safe and effective. Notice the sequence: TreatNOW while everything else continues.

NOTE for those concerned with TOXIC EXPOSURE:

Linda Hersey of Stars and Stripes brings mixed news for Veterans suffering from toxic exposures. The bad news is that, finally, the VA recognizes that toxic exposures lead to increased suicide risk, posttraumatic stress disorder , depression, and alcohol use disorder.

The study, “Deployment-related toxic exposures, mental health problems, and suicide outcomes among Gulf War era U.S. veterans,” looked at the long-term mental health of veterans who reported exposures in the following categories: chemical/biological weapons, anthrax vaccine, Agent Orange (herbicides), solvents/fuels, petroleum combustion products, lead, other metals, pesticides and open-air burn pits.

The VA could help itself by starting to use Hyperbaric Oxygen Therapy as part of their protocol for all of the above, as the TreatNOW Coalition has been doing successfully for over 15 years.

Also, recall it took the VA nearly 30 years to formally recognize that Gulf War Illness was real, so we can be thankful that they’ve moved so quickly; only 26 years to pin down links between toxic inhalation and a plethora of mental and physical health diseases.

Our knowledge of brain wounds and how to heal them has “exploded” in the last decade. The medical universe is mired in old notions about the brain and how to heal brain wounds. We can help in their education by allowing and funding State hospitals and clinics to use HBOT to heal TBI/PTSD while Congress and the VA and DoD catch up.

HBOT Heals Brains, Stops Suicides, Restores Lives. TreatNOW

NOW, THEREFORE, BE IT RESOLVED BY THE MEMBERS OF THE ONE HUNDRED NINTH LEGISLATURE OF NEBRASKA, SECOND SESSION: That the Legislature strongly urges members of the United States Congress to swiftly enact legislation to provide for veterans' access to treatments for traumatic brain injury and post-traumatic stress disorder that include hyperbaric oxygen therapy . . . .

PRESS RELEASE 9 April 2026, Arlington, VA

The office of Senator Kathleen Kauth in the Nebraska Legislature announced that LR293 received a vote of 43-0. The Resolution, on its way to the Governor for a signature, calls on the US Congress to "swiftly enact legislation to provide veterans' access to treatments for traumatic brain injury and post-traumatic stress disorder that include hyperbaric oxygen therapy." Nebraska becomes the 14th state to weigh in on the need for VA action to address the suicide crisis among Veterans .

Nebraska has about 115,000 Veterans. That number equates to over 20,000 Veterans suffering from undiagnosed or untreated brain wounds, with a multi million dollar per year financial burden on Nebraska citizens for untreated TBI/PTSD.

The Resolution recognizes that alternative therapies must be brought forward to do the job that the VA relegates to mental health, where drugs and talk therapy have proven inadequate to stem the suicide epidemic. Both the VA and the DoD call Suicide Prevention their #1 clinical priority and spend hundreds of millions of dollars in a losing effort to treat and heal TBI/PTSD. Veteran suicides since 9/11 now exceed 161,000.

The TreatNOW Coalition is helping in Nebraska and around the country to end suicides. We have learned that Hyperbaric Oxygen is uniquely capable of ending suicidal ideation. It helps end symptoms of PTSD, get patients off most of their drugs, and heal brain wounds. It heals the effects of Concussion, BLAST injury, mild TBI, Persistent Post Concussive Syndrome, and polytrauma from Operator Syndrome, AHI, and Burn Pits. No Veteran or civilian has ever been killed or hurt while undergoing HBOT treatment for TBI/PTSD.

TreatNOW provided support to the Nebraska legislature in understanding the magnitude of the challenge, and the safe and effective intervention available today. Facts matter:

- ~7,085+ U.S. service members killed in combat since 9/11 — ~53,000 wounded in action - 17.6 Veteran suicides per day - 61,000+ veterans have died by suicide since 9/11 — nearly 23 times the combat death toll - 109,000+ veterans have died from drug overdose — prescribed and otherwise — since 9/11 - 270,000+ total veteran deaths from suicide and overdose combined — nearly 38 times the combat death toll - 17.6 veterans die by suicide every single day — the VA’s own number — and the trend is UPWARD year over year - The veteran population has DECREASED by 10% over the same decade — making the rising suicide rate even more catastrophic in real terms - $5.375 billion spent by the U.S. Government on Suicide Prevention over the last ten years — with little improvement in outcomes - 877,000+ Veterans carry untreated brain wounds right now - 33,000+ brain-wounded veterans, athletes, first responders, and civilians have experienced enhanced quality of life through Hyperbaric Oxygen Therapy (HBOT) — many returning to work, school, and active duty, reclaiming a future with freedom to choose, which the current, failed standard of care denied them - Fourteen states have passed legislation or Resolutions calling for the use of HBOT for veterans with TBI/PTSD; seven have allocated over $32M to get started. Five more states are moving in the legislative direction to do what the VA will not.  - 12,500+ Veterans have benefited from HBOT treatment for their TBI/PTSD - 180+ Coalition clinics delivering treatment across the country, many pro bono - 28 peer-reviewed studies confirming HBOT safety and efficacy for brain wounds - 85% recovery rate for mild-to-moderate TBI - 10 Secretaries of the Veterans Administration over 25 years have been informed about the science, safety, and efficacy of HBOT and still the institution refuses to offer it or even inform Veterans about its availability - Hundreds of drugs, devices, processes, computer programs and other interventions by DOD/VA/medicine DO NOT TREAT THE WOUND TO THE BRAIN, and ALL are used off label since none have been approved by the FDA for TBI, PTSD, Concussion, BLAST, or post concussive syndrome or polytrauma. None of the hundreds of drugs prescribed by the VA/DOD are approved by the FDA for brain wounds, and over a dozen warn of suicidal ideation. - Less than ½ of 1% — The ROI for the cost of HBOT treatment for 877,450 Veterans over a lifetime vs. the lifetime cost of no treatment. Projected untreated costs exceed $4.7 Trillion -  And unlike psychedelic and hallucinogenic and plant-based medicines like psilocybin and ayahuasca and ibogaine and MDMA and marijuana, HBOT is backed by decades of research, 28 clinical studies and proven safety and efficacy to treat and heal brain wounds, today. HBOT Heals Brains, Stops Suicides, Restores Lives. TreatNOW.

March is TBI Awareness Month, as the White House has reminded us. The Sea of Troubles at the VA and DoD is the suicide epidemic, their continuing #1 medical priority. It is also Academy Awards month. Up for Best Picture is HAMNET, named for William Shakespeare's son, and the background to his revenge tragedy, Hamlet.

Hamlet's reflections on Yorick's skull is focused on death and revenge. The "Sea of Troubles" for Hamlet was bringing justice to his father's murderer. For us and the families of the 159,000+ suicides, justice demands accountability for the Suicide Epidemic, and the memories of service members who died before their time. The links between suicidal ideation and untreated brain wounds is well-established. Less known are the links between Departmental indolence and negligence at the top. Some call it criminal negligence that so much money keeps getting thrown to failed policies, people, and programs as the suicide trends continue upward.

Congressman and physician Greg Murphy excoriated VA doctors sent to answer questions about the VA's failed record on TBI. TreatNOW has spent nealry two decades listening to the now-repetitious testimony of VA representatives sent to the Hill who mouth out-of-date statistics and "facts" about brain wounds and how to treat them. Worse, those same doctors tout programs that have failed tens of thousands of Veterans with undiagnosed and untreated brain wounds. $5.375 BILLION spent on "prevention" while suicides overwhelm Veterans. Fifteen months in, where's the accountability?

This week, one victim of those failures, a combat Veteran and Agency career ex-employee, called in tears, suicidal, nearly catatonic after viewing CBS 60 Minutes' most recent reporting on Havana Syndrome. Ten years of suffering, of being separated from their career, of being forced to pay for their own treatments, of disrespect, accusations of "malingering," inability to work, focus, remember, love, a victim of drugs-and-talk-therapy, and repeating the cycle all over again with each new flareup. For them, and thousands like them, expecting help from the VA or the USG is hopeless.

Investigative reporter Katherine Herridge has zeroed in on Directed Energy Weapons and the impacts on USG Intelligence Community employees and their families. Even she does not go far enough, failing to go beyond cataloging the destruction. She still fails to talk about how some lucky few have found relief and healing using Hyperbaric Oxygen Therapy.

Dr James Giordano, Director, Center for Disruptive Technology and Future Warfare, Institute for National Security Studies, and Dr. David Relman, MD of Stanford University, both talk about the real consequences of the damage caused by DEWs: loss of consciousness, seizures, mental lapses, inability to concentrate, headaches, intense pressure, pain, disorientation, and difficulty with balance. Intel Agencies and the LEAs have strained to substitute "causes" for a decades-long list of reported symptoms: atmospherics; the environment; a virus; crickets; preexisting conditions; and even mass hysteria.

Such shuck-and-jive is not new . The tactic is classic, mimicing the bafflegab in the past from Big Tobacco; the opioid crisis; the Pentagon Papers; and current spinning like the NFL on CTE; Veterans being denied proper diagnoses and disability for brain wounds; and the continuing charade that the VA is the Center of Excellence for TBI. There was a time, ten or 15 years ago when we didn't have a decade of science and evidence-based medicine, and clinical successes worldwide to demonstrate how to help treat and heal brain wounds caused by TBI, PTSD, Concussion, Havana Syndrome, and a myriad of other neurological and physical insults to the brain. And if the VA is the COE, why are Intrepid Spirit Center doctors sending brain wounded patients for HBOT with the comment: "Nothing we're doing for them is working"?

We know better. The science is sound. The results are demonstrable. It is no longer sufficient for doctors and legislators and military medicine to feign ignorance about the benefits of HBOT. At a minimum, HBOT should have an equal seat at the "alternative therapy" table. The Secretary talks about issuing vouchers to help Veterans get psychedlic help outside the VA. Congressman and retired USMC LTG Jack Bergmann thinks the Government needs to grow spines to overcome the do-nothing attitudes preventing getting help to Veterans. One wonders why the VA needs over a dozen studies on psychedelics? There's no ignoring a seeming crack in the wall-of-silence about the ineffectiveness of too many VA programs.

And remember: nothing the VA or DoD uses or does to control symptoms is on-label for TBI. We could learn from the Israelis who use HBOT for PTSD and TBI across the country and especially over the last decade for their brain wounded Veterans and active duty.

The VA needs to reread its own counsel, issued by their premier researchers over a decade ago. There is no appreciable evidence that anything has changed. Drs. Hoge and Jonas wrote: "It is clear that is a healing environment. . . . These findings reinforce the argument that effective interventions do not yet exist within the present structure of care or that routine postconcussion interventions within the Department of Defense or Veterans Health Administration may even have iatrogenic effects that contribute to symptom persistence . . . .” Iatrogenic: harm, illness, or adverse effects unintentionally caused by a physician, medical treatment, diagnostic procedure, or other medical activity.

They're losing. We're winning, just not fast enough. We need to work together. Veterans and active duty need help, and it's available. HBOT Heals Brains, Stops Suicides, Restores Lives. TreatNOW.

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The TreatNOW Mission is ending service member suicides. Along the way, we have learned that we can end suicidal ideation, help end symptoms of PTSD, get patients off most of their drugs, and heal brain wounds to end the effects of Concussion, BLAST injury, mild TBI, Persistent Post Concussive Syndrome, and polytrauma from Operator Syndrome, AHI, and Burn Pits. No Veteran or civilian has ever been killed or hurt while undergoing HBOT treatment for TBI/PTSD.

"Are we going to just accept these conditions? Or are we going to do something about it?" Barbara Rose Johns

19 December 2025.

Dear Secretary Collins. You probably recognize the statues above: George Washington, an early Freedom Fighter; and Barbara Rose Johns, the recent addition to statuary hall. She stood up as a teenager and said "No" to segregation, and helped usher in another advance in an American culture born of freedom from "the way things are done." She refused to let the culture of segregation prevent her from equality spelled out by the actions of our first President. And she won. Cultures can shift.

We are appealing to you to change the culture at the VA from one of "brain wounds are a mental health issue" to one of: "brain wounds like TBI/PTSD/PCS/BLAST/Concussion must be treated like a wound and healed using modern, proven, scientifically validated alternative therapies."

Sir, you were sworn in as the 12th Secretary of Veterans Affairs on Feb. 5, 2025. On March 31st, you sat for an interview with Shawn Ryan. Seven minutes in, you said this: " So, here's my thought to everybody. We're not going to be your whipping post anymore. I'm going to tell you the truth and I'm going to give you the answers that we need to do and I'm going to take care of our veteran number one." While you didn't mention it then, you preside over the largest health care system in America -- nearly 480,000 employees -- whose #1 clinical priority is Suicide Prevention.

And yet, as you realize, with your budget of over $440 Billion and twenty years of experience, you cannot reverse the upward trend on Veteran Suicides, now close to your own estimates of 159,000 souls.

Former SEAL Ryan replied to you after your long discourse on the need to change the culture in the VA : "I got 100% . Yeah. I haven't stepped into a VA in almost 10 years because my experience has been just atrocious. It was "here's these pills. We can't see you." I mean . . . .I'm having doctors come to me. They don't even know what a Navy SEAL is. . . . They don't understand what combat is. My doctor shows up in a sweatsuit, barely even speaks any English. . . . my show, it started with all special ops combat veterans. And everybody has the same complaints and the same issues . . . .I am friends with the top war fighters on the planet. None of them have a good experience at the VA. None of them have anything positive to say about the VA. None of them trust the VA. And that's why I quit going. I mean, I have more friends that have died of suicide and drug addiction and depression and PTS and everybody's struggling with especially the special operations guys with the traumatic brain injuries and we just aren't getting any answers at all from the VA. . . . it's just created this distrust. . . . I get treated like when I go there. It's like I'm faking an injury or something. And so I just got to the point where I just threw my hands up and I was like, man, this. I'm not doing it. I will personally pay for my own health care on the civilian side which is much much better than anything I've ever had in the VA."

Daily news reveals your proposed plan for reorganizing the VA. Controversial? Sure. Necessary? Undoubtedly. Designed to actually get better care for brain wounds to Veterans? Silence. But your interviews and editorials keep coming back to all the progress being made and all the money you're redirecting to Veteran care. You told Shawn: "We spent $588 million on preventive supposed suicide. We spend $2.3 billion in what we'll call treatment of either the mental aspect, health aspect . . . . so $3 billion total roughly in suicide and our numbers are not changing."

At the risk of stating the obvious, stop throwing good money after bad. Redirect dollars to treatments. You can hire all the psychiatrists you can find and STILL not make a dent in the suicide numbers so long as you continue on the path you've been on for decades. Brain wounds are not primarily mental health problems. Brain wounds -- TBI/PTSD/PCS/BLAST/Concussion -- are wounds. They can be treated. The world outside the VA is treating them with Hyperbaric Oxygen Therapy (HBOT), doing the job your VA cannot and will not do.

We have offered to help the VA become heroes to Shawn Ryan and the SpecOps community, as well as DoD, Veterans, and citizens more broadly. We have helped heal brain wounds in over 12,500 Veterans, over 33,000 citizens. We have active programs with the Wounded Warrior Battalion/East at Camp Lejeune and Fort Bragg, and in 13 states with legislation to use HBOT for TBI/PTSD. And we're doing it with donations and our pro bono efforts.

There is a culture in the VA -- particularly among discredited researchers and psychiatrists -- that HBOT does not work, is too expensive, risky, unproven, a distraction. Your website continues to advertise the top interventions that allegedly meet the test of "evidence-based medicine": Psychopharmacology; Cognitive Processing Therapy (CPT); Eye Movement Desensitization and Reprocessing (EMDR); Prolonged Exposure/Trauma-Focused Psychotherapy. Mr. Secretary, none of these interventions is on-label. They all lack scientific validation as being safe and effective for treating and healing brain wounds. HBOT has more scientific validation proving safety and efficacy than all the interventions used in the VA.

We can help immediately. We already are, living up to the challenge you set in your confirmation and continuing media appearances: the Veteran must come first. We offer you the information and infrastructure you need to shift course; not to abandon all the rice bowls and equities that resist change. Keep hiring more mental health professionals. Continue to dispense billions of dollars on drugs. Let the failed policies continue until they die of their own accord. But with the hundreds of millions of dollars you've already identified as available through reprogramming, make an investment in healing Veterans, not just palliating them. I'm sure you understand why Shawn let you know why he's not going back to the VA. He and his battle buddies can get brain wound healing only outside the VA.

Mr Secretary, you know about "pay fors" and budget-neutral legislation. Bills in Congress now calling for using HBOT for TBI/PTSD all lack funding. The CBO Report on HR 1336 points to $158 Million available to treat 1000 Veterans. We applaud the Report but can treat nearly double that number and in far less than three years using the 170+ TreatNOW Coalition clinics available. Pressing DoD chambers into service can accelerate the healing. The cost to treat is not cheap, but compare it to the current path your Department is on. As we spell out in our book, Brain Drain, we can treat the 877,450 estimated brain-wounded Veterans for less than one-half of one percent of the costs to NOT treat those same suffering Veterans.

You wrote in the Washington Post that "VA’s EHR modernization effort is well on its way to improving the lives of millions of veterans across the country." An Electronic Health Record is designed to save time and money and to ease the burden on staff and patients. The VA's current iteration may save time, but it can't substitute good medicine for failed institutions that simply misconstrue the new science about brain wounds.

The GAO Report on December 12, 2025 summarized: "After three unsuccessful attempts over two decades, the Department of Veterans Affairs (VA) undertook a fourth effort in 2017—the Electronic Health Record Modernization (EHRM) program—to modernize its legacy health information system. GAO has previously reported on the challenges VA has experienced with this effort. In these reports, GAO made 18 recommendations to improve cost estimating, schedule, program management, user adoption and satisfaction, and operational testing. GAO deemed 12 of these as priority recommendations because of their criticality to successful future deployments. VA has not yet fully implemented 16 of the 18 recommendations."

Originally estimated to cost ~$10Billion and be operational within 10 years (2028), the upgrade is now estimated to cost some where between $49.8 billion total lifecycle cost including long-term sustainment — far above the original ~$16 billion estimate. Delivery is expected by 2031. And, as I'm not sure you're aware, the terrific reliability scores you report -- "As of September, our EHR had a 96.68 percent incident-free rate over the prior 18 months" -- are due to the oversight, accountability, and enforcement during that 2-year hiatus.

We applaud your vow to not accept failed policies and structures and performance. We are 100% behind focus on healing Veterans and making their lives not just better, but improving their Quality of Life and that of their families. We can do that together through adding brain wound healing to the dialogue and standard of care the VA can provide with help from the Community. And we don't have to wait. We have already begun. Join us.

"Are we going to just accept these conditions? Or are we going to do something about it?"

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The TreatNOW Mission is ending service member suicides. Along the way, we have learned that we can end suicidal ideation, help end symptoms of PTSD, get patients off most of their drugs, and heal brain wounds to end the effects of Concussion, BLAST injury, mild TBI, Persistent Post Concussive Syndrome, and polytrauma from AHI, Burn Pits, and COVID. No Veteran or civilian has ever been killed while undergoing HBOT treatment for TBI/PTSD.

What do the pictures have in common? The faces of brain injured Warriors and athletes who sacrificed, not just served. And too many dead with undiagnosed brain wounds.

We're twenty-four years out since 9/11. On the order of fifteen thousand Americans — roughly seven thousand U.S. service members and about eight thousand U.S. military contractors — have been killed in the post-9/11 wars in Afghanistan, Iraq, Syria, and related theaters, according to the best available research. Ten times that number are dead from suicide over the same period, and 877,000+ Veterans and millions of citizens suffer with untreated brain wounds.

A third of NFL players surveyed think they have CTE. While the total number of NFL players with Chronic Traumatic Encephalopathy (CTE) isn't known, a landmark Boston University study found CTE in 91.7% (345 out of 376) of the brains from former NFL players studied, highlighting the disease's prevalence linked to repeated head impacts in football. With over 25,000 Veterans of the NFL, we're looking at many thousands of potentially undiagnosed CTE sufferers.

Not just football. Soccer, lacrosse, hockey, rugby, MMA, Volleyball, cheerleading, skiing. Any sport or activity where head injuries occur is a Petrie dish for concussion and potential progressive brain disease.

The Suicide Epidemic among service members and Veterans continues. Over 158,000 Veteran suicides since 9/11. Billions of dollars spent on Suicide Prevention programs, call centers, polls, data centers, conferences, research studies, White Papers, reorganizations, hotlines, cross-sector coordination and collaboration, "means restrictions" , outside consultants, videos, public service announcements, mental health support, "post-attempt care" and followup, more funding, and appeals for more "responsible reporting."

Five Bills in the Congress are awaiting votes in the House and Senate to get help to Veterans suffering brain wounds from TBI/PTSD. Over 66,000 organizations claim to be helping Veterans lead better lives offering hundreds of millions of pills, and billions of dollars on unproven, off-label interventions and drugs. Not even half of Veterans are enrolled in the VA. and long-term neurodegeneration → symptoms of and eventual discovery of CTE.

A line from Bob Dylan's "Subterranean Homesick Blues" is apropos: "You don't need a weatherman to see which way the wind blows."

We already know that wounding the brain causes damage that can lead to premature suffering and death. Twenty years of research into CTE and TBI and PTSD and BLAST injuries concur that banging your head hard enough to cause damage is tantamount to inflicting brain wounds. Nevertheless, current standards of care for these injuries does not include brain wound healing. But you can find billions of dollars for programs that don't work and research that focuses on amost anything except actually using proven means to heal those brain wounds and end the symptoms and continuing brain deterioration.

The five Bills in Congress mentioned above aim to upgrade and modernize how the DoD and VA conceive of and treat TBI/PTSD. All are directly or indirectly tied to the use of alternative therapies, especially Hyperbaric Oxygen Therapy (HBOT):

S.3130 - Veterans TBI Adaptive Care Opportunities Nationwide Act of 2025. S.2737 - Veterans National Traumatic Brain Injury Treatment Act. S.862 - HBOT Access Act of 2025. H. R. 1336 - Veterans National Traumatic Brain Injury Treatment Act. H. R. 72 - TBI and PTSD Treatment Act.

Congressional members are frustrated with a VA and DoD which continue to spend hundreds of millions on Suicide Prevention without bringing the suicide rate down. Further, they recognize the results of thirteen states that have already enacted and funded HBOT state legislation totaling more than $33 million: IN, KY, AZ, FL, NC, MD, VA, OK, TX, WY, TN, ND, and MO, with seven more states drafting Bills for the same purposes.

Those states recognize that:

- Veteran suicides increased from 2000-2024 (now over 157,000) and that they can interrupt that cycle. Annual reports on their programs prove the worth of treatment. - Veterans have been misdiagnosed or had their brain wounds ignored, and that Veterans and athletes with TBI are twice as likely to commit suicide. - Inadequate VA and the medical community standards of care palliate mental health symptoms with off-label non-FDA approved drugs and or counseling, with little to no appreciable effect on brain wound healing. - TBI is a physical brain wound, resulting in debilitating mental, physical, behavioral, moral, and psychological health symptoms. - Current VA treatment protocols to palliate TBI symptoms cost the US Government $118.1 billion annually, $4.7T over 40-year life span. Treatment with HBOT can be done for less than ½ of 1% of lifetime cost , while restoring a Quality of Life denied to Veterans on disability, drugs, and diminished ability to function without help. - 28 clinical trials and studies encapsulating 900+ Veterans demonstrating safety and efficacy since 2007. - Israeli Defense Forces and Ukraine, along with thousands of athletes worldwide use HBOT for TBI/PTSD, to retain military force levels, heal wounds of all kinds, and to ensure peak performance and resilience. - DoD could help meet requirements, military operational needs, and force readiness through immediate intervention with HBOT. They recognize that the 1990 Textbook of Military Medicine has approved HBOT for Blast Wave TBIs for 35-years. Over 12,500+ Veterans have been successfully treated, along with over 750 Special Operators. Successes are found in 100+ TBI Veteran video testimonials: lives restored and suicidal ideation eliminated. Heal Brains. Stop Suicides. Restore Lives. TreatNOW with HBOT

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The TreatNOW Mission is ending service member suicides. Along the way, we have learned that we can end suicidal ideation, help end symptoms of PTSD, get patients off most of their drugs, and heal brain wounds to end the effects of Concussion, BLAST injury, mild TBI, Persistent Post Concussive Syndrome, and polytrauma from AHI, Burn Pits, and COVID. No Veteran or civilian has ever been killed while undergoing HBOT treatment for TBI/PTSD.

October 24, 2025 McLean, Virginia

MAJ Ben Richards (USA, Ret) knows two big things from his experience in Baqubah, Iraq in 2006-7. It he was to succeed with his mission of forging political bonds with warring factions, he had to understand their culture, and he had to build trust.

In what became an ingenious tactic born of his Mormon missionary work among the Chinese community in Canada years earlier, CAPT Richards took off his battle rattle, disarmed, and sat down with leaders of opposing forces to work out agreements. This cooperation with local Sunni Muslim militias became part of the Sunni Awakening, for years after a growing success.

CAPT Richard's daring insights were chronicled by Michael Gordon in the New York Times in 2007. The success of this and other tactics led to the introduction of female "cultural support teams" into the theater in 2009. They could go and learn where males could not.

The essence of the progression of the Awakening: know what you're doing by knowing the environment in which you're operating. To quote Sun Tzu: “If you know the enemy and know yourself, you need not fear the result of a hundred battles. If you know yourself but not the enemy, for every victory gained you will also suffer a defeat. If you know neither the enemy nor yourself, you will succumb in every battle.”

MAJ Richards became a war casualty. His saga with his brain wounds and journey back to a PhD and restoration of his family and his life are one story in hundreds of thousands. The difficulty is with what Nicholas Kristof called "how America is failing its soldiers and veterans, honoring them with lip service and ceremonies but breaking faith with them on all that matters most."

Little has changed in the VA in the years since Ben found Hyperbaric Oxygen Therapy. The "dialogue of the deaf" continues between suffering Veterans and representatives of the VA and DoD who cling to their inadequate standard of care. The longstanding protocols for dealing with "mental health" issues, to include both PTSD and TBI, remain known failures for complex, combat-wounded Veterans.

The VA's own reporting admits as much. In a 2020 report, First-line Psychotherapies for Military-Related PTSD, findings for military and veteran populations with PTSD include:

- First‐line trauma‐focused therapies like cognitive processing therapy (CPT) and prolonged exposure therapy (PE) do not produce meaningful symptom reduction in a substantial fraction of combat patients - A large proportion remain persistently symptomatic, and many do not reach full remission. - Trauma-focused therapies may not perform substantially better than non‐trauma‐focused or supportive interventions in these populations, which is somewhat unexpected given their “gold‐standard” status in many guidelines. - Therefore, clinicians and policymakers should recognize the complexity of military‐related PTSD and consider flexible, perhaps stepped or combined treatment plans rather than assuming a single therapy will suffice for most.

These facts accompany the current damage being done to the VA through professional attrition. The VA has lost more than 6,000 clinicians since January: (nurses ~3,100; medical assistants ~1,300; doctors ~800; social workers ~500; psychologists ~150) as of August 2025. Another source states: in the first 9 months of FY 2025 the VA had 418 fewer registered nurses, 139 fewer medical officers/physicians, 107 fewer social workers, plus declines in other clinical occupations.

At the same time, the rate of severe reported staffing shortages is extremely high: ~79-94% of VA facilities report severe shortages for doctors and nurses, and many mental-health-related provider types are also highly impacted. These two facts together suggest that the VA’s ability to recruit and retain enough providers is under serious strain.

So here we are: ineffective treatments; shrinking professional staff; a continuing Veteran suicide epidemic; and over 877,000 TBI/PTSD Veterans in need of help.

Imagine for a moment that we treat the "Invisible Wounds of War" epidemic the way CAPT Richards confronted sectarian violence in Baqubah. How to quell the violence, understand the problem, and build trust among the factions, and unite for a common purpose?

Few who deal with individuals within the VA complain of mendacity or ill intent on the part of individuals. But the overall picture painted by thousands of Veterans who seek help outside that system paint a picture of a "deep state" culture in need of change. Consider some of the reporting: Wounding Warriors: How Bad Policy Is Making Veterans Sicker and Poorer; Mission Betrayed: How the VA Really Fails America's Vets; Broken Promises; It Shouldn't Be This Hard to Serve Your Country; Service Denied: Marginalized Veterans in the 20th and 21st Centuries; and the prize-winning reporting by Dave Philipps at the New York Times.

Experts who deal with seemingly intractable conflict -- think government shutdown -- come round to central principles in human relations. The quick messages are consistent: Effective negotiators unite empathy and principle. They expand the conversation and the possibilities. To create peace and make progress, it is imperative to uncover deeper human needs and uphold shared values.

In the next issue, we're going to explore A.I. assisted answers to a fundamental question for Veterans suffering from Invisible Brain Wounds: Beginning with the best books on negotiations aimed at peaceful resolution of differences, can you help me construct a strategy to negotiate with the Veterans Administration about how to treat brain-wounded Veterans with alternate, scientifically-proven therapies?

We intend to explore realistic paths forward that can make the VA and DOD real heroes to the Veterans so in need of help for their brain wounds. The Awakening has to happen on both sides, those that resist, and those that need to understand that resistance. We need to find ways to sit with decision makers to construct the roadmap to success.

Congress is going to come back into session, and we need to be ready with positive and negotiated answers to questions that will reduce suicides and transform medical practice regarding brain wound healing.

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The TreatNOW Mission is ending service member suicides. Along the way, we have learned that we can end suicidal ideation, help end symptoms of PTSD, get patients off most of their drugs, and heal brain wounds to end the effects of Concussion, BLAST injury, mild TBI, Persistent Post Concussive Syndrome, and polytrauma from AHI, Burn Pits, and COVID. No Veteran or civilian has ever been killed while undergoing HBOT treatment for TBI/PTSD. For a video Summary, see: https://www.youtube.com/@treatnowdotorg/videos  

Over eighty years ago, the U.S. made what some would call a Faustian bargain: help us get to the atomic bomb before Germany and we'll live with the consequences. Well, the Japanese were forced to swallow the medicine we brewed for the Germans, but the world is living with the consequences.

Similarly, Veterans made a deal with the US Government: we signed a blank check payable with our lives and health; in return, you will take care of us and our families. The check has come due: 7,000 combat deaths, over 53,000 visibly wounded, and 875,000 invisibly brain-wounded service members. Parallels between the nuclear weapons and health care industries are stark. And the distrust levels among victims of each industry continue to mount.

Investigative reporter Duane Pohlman has created a searing documentary on one aspect of the Nuclear Weapons Industry, FALLOUT: Contamination, Cancer, and Death. Pohlman's 5-year award-winning reporting highlights several aspects of an 80+ year saga:

- people in the town surrounding the Portsmouth Ohio Gaseous Diffusion/PORTS plant are dying from cancers at rates exceeding the norm for the US - the government covers up facts and misreports scientific evidence, substituting questionable reports for unbiased statistics - national security secrets and actions continue to take lives long after the plant has closed - cleaning up the contamination may never happen, passing along genetic and environmental risks and alterations for generations - Recent data (2021–2023) showed that premature death rates (under age 74) were 107% higher than the national average. In a population of just over 27,000, this corresponds to over 750 premature deaths during that period. Some studies indicate nearly 10,000 lives negatively affected by PORTS.

The U.S. Department of Energy (DOE) originally had 107 major nuclear weapons and research sites requiring cleanup, but only 15 sites in 11 states remain active today.

Aside from "Atoms for War," the companion "Atoms for Peace" program gave us radioactive substances which are widely used in medicine — particularly in diagnosis and treatment — and many of them are safe when used properly in controlled clinical environments. "Good" radiation is benign when properly used, and is safely used hundreds of thousands of times per day worldwide.

The "bad" radiation is essentially with us forever. Some radioactive substances are extremely dangerous to human health, especially when inhaled, ingested, or when there is prolonged or high-dose exposure. The most dangerous are Polonium, Plutonium, Cesium, Strontium, Iodine, Radon, Americium, Uranium, Tritium, and Cobalt. Well known accidents include: Three Mile Island, Chernobyl, and Fukushima. The few deaths caused by commercial accidents pale in comparison to Nagasaki and Hiroshima (>250,000) and nuclear fallout . Atmospheric nuclear testing appears to have killed hundreds of thousands—possibly into the millions—globally. Hundreds of thousands to nearly a million Americans were affected in varying ways. Over 568,000 additional infant deaths probably occurred in U.S., and possibly several million globally.

So, hundreds of thousands had their lives cut short due to nuclear weapons work, and damage continues. What's the relationship to Veterans? And what about the VA is toxic and life threatening, if not radioactive? And how are the parallels significant for a "cure" that these institutions won't provide for casualties?

TreatNOW has feet in both worlds. The author has a long and deep history with the nuclear industry and has been fighting pro bono with a Coalition of Veterans and others for justice and Veteran brain wound healing for seventeen years. Duane Pohlman's expose threw us together again on national issues that affect millions of lives. There can be no justice and return to health and more normal lives for Veterans or civilians while DOE and the VA continue to mask central truths about the damage already done. Facts, science, and a plan for cleanup, treatment, and accountability are what Veterans with brain wounds and citizens suffering from toxins and radioactive contamination need, NOW.

DOE and the VA are two giants in the US Government. The VA is the sixth largest Department in the government with a budget of $369.3 Billion. The DOE is the 12th largest with a budget of $52 Billion. They embody what some see a "the deep state", wielding several central attributes related to power, structure, belief, and control:

- "Priesthoods" operating out of hierarchical structure. - Centralized, culture-dependent decision-making by an ideology espoused by their intellectual elite. - Social control: With little accountability -- augmented by lack of independent oversight -- neither the VA nor the DOE deviate from subtle control and reversion to rules and regulations that effectively prevent challenge. - Common purpose or goals: For the VA, "Veterans come first." For the DOE, "Safety, national security, research and innovation." Any change in leadership doesn't touch the protective shell the bureaucracy has built to fend off disturbing facts and law suits. - A justifying narrative: Each entity operates with a foundational set of ideas, or an ideology, that justifies its structure, authority, and goals. "Trust us" is the mantra to Veterans and citizens alike, despite decades of scandals and mismanagement. - Resistance to change: The narratives from both DOE and the VA are relatively unchanged after decades of increasing deaths, neglect, statistical sleight-of-hand, and ignoring scientific facts and progress. - Commitment and loyalty. This is the closed self-serving network of contractors, researchers, Foundations, academia, Congress, military, and the chain of command. This fosters an in-group versus out-group antagonism. 

Here is the crux of why so many Veterans consider the VA toxic and "radioactive." They stay away or abandon the VA because the culture and practice of the VA -- medicine in general -- is to treat brain wounds like they do mental health symptoms. No brain wound healing is possible in the current system. Pills and talk therapy rule.

The Interventions/Treatments for PTSD/TBI/Concussion supported by the NICoE, Warrior Transition Units, Intrepid Spirit Centers, Defense Veterans Brain Injury Centers, Walter Reed National Military Medical Center and across DOD/VA/military medical treatment and contractor facilities are administered without an overall Protocol. The Department of Veterans Affairs claims that the four most impressive and effective interventions are:

· Psychopharmacology

· Prolonged Exposure (PE), AKA Trauma-Focused Psychotherapy

· Cognitive Processing Therapy (CPT)

· Eye Movement Desensitization and Reprocessing (EMDR)

The next BLOG will dig deeper into this flawed and unsuccessful approach. We will explore the fundamental misapprehension in current approaches to TBI/PTSD, including why they won't even talk about brain wounds or mention HBOT to Veterans.

Like the citizens around PORTS in Ohio who have been reduced to resignation, depression and anger over being ignored by DOE, Veterans can't get simple truths about what's really behind their symptoms, much less a prescription for the only treatment backed by worldwide peer-reviewed science to heal brain wounds, stop suicidal ideation, and restore Quality of Life.

HBOT. Heal Brains. Stop Suicides. Restore Lives. TreatNOW.

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The TreatNOW Mission is ending service member suicides. Along the way, we have learned that we can end suicidal ideation, help end symptoms of PTSD, get patients off most of their drugs, and heal brain wounds to end the effects of Concussion, BLAST injury, mild TBI, Persistent Post Concussive Syndrome, and polytrauma from AHI, Burn Pits, and COVID. No Veteran or civilian has ever been killed while undergoing HBOT treatment for TBI/PTSD. For a video Summary, see: https://www.youtube.com/@treatnowdotorg/videos  

Information provided by TreatNOW.org does not constitute a medical recommendation. It is intended for informational purposes only, and no claims, either real or implied, are being made.