With no explanation, chose the best option from "A", "B", "C" or "D". S. Rep. No. 102-342, at 47 (1992). 15 . 28 U.S.C. § 2679, the Westfall Act, does not provide for substitution for . claims "brought for a violation of the Constitution” or claims brought for violations of statutes which otherwise authorize a cause of action against the named defendant. 28 U.S.C. § 2679(b)(2). A Bivens action, discussed in Section III.C infra, would be the cause of action for pursuing such claims against the Federal Defendants individually. 16 . Defendants raised a third argument: Plaintiffs’ apparent failure to administratively exhaust their claim pursuant to 28 U.S.C. § 2675(a). (Def.’s Mot. at 22-23). Because there is some doubt as to whether that requirement is jurisdictional, see, e.g., United States v. Wong, — U.S. -, 135 S.Ct. 1625, 191 L.Ed.2d 533 (2015) (<HOLDING>), and because other bars to jurisdiction exist

A: recognizing that exhaustion is mandatory and jurisdictional
B: holding that exhaustion of issues is jurisdictional
C: holding that exhaustion is mandatory and jurisdictional
D: holding that provision requiring exhaustion within two years of injury was not jurisdictional and was subject to tolling
D.