In Bowen v. Georgetown University Hospital, 488 U.S. 204, 212, 109 S.Ct. 468, 102 L.Ed.2d 493 (1988), however, the Supreme Court refused to extend Chevron deference (Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 844, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984)) when "the agency itself has articulated no position on the question." The Court explained that "deference to what appears to be nothing more than an agency's convenient litigating position would be entirely inappropriate." Id. Despite these admonitions, Auer v. Robbins, 519 U.S. 452, 461, 117 S.Ct. 905, 137 L.Ed.2d 79 (1997) explained that an agency's litigating position may be entitled to deference if it reflects the agency's "fair and considered judgment on the matter in question" and is not a "`post hoc rationalization.'" 519 U.S. at 462, 117 S.Ct. 905.