D.W. and Department of Veterans Affairs, William Jennings Bryan Dorn VA Medical Center (Board decision, March 28, 2024)
Board upholds prior arm impairment awards for VA technician (ECAB 23-1046)
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ECAB final decision. The Board affirmed OWCP’s denial of a higher award than five percent right and three percent left arm impairment. A party may petition the Board for reconsideration within 30 days of issuance unless this order specifies another period, under 20 C.F.R. § 501.7(a). FECA compensation decisions are generally not subject to court review under 5 U.S.C. § 8128(b).
Plain-English summary
A VA pharmacy technician sought increased schedule awards for both arms after accepted carpal tunnel and right thumb conditions. Conflicting medical opinions prompted an impartial examination. The examiner found no ratable impairment from the accepted conditions on current examination, and the Board gave his reasoned opinion special weight. She therefore did not establish an increase above the amounts previously awarded.
Decision snapshot
- Authority: FECA impartial medical examination under 5 U.S.C. § 8123(a) and schedule award rating.
- Outcome: May 9, 2023 decision affirmed; prior five and three percent awards not increased.
- Key point: A well reasoned impartial examiner can resolve conflicting impairment opinions.
Full text (ECAB public release)
United States Department of Labor
Employees’ Compensation Appeals Board
________
)
D.W., Appellant
)
)
and ) Docket No. 23-1046
) Issued: March 28, 2024
DEPARTMENT OF VETERANS AFFAIRS,
)
WILLIAM JENNINGS BRYAN DORN VA
)
MEDICAL CENTER, Columbia, SC, Employer
)
__________ )
Appearances: Case Submitted on the Record
Alan J. Shapiro, Esq., for the appellant1
Office of Solicitor, for the Director
DECISION AND ORDER
Before:
ALEC J. KOROMILAS, Chief Judge
JANICE B. ASKIN, Judge
VALERIE D. EVANS-HARRELL, Alternate Judge
JURISDICTION
On August 2, 2023 appellant, through counsel, filed a timely appeal from a May 9, 2023 merit decision of the Office of Workers’ Compensation Programs (OWCP). Pursuant to the Federal Employees’ Compensation Act2 (FECA) and 20 C.F.R. §§ 501.2(c) and 501.3, the Board has jurisdiction over the merits of this case.
1
In all cases in which a representative has been authorized in a matter before the Board, no claim for a fee for legal or other service performed on appeal before the Board is valid unless approved by the Board. 20 C.F.R. § 501.9(e). No contract for a stipulated fee or on a contingent fee basis will be approved by the Board. Id. An attorney or representative’s collection of a fee without the Board’s approval may constitute a misdemeanor, subject to fine or imprisonment for up to one year or both. Id.; see also 18 U.S.C. § 292. Demands for payment of fees to a representative, prior to approval by the Board, may be reported to appropriate authorities for investigation. 2 5 U.S.C. § 8101 et seq.
ISSUE
The issue is whether appellant has met her burden of proof to establish greater than five percent permanent impairment of her right upper extremity and three percent permanent impairment of her left upper extremity, for which she previously received schedule award compensation.
FACTUAL HISTORY
This case has been previously before the Board on a different issue. The facts and circumstances of the case as set forth in the Board’s prior decision are incorporated herein by reference.3 The relevant facts are as follows.
On December 13, 2017 appellant, then a 51-year-old pharmacy technician, filed an occupational disease claim (Form CA-2) alleging that she sustained bilateral carpal tunnel syndrome (CTS) and acquired trigger finger of the right thumb due to factors of her federal employment. She noted that she first became aware of her condition and realized that it was caused or aggravated by her federal employment on June 16, 2017. OWCP accepted the claim for bilateral CTS and right trigger thumb. Appellant underwent right carpal tunnel and right trigger thumb releases on August 24, 2017 and left carpal tunnel release on February 22, 2018. She stopped work on August 23, 2017. OWCP paid appellant wage-loss compensation for intermittent disability on the supplemental rolls from October 17, 2017 through May 4, 2018.4
On May 4, 2020 appellant filed a claim for compensation (Form CA-7) for a schedule award.
In a May 5, 2020 development letter, OWCP indicated that appellant’s claim had been accepted for bilateral CTS and right trigger thumb. It requested that she provide a medical report, which included an impairment rating utilizing the sixth edition of the American Medical Association, Guides to the Evaluation of Permanent Impairment (A.M.A., Guides).5 OWCP afforded appellant 30 days to submit the requested information. Appellant submitted medical evidence and a CA-7 and several CA-7a forms.
By decision dated July 23, 2020, OWCP denied appellant’s schedule award claim, finding that the medical evidence of record was insufficient to establish that her CTS condition had reached a fixed and permanent state or that she was given a permanent impairment of a scheduled member or function of the body as a result of her accepted June 16, 2017 employment injury.
On July 31, 2020 appellant, through counsel, requested a telephone hearing before a representative of OWCP’s Branch of Hearings and Review.
3
Docket No. 18-0876 (issued March 10, 2020).
4
Appellant retired from federal service effective December 6, 2019.
5
A.M.A., Guides (6th ed. 2009).
2
OWCP thereafter received a June 8, 2020 narrative report by Dr. Ralph D’Auria, a Board- certified physical medicine and rehabilitation specialist, who noted appellant’s history of bilateral wrist and right thumb pain since the June 16, 2017 employment injury and outlined her medical and surgical treatment. Dr. D’Auria performed a physical examination which revealed decreased sensation in the palmar and dorsal aspects of the both hands and all fingers; reduced range of motion (ROM) in extension and flexion of the left wrist; normal ROM of the right wrist, bilateral elbows, and right thumb; decreased grip strength in both hands; weakness of the left interossei; negative Tinel’s test bilaterally over the median nerve at the wrist and ulnar nerve at the wrist and elbow; and positive Phalen’s test bilaterally. He diagnosed bilateral CTS and right trigger thumb and opined that appellant had reached maximum medical improvement (MMI) as of June 8, 2020.
Regarding the upper extremities, Dr. D’Auria utilized the diagnosis-based impairment (DBI) rating method, under Table 15-23, Entrapment/Compression Neuropathy Impairment, page 449 of the A.M.A., Guides6 for CTS of each wrist and assigned a grade modifier for physical examination (GMPE) of 2 for decreased sensation per Table 15-23 for CTS, a grade modifier for function history (GMFH) of 3 for constant symptoms per Table 15-23 for CTS, and a grade modifier for clinical studies (GMCS) of 0 per Table 15-23 for CTS, which resulted in an average grade modifier of 2, or a default value of five percent. He noted that appellant had a QuickDASH score of 80, which increased the impairment rating for CTS to six percent permanent impairment of the right upper extremity for right-sided CTS and six percent permanent impairment of the left upper extremity for left-sided CTS.
Regarding the right thumb, Utilizing Table 15-2, Digit Regional Grid, page 392, Dr. D’Auria found that a class of diagnosis (CDX) for symptomatic trigger finger after surgery resulted in a Class 1 impairment, with a default value of six percent impairment. He assigned a GMFH of 2 for pain/symptoms with normal activity, a GMPE of 1 for mildly decreased ROM, and GMCS not applicable. Dr. D’Auria concluded that appellant had a net adjustment of 1, which resulted in a higher rating of seven percent digit impairment, or three percent of the right upper extremity.
Following a preliminary review, by decision dated September 23, 2020, OWCP’s hearing representative vacated the July 23, 2020 decision and remanded the case for consideration of Dr. D’Auria’s June 8, 2020 report by a district medical adviser (DMA).
On October 2, 2020 OWCP routed Dr. D’Auria’s report, along with a statement of accepted facts (SOAF) and the case record, to Dr. Morley Slutsky, a physician Board-certified in occupational medicine serving as OWCP’s DMA, for review and evaluation of appellant’s permanent impairment pursuant to the sixth edition of A.M.A., Guides.7
In an October 18, 2020 report, Dr. Slutsky indicated that he had reviewed the SOAF and the medical record, including Dr. D’Auria’s June 8, 2020 report, and agreed that appellant had reached MMI on June 8, 2020. He noted that the A.M.A., Guides did not allow for an impairment rating under the ROM method for CTS. Dr. Slutsky utilized the DBI method under Table 15-23,
6
Id.
7
Id.
3 page 449, and found a right upper extremity impairment rating of three percent for right-sided CTS and a left upper extremity impairment of three percent for left-sided CTS. With respect to Dr. D’Auria’s differing impairment ratings, Dr. Slutsky observed that he provided a lower GMFH, as appellant did not have either a conduction block or axon loss present on electrodiagnostic testing. He also noted that Dr. D’Auria provided a lower GMPE, as he did not provide any documentation of the upper extremity sensory testing performed, grip/pinch strength cannot be used to rate CTS due to multiple nerve involvement, and there was no documentation of atrophy specific to median nerve dysfunction.
With regard to the right thumb, Dr. Slutsky noted that Dr. D’Auria did not document any right thumb triggering or residuals as of the date of MMI, and the thumb ROM was within normal limits with no specific clinical deficits noted during the June 8, 2020 examination. He opined that there was no basis for a right thumb trigger finger rating.
On October 26, 2020 OWCP forwarded Dr. Slutsky’s October 18, 2020 report to Dr. D’Auria for his review and comment.
In a November 25, 2020 addendum report, Dr. D’Auria indicated that he reviewed Dr. Slutsky’s October 18, 2020 report and clarified that he did observe triggering of the right thumb during his physical examination on June 8, 2020. He explained that he reviewed Dr. Slutsky’s handwritten notes and that Dr. Slutsky had documented findings of triggering of the right thumb therein but had failed to note the findings in his report. Dr. D’Auria opined that his previously issued impairment ratings for appellant remained unchanged.
On December 22, 2020 OWCP forwarded the November 25, 2020 addendum report by Dr. D’Auria to Dr. Slutsky.
In a January 8, 2021 addendum report, Dr. Slutsky reviewed Dr. D’Auria’s November 25, 2020 report and opined that his ratings for permanent impairment of the bilateral upper extremities due to CTS remained unchanged. Regarding the right trigger thumb, he amended his rating to six percent digit impairment, which equated to a two percent right upper extremity impairment, for a total right upper extremity impairment of five percent and a total left upper extremity impairment of three percent. Dr. Slutsky explained that he excluded Dr. D’Auria’s QuickDASH score of 80 for the right trigger thumb because the functional history was determined to be unreliable or inconsistent with other documentation.8
In a January 14, 2021 letter, OWCP advised appellant that it would be referring her for a second opinion evaluation to aide in determining whether she had sustained a permanent impairment due to her accepted June 16, 2017 employment injuries.
By decision dated January 21, 2021, OWCP granted appellant a schedule award for five percent permanent impairment of the right upper extremity (right arm) and three percent permanent impairment of the left upper extremity (left arm). The date of MMI was found to be June 8, 2020.
8
A.M.A., Guides 406.
4
The award covered a period of 24.96 weeks and ran from June 8 through November 29, 2020. OWCP noted that weight of the medical evidence rested with the DMA, Dr. Slutsky.
On February 1, 2021 appellant, through counsel, requested an oral hearing before a representative of OWCP’s Branch of Hearings and Review.
On February 1, 2021 OWCP referred appellant, a copy of the case record, and a series of questions to Dr. Seth Jaffe, a Board-certified orthopedic surgeon, for a second opinion evaluation. In a February 23, 2021 report, Dr. Jaffe outlined the history of the accepted June 16, 2017 employment conditions, his review of the medical record and SOAF, and appellant’s current symptoms, which included tingling down the entire left arm. He documented his physical examination findings and diagnosed bilateral CTS and right trigger thumb. Utilizing the DBI rating method, Dr. Jaffe found no permanent impairment of the upper extremities. He found that the date of MMI was June 8, 2020, and explained that his examination revealed normal gross sensation, intact ROM, normal strength, and no atrophy of either hand or wrist.
Following a preliminary review, by decision dated April 5, 2021, OWCP’s hearing representative set aside the January 21, 2021 decision and remanded the case for consideration of Dr. Jaffe’s February 23, 2021 report by a DMA. The hearing representative noted that OWCP had undertaken a second opinion evaluation regarding appellant’s permanent impairment, but issued a schedule award decision before the evaluation took place.
On April 7, 2021 OWCP routed Dr. Jaffe’s February 23, 2021 report, along with a SOAF and the case record, to the DMA, Dr. Slutsky.
In an April 10, 2021 addendum report, Dr. Slutsky reviewed Dr. Jaffe’s February 23, 2021 report and agreed that his examination findings resulted in no permanent impairment of either upper extremity under the sixth edition of the A.M.A., Guides. He further noted that the date of MMI was February 23, 2021, the date of Dr. Jaffe’s examination.
On May 12, 2021 OWCP requested clarification from Dr. Slutsky. It noted that appellant had been previously awarded compensation for five percent of the right upper extremity and three percent of the left upper extremity and requested that he advise whether the ratings reflected in his April 10, 2021 addendum report included the prior percentage awarded or should be considered in addition to the prior percentage awarded.
In an addendum report dated May 29, 2021, Dr. Slutsky noted appellant’s prior awards and opined that, based upon his review of Dr. Jaffe’s February 23, 2021 report, “there is no change to the prior accepted right upper extremity award of five percent” and “no change to the prior accepted left upper extremity award of three percent.”
By decision dated July 2, 2021, OWCP granted appellant a schedule award for five percent permanent impairment of the right upper extremity (right arm) and three percent permanent impairment of the left upper extremity (left arm). The date of MMI was found to be June 8, 2020.
5
The award covered a period of 24.96 weeks and ran from June 8 through November 29, 2020.9 OWCP noted that weight of the medical evidence rested with Dr. Slutsky, the DMA.
On July 7, 2021 appellant, through counsel, requested a telephonic hearing before a representative of OWCP’s Branch of Hearings and Review in regard to the July 2, 2021 decision.
Following a preliminary review, by decision dated October 6, 2021, OWCP’s hearing representative vacated the July 2, 2021 decision. The hearing representative found a conflict of medical opinion evidence between Dr. Jaffe, for the government, and Dr. D’Auria, for appellant, regarding physical examination findings and the appropriate percentage of permanent impairment of the upper extremities. To resolve the conflict, the hearing representative remanded the case to OWCP to refer appellant, the medical record, a SOAF, and a series of questions to a physician in the appropriate field of medicine to conduct an impartial medical evaluation of appellant’s permanent impairment pursuant to the sixth edition of A.M.A., Guides.
On April 22, 2022 OWCP referred appellant to Dr. Joseph Estwanik, a Board-certified orthopedic surgeon serving as the impartial medical examiner (IME).
In a June 27, 2022 report, Dr. Estwanik outlined the results of his August 28, 2021 evaluation and noted that appellant had undergone bilateral carpal tunnel release surgeries and that a May 2, 2018 postoperative electromyography and nerve conduction velocity (EMG/NCV) study had demonstrated no electrodiagnostic evidence of median ulnar neuropathy and improved median nerve conduction. He documented subjective complaints of numbness and tingling at night in both hands and swelling at the right thumb tendon. Dr. Estwanik performed a physical examination, which revealed negative Tinel’s sign and Phalen’s test bilaterally, local pain in the wrist crease without radiation or tingling, full function of the hands and fingers, no swelling or interosseous muscle or thenar eminence atrophy, no observable or palpable crepitance or triggering at the right flexor pollicis longus tendon pulley, and no abnormal palpation at the A1 pulley with repetitive flexion movements. He indicated that appellant’s subjective complaints were not supported by accurate anatomic objective testing and that he found nonanatomic, nonphysiologic symptom magnification during sensory testing.
Utilizing the sixth edition of the A.M.A., Guides, Dr. Estwanik opined that there was “no physical examination ratable basis for abnormality” and that “the impairment for right and left [CTS] and right trigger thumb is 0.” He noted that he found no positive physical examination findings consistent with bilateral CTS or right trigger thumb. Dr. Estwanik indicated that the date of MMI was February 23, 2021, the date of Dr. Jaffe’s examination.
By decision dated October 28, 2022, OWCP denied appellant’s claim for an increased schedule award.
9
The record reflects that OWCP had paid appellant a schedule award claim for the period June 8 through November 29, 2020 on January 29, 2021. The July 2, 2021 decision indicated that “no additional award or payment” was due.
6
On November 1, 2022 appellant, through counsel, requested a hearing before a representative of OWCP’s Branch of Hearings and Review, which took place on April 5, 2023.
By decision dated May 9, 2023, OWCP’s hearing representative affirmed the October 28, 2022 decision, finding that the special weight of the medical evidence rested with the IME, Dr. Estwanik.
LEGAL PRECEDENT
The schedule award provisions of FECA10 and its implementing regulations11 set forth the number of weeks of compensation payable to employees sustaining permanent impairment from loss or loss of use, of scheduled members or functions of the body. FECA, however, does not specify the manner in which the percentage of loss of a member shall be determined. The method used in making such determination is a matter which rests in the sound discretion of OWCP. For consistent results and to ensure equal justice, good administrative practice necessitates the use of a single set of tables so that there may be uniform standards applicable to all claimants. The A.M.A., Guides has been adopted by OWCP as a standard for evaluation of schedule losses and the Board has concurred in such adoption.12 For schedule awards after May 1, 2009, the impairment is evaluated under the sixth edition of the A.M.A., Guides, published in 2009.13
It is the claimant’s burden of proof to establish permanent impairment of the scheduled member or function of the body as a result of an employment injury.14 OWCP procedures provide that, to support a schedule award, the file must contain competent medical evidence which shows that the impairment has reached a permanent and fixed state and indicates the date on which this occurred (date of MMI), describes the impairment in sufficient detail so that it can be visualized on review, and computes the percentage of impairment in accordance with the A.M.A., Guides.15
In addressing impairment for the upper extremities under the sixth edition of the A.M.A., Guides, an evaluator must establish the appropriate diagnosis for each part of the upper extremity to be rated.16 After a CDX is determined (including identification of a default grade value), the
10
Supra note 2.
11
20 C.F.R. § 10.404.
12
Id.; see also Jacqueline S. Harris, 54 ECAB 139 (2002).
13
Federal (FECA) Procedure Manual, Part 2 -- Claims, Schedule Awards and Permanent Disability Claims, Chapter 2.808.5a (March 2017); id. at Part 3 -- Medical, Schedule Awards, Chapter 3.700.2 and Exhibit 1 (January 2010). 14 E.D., Docket No. 19-1562 (issued March 3, 2020); Edward Spohr, 54 ECAB 806, 810 (2003); Tammy L. Meehan, 53 ECAB 229 (2001).
15
Supra note 13 at Chapter 2.808.5 (March 2017).
16
M.D., Docket No. 20-0007 (issued May 13, 2020); T.T., Docket No. 18-1622 (issued May 14, 2019).
7 impairment class is then adjusted by grade modifiers based on GMFH, GMPE, and GMCS.17 The net adjustment formula is (GMFH - CDX) + (GMPE - CDX) + (GMCS - CDX).18
Regarding the application of ROM or diagnosis-based impairment (DBI) methodologies in rating permanent impairment of the upper extremities, FECA Bulletin No 17-06 provides:
“As the [A.M.A.,] Guides caution that if it is clear to the evaluator evaluating loss of ROM that, a restricted ROM has an organic basis, three independent measurements should be obtained and the greatest ROM should be used for the determination of impairment, the CE [claims examiner] should provide this information (via the updated instructions noted above) to the rating physician(s).”19
The FECA Bulletin further advises:
“Upon initial review of a referral for upper extremity impairment evaluation, the DMA should identify: (1) the methodology used by the rating physician (i.e., DBI or ROM); and (2) whether the applicable tables in Chapter 15 of the [A.M.A.,] Guides identify a diagnosis that can alternatively be rated by ROM.”20
Impairment due to CTS is evaluated under Table 15-23 (Entrapment/Compression Neuropathy Impairment) and accompanying relevant text.21 In Table 15-23, grade modifier levels (ranging from zero to four) are described for the categories of test findings, history, and physical findings. The grade modifier levels are averaged to arrive at the appropriate overall grade modifier level and to identify a default rating value. The default rating value may be modified up or down based on functional scale, an assessment of impact on daily living activities (QuickDASH).22
OWCP’s procedures provide that, after obtaining all necessary medical evidence, the file should be routed to OWCP’s DMA for an opinion concerning the nature and percentage of impairment in accordance with the A.M.A., Guides, with the DMA providing rationale for the percentage of impairment specified.23
Section 8123(a) of FECA which provides that, if there is disagreement between the physician making the examination for the United States and the physician of the employee, the
17
A.M.A., Guides 383-492; see M.P., Docket No. 13-2087 (issued April 8, 2014).
18
Id. at 411.
19
FECA Bulletin No. 17-06 (issued May 8, 2017); V.L., Docket No. 18-0760 (issued November 13, 2018).
20
Id.
21
A.M.A., Guides 449.
22
Id. at 448-49.
23
See supra note 13 at Chapter 2.808.6f) (February 2013). See also J.T., Docket No. 17-1465 (issued September 25, 2019); C.K., Docket No. 09-2371 (issued August 18, 2010); Frantz Ghassan, 57 ECAB 349 (2006).
8
Secretary shall appoint a third physician known as an IME who shall make an examination.24 This is called a referee examination and OWCP will select a physician who is qualified in the appropriate specialty and who has no prior connection with the case.25 The Board has long held that an OWCP DMA may create a conflict in medical opinion with an examining physician.26 When there exists opposing reports of virtually equal weight and rationale and the case is referred to an IME for the purpose of resolving the conflict, the opinion of such specialist, if sufficiently well rationalized and based upon a proper factual background, must be given special weight.27
ANALYSIS
The Board finds that appellant has not met her burden of proof to establish greater than five percent permanent impairment of her right upper extremity or greater than three percent permanent impairment of her left upper extremity, for which she previously received schedule award compensation.
OWCP properly found a conflict in medical opinion between Dr. D’Auria and Dr. Jaffe regarding the extent of permanent impairment in appellant’s upper extremities under the sixth edition of the A.M.A., Guides.28 In order to resolve the conflict, it referred her to Dr. Estwanik for an impartial medical evaluation, pursuant to 5 U.S.C. § 8123(a).
In his June 27, 2022 report, Dr. Estwanik, serving as the IME, opined that appellant had reached MMI as of February 23, 2021. Based upon his review of medical records and examination findings, he applied the A.M.A., Guides and opined that she had no permanent impairment of either upper extremity due to the accepted bilateral CTS or right trigger thumb. Dr. Estwanik explained that, on physical examination, appellant’s subjective complaints were not supported by accurate anatomic objective testing, and he found no positive physical examination findings regarding CTS or right trigger thumb present. He indicated that there was no physical examination ratable basis for abnormality and concluded that the impairment for right and left carpal tunnel syndrome and right trigger thumb was zero.
The Board finds that the special weight of the medical opinion evidence is represented by the thorough, well-rationalized opinion of Dr. Estwanik. Dr. Estwanik’s reports established that he properly applied the A.M.A., Guides to his examination findings. The Board finds that his opinion has reliability, probative value, and convincing quality with respect to its conclusions regarding the relevant issues of the present case. Dr. Estwanik provided a thorough factual and medical history, and he accurately summarized the relevant medical evidence. He properly utilized
24
5 U.S.C. § 8123(a); J.K., Docket No. 20-0907 (issued February 12, 2021); R.S., Docket No. 10-1704 (issued May 13, 2011); S.T., Docket No. 08-1675 (issued May 4, 2009); M.S., 58 ECAB 328 (2007). 25 20 C.F.R. § 10.321; R.C., 58 ECAB 238 (2006).
26
See G.W., Docket No. 16-0525 (issued August 2, 2017); Harold Travis, 30 ECAB 1071 (1979); see 20 C.F.R.
§ 10.321(b).
27
See J.K., supra note 24; Darlene R. Kennedy, 57 ECAB 414 (2006); Gloria J. Godfrey, 52 ECAB 486 (2001);
James P. Roberts, 31 ECAB 1010 (1980).
28
Supra note 5.
9 the DBI method to rate appellant’s accepted upper extremity conditions. As Dr. Estwanik’s report is detailed, well rationalized, and based on a proper factual background, his opinion represents the special weight of the medical evidence. Consequently, appellant has not met her burden of proof to establish greater than five percent permanent impairment of her right upper extremity or three percent permanent impairment of her left upper extremity, for which she previously received schedule award compensation.
Appellant may request a schedule award, or increased schedule award at any time based on evidence of a new exposure or medical evidence showing progression of an employment-related condition resulting in permanent impairment or increased permanent impairment.
CONCLUSION
The Board finds that appellant has not met her burden of proof to establish more than five percent permanent impairment of her right upper extremity or three percent permanent impairment of her left upper extremity, for which she previously received schedule award compensation.
ORDER
IT IS HEREBY ORDERED THAT the May 9, 2023 decision of the Office of Workers’ Compensation Programs is affirmed.
Issued: March 28, 2024
Washington, DC
Alec J. Koromilas, Chief Judge
Employees’ Compensation Appeals Board
Janice B. Askin, Judge
Employees’ Compensation Appeals Board
Valerie D. Evans-Harrell, Alternate Judge Employees’ Compensation Appeals Board
10
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