M.C. and Department of Veterans Affairs, William S. Middleton Memorial Veterans’ Hospital (Board decision, February 18, 2026)

ECAB remand decision. The Board reversed OWCP’s September 24, 2025 denial and remanded the claim for a decision on whether the diagnosed hamstring injury was caused by the workplace incident; benefits remain unresolved. 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 medical clerk reported injuring his left hamstring while lifting printer paper at work. The Board found that physicians had diagnosed a hamstring injury linked in time to the accepted incident. It reversed OWCP’s finding that no diagnosed condition had been established and sent the claim back for a separate decision on medical causation.

Decision snapshot

• Authority: Federal Employees’ Compensation Act, 5 U.S.C. § 8101 et seq.; 20 C.F.R. §§ 501.2(c), 501.3.
• Outcome: OWCP’s denial reversed; claim remanded for review of whether the diagnosed injury was caused by the incident.
• Key point: Proof of a diagnosed condition does not itself decide whether work caused it.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
M.C., Appellant
)
)
and ) Docket No. 26-0006
) Issued: February 18, 2026
DEPARTMENT OF VETERANS AFFAIRS,
)
WILLIAM S. MIDDLETON MEMORIAL
)
VETERANS’ HOSPITAL, Madison, WI,
)
Employer
)
__________ )

Appearances: Case Submitted on the Record
Appellant, pro se
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 October 1, 2025 appellant filed a timely appeal from a September 24, 2025 merit decision of the Office of Workers’ Compensation Programs (OWCP).1 Pursuant to the Federal

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Appellant submitted a timely request for oral argument before the Board. 20 C.F.R. § 501.5(b). Pursuant to the Board’s Rules of Procedure, oral argument may be held in the discretion of the Board. 20 C.F.R. § 501.5(a). In support of appellant’s oral argument request, appellant asserted the correct evidence was not reviewed as it was included in the wrong file. He further asserted that this evidence provided his physician’s explanation of how the injury occurred. The Board, in exercising its discretion, denies appellant’s request for oral argument because the argument on appeal can adequately be addressed in a decision based on a review of the case record. Oral argument in this appeal would further delay issuance of a Board decision and not serve a useful purpose. As such, the oral argument request is denied, and this decision is based on the case record as submitted to the Board. 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.3

ISSUE

The issue is whether appellant has met his burden of proof to establish a diagnosed medical condition in connection with the accepted June 9, 2025 employment incident.

FACTUAL HISTORY

On June 10, 2025 appellant, then a 43-year-old medical clerk, filed a traumatic injury claim (Form CA-1) alleging that on June 9, 2025 he sustained a partially torn hamstring when he was lifting printer paper off the floor and felt a pop in his left hamstring while in the performance of duty. He stopped work on June 9, 2025, and returned on June 17, 2025.

In support of his claim, appellant submitted a witness statement from K.P., a coworker, who noted that he witnessed the incident and heard appellant cry in pain, yelling that his “hamstring just snapped.” She notified his supervisor and indicated that he sought treatment at urgent care immediately following the event.

In a June 12, 2025 report, Dr. Joseph R. Berg, an osteopath Board-certified in family medicine, reported that appellant was evaluated for left thigh pain which had been present for three days. He noted that the pain was located in the posterior thigh and began at work after appellant bent over to pick something up and felt a pop. Dr. Berg reported that he was initially evaluated at the emergency room on June 9, 2025 for pain symptoms and diagnosed with hamstring injury, subsequent encounter, noting that x-rays of his pelvis, femur and knee were obtained at that time which revealed normal. He held appellant off work and recommended physical therapy. Treatment notes of even date from a registered nurse were also provided.

In a narrative report also dated June 12, 2025, Dr. Berg indicated that appellant was evaluated that date for an injury that was sustained at work on June 9, 2025, reporting that he was bending at the waist to pick something up off the floor when he injured his left hamstring. He related that appellant was immediately evaluated in the emergency department and diagnosed with a hamstring tear which he reported was caused by the bending that occurred at work. Dr. Berg noted that appellant’s treatment included resting, modified activity and performing home exercise as he was unable to work as a result of his injury from June 9 through 16, 2025.

On June 12, 2025 the employing establishment controverted the claim.

2
5 U.S.C. § 8101 et seq.
3
The Board notes that following the September 24, 2025 decision, appellant submitted additional evidence to OWCP. However, the Board’s Rules of Procedure provides: “The Board’s review of a case is limited to the evidence in the case record that was before OWCP at the time of its final decision. Evidence not before OWCP will not be considered by the Board for the first time on appeal.” 20 C.F.R. § 501.2(c)(1). Thus, the Board is precluded from reviewing this additional evidence for the first time on appeal. Id.

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In a June 12, 2025 employing establishment work capacity evaluation, Dr. Berg documented appellant’s restrictions.

In a July 11, 2025 development letter, OWCP informed appellant of the deficiencies of his claim. It advised him of the type of factual and medical evidence required and provided a questionnaire for his completion. OWCP afforded appellant 60 days to submit the necessary evidence. No additional evidence was received.

Following OWCP’s development letter, appellant submitted emergency department reports dated June 9, 2025 documenting treatment with Dr. Adam Carrizales, Board-certified in emergency medicine, for excruciating pain to the posterior left thigh after he bent over to pick up a piece of paper at work and felt a very loud pop. Dr. Carrizales ordered x-rays of the pelvis, left femur, and left knee which found no acute osseous abnormalities. He noted that there was no evidence of complete tear and no avulsion of the tendon insertions, no sciatic symptoms or lumbar disc herniation findings, and no indication for imaging at this time. Dr. Carrizales diagnosed left hamstring injury and noted that appellant was evaluated by physical therapy in the emergency department on that date prior to his discharge and referral to sports medicine.

In an evaluation note also dated June 9, 2025, Dr. Simanjit Mand, Board-certified in emergency medicine, examined appellant and noted findings of mild erythema overlying the posterior thigh, possible palpable swelling, and intact flexion and full extension. She noted that she agreed with the findings of Dr. Carrizales. An emergency department physical therapy report and x-rays of the pelvis, left femur, and left knee of even date were also provided.

In a follow-up letter dated August 22, 2025, OWCP advised appellant that it had conducted an interim review, and the evidence remained insufficient to establish his claim. It noted that he had 60 days from the July 11, 2025 letter to submit the necessary evidence. OWCP further advised that if the evidence was not received during this time, it would issue a decision based on the evidence contained in the record.

In support of his claim, appellant resubmitted medical reports previously of record.

By decision dated September 24, 2025, OWCP denied appellant’s traumatic injury claim, finding that the evidence of record was insufficient to establish a diagnosed medical condition in connection with the accepted June 9, 2025 employment incident. It concluded, therefore, that the requirements had not been met to establish an injury as defined by FECA.

LEGAL PRECEDENT

An employee seeking benefits under FECA4 has the burden of proof to establish the essential elements of his or her claim, including that the individual is an employee of the United States within the meaning of FECA, that the claim was timely filed within the applicable time

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Supra note 2.

3 limitation of FECA,5 that an injury was sustained in the performance of duty as alleged, and that any disability or medical condition for which compensation is claimed is causally related to the employment injury.6 These are the essential elements of each and every compensation claim, regardless of whether the claim is predicated upon a traumatic injury or an occupational disease.7

To determine whether a federal employee has sustained a traumatic injury in the performance of duty, it first must be determined whether fact of injury has been established. First, the employee must submit sufficient evidence to establish that he or she actually experienced the employment incident at the time and place, and in the manner alleged. Second, the employee must submit sufficient evidence to establish that the employment incident caused a personal injury.8

The medical evidence required to establish causal relationship between a claimed specific condition and an employment incident is rationalized medical opinion evidence. 9 The opinion of the physician must be based on a complete factual and medical background of the employee, must be one of reasonable medical certainty, and must be supported by medical rationale explaining the nature of the relationship between the diagnosed condition and specific employment incident identified by the employee.10

ANALYSIS

The Board finds that appellant has met his burden of proof to establish a diagnosed medical condition in connection with the accepted June 9, 2025 employment incident.

In support of his claim, appellant submitted a report dated June 12, 2025, wherein Dr. Berg diagnosed left hamstring injury, subsequent encounter, following his treatment of appellant on the date of the claimed injury. Additionally, Dr. Carrizales, opined that there was a hamstring injury, but no evidence of complete tear and no avulsion of the tendon insertions. The Board thus finds that appellant has established a diagnosed medical condition in connection with the accepted June 9, 2025 employment incident.11 Consequently, the case shall be remanded for consideration

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E.K., Docket No. 22-1130 (issued December 30, 2022); F.H., Docket No. 18-0869 (issued January 29, 2020);
J.P., Docket No. 19-0129 (issued April 26, 2019); Joe D. Cameron, 41 ECAB 153 (1989). 6 S.H., Docket No. 22-0391 (issued June 29, 2022); L.C., Docket No. 19-1301 (issued January 29, 2020);
J.H., Docket No. 18-1637 (issued January 29, 2020); James E. Chadden, Sr., 40 ECAB 312 (1988). 7 E.H., Docket No. 22-0401 (issued June 29, 2022); P.A., Docket No. 18-0559 (issued January 29, 2020); K.M., Docket No. 15-1660 (issued September 16, 2016); Delores C. Ellyett, 41 ECAB 992 (1990). 8 H.M., Docket No. 22-0343 (issued June 28, 2022); T.J., Docket No. 19-0461 (issued August 11, 2020); K.L., Docket No. 18-1029 (issued January 9, 2019); John J. Carlone, 41 ECAB 354 (1989). 9 S.M., Docket No. 22-0075 (issued May 6, 2022); S.S., Docket No. 19-0688 (issued January 24, 2020); A.M., Docket No. 18-1748 (issued April 24, 2019); Robert G. Morris, 48 ECAB 238 (1996). 10 J.D., Docket No. 22-0935 (issued December 16, 2022); T.L., Docket No. 18-0778 (issued January 22, 2020);
Y.S., Docket No. 18-0366 (issued January 22, 2020); Victor J. Woodhams, 41 ECAB 345, 352 (1989). 11 J.C., Docket No. 25-0420 (issued June 18, 2025); M.B., Docket No. 25-0307 (issued March 25, 2025); G.K., Docket No. 24-0012 (issued March 26, 2024).

4 of the medical evidence with regard to whether appellant has met his burden of proof to establish that his diagnosed medical condition is causally related to the accepted June 9, 2025 employment incident.12 Following this and other such further development as deemed necessary, OWCP shall issue a de novo decision.

CONCLUSION

The Board finds that appellant has met his burden of proof to establish a diagnosed medical condition in connection with the accepted June 9, 2025 employment incident.

ORDER

IT IS HEREBY ORDERED THAT the September 24, 2025 decision of the Office of Workers’ Compensation Programs is reversed, and this case is remanded for further proceedings consistent with this decision of the Board.

Issued: February 18, 2026
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

12
V.I., Docket No. 23-0555 (issued January 8, 2026); C.L., Docket No. 25-0468 (issued May 8, 2025); S.R., Docket No. 22-0421 (issued July 15, 2022).

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