A.H. and U.S. Postal Service, New Brunswick Post Office (Board decision, March 6, 2026)

ECAB final decision. The Board affirmed OWCP's September 15 and 30, 2025 denials of wage-loss compensation for the claimed July and August 2025 work absences. 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 postal mail processing clerk sought wage-loss compensation for several days and periods away from work after an accepted 2024 workplace fall. Her orthopedic surgeon restricted her work and later released her to full duty, but did not explain how the accepted injuries caused disability on the specific dates claimed. The Board also found that imaging alone did not answer that causal question. It upheld OWCP's denial of compensation for the claimed absences.

Decision snapshot

• Authority: Federal Employees' Compensation Act, 5 U.S.C. § 8101 et seq.; 5 U.S.C. § 8128(a).
• Outcome: Wage-loss denials for July and August 2025 affirmed.
• Key point: Medical evidence had to connect the accepted injury to disability on the dates for which pay was claimed.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
A.H., Appellant
)
)
and ) Docket No. 26-0027
) Issued: March 6, 2026
U.S. POSTAL SERVICE, NEW BRUNSWICK
)
POST OFFICE, Edison, NJ, 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
PATRICIA H. FITZGERALD, Deputy Chief Judge JANICE B. ASKIN, Judge

JURISDICTION

On October 9, 2025, appellant filed a timely appeal from September 15 and 30, 2025 merit decisions of the Office of Workers’ Compensation Programs (OWCP). Pursuant to the Federal Employees’ Compensation Act1 (FECA) and 20 C.F.R. §§ 501.2(c) and 501.3, the Board has jurisdiction over the merits of this case.2

1
5 U.S.C. § 8101 et seq.
2
The Board notes that following the September 30, 2025 decision and on appeal, OWCP received additional evidence. 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.
ISSUE

The issue is whether appellant has met her burden of proof to establish disability from work on July 18, 2025, and during the periods July 21 through August 1, 2025 and August 4 through 16, 2025 causally related to the accepted October 10, 2024 employment injury.

FACTUAL HISTORY

On October 17, 2024, appellant, then a 51-year-old mail processing clerk, filed a traumatic injury claim (Form CA-1) alleging that on October 10, 2024 she sustained bilateral hand and wrist, right leg, knee, and head injuries when she slipped and fell on a workroom floor while in the performance of duty. She stopped work on October 10, 2024. OWCP accepted the claim for sprains of the right rotator cuff, right wrist, and right hip.

Appellant accepted a modified job offer and returned to work four hours per day as of November 25, 2024.

In reports dated July 2 and 28, 2025, Dr. Christine Corradino, a Board-certified orthopedic surgeon, diagnosed right ankle sprain, right knee contusion, and right knee medial collateral ligament sprain. In the July 2, 2025 report, she released appellant to return to work on August 4, 2025 with restrictions. In the July 28, 2025 report, Dr. Corradino released appellant to return to full-duty work with no restrictions as of August 18, 2025.

On July 28, 2025, OWCP received an October 28, 2024 x-ray of appellant’s lumbar spine which revealed a Schmorl’s node formation on the superior endplate of T12 and L1. A January 22, 2025 magnetic resonance imaging (MRI) scan of appellant’s right ankle related an impression of tendinopathy of the posterior and anterior tibial tendon, flexor hallucis longus tendon and extensor digitorum longus tendon; and tear of the anterior talofibular ligament. A January 22, 2025 MRI scan of appellant’s right knee noted findings of bone bruises in the distal femur, lateral tibial plateau, and in the anterior aspect of the patella; strain and partial tear of the medial collateral ligament; knee effusion; and prepatellar and pretibial bursitis.

On July 28, 2025, appellant filed a claim for compensation (Form CA-7) for disability from work for the period July 12 through 25, 2025. The employing establishment reported on the reverse side of the claim form that appellant was on leave without pay (LWOP) on July 18, 2025. It also reported that appellant was on sick leave from July 12 through 17, 2025, and on annual leave from July 19 through 25, 2025.

In a development letter dated July 29, 2025, OWCP notified appellant of the deficiencies in her claim for wage-loss compensation received on July 28, 2025 for July 18, 2025. It noted that no evidence had been received to support her claim and advised her of the type of medical evidence needed to establish the claim and afforded her 30 days to respond.

On August 12, 2025, appellant submitted a Form CA-7 claim for disability from work for the period July 21 through August 1, 2025.

In a development letter dated August 18, 2025, OWCP notified appellant of the deficiencies in her claim for wage-loss compensation. It noted that she stopped work on July 21,

2
2025 and had not returned. OWCP advised her of the type of medical evidence needed to establish the claim and afforded her 30 days to respond.

On August 27, 2025, appellant submitted a Form CA-7 claim for disability from work for the period August 4 through 16, 2024.

By decision dated September 15, 2025, OWCP denied appellant’s claim for disability from work on July 18, 2025.

By decision dated September 30, 2025, OWCP denied appellant’s claim for disability for work for the periods July 21 through August 1, 2025 and August 4 through 16, 2025.

LEGAL PRECEDENT

An employee seeking benefits under FECA3 has the burden of proof to establish the essential elements of his or her claim including that any disability or specific condition for which compensation is claimed is causally related to the employment injury.4

Under FECA the term “disability” means the incapacity, because of an employment injury, to earn the wages that the employee was receiving at the time of injury.5 Disability is thus not synonymous with physical impairment, which may or may not result in an incapacity to earn wages.6 An employee who has a physical impairment causally related to a federal employment injury, but who nevertheless has the capacity to earn the wages he or she was receiving at the time of injury, has no disability as that term is used in FECA.7 When, however, the medical evidence establishes that the residuals or sequelae of an employment injury are such that, from a medical standpoint, they prevent the employee from continuing in his or her employment, he or she is entitled to compensation for loss of wages.8

The medical evidence required to establish causal relationship between a claimed period of disability and an employment injury is rationalized medical opinion evidence. The opinion of the physician must be based on a complete factual and medical background of the claimant, must

3
Supra note 1.
4
R.B., Docket No. 25-0715 (issued December 9, 2025); C.B., Docket No. 20-0629 (issued May 26, 2021); D.S., Docket No. 20-0638 (issued November 17, 2020); S.W., Docket No. 18-1529 (issued April 19, 2019); J.F., Docket No. 09-1061 (issued November 17, 2009); Kathryn Haggerty, 45 ECAB 383 (1994); Elaine Pendleton, 40 ECAB 1143 (1989). 5 20 C.F.R. § 10.5(f).
6
See R.B., supra note 4; L.W., Docket No. 17-1685 (issued October 9, 2018).
7
See M.W., Docket Nos. 23-0031 and 23-0333 (issued May 12, 2025); K.H., Docket No. 19-1635 (issued March 5, 2020).
8
See R.B., supra note 4; D.R., Docket No. 18-0323 (issued October 2, 2018).

3 be one of reasonable medical certainty, and must be supported by medical rationale explaining the nature of the relationship between the claimed disability and the accepted employment injury.9

For each period of disability claimed, the employee has the burden of proof to establish that he or she was disabled from work causally related to the accepted employment injury.10 The Board will not require OWCP to pay compensation for disability in the absence of medical evidence directly addressing the specific dates of disability for which compensation is claimed. To do so would essentially allow an employee to self-certify their disability and entitlement to compensation.11

ANALYSIS

The Board finds that appellant has not met her burden of proof to establish disability from work on July 18, 2025, and during the periods July 21 through August 1, 2025 and August 4 through 16, 2025, causally related to the accepted October 10, 2024 employment injury.

In reports dated July 2 and 28, 2025, Dr. Corradino diagnosed right ankle sprain, right knee contusion, and right knee medial collateral ligament sprain. She found that appellant could return to work with restrictions on August 4, 2025 and to full-duty work with no restrictions on August 18, 2025. Dr. Corradino, however, offered no opinion as to the cause of appellant’s disability. The Board has held that medical evidence that does not offer an opinion regarding the cause of an employee’s condition or disability is of no probative value on the issue of causal relationship.12 Therefore, this evidence is insufficient to establish appellant’s disability claim.

Appellant also submitted an October 28, 2024 x-ray of the lumbar spine and January 22, 2025 MRI scans of the right knee and right ankle. However, diagnostic studies, standing alone, lack probative value as they do not address whether an accepted employment condition caused the claimed disability.13

As the medical evidence of record is insufficient to establish causal relationship between the claimed disability and the accepted October 10, 2024 employment injury, the Board finds that appellant has not met her burden of proof.

9
R.B., id.; S.J., Docket No. 17-0828 (issued December 20, 2017); Kathryn E. DeMarsh, 56 ECAB 677 (2005).
10
A.M., Docket No. 25-0788 (issued November 17, 2025); see C.W., Docket No. 25-0243 (issued July 17, 2025);
B.D., Docket No. 18-0426 (issued July 17, 2019); Amelia S. Jefferson, 57 ECAB 183 (2005); Fereidoon Kharabi, 52 ECAB 291, 293 (2001). 11 Id.
12
See G.R., Docket No. 25-0540 (issued June 26, 2025); F.S., Docket No. 23-0112 (issued April 26, 2023);
L.B., Docket No. 18-0533 (issued August 27, 2018); D.K., Docket No. 17-1549 (issued July 6, 2018). 13 See B.B., Docket No. 25-0661 (issued September 9, 2025); A.V., Docket No. 19-1575 (issued June 11, 2020).

4
Appellant may submit new evidence or argument with a written request for reconsideration to OWCP within one year of this merit decision, pursuant to 5 U.S.C. § 8128(a) and 20 C.F.R.
§§ 10.605 through 10.607.

CONCLUSION

The Board finds that appellant has not met her burden of proof to establish disability from work on July 18, 2025, and during the periods July 21 through August 1, 2025, and August 4 through 16, 2025, causally related to the accepted October 10, 2024 employment injury.

ORDER

IT IS HEREBY ORDERED THAT the September 15 and 30, 2025 decisions of the Office of Workers’ Compensation Programs are affirmed.

Issued: March 6, 2026
Washington, DC

Alec J. Koromilas, Chief Judge
Employees’ Compensation Appeals Board

Patricia H. Fitzgerald, Deputy Chief Judge Employees’ Compensation Appeals Board

Janice B. Askin, Judge
Employees’ Compensation Appeals Board

5