J.G. and U.S. Postal Service, Santa Clarita Post Office (Board decision, March 10, 2026)

ECAB remand decision. The Board set aside OWCP's June 30, August 13, and September 9, 2025 denials and returned the elbow claim for the full 60-day evidence period and a new decision. Entitlement remains 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 postal mail handler claimed a right elbow injury after handling oversized parcels at work. OWCP asked her for more medical evidence on May 8, 2025 and gave her 60 days to respond, but denied the claim on June 30, before that period ended. The Board found that the 60th day was July 7 and that OWCP had denied the claim too soon. It set aside three OWCP decisions and directed a new decision after the full response period.

Decision snapshot

• Authority: 20 C.F.R. § 10.121, requiring at least 60 days to submit requested evidence.
• Outcome: Three denials set aside; claim remanded for the full evidence period.
• Key point: OWCP had to wait until its stated evidence deadline before deciding the claim.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
J.G., Appellant
)
) Docket No. 26-0119
and ) Issued: March 10, 2026
)
U.S. POSTAL SERVICE, SANTA CLARITA
)
POST OFFICE, Santa Clarita, CA, Employer
)
__________ )

Appearances: Case Submitted on the Record
Appellant, pro se
Office of Solicitor, for the Director

ORDER REMANDING CASE

Before:
PATRICIA H. FITZGERALD, Deputy Chief Judge JANICE B. ASKIN, Judge
VALERIE D. EVANS-HARRELL, Alternate Judge

On October 28, 2025 appellant filed a timely appeal from June 30, August 13, and September 9, 2025 merit decisions of the Office of Workers’ Compensation Programs (OWCP). The Clerk of the Appellate Boards docketed the appeal as No. 26-0119.1

On March 6, 2025 appellant, then a 63-year-old mail handler, filed a traumatic injury claim (Form CA-1) alleging that, on February 21, 2025,2 she sustained an injury to the right elbow when she was working a six-person job alone, including feeding oversized parcels to the line while in

1
The Board notes that, following the September 9, 2025 decision, appellant submitted additional evidence to OWCP. However, the Board’s Rules of Procedures 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. 2 Appellant noted February 22, 2025 as the date of injury on the claim form, but later clarified that the correct date of injury was February 21, 2025. the performance of duty.3 She stopped work on February 21, 2025 and returned to full-time modified duty with restrictions on February 25, 2025.

Appellant submitted additional factual and medical evidence in support of her claim.

In a May 8, 2025 development letter, OWCP informed appellant of the deficiencies of her claim. It advised her of the type of medical evidence needed and afforded her 60 days to submit the necessary evidence.

Appellant subsequently submitted additional medical evidence in support of her claim.

In a follow-up letter dated May 30, 2025, OWCP advised appellant that it had conducted an interim review, and that the evidence remained insufficient to establish her claim. It noted that she had 60 days from the May 8, 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.

By decision dated June 30, 2025, OWCP denied appellant’s claim, finding that the evidence of record was insufficient to establish a medical condition causally related to the accepted February 21, 2025 employment incident.

Appellant requested reconsideration and submitted additional medical evidence.

By decisions dated August 13 and September 9, 2025, OWCP denied modification.

The Board, having duly considered this matter, finds that the case is not in posture for decision.

Section 10.121 of OWCP’s regulations provides that if a claimant submits factual evidence, medical evidence, or both in support of his or her claim, but OWCP determines that this evidence is not sufficient to meet the burden of proof, it will inform the claimant of the additional evidence needed and provide the claimant at least 60 days to submit the evidence required.4

The 60th day following the May 8, 2025 development letter was July 7, 2025. However, OWCP issued its decision denying appellant’s claim on June 30, 2025. It, therefore, did not fulfill its responsibility under section 10.121 of its regulations.5

3
OWCP assigned the present claim OWCP File No. xxxxxx774. Appellant has a prior claim accepted for right carpal tunnel syndrome under OWCP File No. xxxxxx252. OWCP has administratively combined OWCP File Nos. xxxxxx252 and xxxxxx774, with the latter serving as the master file. 4 20 C.F.R. § 10.121. Effective March 7, 2023, 20 C.F.R. § 10.121 was amended to allow a claimant 60 days, increased from the prior 30-day period, to submit supporting evidence on an initial claim. See also Federal (FECA) Procedure Manual, Part 2 -- Claims, Initial Development of Claims, Chapter 2.800.4c(2) (November 2023). 5 Id. See also Order Remanding Case, L.C., Docket No. 22-1341 (issued January 26, 2023).

2
Thus, the Board finds that this case must be remanded for proper application of OWCP’s procedures, allowing appellant 60 days to respond to the request for additional evidence, to be followed by a de novo decision. Accordingly,

IT IS HEREBY ORDERED THAT the June 30, August 13, and September 9, 2025 decisions of the Office of Workers’ Compensation Programs are set aside, and the case is remanded for further proceedings consistent with this order of the Board.

Issued: March 10, 2026
Washington, DC

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

Janice B. Askin, Judge
Employees’ Compensation Appeals Board

Valerie D. Evans-Harrell, Alternate Judge Employees’ Compensation Appeals Board

3