S.B. and U.S. Postal Service, Pleasant Ridge Annex Post Office (Board decision, March 4, 2026)

ECAB final decision. The Board affirmed OWCP's October 16, 2025 denial of the occupational disease claim. 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 city carrier attributed plantar fasciitis in her right foot to prolonged walking on her route. OWCP accepted the described work factors but denied the claim because the medical record did not establish a causal connection. The Board found that her podiatrist identified the condition and linked it to weight bearing at work without explaining how those duties caused or aggravated it. Reports from a physician assistant, unsigned notes, and diagnostic scans also did not supply the required reasoned medical opinion. The Board affirmed the denial.

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 of the occupational disease claim was affirmed.
• Key point: A physician must explain how the accepted work factors caused or aggravated the diagnosed condition.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
S.B., Appellant
)
)
and ) Docket No. 26-0124
) Issued: March 4, 2026
U.S. POSTAL SERVICE, PLEASANT RIDGE
)
ANNEX POST OFFICE, Greensboro, NC,
)
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 VALERIE D. EVANS-HARRELL, Alternate Judge

JURISDICTION

On November 24, 2025 appellant filed a timely appeal from an October 16, 2025 merit decision 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.

ISSUE

The issue is whether appellant has met her burden of proof to establish a medical condition causally related to the accepted factors of her federal employment.

FACTUAL HISTORY

On June 9, 2025 appellant, then a 37-year-old city carrier, filed an occupational disease claim (Form CA-2) alleging that she developed plantar fasciitis due to factors of her federal

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5 U.S.C. § 8101 et seq. employment. She noted that she first became aware of this condition and realized its relationship to her federal employment on May 8, 2025. In an attached statement, appellant related that her walking 11 hours per day was the cause of her right foot plantar fasciitis condition. She stopped work on May 8, 2025 and returned on June 10, 2025.

In support of her claim, appellant submitted an unsigned note from a local medical provider dated May 8, 2025, which noted that appellant was seen that day and that she should not perform a walking route. A May 16, 2025 unsigned note from the same facility related that appellant had been seen on May 8, 2025 with a recommendation to wear shoes with silicone heel cups. Appellant’s restrictions were noted including limited standing or walking for no more than an hour at a time.

In progress notes dated May 29, 2025, Thomas Scott Steele, a physician assistant, diagnosed right foot plantar fasciitis. He related that appellant had a walking route and was on her feet for a prolonged period of time. Appellant related that her pain was aggravated while at work and with weightbearing activity.

In an unsigned note dated May 29, 2025, a medical provider opined that appellant should be placed on sedentary duty.

An unsigned note from a medical provider dated June 20, 2025 related that appellant was followed for plantar fasciitis. It further related that this condition was due to repetitive stress and overuse, which could increase inflammation to the bottom of the foot, and which was exacerbated by weightbearing activity.

In a development letter dated June 27, 2025, OWCP informed appellant of the deficiencies of her claim. It advised her of the type of medical evidence needed to establish her claim. OWCP afforded appellant 60 days to submit the necessary evidence.

In a report dated May 8, 2025, Mr. Steele diagnosed right foot plantar fasciitis. He recounted appellant’s work duties and noted her complaints of pain on the plantar aspect of the right heel which was aggravated with weightbearing activity. On physical examination, Mr. Steele observed tenderness on palpation along the plantar aspect of the right heel and normal range of foot motion. A review of right foot x-ray interpretation revealed plantar calcaneal enthesophyte, pes cavovarus and no acute osseous abnormality.

A June 18, 2025 right ankle magnetic resonance imaging (MRI) scan demonstrated plantar fasciitis and mild distal Achilles tendinosis.

In a duty status report (Form CA-17) dated July 11, 2025, Mr. Steele noted appellant’s diagnosis of plantar fasciitis, which he attributed to appellant’s employment. He also related appellant’s work restrictions.

In a follow-up letter dated July 25, 2025, OWCP advised appellant that it had conducted an interim review, and the evidence remained insufficient to establish her claim. It noted that she had 60 days from the June 27, 2025 letter to submit the requested 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.

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In a July 17, 2025 work capacity evaluation (Form OWCP-5c), Dr. Jeremiah Thomas, a podiatrist, diagnosed chronic plantar fasciitis and provided work restrictions.

In a September 3, 2025 attending physician’s report (Form CA-20), Dr. Thomas diagnosed plantar fasciitis which he attributed to prolonged weight bearing on feet at work. Appellant’s physical examination findings were noted as bilateral heel tenderness on palpation and decreased ankle dorsiflexion.

By decision dated October 16, 2025, OWCP denied appellant’s claim, finding that the medical evidence of record was insufficient to establish causal relationship between her diagnosed medical condition and the accepted factors of her federal employment.

LEGAL PRECEDENT

An employee seeking benefits under FECA2 has the burden of proof to establish the essential elements of his or her claim, including the fact 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 limitation of FECA, 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.3 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.

To establish that an injury was sustained in the performance of duty in an occupational disease claim, a claimant must submit: (1) a factual statement identifying employment factors alleged to have caused or contributed to the presence or occurrence of the disease or condition; (2) medical evidence establishing the presence or existence of the disease or condition for which compensation is claimed; and (3) rationalized medical evidence establishing that the diagnosed condition is causally related to the identified employment factors.4

Causal relationship is a medical question that requires rationalized medical opinion evidence to resolve the issue.5 The opinion of the physician must be based on a complete factual and medical background, 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 the specific employment factors.6

2
Id.
3
T.S., Docket No. 25-0138 (issued January 22, 2025); D.S., Docket No. 25-0034 (issued November 18, 2024); C.K., Docket No. 19-1549 (issued June 30, 2020); Elaine Pendleton, 40 ECAB 1143 (1989). 4 T.S., id.; C.M., Docket No. 24-0893 (issued November 15, 2024); L.D., Docket No. 19-1301 (issued January 29, 2020); Victor J. Woodhams, 41 ECAB 345, 352 (1989). 5 T.S., id.; S.R., Docket No. 24-0839 (issued October 30, 2024); T.H., 59 ECAB 388 (2008); Robert G. Morris, 48 ECAB 238 (1996). 6 T.S., id.; E.J., Docket No. 24-0777 (issued September 12, 2024); D.J., Docket No. 19-1301 (issued January 29, 2020).

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ANALYSIS

The Board finds that appellant has not met her burden of proof to establish a medical condition causally related to the accepted factors of her federal employment.

In a Form OWCP-5c dated July 17, 2025, Dr. Thomas noted appellant’s diagnosis of chronic plantar fasciitis and provided work restrictions. However, he did not offer an opinion regarding the cause of appellant’s diagnosed condition. The Board has held that a medical report that does not contain a medical opinion addressing causal relationship is of no probative value.7 Thus, this evidence is insufficient to establish appellant’s claim.

In a September 3, 2025 Form CA-20, Dr. Thomas related findings of bilateral heel tenderness and decreased ankle dorsiflexion. He diagnosed plantar fasciitis. Dr. Thomas attributed the diagnosis to appellant’s prolonged weight bearing on her feet at work. However, he failed to explain with medical rationale how the diagnosed condition was caused or aggravated by the accepted employment factors. The Board has held that medical evidence that does not offer a rationalized explanation by the physician of how employment factors physiologically caused or aggravated the diagnosed condition(s) is of limited probative value.8 This evidence is therefore insufficient to establish the claim.

OWCP also received May 8, 29, and July 11, 2025 progress notes and a Form CA-17 dated July 11, 2025 from Mr. Steele, a physician assistant. Certain healthcare providers such as physician assistants are not considered physicians as defined under FECA.9 Consequently, these reports will not suffice for purposes of establishing entitlement to FECA benefits.

The record also includes unsigned notes. The Board has held that reports that are unsigned or bear an illegible signature lack proper identification and cannot be considered probative medical evidence as the author cannot be identified as a physician.10 Thus, these notes are insufficient to establish appellant’s claim.

A June 16, 2025 x-ray interpretation and a June 18, 2025 MRI scan report were also submitted. The Board has also held that diagnostic reports, standing alone, lack probative value 7 B.E., Docket No. 24-0614 (issued July 12, 2024); W.O., Docket No. 22-0418 (issued February 15, 2023); L.E., Docket No. 19-0470 (issued August 12, 2019); M.J., Docket No. 18-1114 (issued February 5, 2019); see also J.B., Docket No. 22-0872 (issued August 22, 2022); L.B., Docket No. 18-0533 (issued August 27, 2018); D.K., Docket No. 17-1549 (issued July 6, 2018). 8 D.D., Docket No. 25-0751 (issued August 27, 2025); T.L., Docket No. 23-0073 (issued January 9, 2023);
V.D., Docket No. 20-0884 (issued February 12, 2021); Y.D., Docket No. 16-1896 (issued February 10, 2017). 9 Section 8101(2) of FECA provides that physician includes surgeons, podiatrists, dentists, clinical psychologists, optometrists, chiropractors, and osteopathic practitioners within the scope of their practice as defined by State law. 5 U.S.C. § 8101(2); 20 C.F.R. § 10.5(t). See Federal (FECA) Procedure Manual, Part 2 -- Claims, Causal Relationship, Chapter 2.805.3a(1) (May 2023); David P. Sawchuk, 57 ECAB 316, 320 n.11 (2006) (lay individuals such as physician assistants and nurses, are not competent to render a medical opinion under FECA). See also F.A., Docket No. 24-0014 (issued January 30, 2026) (physician assistants are not considered physicians as defined by FECA). 10 See D.F., Docket No. 22-0904 (issued October 31, 2022); see also R.C., Docket No. 19-0376 (issued July 15, 2019); Merton J. Sills, 39 ECAB 572, 575 (1988).

4 on the issue of causal relationship as they do not provide an opinion as to whether the accepted employment incident caused a diagnosed condition.11 Consequently, this evidence is insufficient to establish appellant’s claim.

As the medical evidence of record is insufficient to establish causal relationship between a medical condition and the accepted factors of federal employment, the Board finds that appellant has not met her burden of proof.

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 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 a medical condition causally related to the accepted factors of her federal employment.

ORDER

IT IS HEREBY ORDERED THAT the October 16, 2025 decision of the Office of Workers’ Compensation Programs is affirmed.

Issued: March 4, 2026
Washington, DC

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

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

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

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C.W., Docket No. 25-0046 (issued December 19, 2024); S.R., Docket No. 24-0839 (issued October 30, 2024);
W.L., Docket No. 20-1589 (issued August 26, 2021); A.P., Docket No. 18-1690 (issued December 12, 2019).

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