B.F. and U.S. Postal Service, Minneapolis Post Office (Board decision, March 11, 2026)

ECAB remand decision. The Board set aside OWCP's June 26, 2025 disability decision and returned the case for combined review of two claim files with overlapping disability periods. Compensation 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 Minneapolis postal carrier sought compensation for periods of missed work under a claim involving an accepted left trapezius strain. He had a separate claim involving his left leg, and the two files covered overlapping periods of claimed disability. OWCP denied compensation without administratively combining the files. The Board found that both records were needed for a full review, set aside the denial, and directed OWCP to combine the files and issue a new decision.

Decision snapshot

• Authority: Federal Employees' Compensation Act, 5 U.S.C. § 8101 et seq.; OWCP file-combination procedures cited in the order.
• Outcome: Disability decision set aside; overlapping claim files to be combined on remand.
• Key point: OWCP must consider both claim files when claimed disability periods overlap.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
B.F., Appellant
)
)
and ) Docket No. 26-0154
) Issued: March 11, 2026
U.S. POSTAL SERVICE, MINNEAPOLIS POST
)
OFFICE, Minneapolis, MN, Employer
)
__________ )

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

ORDER REMANDING CASE

Before:
ALEC J. KOROMILAS, Chief Judge
JANICE B. ASKIN, Judge
VALERIE D. EVANS-HARRELL, Alternate Judge

On December 4, 2025 appellant filed a timely appeal from a June 26, 2025 merit decision of the Office of Workers’ Compensation Programs (OWCP). The Clerk of the Appellate Boards docketed the appeal as No. 26-0154.1

On May 6, 2024 appellant, then a 38-year-old city carrier, filed an occupational disease claim (Form CA-2) alleging he developed pain in his neck and left shoulder due to factors of his federal employment, including repetitive motion and overexertion through a holiday period.2 He noted that he first became aware of his condition and its relationship to his federal employment on April 2, 2024. OWCP accepted the claim for left trapezius strain.

1
The Board notes that, following the June 26, 2025 decision, 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. 2 OWCP assigned the present claim OWCP File No. xxxxxx332. On June 21, 2024 appellant filed a Form CA-2 for reoccurring inflammation and chronic pain in his left leg, which OWCP denied under OWCP File No. xxxxxx930. Under OWCP File No. xxxxxx930, he filed a claim for compensation (Form CA-7) for disability from work for the period June 5 through September 5, 2024. Appellant’s claims have not been administratively combined by OWCP.
On June 23, 2024, appellant began filing CA-7 claims for compensation for intermittent disability from work for the period April 2 through November 11, 2024.

By decision dated January 30, 2025, OWCP denied appellant’s disability claim finding that the medical evidence of record was insufficient to establish disability from work during the period April 2 through November 11, 2024, causally related to the accepted employment injury.

On February 5, 2025, appellant requested a review of the written record by a representative of OWCP’s Branch of Hearings and Review and submitted additional evidence.

By decision dated June 26, 2025, an OWCP hearing representative affirmed the February 5, 2025 decision.

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

The Board notes that the claimed periods of disability are for injuries to different parts of the body. However, OWCP’s procedures provide that cases should be administratively combined when correct adjudication of the issues depends on frequent cross-referencing between files, including cases involving overlapping periods of disability.3 This allows OWCP to consider all relevant claim files in developing a given claim.4 As appellant’s claims under OWCP File Nos. xxxxxx930 and xxxxxx332 involve overlapping periods of disability, they should be administratively combined for a full and fair adjudication.5 This will allow OWCP to consider all relevant reports and accompanying evidence in developing appellant’s disability claim.6

The Board shall, therefore, remand the case for OWCP to administratively combine OWCP File Nos. xxxxxx930 and xxxxxx332. Following this and other such further development as deemed necessary, OWCP shall issue a de novo decision. Accordingly,

3
Federal (FECA) Procedure Manual, Part 2 -- Claims, File Maintenance and Management, Chapter 2.400.8c(3) (February 2000).
4
Id.
5
See Order Remanding Case, S.S., Docket No. 19-1597 (issued June 22, 2020).
6
Id. See also K.G., Docket No. 21-0068 (issued July 29, 2022); D.J., Docket No. 20-0997 (issued November 20, 2020); S.D., Docket No. 19-0590 (issued August 28, 2020).

2
IT IS HEREBY ORDERED THAT the June 26, 2025 decision of the Office of Workers’ Compensation Programs is set aside, and the case is remanded for further proceedings consistent with this order of the Board.

Issued: March 11, 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

3