A.H. and U.S. Postal Service, Detroit Post Office (Board decision, June 22, 2026)

ECAB remand decision. The Board set aside OWCP's October 17, 2025 decision and remanded for combined review of two right arm files. 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 appealed a decision concerning an injury to her right arm and shoulder after a fall in a mail truck. Another OWCP claim file also involved her right upper extremity. The Board found that the files needed to be combined for a full review. It directed OWCP to combine them and issue a new decision.

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 decision set aside; related right arm files must be combined.
• Key point: The Board needed both right upper extremity files to review the claim fairly.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
A.H., Appellant
)
)
and ) Docket No. 26-0278
) Issued: June 22, 2026
U.S. POSTAL SERVICE, POST OFFICE,
)
Detroit, MI, 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
PATRICIA H. FITZGERALD, Deputy Chief Judge JANICE B. ASKIN, Judge

On January 20, 2026 appellant filed a timely appeal from an October 17, 20251 merit decision of the Office of Workers’ Compensation Programs (OWCP). The Clerk of the Appellate Boards docketed the appeal as 26-0278.

On September 13, 2024 appellant, then a 46-year-old city carrier, filed a traumatic injury claim (Form CA-1) alleging that on September 3, 2024 she sustained pain in her right arm and shoulder when she fell inside her mail truck cabin while in the performance of duty.2 She stopped work on September 4, 2024. OWCP accepted the claim for right shoulder sprain, right

1
The Board notes that, following the October 27, 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. 2 OWCP assigned the present claim OWCP File No. xxxxxx063. Appellant has a subsequent claim for a November 25, 2024 traumatic injury under OWCP File No. xxxxxx464 in which she asserted that she reinjured her right shoulder, (while exceeding her work restrictions. Appellant’s claims had not been administratively combined by OWCP at the time of the October 17, 2025 decision. elbow contusion, right rotator cuff tear, and right elbow lateral epicondylitis. It paid appellant wage-loss compensation on the supplemental rolls commencing October 19, 2024.

Beginning on December 4, 2024 appellant filed a series of claims for compensation (Form CA-7) for disability from work commencing November 27, 2024.

By decision dated July 31, 2025, OWCP denied appellant’s claim for disability during the period commencing November 24, 2025. By memorandum dated July 31, 2025, it determined that the July 31, 2025 decision should be rescinded as it had not untaken the necessary development prior to denying the claimed period of disability.

In an August 13, 2025 development letter, OWCP notified appellant of the deficiencies of her disability claim and advised her of the type of evidence needed for the claimed dates of disability. It afforded her 30 days to respond.

On October 17, 2025 OWCP advised appellant that the July 31, 2025 decision had been vacated.

By decision dated October 17, 2025, OWCP denied appellant’s Form CA-7 claim for disability from work commencing November 24, 2024.

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

OWCP’s procedures provide that cases should be administratively combined where a new injury case is reported for an employee who filed another injury claim for the same part of the body and when correct adjudication of the issues depends on frequent cross-referencing between files.3 For example, if a new injury case is reported for an employee who previously filed an injury claim for a similar condition or the same part of the body, doubling is required. 4 Appellant’s claims under OWCP File Nos. xxxxxx063 and xxxxxx464 both involve the right upper extremity. Therefore, these claims must be administratively combined for full and fair adjudication.5

The case shall, therefore, be remanded to OWCP for further development. On remand, OWCP shall administratively combine OWCP File Nos. xxxxxx063 and xxxxxx464. 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 2.400.8(c) (February 2000).
4
Id.; Order Remanding Case, G.D., Docket No. 25-0085 (issued November 18, 2024); Order Remanding Case, N.V., Docket No. 23-0044 (issued April 20, 2023); Order Remanding Case, L.G., Docket No. 18-1676 (issued August 22, 2019); Order Remanding Case, D.L., Docket No. 17-1588 (issued January 28, 2019). 5 See Order Remanding Case, J.S., Docket No. 26-0225 (issued April 30, 2026); Order Remanding Case, C.Y., Docket No. 20-1079 (issued December 7, 2020); L.G., id.; Order Remanding Case, K.T., Docket No. 17-0432 (issued August 17, 2018).

2
IT IS HEREBY ORDERED THAT the October 17, 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: June 22, 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

3