V.T. and Department of Homeland Security, Transportation Security Administration (Board decision, June 8, 2026)

ECAB remand decision. The Board set aside OWCP's August 27, 2025 decision and remanded for combined review of three related claim 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 Transportation Security Administration worker appealed a decision involving shoulder and wrist conditions. Two earlier files also involved those body areas, but they had not been combined with the current claim. The Board found that a fair decision required access to all three files. 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; shoulder and wrist files must be combined.
• Key point: Related injury files needed joint review before the claim could be decided.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
V.T., Appellant
)
)
and ) Docket No. 26-0325
) Issued: June 8, 2026
DEPARTMENT OF HOMELAND SECURITY,
)
TRANSPORTATION SECURITY
)
ADMINISTRATION, Orlando, FL, Employer
)
__________ )

Appearances: Case Submitted on the Record
Wayne Johnson, Esq., for the appellant1
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 February 23, 2026 appellant, through counsel, filed a timely appeal from an August 27, 2025 merit decision of the Office of Workers’ Compensation Programs (OWCP). The Clerk of the Appellate Boards docketed the appeal as No. 26-0325.

On May 30, 2023 appellant, then a 60-year-old compliance inspection and support specialist, filed an occupational disease claim (Form CA-2) alleging that he developed bilateral shoulder and wrist conditions due to factors of his federal employment. He explained that his initial bilateral shoulder conditions progressed to his wrists and that his request to expand the

1
In all cases in which a representative has been authorized in a matter before the Board, no claim for a fee for legal or other service performed on appeal before the Board is valid unless approved by the Board. 20 C.F.R. § 501.9(e). No contract for a stipulated fee or on a contingent fee basis will be approved by the Board. Id. An attorney or representative’s collection of a fee without the Board’s approval may constitute a misdemeanor, subject to fine or imprisonment for up to one year or both. Id.; see also 18 U.S.C. § 292. Demands for payment of fees to a representative, prior to approval by the Board, may be reported to appropriate authorities for investigation. acceptance of his shoulder claim to include the wrist conditions was denied by OWCP.2 Appellant noted that he first became aware of his condition on December 17, 2015, and realized its relation to his federal employment on November 8, 2022.

In an accompanying May 30, 2023 statement, appellant attributed his wrist conditions to 20 years of lifting passenger luggage weighing approximately 50 pounds; pressing keypads on the x-ray machine for 30-minute intervals each day; stacking bags against the wall; and pushing and pulling crates to move and unload luggage.

Appellant submitted medical evidence in support of his claim.

By decision dated August 3, 2023, OWCP denied appellant’s occupational disease claim, finding that the medical evidence of record was insufficient to establish causal relationship between a medical condition and the accepted factors of his federal employment.

In an August 5, 2024 request for reconsideration appellant, through counsel, alleged that he developed bilateral carpal tunnel syndrome (CTS) following his bilateral shoulder arthroscopic surgeries under OWCP File No. xxxxxx770. Counsel alleged that appellant’s bilateral CTS worsened due to his compensating from his shoulder injuries and his continued work following his shoulder surgeries.

Additional medical evidence was submitted in support of his claim.

By decision dated August 12, 2024, OWCP denied modification of its August 3, 2023 decision.

On August 12, 2025 appellant, through counsel, requested reconsideration. He summarized appellant’s medical treatment for his alleged wrist conditions. Additional medical evidence was submitted.

By decision dated August 27, 2025, OWCP denied modification of the August 12, 2024 decision.

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 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

2
OWCP assigned the present claim OWCP File No. xxxxxx524. Under OWCP File No. xxxxxx770, appellant filed a Form CA-1 alleging that on December 17, 2015 he injured his left shoulder. OWCP accepted the claim for left shoulder lesion and left shoulder partial rotator cuff tear or rupture and a subsequent right shoulder rotator cuff tear. Under OWCP File No. xxxxxx693, on August 15, 2023, appellant filed a Form CA-2 for the same conditions claimed in the current file. This claim has not been formally adjudicated by OWCP. 3 Federal (FECA) Procedure Manual, Part 2 -- Claims, File Maintenance and Management, Chapter 2.400.8c (February 2000).

2 condition or the same part of the body, doubling is required.4 Appellant’s claims under OWCP File Nos. xxxxxx770 and xxxxxx693 also involved appellant’s shoulder and wrist conditions and should, therefore, be administratively combined with the present claim for a full and fair adjudication.5

The case shall, therefore, be remanded for OWCP to administratively combine OWCP File Nos. xxxxxx770 and xxxxxx693 with the present claim. Following this and other such further development as deemed necessary, OWCP shall issue a de novo decision. Accordingly,

IT IS HEREBY ORDERED THAT the August 27, 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 8, 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

4
Id.; K.K., Docket No. 26-0224 (issued April 29, 2026); L.G., Docket No. 18-1676 (issued August 22, 2019);
D.L., Docket No. 17-1588 (issued January 28, 2019).
5
See C.Y., Docket No. 20-1079 (issued December 7, 2020); L.G., id.; K.T., Docket No. 17-0432 (issued August 17, 2018).

3