B.S. and U.S. Postal Service, North Texas Processing & Distribution Center (Board decision, June 29, 2026)

ECAB final decision. The Board affirmed OWCP's September 18, 2025 and February 4, 2026 denials of the remaining claimed treatment-related work time. 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 sought compensation for time away from work for medical treatment after an accepted injury. OWCP disputed the remaining hours claimed on three dates in 2025. The Board found no medical evidence showing that he attended treatment for the accepted injury on those dates and lost work time for it. It affirmed the denials.

Decision snapshot

• Authority: Federal Employees' Compensation Act, 5 U.S.C. § 8101 et seq.; 20 C.F.R. §§ 501.2(c), 501.3.
• Outcome: Remaining treatment-related wage loss claim denied.
• Key point: Payment for missed work to obtain treatment required evidence of treatment for the accepted injury on the claimed dates.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
B.S., Appellant
)
)
and ) Docket No. 26-0369
) Issued: June 29, 2026
U.S. POSTAL SERVICE, NORTH TEXAS
)
PROCESSING & DISTRIBUTION CENTER,
)
Coppell, TX, 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
JANICE B. ASKIN, Judge
VALERIE D. EVANS-HARRELL, Alternate Judge

JURISDICTION

On March 5, 2026 appellant filed a timely appeal from September 18, 2025, and February 4, 2026 merit decisions 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.2

ISSUE

The issue is whether appellant has met his burden of proof to establish the remaining claimed disability from work to obtain medical treatment on June 25 and 26, and August 20, 2025, causally related to his accepted October 13, 2021 employment injury.

1
5 U.S.C. § 8101 et seq.
2
The Board notes that, following the February 4, 2026 decision, OWCP received additional evidence. 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.
FACTUAL HISTORY

On October 14, 2021 appellant, then a 29-year-old mail handler, filed a traumatic injury claim (Form CA-1) alleging that on October 13, 2021 he injured his back and arms when he was pinned by a forklift while in the performance of duty. OWCP accepted the claim for low back strain and contusions of the low back and pelvis. It later expanded its acceptance of the claim to include lumbar radiculopathy. Appellant stopped work on October 14, 2022, and returned to full- time modified-duty work with restrictions on December 4, 2022.

On July 10, 2025 appellant filed a claim for compensation (Form CA-7) claiming intermittent disability from work for the period May 19 through July 3, 2025. The accompanying time analysis form (Form CA-7a) indicated that he used 3.60 hours of leave without pay (LWOP) on May 21, 2025, 3.30 hours of LWOP on May 28, 2025, and 4.0 hours of LWOP on May 29, June 4, 5, 11, 18, 25, and 26, and July 2 and 3, 2025 to attend physical therapy appointments.3

In a development letter dated July 15, 2025, OWCP informed appellant that it would authorize payment for 3.60 hours on May 21, 2025, 3.30 hours on May 28, 2025, and 4.0 hours on May 29, June 4, 5, 11, and 18, and July 2 and 3, 2025. It also informed him of the deficiencies of his claim for wage-loss compensation to obtain medical care on June 25 and 26, 2025, and specifically requested that he provide a medical note or therapy slip verifying treatment for the accepted October 13, 2021 employment injury on those dates. OWCP afforded appellant 30 days to respond.

OWCP thereafter received a medical report by Dr. Nara Pravat, Board-certified in physiatry and pain medicine, dated July 21, 2025.

By decision dated September 18, 2025, OWCP denied appellant’s remaining claimed disability from work to obtain medical treatment on June 25 and 26, 2025, causally related to the accepted October 13, 2021 employment injury.

In the interim, on September 17, 2025, appellant filed a Form CA-7 claiming intermittent disability from work for the period July 23 through September 11, 2025. The accompanying Form CA-7a indicated that he used 3.98 hours of LWOP on July 23, 2025, 4.03 hours of LWOP on July 24, 2025, and 4.0 hours of LWOP on July 30, August 6, 7, 13, 18, 20, 21, and 27, and September 4 and 11, 2025 to attend physical therapy appointments.

In a development letter dated November 18, 2025, OWCP informed appellant that it would authorize payment for 3.98 hours on July 23, 2025, 4.03 hours on July 24, 2025, and 4.0 hours on July 30, August 6, 7, 13, 18, 21, and 27, and September 4 and 11, 2025. It also informed him of the deficiencies of his claim for wage-loss compensation to obtain medical care on August 20, 2025, and specifically requested that he provide a medical note or therapy slip verifying treatment for the accepted October 13, 2021 employment injury on that date. OWCP afforded appellant 30 days to respond.

3
The Form CA-7a also indicated that compensation had not been claimed nor any LWOP used on May 19, 2025.

2
OWCP thereafter received physical therapy reports dated September 22 through December 9, 2025, and medical reports by Dr. Pravat dated October 22 through December 19, 2025.

By decision dated February 4, 2026, OWCP denied appellant’s remaining claimed disability from work to obtain medical treatment on August 20, 2025, causally related to the accepted October 13, 2021 employment injury.

LEGAL PRECEDENT

Section 8103 of FECA provides for medical expenses, along with transportation and other expenses incidental to securing medical care, for injuries.4 A claimant is entitled to compensation for any time missed from work due to medical examination or treatment for an employment-related condition.5 However, OWCP’s obligation to pay for expenses incidental to obtaining medical care, such as loss of wages, extends only to expenses incurred for treatment of the effects of any employment-related condition.6 Appellant has the burden of proof, which includes the necessity to submit supporting rationalized medical evidence.7 The evidence should establish that a claimant attended an examination or treatment for the accepted work injury on the dates claimed in order for compensation to be payable.8 For a routine medical appointment, a maximum of four hours of compensation may be allowed.9 However, longer periods of time may be allowed when required by the nature of the medical procedure and/or the need to travel a substantial distance to obtain the medical care. The claims for wage loss should be considered on a case-by-case basis.10

ANALYSIS

The Board finds that appellant has not met his burden of proof to establish the remaining claimed disability for work to obtain medical treatment on June 25 and 26, and August 20, 2025, causally related to his accepted October 13, 2021 employment injury.

As noted above, OWCP’s procedures provide that wages lost for compensable medical examination or treatment may be reimbursed.11 The evidence should establish that a claimant attended an examination or treatment for the accepted work injury on the dates claimed in order

4
5 U.S.C. § 8103(a).
5
Federal (FECA) Procedure Manual, Part 2 -- Claims, Wages Lost for Medical Examination or Treatment, Chapter 2.901.19 (February 2013); see T.S., Docket No. 24-0909 (issued November 25, 2024); S.M., Docket No. 17-1557 (issued September 4, 2018). 6 H.S., Docket No. 23-0557 (issued October 5, 2023); Zane H. Cassell, 32 ECAB 1537, 1540-41 (1981).
7
Id.; see also S.M., supra note 5.
8
Supra note 5 at Chapter 2.901.19a(3).
9
J.B., Docket No. 22-1301 (issued March 26, 2024); A.F., Docket No. 20-0522 (issued November 4, 2020).
10
Supra note 5 at Chapter 2.901.19c.
11
Supra note 5.

3 for compensation to be payable. For a routine medical appointment, a maximum of four hours may be allowed.12

As appellant has not submitted medical evidence establishing that he lost time from work to obtain medical treatment on June 25 and 26, and August 20, 2025, causally related to his accepted October 13, 2021 employment injury, the Board finds that he has not met his burden of proof.13

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(a) and 20 C.F.R.
§§ 10.605 through 10.607.

CONCLUSION

The Board finds that appellant has not met his burden of proof to establish the remaining claimed disability for work to obtain medical treatment on June 25 and 26, and August 20, 2025, causally related to his accepted October 13, 2021 employment injury.

ORDER

IT IS HEREBY ORDERED THAT the September 18, 2025, and February 4, 2026 decisions of the Office of Workers’ Compensation Programs are affirmed.

Issued: June 29, 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

12
Id.; see also S.H., Docket No. 25-0157 (issued February 19, 2025).
13
See id.

4