S.S. and U.S. Postal Service, San Francisco Processing & Distribution Center Finance Post Office (Board decision, August 13, 2026)

ECAB remand decision. The Board set aside OWCP's February 26, 2026 denial of wage loss compensation and returned the claim for findings on the submitted medical evidence; 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's finality rule in 5 U.S.C. § 8128(b) generally bars court review of compensation decisions; this remand does not award benefits.

Plain-English summary

A postal delivery worker injured his right knee against a mail truck doorpost and later claimed wage loss compensation. OWCP denied the claim, saying the evidence did not show work related disability during the claimed period. The Board found that OWCP had not made findings about the medical reports and work restrictions the worker submitted. It set aside the denial and directed OWCP to issue a new decision with findings of fact and an explanation of its reasons.

Decision snapshot

• Authority: Federal Employees' Compensation Act, 5 U.S.C. § 8124(a); 20 C.F.R. § 10.126.
• Outcome: Wage loss denial set aside and remanded for a reasoned decision.
• Key point: OWCP needed to address the submitted medical evidence when explaining its disability decision.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
S.S., Appellant
)
)
and ) Docket No. 26-0410
) Issued: August 13, 2026
U.S. POSTAL SERVICE, SAN FRANCISCO
)
PROCESSING & DISTRIBUTION CENTER
)
FINANCE POST OFFICE, San Francisco, CA,
)
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 VALERIE D. EVANS-HARRELL, Alternate Judge

On March 13, 2026 appellant filed a timely appeal from a February 26, 2026 merit decision of the Office of Workers’ Compensation Programs (OWCP). The Clerk of the Appellate Boards docketed the appeal as No. 26-0410.1

On November 7, 2025 appellant, then a 54-year-old postal collect and delivery employee, filed a traumatic injury claim (Form CA-1) alleging that on October 21, 2025, he sustained a right knee sprain when he struck his right knee on the doorpost of his vehicle as he was getting out of his truck to deliver mail, while in the performance of duty. He stopped work on October 22, 2025. OWCP accepted the claim for contusion of right knee, initial encounter.

In support of his claim, appellant submitted medical reports, progress forms, and work status notes dated October 22 through December 22, 2025 from Dr. Brett Curtis, Board-certified 1 The Board notes that, following the February 26, 2026 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. in emergency medicine. Dr. Curtis noted that he evaluated appellant on October 22, 2025 for an October 21, 2025 injury after he struck his right lateral knee on the inside of his vehicle door. He diagnosed contusion of right knee, initial encounter, and sprain of medial collateral ligament of right knee. Dr. Curtis released appellant to modified-duty sedentary work with restrictions of no commercial driving effective October 22, 2025.

On January 16, 2026 appellant filed a claim for compensation (Form CA-7) for disability from work during the period October 21, 2025 through February 10, 2026.

In a development letter dated January 20, 2026, OWCP informed appellant of the deficiencies of his claim for wage-loss compensation commencing October 21, 2025. It advised him of the type of medical evidence needed to establish his claim and afforded him 30 days to respond.

In response to OWCP’s development letter, appellant submitted additional evidence in support of his claim, including a January 17, 2026 magnetic resonance imaging (MRI) scan of the right knee demonstrating a medial meniscus tear.

In medical reports, forms, and work status notes dated January 10 through February 5, 2026, Dr. Paula Louise Conolly, Board-certified in integrative medicine, documented treatment for his right lateral knee injury.

In her reports, Dr. Conolly discussed appellant’s history of injury to his right lateral knee from a direct blow against the mail truck. She diagnosed sprain of medial collateral ligament of right knee and contusion of right knee, initial counter, which she opined was work-related as his symptoms began following his employment injury. Dr. Conolly noted physical examination findings including appellant’s antalgic gait and constant pain with ambulation. She released appellant to modified duty, sedentary work, with restrictions of no walking and no standing. In her February 5, 2026 report, Dr. Conolly noted that in response to appellant’s modified duty, the employing establishment took him off work.

By decision dated February 26, 2026, OWCP summarily denied appellant’s claim for disability from work commencing October 21, 2025. It found that the medical evidence of record was insufficient to establish disability from work during the claimed period, causally related to his accepted October 21, 2025 employment injury.

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

Section 8124(a) of FECA provides that OWCP shall determine and make a finding of fact and make an award for or against payment of compensation.2 Its regulations at section 10.126 provide that the decision of the Director of OWCP shall contain findings of fact and a statement of reasons.3 As well, OWCP’s procedures provide that the reasoning behind its evaluation should

2
5 U.S.C. § 8124(a).
3
20 C.F.R. § 10.126.

2 be clear enough for the reader to understand the precise defect of the claim and the kind of evidence, which would overcome it.4

The Board finds that OWCP’s February 26, 2026 decision summarily denied appellant’s disability claim without making findings regarding the medical evidence appellant submitted. OWCP did not discharge its responsibility to set forth findings of fact and a clear statement of reasons explaining the disposition so that appellant could understand the basis for the decision regarding his disability claim.5

Therefore, the Board shall set aside OWCP’s February 26, 2026 decision and remand the case for a de novo decision, which includes findings of fact and a statement of reasons for its decision pursuant to the standard set forth in section 5 U.S.C. § 8124(a) and 20 C.F.R. § 10.126. Accordingly,

IT IS HEREBY ORDERED THAT the February 26, 2026 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: August 13, 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

4
Federal (FECA) Procedure Manual, Part 2 -- Claims, Disallowances, Chapter 2.1400.5 (February 2013) (all decisions should contain findings of fact sufficient to identify the benefit being denied and the reason for the disallowance). 5 See Order Remanding Case, T.T., Docket No. 25-0523 (issued June 24, 2025); Order Remanding Case, B.K., Docket No. 23-0126 (issued May 10, 2023).

3