E.D. and U.S. Postal Service, Ozone Park Annex (Board decision, July 23, 2026)

ECAB final decision. The Board affirmed OWCP's March 6, 2026 decision ending wage loss and medical benefits for the accepted injury. 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 letter carrier had received compensation for a 2008 work injury. OWCP obtained a medical evaluation and concluded that the accepted work conditions no longer caused disability or required treatment. The Board found the evidence sufficient to support termination of wage loss and medical benefits and affirmed OWCP's 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: Termination of wage loss and medical benefits affirmed.
• Key point: The medical evidence supported OWCP's finding that accepted injury residuals had ended.

Full text (ECAB public release)

United States Department of Labor
Employees’ Compensation Appeals Board

________
)
E.D., Appellant
)
)
and ) Docket No. 26-0411
) Issued: July 23, 2026
U.S. POSTAL SERVICE, OZONE PARK
)
ANNEX, Jamaica, NY, 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
PATRICIA H. FITZGERALD, Deputy Chief Judge JANICE B. ASKIN, Judge

JURISDICTION

On March 29, 2026 appellant filed a timely appeal from a March 6, 2026 merit decision 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.

ISSUES

The issues are: (1) whether OWCP met its burden of proof to terminate appellant’s wage- loss compensation and medical benefits, effective January 30, 2026, as she no longer had disability or residuals causally related to her accepted June 30, 2008 employment injury; and (2) whether appellant has met her burden of proof to establish continuing disability or residuals, on or after January 30, 2026, causally related to the accepted employment injury.

1
5 U.S.C. § 8101 et seq.
FACTUAL HISTORY

This case has previously been before the Board on a different issue.2 The facts and circumstances as set forth in the Board’s prior order are incorporated herein by reference.

On June 30, 2008 appellant, then a 30-year-old letter carrier, filed a traumatic injury claim (Form CA-1) alleging that on that date she injured her left wrist when she lifted a heavy box while in the performance of duty.3 She stopped work on June 30, 2008. OWCP accepted the claim for left wrist sprain and left wrist de Quervain’s disease. It paid appellant intermittent wage-loss compensation on the supplemental rolls commencing August 15, 2008. Appellant returned to limited-duty work on November 5, 2008.

On June 16, 2025 OWCP referred appellant, the medical record, a statement of accepted facts (SOAF), and a series of questions to Dr. Howard Kiernan, a Board-certified orthopedic surgeon, for a second opinion examination regarding the status of the nature and extent of appellant’s injury-related residuals and disability.

In a report dated July 16, 2025, Dr. Kiernan related appellant’s history of injury, provided examination findings, and noted his review of the SOAF and the medical record. He reported normal left wrist sensation; negative Tinel’s, Phalen’s, and Finkelstein tests; no thenar muscle atrophy; 5/5 grip, pinch, and intrinsic muscle strength; normal left wrist range of motion (ROM); and no complaint of tenderness on palpation of the left wrist. Dr. Kiernan diagnosed history of left wrist sprain, healed; and history of left radial styloid tenosynovitis, healed. He concluded that, based on clinical findings, appellant had no active residuals of the accepted employment injury. Dr. Kiernan further opined that appellant was medically capable of performing her date-of-injury job as a letter carrier. He advised that her prognosis was good and there was no need for further medical treatment.

On August 21, 2025 OWCP advised appellant of its notice of proposed termination of her wage-loss compensation and medical benefits, as the evidence of record established that she no longer had employment-related disability or residuals causally related to her accepted June 30, 2008 employment injury. It afforded her 30 days to submit additional evidence or argument if she disagreed with the proposed termination.

On August 29, 2025 appellant disagreed with the proposed termination of her medical and wage-loss compensation benefits.

2
Order Remanding Case, Docket No. 20-0745 (issued May 18, 2021).
3
OWCP assigned the present claim OWCP File No. xxxxxx383. On January 8, 2009 appellant filed a traumatic injury claim (Form CA-1) alleging that, on that date, she slipped on black ice and injured her left wrist, shoulder, and hand. OWCP assigned that claim OWCP File No. xxxxxx436. On November 12, 2019 appellant filed an occupational disease claim (Form CA-2) alleging that she sustained severe bilateral wrist pain causally related to factors of her federal employment. OWCP assigned that claim OWCP File No. xxxxxx540 and accepted it for bilateral radial styloid tenosynovitis (de Quervain’s). On November 19, 2020 it administratively combined OWCP File Nos. xxxxxx436, xxxxxx540 and xxxxxx383, with the latter designated as the master file.

2
In an August 27, 2025 report, Dr. Yehuda Kleinman, a Board-certified orthopedic surgeon, noted that appellant returned for follow-up of her chronic bilateral wrist de Quervain’s tenosynovitis. On physical examination of the left wrist, he observed no thenar or hypothenar eminence atrophy, and abnormal Finkelstein test. Dr. Kleinman diagnosed bilateral de Quervain’s tenosynovitis and related that appellant would continue with conservative medical treatment.

By decision dated January 30, 2026, OWCP terminated appellant’s wage-loss compensation and medical benefits, effective that date, finding that she no longer had disability or residuals causally related to her accepted June 30, 2008 employment injury. It found Dr. Kiernan’s opinion constituted the weight of the medical opinion evidence.

On February 26, 2026 appellant requested reconsideration and submitted additional medical evidence.

In a February 25, 2026 report, Dr. Kleinman related that appellant had a chronic condition affecting the bones, joints, tendons, and nerves of both hands. He provided physical examination findings of the left wrist indicating that thenar eminence atrophy was present, hypothenar eminence atrophy not present, abnormal Finkelstein’s test, decreased grip strength, and decreased pinch strength. Dr. Kleinman noted that appellant required splints for all activities and anti- inflammatory medication. He concluded that she had been unable to return to work since increased activity would increase her symptoms, thus, appellant remained disabled due to her chronic condition. Dr. Kleinman diagnosed chronic bilateral wrist and hand dysfunction, which he attributed to her work-related activities.

By decision dated March 6, 2026, OWCP denied modification of the January 30, 2026 termination decision.

LEGAL PRECEDENT -- ISSUE 1

Once OWCP accepts a claim and pays compensation, it has the burden of justifying modification or termination of an employee’s benefits.4 After it has determined that an employee has disability causally related to his or her federal employment, OWCP may not terminate compensation without establishing that the disability has ceased or that it is no longer related to the employment.5 Its burden of proof includes the necessity of furnishing rationalized medical opinion evidence based on a proper factual and medical background.6

4
See R.A., Docket No. 26-0062 (issued May 1, 2026); M.B., Docket No. 24-0697 (issued July 25, 2024);
L.M., Docket No. 22-0342 (issued August 25, 2023); T.C., Docket No. 20-1163 (issued July 13, 2021); Paul L. Stewart, 54 ECAB 824 (2003). 5 M.B., id.; A.T., Docket No. 20-0334 (issued October 8, 2020); E.B., Docket No. 18-1060 (issued November 1, 2018).
6
M.B., id.; C.R., Docket No. 19-1132 (issued October 1, 2020); G.H., Docket No. 18-0414 (issued November 14, 2018).

3
The right to medical benefits for an accepted condition is not limited to the period of entitlement for disability.7 To terminate authorization for medical treatment, OWCP must establish that appellant no longer has residuals of an employment-related condition, which would require further medical treatment.8

ANALYSIS -- ISSUE 1

The Board finds that OWCP met its burden of proof to terminate appellant’s wage-loss compensation and medical benefits, effective January 30, 2026.

In his July 16, 2025 report, Dr. Kiernan related appellant’s history of injury, provided examination findings, and noted his review of the SOAF and the medical record. He found no complaint of tenderness on palpation, normal sensation, negative Tinel’s, Phalen’s, and Finkelstein tests; no thenar muscle atrophy; 5/5 grip, pinch, and intrinsic muscle strength; and normal ROM. Based on his evaluation of appellant and diagnostic studies, Dr. Kiernan opined that the work- related conditions had resolved, further medical treatment was not required, and she could return to work in her date-of-injury position without restrictions.

The Board finds that the opinion of Dr. Kiernan has reliability, probative value, and convincing quality with respect to its conclusions regarding the issue of continuing work-related disability and residuals. He provided a thorough factual and medical history and accurately summarized the relevant medical evidence. Dr. Kiernan provided sufficient medical rationale for his opinion by explaining that appellant had no objective evidence of the June 30, 2008 employment injury.9 Accordingly, the Board finds that OWCP properly relied on his second opinion report in terminating appellant’s wage-loss compensation and medical benefits.10

OWCP also received an August 27, 2025 report from Dr. Kleinman diagnosing de Quervain’s tenosynovitis. On physical examination, he observed a limited subjective finding of abnormal Finkelstein test. Dr. Kleinman concluded that she had been unable to return to work since increased activity would increase her symptoms, thus, appellant remained disabled due to her chronic condition. He, however, failed to provide a well-rationalized opinion, with supporting objective evidence, explaining that appellant’s accepted conditions had not resolved. The Board has held that a report is of limited probative value if it does not contain medical rationale.11

7
J.W., Docket No. 19-1014 (issued October 24, 2019); L.W., Docket No. 18-1372 (issued February 27, 2019).
8
L.S., Docket No. 19-0959 (issued September 24, 2019); R.P., Docket No. 18-0900 (issued February 5, 2019).
9
See F.M., Docket No. 25-0599 (issued July 25, 2025); C.W., Docket No. 21-0943 (issued February 17, 2023);
W.C., Docket No. 18-1386 (issued January 22, 2019); D.W., Docket No. 18-0123 (issued October 4, 2018); Melvina Jackson, 38 ECAB 443 (1987). 10 F.M., id.; D.D., Docket No. 21-1029 (issued February 22, 2022); R.P., Docket No. 20-0891 (issued September 20, 2021); N.G., Docket No. 18-1340 (issued March 6, 2019); A.F., Docket No. 16-0393 (issued June 24, 2016). 11 See F.M., id.; S.T., Docket No. 23-0610 (issued April 8, 2024); T.T., Docket No. 18-1054 (issued April 8, 2020);
Y.D., Docket No. 16-1896 (issued February 10, 2017).

4
Therefore, this evidence is insufficient to overcome the weight of the evidence accorded to Dr. Kiernan or create a conflict in the medical opinion evidence.12

The Board finds, therefore, that OWCP met its burden of proof to terminate appellant’s wage-loss compensation and medical benefits, effective January 30, 2026.

LEGAL PRECEDENT -- ISSUE 2

When OWCP properly terminates compensation benefits, the burden shifts to appellant to establish continuing residuals or disability after that date, causally related to the accepted employment injury.13 To establish causal relationship between the condition as well as any attendant disability claimed and the employment injury, an employee must submit rationalized medical evidence based on a complete medical and factual background, supporting such causal relationship.14

ANALYSIS -- ISSUE 2

The Board finds that appellant has not met her burden of proof to establish continuing disability or residuals on or after January 30, 2026, causally related to the accepted June 30, 2008 employment injury.

After the January 30, 2026 termination of her wage-earning compensation and medical benefits, appellant submitted a February 25, 2026 report wherein Dr. Kleinman noted additional findings from her current physical examination which he did not note in his August 27, 2025 report. He diagnosed chronic bilateral wrist and hand dysfunction, which he attributed to her work- related activities. However, Dr. Kleinman did not provide a rationalized medical opinion explaining that appellant continued to have disability or residuals, on or after January 30, 2026, causally related to the accepted employment injury. He did not explain how objective findings demonstrated that appellant had disability or residuals of the accepted June 30, 2008 employment injury on or after January 30, 2026. The Board has held that a report is of limited probative value regarding causal relationship if it does not contain sufficient medical rationale.15

12
See C.W., Docket No. 26-0091 (issued March 17, 2026); S.M., Docket No. 18-0673 (issued January 25, 2019);
C.S., Docket No. 18-0952 (issued October 23, 2018); Manuel Gill, 52 ECAB 282 (2001). 13 See C.W., id.; S.M., Docket No. 18-0673 (issued January 25, 2019); C.S., Docket No. 18-0952 (issued October 23, 2018); Manuel Gill, 52 ECAB 282 (2001).
14
Id.
15
See C.W., id.; T.T., Docket No. 18-1054 (issued April 8, 2020); Y.D., Docket No. 16-1896 (issued February 10, 2017).

5
As the medical evidence of record is insufficient to establish continuing disability or residuals, on or after January 30, 2026, causally related to appellant’s accepted June 30, 2008 employment injury, the Board finds that she has not met her burden of proof.16

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 OWCP met its burden of proof to terminate appellant’s wage-loss compensation and medical benefits, effective January 30, 2026, as she no longer had disability or residuals causally related to her accepted June 30, 2008 employment injury. The Board further finds that appellant has not met her burden of proof to establish continuing disability or residuals on or after January 30, 2026 causally related to her accepted June 30, 2008 employment injury.

ORDER

IT IS HEREBY ORDERED THAT the March 6, 2026 decision of the Office of Workers’ Compensation Programs is affirmed.

Issued: July 23, 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

16
R.R., Docket No. 25-0090 (issued January 31, 2025); C.L., Docket No. 23-0012 (issued April 26, 2024);
P.H., Docket No. 21-1072 (issued May 18, 2022); R.C., Docket No. 19-0376 (issued July 15, 2019).

6