United States Department of Labor

Employees’ Compensation Appeals Board

__________________________________________

A.S., Appellant

and

U.S. POSTAL SERVICE, CITY COLLEGES OF 

CHICAGO POST OFFICE, Chicago, IL, 

Employer

__________________________________________

)

)

)

)

)

)

)

)

)

Docket No. 20-1068

Issued: September 21, 2022

Appearances: Case Submitted on the Record

Appellant, pro se

Office of Solicitor, for the Director

DECISION AND ORDER

Before:

PATRICIA H. FITZGERALD, Deputy Chief Judge

JANICE B. ASKIN, Judge

VALERIE D. EVANS-HARRELL, Alternate Judge

JURISDICTION

On April 22, 2020 appellant filed a timely appeal from an October 25, 2019 merit decision 

of the Office of Workers’Compensation Programs (OWCP).1 Pursuant to the Federal Employees’

Compensation Act2(FECA) and 20 C.F.R. §§ 501.2(c) and 501.3, the Board has jurisdiction over 

the merits of this case.3

1 Appellant submitted a timely request for oral argument before the Board. 20 C.F.R. § 501.5(b). However, 

appellant subsequently withdrew her request. 

2

5 U.S.C. § 8101 et seq.

3 The Board notes that following the October 25, 2019 decision, OWCP received additional evidence. 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

ISSUE

The issue is whether appellant has met her burden of proof to establish greater than 25

percent permanent impairment of her right upper extremity or greater than 29 percent permanent 

impairment of her left upper extremity, for which she previously received schedule award

compensation. 

FACTUAL HISTORY

On May 15, 2007 appellant, then a 58-year-old distribution/window clerk, filed an 

occupational disease claim (Form CA-2) alleging that she sustained bilateral carpal tunnel 

syndrome (CTS) and bilateral cubital tunnel syndrome as a result of repetitive factors of her federal 

employment, including sorting and throwing mail.

4

 She retired effective June 2, 2007. On

April 14, 2008 OWCP accepted the claim for bilateral CTS and a right ulnar lesion and authorized 

appropriate surgical procedures.

5

On September 15, 2010 appellant filed a claim for compensation (Form CA-7) for a 

schedule award.

By decision dated August 25, 2011, OWCP granted appellant a schedule award for 5 

percent permanent impairment of the left upper extremity and 10 percent permanent impairment 

of the right upper extremity. The award ran for 46.8 weeks of compensation for the period May 4, 

2011 through March 26, 2012. The weight of the medical opinion evidence was accorded to the 

district medical adviser (DMA) based upon his rating of appellant’s accepted bilateral CTS and a 

right ulnar lesion conditions. 

On September 20, 2011 appellant requested an oral hearing before a representative of

OWCP’s Branch of Hearings and Review, which was held on March 21, 2012. By decision dated 

June 11, 2012, OWCP’s hearing representative set aside the August 25, 2011 decision and 

remanded the case for OWCP to provide its DMA with newly-submitted evidence and, following 

further development, issue a de novo decision regarding appellant’s bilateral upper extremity 

impairments under the applicable provisions of the sixth edition of the American Medical 

Association, Guides to the Evaluation of Permanent Impairment (A.M.A., Guides).

6

In a report dated July 15, 2012, the DMA recommended that appellant undergo a second 

opinion evaluation. 

4 The present claim was assigned OWCP File No. xxxxxx896 by OWCP. Appellant also has a claim under OWCP 

File No. xxxxxx709 for a traumatic injury on February 7, 2003, when she was hit in the back with an all-purpose 

container. That claim was accepted for aggravation of fibromyalgia, and cervical and lumbar radiculopathy. 

Appellant’s claims have not been administratively combined by OWCP. 

5 Appellant underwent left CTS release surgery on September 20, 2009;right CTS release surgery on July 11, 2008; 

and right ulnar nerve entrapment cubital tunnel elbow surgery on November 6, 2008. 

6 A.M.A., Guides(6th ed. 2009).
3

OWCP referred appellant to Dr. Allan Brecher, a Board-certified orthopedic surgeon, for 

a second opinion evaluation. Dr. Brecher reported on September 28, 2012 that appellant had eight

percent permanent impairment of the right upper extremity and seven percent permanent 

impairment of the left upper extremity. 

The DMA reviewed the case file again on November 12, 2012 and determined that 

appellant was not entitled to an increased schedule award. 

By decision dated December 7, 2012, OWCP denied the claim for an increased schedule 

award.

On December 26, 2012 appellant requested a hearing before a representative of OWCP’s

Branch of Hearings and Review. By decision dated February 4, 2013, OWCP’s hearing 

representative conducted a preliminary review, set aside the December 7, 2012 decision, and 

remanded the case to OWCP for a supplemental opinion from Dr. Brecher, who was to provide an 

assessment of upper extremity permanent impairment including consideration of any preexisting 

conditions.

On March 26, 2013 Dr. Brecher affirmed his prior rating. 

By decision dated May 15, 2013, OWCP again denied appellant’s claim for an increased 

schedule award. 

On May 16, 2013 OWCP expanded the acceptance of appellant’s claim to include disorders

of bursae and tendons in the right shoulder region.

On June 10, 2013 appellant requested a hearing before a representative of OWCP’s Branch 

of Hearings and Review. By decision dated August 5, 2013, OWCP’s hearing representative found

that the case was not in posture for a hearing and vacated OWCP’s May 15, 2013 decision. He

remanded the case to OWCP for further development, including referral of appellant for a new 

second opinion evaluation pursuant to the A.M.A., Guides and The Guides Newsletter, Rating 

Spinal Nerve Extremity Impairment Using the Sixth Edition (July/August 2009) (The Guides 

Newsletter).

OWCP referred appellant to Dr. James Elmes, a Board-certified orthopedic surgeon, for a 

new second opinion impairment evaluation. In a January 23, 2014 report, Dr. Elmes related that 

appellant had no ratable permanent impairment due to her bilateral CTS and right cubital tunnel 

conditions; however if shoulder impingement were an accepted condition she would be entitled to 

a schedule award for 20 percent permanent impairment of the right and left shoulders. 

On February 17, 2014 the DMA reviewed the record again and concluded that appellant 

was not entitled to an increased schedule award. 

By decision dated March 12, 2014, OWCP again denied the claim for an increased 

schedule award. It accorded the weight of the medical opinion evidence to the DMA.

On April 9, 2014 appellant requested a hearing before a representative of OWCP’s Branch 

of Hearings and Review. The hearing was held on July 30, 2014. 
4

By decision dated October 21, 2014, OWCP’s hearing representative set aside the 

March 12, 2014 decision and remanded the case to OWCP to obtain a supplemental report from

Dr. Elmes.

In a supplemental report dated December 1, 2014, Dr. Elmes affirmed his prior opinion. 

On March 6, 2015 a DMA reviewed the case record and concluded that appellant was not 

entitled to an increased schedule award. 

By decision dated March 11, 2015, OWCP again denied appellant’s claim for an increased 

schedule award. It accorded the weight of the medical opinion evidence to the DMA. 

On April 3, 2015 appellant requested an oral hearing before a representative of OWCP’s 

Branch of Hearings and Review. By decision dated July 8, 2015, OWCP’s hearing representative 

conducted a preliminary review and found the case not in posture for a hearing. She set aside the 

March 11, 2015 decision and remanded the case to OWCP for referral to a new second opinion 

physician for a report on whether appellant’s shoulder conditions were temporary or permanent 

and for an additional bilateral upper extremity permanent impairment rating. 

OWCP referred appellant to Dr. Salman Chaudri, an osteopath Board-certified in 

orthopedic surgery, for a second opinion evaluation. Dr. Chaudri rendered a report on 

April 28, 2016. He opined that appellant’s employment duties could have caused bilateral 

shoulder impingement; however, the condition had resolved. 

On May 25, 2016 OWCP expanded the acceptance of the claim to include temporary 

aggravation of bilateral shoulder impingement, resolved as of May 4, 2011. 

Following review by a DMA of the case file on May 25, 2016, by decision dated June 7, 

2016, OWCP again denied appellant’s claim for an increased schedule award. It accorded the 

weight of the medical evidence to the DMA.

On July 5, 2016 appellant requested a hearing before a representative of OWCP’s Branch 

of Hearings and Review. A hearing was held on December 29, 2016. 

By decision dated January 30, 2017, OWCP’s hearing representative vacated OWCP’s 

June 7, 2016 decision and remanded the case to OWCP to update the statement of accepted facts 

(SOAF) and obtain a supplemental opinion from Dr. Chaudri.

Following further development, OWCP determined that a referral to another second 

opinion physician was necessary and referred appellant to Dr. Theodore Suchy, an osteopath 

Board-certified in orthopedic surgery. Dr. Suchy reported on June 29, 2017 that appellant had 

eight percent permanent impairment of the right upper extremity, based upon median and ulnar 

nerve impairment, and five percent permanent impairment of the left upper extremity for median 

nerve permanent impairment. 

On August 18, 2017 the DMA reviewed the case record and concluded that appellant was 

not entitled to an increased schedule award. 
5

By decision dated August 24, 2017, OWCP again denied appellant’s claim for an increased 

schedule award. It accorded the weight of the medical opinion evidence to the DMA.

On September 18, 2017 appellant requested a hearing before an OWCP hearing 

representative. Following a preliminary review, by decision dated December 5, 2017, an OWCP 

hearing representative set aside the August 24, 2017 decision and remanded the case to OWCP to 

combine OWCP File No. xxxxxx709 with the current claim and to then obtain a supplemental 

report from Dr. Suchy. If Dr. Suchy was unwilling to provide the requested information, OWCP 

was directed to refer appellant for a new second opinion evaluation.

Following further development with Dr. Suchy, OWCP referred appellant along with a 

SOAF to Dr. Brecher for a second opinion impairment evaluation. In a May 30, 2018 report,

Dr. Brecher opined that appellant had 18 percent permanent impairment of the right upper 

extremity and 18 percent permanent impairment of the left upper extremity. 

In an August 1, 2018 report, the DMA related that Dr. Brecher’s and Dr. Suchy’s 

examination findings differed and recommended that a new second opinion impairment evaluation 

be obtained. The DMA also found that the date of maximum medical improvement (MMI) was 

undetermined. 

OWCP issued a new SOAF on October 4, 2018 and referred appellant to Dr. Elmes, for a 

second opinion impairment evaluation. In a January 24, 2019 report, Dr. Elmes reviewed the 

medical evidence, including the objective studies of record, along with his previous impairment 

reports. He noted appellant’s complaints of bilateral shoulder pain, bilateral hand pain, and 

bilateral elbow pain and provided examination findings, including three measurements of the 

goniometer for the bilateral shoulders, elbows, wrists and cervical and lumbar spine. Dr. Elmes 

noted that she had tenderness anteriorly and posteriorly in the right shoulder and mildly on the 

lateral aspect with no atrophy, crepitus or swelling and a negative drop-arm test. Appellant had 

mild positive Neer abduction test. Under the diagnosis-based impairment (DBI) methodology,

Dr. Elmes found, under Table 15-5 page 402 of the A.M.A., Guides, that she had Class 1 or 1 

percent impairment for shoulder impingement syndrome. Under the range of motion (ROM) 

impairment methodology under Table 15-34 page 475, he found that for the right shoulder flexion 

80 degrees equaled 9 percent impairment, extension 40 degrees equaled 1 percent impairment; 

abduction 80 degrees equaled 6 percent impairment; adduction 30 degrees equaled 1 percent 

impairment; external rotation 40 degrees equaled 2 percent impairment; internal rotation 50 

degrees equaled 2 percent impairment, for a total of 21 percent right upper extremity impairment. 

For the left shoulder, Dr. Elmes found that: flexion 80 degrees equaled 9 percent impairment; 

extension 30 degrees equaled 1 percent impairment; abduction 80 degrees equaled 6 percent 

impairment; adduction 30 degrees equaled 1 percent impairment; external rotation 50 degrees 

equaled 2 percent impairment; and internal rotation to 60 degrees equaled 2 percent impairment,

for a total of 21 percent left upper extremity impairment. He opined that as the ROM impairment

methodology of the A.M.A., Guides yielded the greater impairment, appellant had 21 percent 

permanent impairment of the right shoulder and 21 percent permanent impairment of the left 

shoulder. Dr. Elmes further opined that no additional impairment was recommended for the right 

and left CTS, right cubital tunnel, and right and left elbow conditions as his review of the additional 

medical records and appellant’s January 24, 2019 evaluation was unchanged from his January 16, 

2014 report. Regarding appellant’s cervical condition, he related that while her March 28, 2008
6

electromyogram (EMG) studies noted C5-6 radiculopathy, and October 13, 2010 and March 11, 

2011 EMG studies were within normal limits, except for a slight delay at the elbow level ulnar 

nerve on October 13, 2010.

In a February 21, 2019 report, Dr. Michael M. Katz, a Board-certified orthopedic surgeon

serving an OWCP DMA, reviewed Dr. Elmes’ findings and found that appellant reached MMI on 

January 24, 2019. He also concurred with Dr. Elmes’ impairment findings, as she had 21 percent 

permanent impairment for the right upper extremity and 21 percent permanent impairment for the 

left upper extremity based on the ROM methodology for her shoulder conditions, which yielded

the greater impairment over that of the DBI rating. For the right upper extremity, the DMA 

combined the 21 percent shoulder impairment with the prior, nonoverlapping award of 10 percent 

impairment to find a total impairment of 29 percent. From the total impairment of 29 percent, he 

subtracted the 10 percent prior award and found that appellant was due an additional award of 19 

percent right upper extremity impairment. For the left upper extremity, the DMA combined the 

21 percent shoulder impairment with the prior, nonoverlapping award of 5 percent left upper 

extremity impairment, to find a total impairment of 25 percent. From the total impairment of 25 

percent left upper extremity impairment, he subtracted the 5 percent prior award and found that 

the additional award now due was 20 percent left upper extremity impairment. 

By decision dated March 19, 2019, OWCP awarded appellant an increased schedule award 

of 19 percent (for a total of 29 percent) permanent impairment of the right upper extremity and an 

increased schedule award of 20 percent (for a total of 25 percent) permanent impairment of the left 

upper extremity as a result of her bilateral shoulder conditions. The award ran for 121.68 weeks 

for the period January 24, 2019 to May 24, 2021. OWCP accorded the weight of the medical 

evidence to the DMA’s, Dr. Katz’, February 25, 2019 report.

On April 17, 2019 appellant requested an oral hearing before a representative of OWCP’s 

Branch of Hearings and Review. 

By decision dated April 18, 2019, OWCP amended its March 19, 2019 decision to reflect 

a correct calculation of the consumer price index (CPI). 

A telephonic hearing was held on August 12, 2019.

Subsequent to the hearing, appellant received statements from appellant from May 16 to 

September 16, 2019. Also received were medical records, treatment notes, and diagnostic test 

results dated December 29, 2015 through February 13, 2019. 

By decision dated October 25, 2019, OWCP’s hearing representative affirmed OWCP’s 

March 19, 2019 decision, which was amended on April 18, 2019. 
7

LEGAL PRECEDENT

The schedule award provisions of FECA7 and its implementing regulations8 set forth the 

number of weeks of compensation payable to employees sustaining permanent impairment from 

loss or loss of use of scheduled members or functions of the body. However, FECA does not 

specify the manner in which the percentage of loss shall be determined. For consistent results and 

to ensure equal justice under the law to all claimants, good administrative practice necessitates the 

use of a single set of tables so that there may be uniform standards applicable to all claimants.

Through its implementing regulations, OWCP adopted the A.M.A., Guides as the appropriate 

standard for evaluating schedule losses.9 As of May 1, 2009, schedule awards are determined in 

accordance with the sixth edition of the A.M.A., Guides (2009).10 The Board has approved the 

use by OWCP of the A.M.A., Guides for the purpose of determining the percentage loss of use of 

a member of the body for schedule award purposes.11

In determining impairment for the upper extremities under the sixth edition of the A.M.A., 

Guides, an evaluator must establish the appropriate diagnosis for each part of the upper extremity 

to be rated. With regard to the shoulder, the relevant portion of the arm for the present case, 

reference is made to Table 15-5 (Shoulder Regional Grid) beginning on page 401. After the class 

of diagnosis (CDX) is determined from the Shoulder Regional Grid (including identification of a 

default grade value), the net adjustment formula is applied using the grade modifier for functional 

history (GMFH), grade modifier for physical examination (GMPE), and grade modifier for clinical 

studies (GMCS). The net adjustment formula is (GMFH - CDX) + (GMPE - CDX) + (GMCS -

CDX).12

Regarding the application of ROM or DBI impairment methodologies in rating permanent 

impairment of the upper extremities, FECA Bulletin No. 17-06 provides:

“As the [A.M.A.,] Guides caution that if it is clear to the evaluator evaluating loss 

of ROM that a restricted ROM has an organic basis, three independent 

measurements should be obtained and the greatest ROM should be used for the 

determination of impairment, the CE [claims examiner] should provide this 

information (via the updated instructions noted above) to the rating physician(s).

7

5 U.S.C. § 8107.

8

20 C.F.R. § 10.404.

9

Id. See also R.C., Docket No. 20-0274 (issued May 13, 2021); Ronald R. Kraynak, 53 ECAB 130 (2001).

10 See Federal (FECA) Procedure Manual, Part 3 -- Medical, Schedule Awards, Chapter 3.700, Exhibit 1 

(January2010); Federal Procedure Manual, Part 2 -- Claims, Schedule Awards and Permanent Disability Claims, 

Chapter 2.808.5a (March 2017).

11 R.C., supra note 9; P.R., Docket No. 19-0022 (issued April9, 2018); Isidoro Rivera, 12 ECAB 348 (1961).

12 See A.M.A., Guides 405-12. Table 15-5 also provides that, if motion loss is present for a claimant with certain 

diagnosed conditions, permanent impairment may alternatively be assessed using Section 15.7 (ROM impairment). 

Such a ROM assessment stands alone and is not combined with a DBI rating. Id. at 401-05, 475-78.
8

“Upon initial review of a referral for upper extremity impairment evaluation, the 

DMA should identify (1) the methodology used by the rating physician (i.e., DBI 

or ROM) and (2) whether the applicable tables in Chapter 15 of the [A.M.A.,] 

Guidesidentify a diagnosis that can alternatively be rated by ROM. If the [A.M.A.,] 

Guides allow for the use of both the DBI and ROM methods to calculate an 

impairment rating for the diagnosis in question, the method producing the higher 

rating should be used. (Emphasis in the original.)”

The FECA Bulletin further provides:

“If the rating physician provided an assessment using the DBI method and the 

[A.M.A.,] Guides allow for use of ROM for the diagnosis in question, the DMA 

should independently calculate impairment using both the ROM and DBI methods 

and identify the higher rating for the CE.

“If the medical evidence of record is not sufficient for the DMA to render a rating 

on ROM where allowed, the DMA should advise as to the medical evidence 

necessary to complete the rating. However, the DMA should still render an 

impairment rating using the DBI method, if possible, given the available 

evidence.13”

OWCP’s procedures provide that, after obtaining all necessary medical evidence, the file 

should be routed to an OWCP medical adviser for an opinion concerning the nature and percentage 

of impairment in accordance with the A.M.A., Guides, with the medical adviser providing 

rationale for the percentage of impairment specified.14

ANALYSIS

The Board finds that appellant has not met her burden of proof to establish greater than 25 

percent permanent impairment of her right upper extremity or greater than 29 percent permanent 

impairment of her left upper extremity, for which she previously received schedule award 

compensation. 

By decision dated August 25, 2011, OWCP granted appellant a schedule award for 5 

percent permanent impairment of the left upper extremity and 10 percent permanent impairment 

of the right upper extremity for her accepted bilateral CTS and a right ulnar lesion condition. 

Following a complex procedural history, OWCP issued an updated October 4, 2018 SOAF 

and referred appellant to Dr. Elmes for another second opinion reevaluation. In his January 24, 

2019 report, Dr. Elmes reviewed the SOAF and the medical evidence of record along with his 

previous impairment reports. He noted appellant’s examination findings and that he took three 

13 FECA Bulletin No. 17-06 (issued May8, 2017).

14 See supra note 10at Chapter 2.808.6f (March 2017); see also D.J.,Docket No. 19-0352 (issued July 24, 2020).
9

measurements with the goniometer for measuring the bilateral shoulders, elbows, wrists and 

cervical and lumbar spine. 

Under the DBI methodology for both shoulders, Dr. Elmes found, under Table 15-5 of the 

A.M.A., Guides, that appellant had Class 1 or 1 percent permanent impairment for shoulder 

impingement syndrome. For the right shoulder, under the ROM impairment methodology,

Dr. Elmes found that under Table 15-34 page 475, flexion 80 degrees equaled 9 percent 

impairment, extension 40 degrees equaled 1 percent impairment, abduction 80 degrees equaled 6 

percent impairment, adduction 30 degrees equaled 1 percent impairment, external rotation 40 

degrees equaled 2 percent impairment, internal rotation 50 degrees equaled 1 percent impairment, 

for a total of 21 percent right upper extremity impairment. For the left shoulder, under the ROM 

impairment methodology, he found, under Table 15-34 page 475, that flexion 80 degrees equaled 

9 percent impairment, extension 30 degrees equaled 1 percent impairment, abduction 80 degrees 

equaled 6 percent impairment, adduction 30 degrees equaled 1 percent impairment, external 

rotation 50 degrees equaled 2 percent impairment, and internal rotation to 60 degrees equaled 2 

percent impairment, for a total of 21percent left upper extremity impairment. Dr. Elmes opined 

that as the ROM impairment methodology of the A.M.A., Guides yielded the greater impairment, 

appellant had 21 percent permanent impairment of the right shoulder and 21 percent permanent 

impairment of the left shoulder. 

Dr. Elmes further opined that no additional impairment was recommended for the bilateral 

CTS, right cubital tunnel, and bilateral elbow conditions. He reviewed appellant’s current 

examination along with her medical records and his previous report of January 16, 2014, which 

indicated that the only abnormality in the EMG studies was a slight delay at the elbow level ulnar 

nerve on October 13, 2010, but was not supported by clinical findings. As there were no current 

objective findings, Dr. Elmes opined that no additional impairment was recommended for the right 

and left CTS, right cubital tunnel, and right and left elbow conditions. 

In accordance with its procedures,15 OWCP properly referred the evidence of record to

DMA Dr. Katz, who reviewed the clinical findings of Dr. Elmes. In his report of February 21, 

2019, Dr. Katz opined that appellant reached MMI on January 24, 2019. He further concurred 

with the impairment findings of Dr. Elmes. This included that appellant had 21 percent permanent 

impairment for the right upper extremity and 21 percent permanent impairment for the left upper 

extremity based on the ROM methodology for her shoulder conditions, which yielded a greater 

impairment than the DBI ratings of those conditions, and that there was no additional impairment, 

beyond that previously awarded, for the bilateral CTS and right ulnar lesion conditions. With 

regard to the right upper extremity, the DMA combined the 21 percent shoulder impairment with 

the prior, nonoverlapping award of 10 percent impairment to find a total impairment rating of 29 

percent. OWCP awarded appellant an additional 19 percent right upper extremity impairment. 

For the left upper extremity, the DMA combined the 21 percent shoulder impairment with the 

prior, nonoverlapping award of 5 percent left upper extremity impairment, to find a total 

impairment rating of 25 percent. From the total impairment rating of 25 percent left upper 

15 Id.
10

extremity impairment, he subtracted the 5 percent prior award and found that the additional award 

due was 20 percent left upper extremity impairment. 

The Board finds that OWCP properly determined that the clinical findings and reports of

Dr. Elmes and the DMA constitute the weight of the medical evidence.16 There is no probative 

medical evidence of record demonstrating greater impairment than that previously awarded. 17 

Therefore, appellant has not met her burden of proof to establish an increased schedule award for 

either the left or right upper extremities.

Appellant may request a schedule award or increased schedule award at any time based on 

evidence of a new exposure or medical evidence showing progression of an employment-related 

condition resulting in permanent impairment or increased permanent impairment.

CONCLUSION

The Board finds that appellant has not met her burden of proof to establish greater than 25 

percent permanent impairment of her right upper extremity or greater than 29 percent permanent 

impairment of her left upper extremity, for which she previously rece ived schedule award 

compensation. 

16 J.S.,Docket No. 19-1567 (issued April1, 2020); J.H.,Docket No. 18-1207 (issued June20, 2019); M.C.,Docket 

No. 15-1757 (issued March 17, 2016).

17 See J.S., id.; J.M., Docket No. 18-1334 (issued March 7, 2019).
11

ORDER

IT IS HEREBY ORDERED THAT the October 25, 2019 decision of the Office of 

Workers’ Compensation Programs is affirmed. 

Issued: September 21, 2022

Washington, DC

Patricia H. Fitzgerald, Deputy Chief Judge

Employees’ Compensation Appeals Board

Janice B. Askin, Judge

Employees’ Compensation Appeals Board

Valerie D. Evans-Harrell, Alternate Judge

Employees’ Compensation Appeals Board