United States Department of Labor

Employees’ Compensation Appeals Board

__________________________________________

R.S., Appellant

and

DEPARTMENT OF THE INTERIOR, 

NATIONAL PARK SERVICE, Washington, DC, 

Employer

__________________________________________

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Docket No. 20-0177

Issued: September 3, 2021

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

PATRICIA H. FITZGERALD, Alternate Judge

JURISDICTION

On October 30, 2019 appellant filed a timely appeal from two May 16, 2019 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

ISSUES

The issues are: (1) whether appellant received an overpayment of compensation in the 

amount of $1,500.86, for the periods June 28 through July 27, 2013 and January 12 through 

March 8, 2014, because he improperly received wage-loss compensation at an augmented 

compensation rate; (2) whether he received an overpayment of compensation in the amount of 

 

1

5 U.S.C. § 8101 et seq.

2 The Board notes that,following the May 16, 2019 decisions, 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

$67,945.28, for the period June 28, 2013 through September 16, 2017, because he improperly 

received an attendant allowance; (3) whether OWCP properly found appellant at fault in the 

creation of the $1,500.86 and $67,945.28 overpayments, thereby precluding waiver of recovery of 

the overpayments; and (4) whether it properly required recovery of the $1,500.86 and $67,945.28 

overpayments by deducting $254.93 and $764.81, respectively, from appellant’s continuing 

compensation payments every 28 days.

FACTUAL HISTORY

OWCP accepted that on November 14, 1973 appellant, then a 46-year-old engineer, 

sustained a head contusion, vitreous detachment of the left eye, and cervical, lumbosacral, and 

right ankle strains due to a motor vehicle accident which occurred while in the performance of 

duty. It also accepted that he sustained a head contusion, and cervical, lumbosacral, and right 

ankle sprains due to a December 14, 1983 fall at work. Appellant last worked for the employing 

establishment on December 14, 1983 and OWCP paid him wage-loss compensation for disability 

from work on the supplemental and periodic rolls.

The case record reflects that on January 15, 1998 OWCP authorized appellant to receive 

an attendant allowance at a minimum rate of $1,384.62 every 28 days in order to compensate for 

his wife’s attending to his daily needs.

The case record contains several Form EN1032 documents, in which OWCP informed him

that the basic rate of compensation was 66 2/3 percent of the applicable pay rate if he had no 

eligible dependents within the meaning of FECA. OWCP further noted that compensation was 

payable at 75 percent of the applicable pay rate if he had one or more eligible dependents. It

informed appellant that he could claim additional compensation for a dependent if he had a spouse 

who was a member of his household or, under specified circumstances, a child or parent dependent 

upon his support. He had been paid at the augmented rate as his wife was a dependent. Appellant 

completed those forms between January 10, 1986 and December 13, 2013.

In a Form EN1032, signed on December 13, 2013, appellant advised OWCP that his wife 

had passed away on June 27, 2013 and he, therefore, no longer had a dependent for benefit rate 

purposes.

3

In an April 4, 2019 notice, OWCP advised appellant of its preliminary determination that 

he had received an overpayment of compensation in the amount of $1,500.86, for the periods

June 28 through July 27, 2013 and January 12 through March 8, 2014, because he received 

 

3 On June 29, 2013 OWCP paid appellant $5,384.34 in compensation for the period covering June 2 through 

29, 2013. On July 27, 2013 it paid him $5,384.34 in compensation for the period covering June 30 through 

July 27, 2013. On February 8, 2014 OWCP paid appellant $5,374.66 in compensation for the period January 12 

through February 8, 2014.
3

augmented compensation at the 75 percent pay rate to which he was not entitled.

4

 It provided a 

calculation of the overpayment, noting that appellant had a weekly pay rate of $4,400.00 and that 

proper application of the 66 2/3 pay rate meant that he was entitled to $4,191.43 for the period 

June 28 through July 27, 2013 and $7,840.86 for the period January 12 through March 8, 2014, 

with the two figures totaling $12,032.29. However, appellant actually received $4,714.29 and 

$8,818.86 for those respective periods, for a total of $13,533.15. OWCP found a $1,500.86 

overpayment by subtracting $12,032.29 from $13,533.15.5 It also made a preliminary 

determination that appellant was at fault in the creation of the overpayment because he accepted 

payments that he knew, or reasonably should have known, to have been incorrect. OWCP advised 

him that he could submit evidence challenging the fact, amount, or finding of fault and request 

waiver of the overpayment. It informed appellant that he could submit additional evidence in 

writing or at pre-recoupment hearing, but that a pre-recoupment hearing must be requested within 

30 days of the date of the written notice of overpayment. OWCP requested that he complete and 

return an enclosed overpayment recovery questionnaire (Form OWCP-20) within 30 days to be 

considered regarding the questions of waiver and method of recovery of the overpayment.

In a separate April 4, 2019 notice, OWCP advised appellant of its preliminary 

determination that he received a $67,945.28 overpayment of compensation for the period June 28, 

2013 through September 16, 2017 because he received an attendant allowance every 28 days 

during this period for which he did not qualify following the death of his wife. It indicated that he

received $67,945.28 in attendant allowance compensation for the period June 28, 2013 through 

September 16, 2017, but was not entitled to receive any portion of this amount because the entire 

payment period occurred after his wife’s death.6 OWCP also made a preliminary determination 

that appellant was at fault in the creation of the overpayment because he accepted payments that 

he knew, or reasonably should have known, to have been incorrect. It advised appellant regarding 

his options for challenging the fact, amount, or finding of fault, and for requesting waiver of 

 

4

In a June 5, 2018 notice, OWCP had previously advised appellant of its preliminary determination that he received 

a $58,481.20 overpayment of compensation for the period June 27, 2013 through September 16, 2017. In response to 

its request, appellant submitted an overpayment recovery questionnaire (Form OWCP-20), signed on July 2, 2018, in 

which he reported monthly income of $8,206.00, monthly expenses of $2,900.00, and assets of $21,000.00. A 

telephonic pre-recoupment hearing was held on November 16, 2018 before a representative of OWCP’s Branch of 

Hearings and Review and, by decision dated February 14, 2019, OWCP’s hearing representative advised that further 

development was required (including a more detailed explanation of the manner of the creation of the overpayment) 

before a final overpayment decision could be issued.

5 The case record contains payroll records and an April4, 2019 manual adjustment form detailing the calculation 

of the $1,500.86 overpayment for the periods June28 through July 27, 2013 and January 12 through March 8, 2014. 

The period June 28 through July 27, 2013 was covered by two electronic bank deposits. The first deposit was made 

on June 29, 2013 and covered the period June 2 through 29, 2013, thereby coinciding with the overpayment period 

for the last two days covered by the deposit (June 28 and 29, 2013). The second deposit was made on July 27, 2013 

and covered the period June30 through July 27, 2013, thereby coincidingwith the overpayment period for all the days 

covered by the deposit. Appellant had returned six bank deposits covering the period July 28, 2013 through 

January 11, 2014 and was paid compensation for that period.

6 The case record contains payroll records and an April 4, 2019 manual adjustment form detailing the calculation 

of the $67,945.28 overpayment. The documents show that appellant received an attendant allowance of $1,384.62 

every 28 days. The first electronic bank deposit which contained a prohibited portion of the $1,384.62 attendant 

allowance was made on June 29, 2013 and covered the period June 2 through 29, 2013, thereby coinciding with the 

overpayment period for the last two days covered by the deposit (June 28 and 29, 2013). The second electronic bank 

deposit which contained a prohibited $1,384.62 attendant allowance was made on July 27, 2013 and covered the period 

June 30 through July 27, 2013, thereby coincidingwith the overpayment period for all the days covered by the deposit.
4

recovery of the overpayment. OWCP again requested that he complete and return a Form OWCP20 within 30 days.

No response was received.

By decision dated May 16, 2019, OWCP found that appellant received an overpayment of 

compensation in the amount of $1,500.86 for the periods June 28 through July 27, 2013 and 

January 12 through March 8, 2014 because he improperly received wage-loss compensation at an 

augmented compensation rate. It also found him at fault in the creation of the $1,500.86 

overpayment, thereby precluding waiver of recovery of the overpayment. OWCP found appellant

at fault in the creation of the $1,500.86 overpayment because he neglected to provide notification 

within 90 days of the change in his dependency status and he knowingly continued to receive 

compensation at a pay rate to which he was not entitled. It denied waiver of recovery of the 

overpayment as he did not respond to its April 4, 2019 request for financial information and 

determined that recovery of the $1,500.86 overpayment would be made by deducting $254.93 from 

his continuing compensation payments every 28 days.

By separate decision dated May 16, 2019, OWCP found that appellant received an 

overpayment of compensation in the amount of $67,945.28 for the period June 28, 2013 to 

September 16, 2017, because he improperly received an attendant allowance. It further determined 

that he was at fault in the creation of the $67,945.28 overpayment, thereby precluding waiver of 

recovery of the overpayment. OWCP noted that appellant’s wife had been authorized since 1998 

to provide attendant services and appellant should have reasonably known that the payments he 

received following her death were incorrect and that he was no longer entitled to receive the 

attendant allowance. It determined that recovery of the $67,945.28 overpayment would be made 

by deducting $764.81 from appellant’s continuing compensation payments every 28 days.

LEGAL PRECEDENT -- ISSUE 1

FECA provides that the United States shall pay compensation for the disability or death of 

an employee resulting from personal injury sustained while in the performance of his duty.7 When 

an overpayment has been made to an individual because of an error of fact or law, adjustment shall 

be made under regulations prescribed by the Secretary of Labor by decreasing later payments to 

which the individual is entitled.”

8

If the disability is total, the United States shall pay the employee during the period of total 

disability the basic compensation rate of 66 2/3 percent of his or her monthly pay. A disabled 

employee is entitled to an augmented compensation rate of 75 percent if he or she has one or more 

dependents.9 If a claimant received compensation at the augmented rate during a period when he 

or she did not have an eligible dependent, the difference between the compensation that was 

 

7

5 U.S.C. § 8102(a).

8

Id. at § 8129(a).

9

See O.R., 59 ECAB 432, 436 (2008). See also 5 U.S.C. §§ 8105(a) and 8110(b).
5

disbursed at the 75 percent augmented rate and the compensation that should have been disbursed 

at the 66 2/3 percent basic rate constitutes an overpayment of compensation.10

ANALYSIS -- ISSUE 1

The Board finds that appellant received an overpayment of compensation in the amount of 

$1,500.86 for the periods June 28 through July 27, 2013 and January 12 through March 8, 2014 

because he improperly received wage-loss compensation at an augmented compensation rate.

For the periods June 28 through July 27, 2013 and January 12 through March 8, 2014,

appellant received augmented compensation at the 75 percent pay rate (for a claimant with at least 

one dependent) to which he was not entitled because his wife had passed away on June 27, 2013 

and he no longer had a dependent within the meaning of FECA.11 OWCP provided a calculation 

of the overpayment, noting that appellant had a weekly pay rate of $4,400.00 and that proper 

application of the 66 2/3 pay rate meant that he was entitled to $4,191.43 for the period June 28 

through July 27, 2013 and $7,840.86 for the period January 12 through March 8, 2014, with the 

two figures, totaling $12,032.29. However, appellant actually received $4,714.29 and $8,818.86 

for those respective periods, totaling $13,533.15; therefore the $1,500.86 overpayment was 

derived by subtracting $12,032.29 from $13,533.15. For these reasons, the Board finds that 

appellant received a $1,500.86 overpayment of compensation for the periods June 28 through 

July 27, 2013 and January 12 through March 8, 2014.

LEGAL PRECEDENT– ISSUE 2

Section 8103 of FECA provides that the United States shall furnish to an employee who is 

injured while in the performance of duty, the services, appliances, and supplies prescribed or 

recommended by a qualified physician, which OWCP considers likely to cure, give relief, reduce 

the degree or the period of disability, or aid in lessening the amount of the monthly compensation. 12 

Section 8111 of FECA provides that the Secretary of Labor may pay an employee who has been 

awarded compensation an additional sum of not more than $1,500.00 a month, as the Secretary 

considers necessary, when the Secretary finds that the service of an attendant is necessary 

constantly because the employee is totally blind or has lost the use of both hands or both feet or is 

paralyzed and unable to walk or because of other disability resulting from the injury making him 

or her so helpless as to require constant attendance.13 As noted above, when an overpayment has 

been made to an individual because of an error of fact or law, adjustment shall be made under 

regulations prescribed by the Secretary of Labor by decreasing later payments to which the 

individual is entitled.”

14

 

10 See C.F., Docket No. 18-1344 (issued August22, 2019); Ralph P. Beachum, Sr., 55 ECAB 442, 445 (2004).

11 See supra notes 8 and 9.

12 5 U.S.C. § 8103; see Dona M. Mahurin, 54 ECAB 309 (2003).

13 5 U.S.C. § 8111. See also Federal (FECA) Procedure Manual, Part 2 -- Claims, Developing and Evaluating 

Medical Evidence, Chapter 2.810.21 (September 2010).

14 See supra note 7.
6

ANALYSIS -- ISSUE 2

The Board finds that appellant received an overpayment of compensation in the amount of

$67,945.28 for the period June 28, 2013 through September 16, 2017 because he improperly 

received an attendant allowance.

On January 15, 1998 OWCP authorized appellant to receive an attendant allowance at a 

minimum rate of $1,384.62 every four weeks in order to compensate for his wife’s attending to his 

daily needs.15 For the period June 28, 2013 through September 16, 2017, appellant received an 

attendant allowance every 28 days during this period for which he did not qualify because his wife, 

who had served as his attendant, had died on June 27, 2013. The case record contains documents 

showing that appellant received $67,945.28 in attendant allowance compensation for the period 

June 28, 2013 through September 16, 2017, but was not entitled to receive any portion of this 

amount because the entire payment period fell after his wife’s death. For these reasons, the Board 

finds that appellant received a $67,945.28 overpayment.

LEGAL PRECEDENT -- ISSUE 3

Section 8129(b) of FECA16 provides that [a]djustment or recovery by the United States 

may not be made when incorrect payment has been made to an individual who is without fault and 

when adjustment or recovery would defeat the purpose of this subchapter or would be against 

equity and good conscience. Section 10.433 of OWCP’s implementing regulations17 provides that 

in determining whether a claimant is at fault, it will consider all pertinent circumstances. An 

individual is with fault in the creation of an overpayment who: 

“(1) Made an incorrect statement as to a material fact which he or she knew or 

should have known to be incorrect; or 

“(2) Failed to provide information which he or she knew or should have known to 

be material; or 

“(3) Accepted a payment which he or she knew or should have known to be 

incorrect.”

The Board has held that an employee who receives payments from OWCP in the form of 

direct deposit may not be at fault the first or second time incorrect funds are deposited into his or 

her account, as the acceptance of the resulting overpayment lacks the requisite knowledge.18 The 

Board has also held in cases involving a series of incorrect payments, where the requisite 

knowledge is established by a letter or telephone call from OWCP or simply with the passage of 

time and a greater opportunity for discovery, the claimant will be at fault for accepting the 

 

15 See supra notes 11 and 12.

16 5 U.S.C. § 8129(b).

17 20 C.F.R. § 10.433.

18 See M.J., Docket No. 19-1665 (issued July 29, 2020); Tammy Craven, 57 ECAB 689 (2006).
7

payments subsequently deposited.19 Previous cases have held that receiving one or two erroneous 

direct deposit payments does not necessarily create the requisite knowledge to find that a claimant 

was at fault in the creation of the overpayment.20

ANALYSIS -- ISSUE 3

The Board finds that OWCP improperly found appellant at fault in the creation of the 

$1,500.86 overpayment for the period June 28 through July 27, 2013, but properly found him at 

fault for the period January 12 through March 8, 2014.

OWCP determined that appellant was at fault in the creation of the overpayment because 

he accepted payments that he knew or should have known to have been incorrect. The Board finds, 

however, that OWCP failed to establish that, at the time appellant accepted the initial two payments

of compensation following June 27, 2013, the date of his wife’s death, he knew or should have 

known the payments to have been incorrect.

As noted above, OWCP properly found that appellant received an overpayment of 

compensation in the amount of $1,500.86 for the periods June 28 through July 27, 2013 and 

January 12 through March 8, 2014 because he improperly received wage-loss compensation at an 

augmented compensation pay rate after his wife’s death. The period June 28 through July 27, 2013 

was covered by two electronic bank deposits. The first deposit was made on June 29, 2013 and 

covered the period June 2 through 29, 2013, thereby coinciding with the overpayment period for 

the last two days covered by the deposit (June 28 and 29, 2013). The second deposit was made on 

July 27, 2013 and covered the period June 30 through July 27, 2013, thereby coinciding with the 

overpayment period for all the days covered by the deposit.

As discussed, in cases where a claimant receives compensation through direct deposit, 

OWCP must establish that at the time a claimant received the direct deposit in question that he or 

she knew or should have known that the payment was incorrect.21 The Board has held that an 

employee who receives payments from OWCP in the form of a direct deposit may not be at fault 

for the first incorrect deposit into his or her account since the acceptance of the overpayment, at 

the time of receipt of the direct deposit, lacks the requisite knowledge.22 Because fault is defined 

by what the claimant knew or should have known at the time of acceptance, one of the 

consequences of electronic fund transfers is that the claimant lacks the requisite knowledge at the 

time of the first incorrect payment.23 Whether or not OWCP determines that an individual is at 

fault with respect to the creation of an overpayment depends on the circumstances surrounding the 

overpayment.24 It is not appropriate, however, to make a finding that a claimant has accepted an 

overpayment through direct deposit until such time as a reasonable person would have been aware 

 

19 See J.W., Docket No. 10-1271 (issued February 3, 2011); see also Karen Dixon, 56 ECAB 145 (2004).

20 V.S., Docket No. 13-1278 (issued October 23, 2013).

21 See C.K., Docket No. 12-0746 (issued May 1, 2012).

22 See M.J., supra note 18; see also George A. Hirsch, 47 ECAB 520 (1996).

23 Id.

24 Id.;see also K.D., Docket No. 13-0451 (issued April12, 2013).
8

that this overpayment had occurred. This awareness could be established either through 

documentation such as a bank statement or notification from OWCP or where a reasonable period 

of time has passed during which a claimant could have reviewed independent confirmation of the 

incorrect payment.25

Appellant received compensation by direct deposit payments every 28 days. With respect 

to the $1,500.86 overpayment, the evidence of record does not establish that, as of the first and 

second direct deposits of compensation after June 27, 2013, he knew or reasonably should have 

known that he was accepting direct deposits to which he was not entitled. There is no

documentation or other evidence to demonstrate that appellant had clear knowledge at the time he 

received direct deposits from OWCP on June 29 and July 27, 2013, covering the period of the 

overpayment from June 28 through July 27, 2013, that the payments were incorrect, or that a 

reasonable period of time passed during which he could have reviewed bank statements or been 

informed of the incorrect payment. Therefore, he is not at fault in the acceptance of the two direct 

deposit covering the period of the overpayment from June 28 through July 27, 2013.

In cases involving a series of incorrect payments, where the requisite knowledge is 

established by documentation from OWCP or simply with the passage of time and opportunity for 

discovery, the claimant will be at fault for accepting the payments subsequently deposited.26 By 

the time of the February 8, 2014 payment covering the period January 12 to February 8, 2014, 

appellant knew or should have known that he was not entitled to receive wage-loss compensation 

at the augmented pay rate.

27

 

Accordingly, the Board will affirm the finding of fault for the remaining period of 

$1,500.86 overpayment, i.e., January 12 through March 8, 2014. 

The Board further finds that OWCP improperly found appellant at fault in the creation of 

the $67,945.28 overpayment for the period June 28 through July 27, 2013, but properly found him 

at fault for the period July 28, 2013 through September 16, 2017.

As noted above, appellant received an overpayment of compensation in the amount of 

$67,945.28 for the period June 28, 2013 through September 16, 2017 because he improperly 

received an attendant allowance ($1,384.62 every 28 days) after his wife died on June 27, 2013. 

The first electronic bank deposit which included a prohibited portion of the $1,384.62 attendant 

allowance was made on June 29, 2013 and covered the period June 2 through 29, 2013, thereby 

coinciding with the overpayment period for the last two days covered by the deposit (June 28 and 

29, 2013). The second electronic bank deposit which included a prohibited $1,384.62 attendant 

allowance was made on July 27, 2013 and covered the period June 30 through July 27, 2013, 

thereby coinciding with the overpayment period for all the days covered by the deposit.

With respect to the $67,945.28 overpayment, the evidence of record does not establish that, 

as of the first and second direct deposits of compensation after June 27, 2013, appellant knew or 

reasonably should have known that he was accepting direct deposits, including compensation for 

 

25 See K.H., Docket No. 06-0191 (issued October 30, 2006).

26 See supra note 18.

27 See supra note 24.
9

an attendant allowance, to which he was not entitled. There is no documentation or other evidence 

to demonstrate that he had clear knowledge at the time he received direct deposits from OWCP on 

June 29 and July 27, 2013, covering the period of the overpayment from June 28 through July 27, 

2013, that the payments were incorrect, or that a reasonable period of time passed during which 

he could have reviewed bank statements or been informed of the incorrect payment. Therefore, 

appellant is not at fault in the acceptance of the two direct deposits covering the period of the 

overpayment from June 28 through July 27, 2013.28

As noted above, in cases involving a series of incorrect payments, where the requisite 

knowledge is established by documentation from OWCP or simply with the passage of time and 

opportunity for discovery, the claimant will be at fault for accepting the payments subsequently 

deposited.29 By the time of the third payment dated August 24, 2013, given the passage of time, 

appellant knew or should have known that he was not entitled to receive an attendant allowance 

after the June 27, 2103 death of his wife.30 

Accordingly, the Board will affirm the finding of fault for the remaining period of 

$67,945.28 overpayment, i.e., July 28, 2013 through September 16, 2017. 

With respect to both the $1,500.86 and $67,945.28 overpayments, this case is not in posture 

for decision regarding the issue of waiver of recovery of the overpayments created by the June 29 

and July 27, 2013 direct deposits covering the period of each overpayment from June 28 through 

July 27, 2013. The case must therefore be remanded for OWCP in order to determine whether 

appellant is entitled to waiver of recovery for these direct deposits of compensation covering the 

period of each overpayment from June 28 through July 27, 2013.

31

 As appellant’s eligibility for 

waiver for a portion of the overpayments cannot yet be determined, on remand OWCP shall grant 

appellant an opportunity to submit an updated Form OWCP-20 and consider the relevant financial 

evidence on this issue. Following this and all other development deemed necessary, OWCP shall 

issue a de novo decision.

CONCLUSION

The Board finds that appellant received an overpayment of compensation in the amount of 

$1,500.86 for the periods June 28 through July 27, 2013 and January 12 through March 8, 2014 

because he improperly received wage-loss compensation at an augmented compensation rate, and 

an overpayment in the amount of $67,945.28 for the period June 28, 2013 to September 16, 2017 

because he improperly received an attendant allowance. The Board finds that OWCP improperly 

found appellant at fault in the creation of the $1,500.86 overpayment for the period June 28 through 

July 27, 2013, but properly found him at fault for the period January 12 through March 8, 2014. 

The Board finds that OWCP improperly found appellant at fault in the creation of the $67,945.28 

 

28 Id.

29 See J.W., Docket No. 10-1271 (issued February 3, 2011); see also Karen Dixon, 56 ECAB 145 (2004).

30 Id.

31 In light ofthe Board’s disposition of Issue 3,it is premature to addressIssue 4.
10

overpayment for the period June 28 through July 27, 2013, but properly found him at fault for the 

period July 28, 2013 through September 16, 2017. 

ORDER

IT IS HEREBY ORDERED THATthe May 16, 2019 decisions of the Office of Workers’

Compensation Programs are affirmed in part, and set aside in part. The case is remanded to OWCP 

for further proceedings consistent with this decision of the Board.

Issued: September 3, 2021

Washington, DC

Alec J. Koromilas, Chief Judge

Employees’ Compensation Appeals Board

Janice B. Askin, Judge

Employees’ Compensation Appeals Board

Patricia H. Fitzgerald, Alternate Judge

Employees’ Compensation Appeals Board