The Claims Examiner will give particular attention to those cases where the injury is due to a fall that may have been caused by a personal and non-occupational pathology, such as, a myocardial infarction, fainting spell, or epileptic seizure. Injuries caused by such conditions are excluded from coverage under the FECA unless there is intervention or contribution by some hazard or special condition of the employment, including normal furnishings of an office or other workplace.
In such cases, it is the CE’s responsibility to obtain appropriate evidence from the injured employee, the immediate superior, the witnesses, and the attending physician, showing whether the fall was due to an idiopathic condition or an unknown cause. If the incident was due to an idiopathic condition, the record must also clearly show whether the fall was to the immediate supporting surface (floor) or whether some special condition, hazard, or instrumentality of the work contributed to or intervened as a cause of the injury. If some factor of the employment intervened or contributed to the injury resulting from the fall, the employee has coverage under the FECA for the results of the injury but not for the idiopathic condition which caused the fall.
A distinction must be made between idiopathic falls and those falls which are merely unexplained. If a fall is not shown to be caused by an idiopathic condition, it is simply unexplained and is, therefore, compensable if it occurred in the performance of duty. An idiopathic fall is one where a personal, non-occupational pathology causes an employee to collapse. An unexplained fall is one where the cause is unknown even to the employee.
The Employee Compensation Appeal Board made the distinction between idiopathic and unexplained falls in the following two cases:
- Martha G. List, 26 ECAB 200. Employee Joseph G List’s fall at work on December 21, 1972 resulted in his death. There was no evidence that any obstacle or other irregular condition of the workplace caused the fall. The employee had a history of hypertension and episodes of falling but he had not fallen from the end of 1967 until December 21, 1972. An Office medical advisor filed a brief opinion stating that it was “reasonable to assume that the hypertension probably was out of control and that a ‘small stroke’ occurred on 21 Dec. 72 and was the reason for the fall.”
The Board reversed the Office’s decision that the employee’s injury was caused by an idiopathic fall and neither arose out of nor was causally related to the employment. In support of the finding that the employee’s fall was unexplained and his resulting death was compensable, the Board stated: The question of causal relationship in a case of a fall like that in the present case is a medical one. The only medical evidence in the case record indicating that the employee’s fall was idiopathic is the statement of the Office Medical Advisor. His opinion is speculative and lacking in rationale; it is therefore insufficient to establish that the employee’s fall was idiopathic and to prove that it was due to a preexisting physical condition.
- Gertrude E. Evans, 26 ECAB 195. Employee Wesley W. Evans’ fall at work on May 7, 1973 resulted in his death. There was no indication that anything in the workplace caused him to fall. The employee had a three to five-year history of dizziness and fainting spells as well as a series of falls and hospitalizations in the period immediately preceding the May 1973 episode. He had been hospitalized a month before the May 1973 episode, complaining of dizziness and passing out. Although the attending physician could not diagnose the employee’s condition, his reports and those of other physicians made it clear that they regarded the May 1973 episode and the previous ones as having a common cause of an abnormal physical condition.
The Board affirmed the Office’s finding that the employee’s fall was idiopathic in nature but remanded the case for a determination as to whether or not the employee struck an intervening object when he fell on May 7, 1973.
Whether a fall at work is idiopathic or unexplained will usually be determined on the basis of the medical evidence. If the medical evidence shows that the employee’s fall was caused by a non-occupational, preexisting physical condition, it is idiopathic and not compensable. Absent such evidence, the fall is unexplained and compensable.
Information per FECA Procedure Manual