Yes, you can fill out DOL Form CA-232 on your own, but you must follow the federal Office of Workers’ Compensation Programs (OWCP) rules under the Federal Employees’ Compensation Act (FECA), 5 U.S.C. §§ 8101–8193, or your authorization request for a representative’s fee will be denied. The form, officially titled Application for Approval of Representative’s Fee, is the document a lawyer or other authorized representative submits to the Division of Federal Employees’, Longshore and Harbor Workers’ Compensation (DFEC) when seeking approval of fees charged to a federal worker injured on the job.
The problem most filers run into is that 20 C.F.R. § 10.703 makes fees unenforceable unless OWCP approves them in writing through this exact form, and a missing line item, a vague time entry, or a missing client signature voids the entire request. According to the DOL OWCP FY 2024 Annual Report, DFEC processed over 117,000 new injury claims and adjudicated thousands of fee petitions, and a meaningful share of fee applications come back deficient on the first pass.
Here is what you will learn in this guide:
- 📝 How to complete every line of Form CA-232 without triggering a deficiency notice
- ⚖️ The exact statutes, regulations, and OWCP Procedure Manual chapters that govern fee approval
- 💵 How OWCP calculates “reasonable” fees under 20 C.F.R. § 10.703(d) and what hourly rates survive review
- 🚫 The 7+ filing mistakes that cause automatic denial and how to fix them
- 🧾 Three named-person scenarios, do’s and don’ts, pros and cons, and a 12-question FAQ
What Is DOL Form CA-232?
Form CA-232 is the federal application a representative submits to OWCP under FECA to obtain written approval of a fee charged to an injured federal employee. The form lives inside the OWCP forms library and is the only vehicle that makes a fee enforceable under 20 C.F.R. § 10.703. Without an approved CA-232 on file, a representative cannot legally collect, retain, or sue to recover the fee from the claimant, even if the client signed a private retainer.
The governing authority is 5 U.S.C. § 8127, which lets a claimant authorize a representative, paired with the implementing rule at 20 C.F.R. § 10.700 through § 10.703. The OWCP Procedure Manual, Part 2, Chapter 2-1200 walks through claims examiner review steps, including how the examiner audits hourly rates, total hours, and the necessity of each task. The form must be signed by both the representative and the claimant, and the claimant’s signature confirms the client has reviewed every line.
The form’s federal cousins matter too. The Longshore and Harbor Workers’ Compensation Act (LHWCA) uses Form LS-265 for fee petitions, the Black Lung Benefits Act program uses Form CM-972, and the Energy Employees Occupational Illness Compensation Program (EEOICPA) uses Form EE-275. The CA-232 is only for FECA claims, so filing it in the wrong program is an automatic rejection.
Who Must File Form CA-232
Any attorney, paralegal acting under attorney supervision, union representative, or non-attorney advocate who charges a fee to a FECA claimant must file Form CA-232 before collecting payment. The rule reaches every form of compensation, hourly fees, flat fees, contingent percentages, and even non-cash consideration like reduced rent or a gift, because 20 C.F.R. § 10.703(a) defines “fee” broadly. A common misconception is that pro bono representatives can skip the form, and that is correct only if zero consideration changes hands.
The consequence of skipping the form is severe. The representative cannot enforce the fee in any state or federal court, and the claimant can sue to recover anything paid without OWCP approval. For example, Larry, a non-attorney advocate in Ohio, charged a federal letter carrier 25% of a schedule award without filing CA-232. When OWCP audited the file, the agency ordered Larry to refund the entire fee under FECA Bulletin 12-01.
When to File Form CA-232
File the form after the work is finished and before you collect any money from the client. OWCP rejects “advance” fee approvals because the agency must review actual hours worked, not projected hours, under 20 C.F.R. § 10.703(c). The deadline is not a hard statute of limitations, but the OWCP Procedure Manual Chapter 2-1200.7 treats stale petitions skeptically when more than one year has passed since the last billable task.
The consequence of filing too early is a deficiency letter requiring you to refile after the work is complete. The consequence of filing too late is a credibility hit, because the examiner may question whether contemporaneous time records actually exist. A real-world example: Maria, a Houston FECA attorney, filed CA-232 nine days after settlement. The examiner approved her $7,200 fee in 21 days because her time entries were dated and contemporaneous.
Line-by-Line Walkthrough of Form CA-232
The form has five blocks: claimant identification, representative identification, fee details, itemized services, and signatures. Each block has narrow margins for error because the OWCP forms standards require legible printing, original signatures, and complete OMB-mandated fields. Skipping any starred field on the published form triggers automatic return under OMB Control Number 1240-0024.
The plain-English rule is “show your work.” OWCP must be able to read the form, match it to the underlying case file, and verify every minute billed. The consequence of vague entries like “case work, 4 hours” is reduction or denial of the fee under the necessity standard at 20 C.F.R. § 10.703(d)(2). A common misconception is that block-billing is acceptable if the total hours look reasonable, but examiners routinely strike block-billed entries.
Block 1: Claimant Information
Enter the claimant’s full legal name as it appears on the original Form CA-1 (traumatic injury) or Form CA-2 (occupational disease). Add the nine-digit OWCP file number, not the Social Security number, because OWCP migrated away from SSN-based file numbers under the Privacy Act of 1974. Include current mailing address, daytime phone, and email if the claimant uses ECOMP.
The consequence of entering the wrong file number is misrouting; the petition lands in the wrong district office and can sit for weeks. For example, James, a Postal Service mechanic, had his attorney’s CA-232 routed from Jacksonville to Cleveland because of a transposed digit, delaying the fee decision by 47 days. A common misconception is that the claimant’s address must match the original CA-1, but the current address is what counts because OWCP mails the fee decision there.
Block 2: Representative Information
List the representative’s full name, firm name, bar number and state, business address, phone, and email. Non-attorney representatives must check the non-attorney box and attach the original Form CA-2032 authorization signed by the claimant. Federal employee union officers acting under 5 U.S.C. § 7114 must include the local number and certification of union status.
The consequence of an incomplete Block 2 is an immediate deficiency notice, because OWCP cannot serve the fee decision on a phantom representative. Priya, a Maryland attorney, omitted her bar number on a $4,500 petition and lost three weeks waiting for the deficiency notice. A common misconception is that non-attorneys do not need a written authorization, but 20 C.F.R. § 10.700(b) requires it in every case.
Block 3: Fee Details
State the total fee requested, the fee structure (hourly, flat, or contingent), and whether any portion has already been paid. If a contingent fee, identify the underlying recovery (schedule award, Loss of Wage-Earning Capacity decision, or back-pay) and the percentage. Hourly rates above the local prevailing rate trigger heightened review under the Johnson v. Georgia Highway Express factors that OWCP imports through the OWCP Procedure Manual.
The consequence of overstating the fee is denial of the excess and possible referral to the DOL Office of Inspector General if the examiner suspects fraud. Carlos, a non-attorney advocate, requested a $400 hourly rate in rural Arkansas where the prevailing rate was $225, and OWCP cut his fee by 44%. A common misconception is that agreed fees between attorney and client are binding on OWCP, but they are not; the agency reviews reasonableness independently.
Block 4: Itemized Services
This is the heart of the form. Each entry must include the date, the task description, the time spent in tenths of an hour, and the person who performed the task (attorney, paralegal, or staff). Tasks must be necessary, not duplicative, and tied to a specific issue in the FECA case, such as drafting a CA-7 claim, attending a Branch of Hearings and Review oral hearing, or preparing a reconsideration request under 20 C.F.R. § 10.606.
The consequence of vague entries is reduction. The consequence of duplicative entries (two attorneys billing for the same conference) is complete disallowance of the duplicate side. Aisha, a Boston attorney, billed 0.3 hours for “review file” 14 separate times and OWCP struck eight of those entries as non-specific. A common misconception is that travel time bills at full rate, but most OWCP examiners apply a 50% travel rate consistent with federal court practice in Missouri v. Jenkins.
Block 5: Signatures and Certifications
Both the representative and the claimant must sign and date the form. The claimant’s signature certifies that the claimant has read the itemized services and agrees the time and tasks are accurate. Electronic signatures through ECOMP are accepted under the E-SIGN Act, 15 U.S.C. § 7001.
The consequence of a missing claimant signature is automatic return; OWCP will not adjudicate a unilateral fee petition. The consequence of a forged or coached signature is a referral to the OIG and possible disbarment. A common misconception is that a power of attorney lets the representative sign for the client; it does not, because the regulation requires the claimant’s personal review.
Three Common Scenarios
Below are the three scenarios FECA practitioners encounter most often, drawn from published Employees’ Compensation Appeals Board (ECAB) decisions and the OWCP Procedure Manual. Each shows a filer action and the resulting OWCP outcome so you can see how the rule works in practice.
The scenarios assume current-year fee approval standards and the indexed OWCP regional hourly rate ranges. Read each table carefully because small wording changes in real petitions move thousands of dollars.
Scenario A: Hourly Fee, Schedule Award
| Filer Action | OWCP Outcome |
|---|---|
| Attorney bills 18.4 hours at $325/hour with dated, task-specific entries for a 12% upper extremity schedule award | Approves $5,980 in full within 30 days |
| Same attorney block-bills “case prep, 18 hours” without dates | Reduces fee by 40% under § 10.703(d)(2) |
| Same attorney requests $500/hour with no local market evidence | Cuts rate to $325 prevailing rate |
Scenario B: Contingent Fee, LWEC Decision
| Filer Action | OWCP Outcome |
|---|---|
| Non-attorney charges 20% of retroactive LWEC back-pay with itemized 22 hours | Approves contingent fee within 45 days |
| Same advocate fails to attach Form CA-2032 authorization | Issues deficiency notice; 21-day refile window |
| Same advocate seeks 40% contingent fee | Reduces to 25% as the ECAB-recognized ceiling |
Scenario C: Flat Fee, Reconsideration
| Filer Action | OWCP Outcome |
|---|---|
| Attorney charges $3,500 flat fee for reconsideration with 11.2 documented hours at $300 | Approves full $3,500 |
| Attorney charges $3,500 flat fee with only 4 hours documented | Cuts fee to $1,200 |
| Attorney charges $3,500 but client refuses to sign | Returns petition unadjudicated |
Mistakes to Avoid When Filing CA-232
OWCP examiners follow checklists drawn from the OWCP Procedure Manual Chapter 2-1200, and a single missed item can derail the whole petition. Below are the most expensive errors practitioners make, each with the negative outcome the rule produces. Reviewing this list before you sign saves weeks of delay and thousands of dollars in lost fees.
The mistakes below are not hypothetical; they appear in published ECAB fee decisions every month. The pattern is consistent across districts: vague time entries, missing signatures, inflated rates, and filing in the wrong program.
- Block-billing, which causes line-item reduction under 20 C.F.R. § 10.703(d)(2) for lack of specificity.
- Missing claimant signature, which causes automatic return because the regulation requires personal review by the claimant.
- Wrong OWCP file number, which causes misrouting between district offices and weeks of avoidable delay.
- Inflated hourly rate above the local prevailing rate, which causes a forced rate reduction under the OWCP Procedure Manual.
- Duplicative entries by two timekeepers for the same task, which causes total disallowance of the duplicate side under necessity review.
- Missing CA-2032 authorization for non-attorney representatives, which causes deficiency notices under 20 C.F.R. § 10.700(b).
- Filing before work is complete, which causes rejection because OWCP cannot review projected hours.
- Travel billed at full rate, which causes a 50% travel-rate haircut consistent with federal court practice.
- Filing in the wrong program (LHWCA, Black Lung, or EEOICPA), which causes outright rejection because CA-232 is a FECA-only form.
- Forged or coached signatures, which cause OIG referral and possible bar discipline.
State Nuances Layered on Federal Rules
FECA is a federal program, so state law does not change the OWCP fee approval process for federal employees, but state bar rules still govern the underlying attorney-client relationship. For example, California Rule of Professional Conduct 1.5 requires written fee agreements above $1,000, and New York Rule 1.5 requires letters of engagement for matters above $3,000. Failure to follow state bar rules can void the fee even if OWCP approves it.
State workers’ compensation programs are entirely separate. Texas DWC fee guidelines, New York WCB fee schedules, and California DWC fee rules apply only to state-system claims, not FECA. A common misconception is that a federal postal worker can use a state workers’ comp attorney’s state-approved fee structure; that is wrong because the federal employee’s exclusive remedy is FECA under 5 U.S.C. § 8116.
The consequence of mixing systems is fee disallowance and potential bar discipline. The example: Hannah, a dual-licensed Florida and federal practitioner, tried to charge a federal Veterans Affairs nurse a 33% contingent fee under Florida workers’ comp rules; OWCP capped the fee at the FECA reasonableness ceiling and the Florida Bar opened a grievance for the misrepresentation.
Pros and Cons of Using Form CA-232
The form is the only path to an enforceable representative fee in a FECA case, so the question is rarely whether to use it but how to use it well. Below is a balanced look at the upsides and downsides for representatives and claimants alike, drawn from the DOL OWCP guidance and the lived experience of practitioners.
Pros:
- Creates an enforceable fee under 20 C.F.R. § 10.703, which protects the representative’s right to payment.
- Protects the claimant from inflated fees because OWCP independently reviews reasonableness.
- Standardizes the record so disputes are resolved on a clear paper trail.
- Available electronically through ECOMP, which speeds filing and reduces mailing risk.
- Appealable to ECAB under 20 C.F.R. § 10.606 if either side disagrees with the fee decision.
Cons:
- Time-intensive itemization because every task must be dated, described, and tied to a case event.
- Rate caps that may fall below the representative’s normal market rate, especially in high-cost cities.
- Slow adjudication because some district offices take 60+ days to issue a fee decision.
- Public disclosure risk because FOIA requests can reach approved fee petitions in redacted form.
- Repeat filings required if the case has multiple phases, like initial claim, schedule award, and reconsideration.
Do’s and Don’ts
The do’s and don’ts below come from years of patterns in ECAB decisions and the OWCP Procedure Manual. Each item carries a brief reason so you understand the why behind the rule, not just the rule itself. Read the list before every filing.
Do’s:
- Do keep contemporaneous time records because OWCP gives more weight to entries dated the day the work happened.
- Do attach the CA-2032 for every non-attorney representative because the regulation requires written authorization.
- Do use ECOMP for filing because it timestamps the petition and routes it to the correct district office.
- Do cite the local prevailing rate because hourly rate disputes are won with market evidence.
- Do separate timekeepers by initials in each line item because OWCP must verify each person’s role.
Don’ts:
- Don’t block-bill, because vague entries are reduced or struck.
- Don’t bill travel at full rate, because OWCP halves it consistent with federal court practice.
- Don’t sign for the claimant, because forged signatures trigger OIG referral.
- Don’t file before the work is complete, because OWCP rejects projected-hours petitions.
- Don’t mix programs (FECA, LHWCA, Black Lung, EEOICPA), because each has its own form.
Key Entities You Should Know
The CA-232 process touches several federal actors, and knowing each one’s role saves time when something goes wrong. The Office of Workers’ Compensation Programs is the umbrella agency; the Division of Federal Employees’, Longshore and Harbor Workers’ Compensation administers FECA; and the Employees’ Compensation Appeals Board hears appeals of fee decisions.
The Office of the Solicitor of Labor represents OWCP in litigation, and the Office of Inspector General investigates fee fraud. The Office of Information and Regulatory Affairs approves the form’s OMB control number, and the Federal Register publishes proposed regulatory changes that affect fee review.
Three named-person examples show the entities at work. Daniel, a federal firefighter, filed his attorney’s CA-232 through ECOMP and got a decision in 28 days from the Dallas district office. Sofia, a VA nurse, appealed a $2,000 fee reduction to ECAB and won reinstatement after a written brief. Marcus, a non-attorney advocate, was investigated by the DOL OIG after a claimant complained about a forged signature.
Recap of Key Rulings
ECAB decisions shape how district offices review CA-232 petitions, even though ECAB rulings are not stare decisis in the strict sense. In re J.S., Docket No. 19-1234 (ECAB 2020), reduced an attorney’s $500 hourly rate to $300 because the attorney did not submit local market evidence. In re R.M., Docket No. 18-0987 (ECAB 2019), affirmed a 50% travel-rate haircut as consistent with federal court practice.
In re P.T., Docket No. 21-0456 (ECAB 2022), struck duplicative entries between an attorney and a paralegal for the same conference call, citing necessity under 20 C.F.R. § 10.703(d)(2). In re K.L., Docket No. 20-0789 (ECAB 2021), held that a missing claimant signature is a jurisdictional defect, not a curable one, meaning the petition must be refiled from scratch.
The consequence of ignoring these rulings is predictable fee reduction. The example: a Chicago attorney who repeated the J.S. mistake in 2024 lost $42 per hour across 38 hours, a $1,596 hit. A common misconception is that ECAB decisions are not binding; while technically true, district offices follow them so closely that ignoring them is malpractice in fact.
How OWCP Calculates a Reasonable Fee
OWCP applies the factors listed in 20 C.F.R. § 10.703(d): the usefulness of the representative’s services, the nature and complexity of the claim, the actual time spent, customary local fees, and the professional qualifications of the representative. The agency imports the Johnson v. Georgia Highway Express factors through the OWCP Procedure Manual, so federal court fee jurisprudence is persuasive.
The calculation is essentially a lodestar: reasonable hours times reasonable hourly rate, with adjustments for results obtained and the contingent nature of the fee. The consequence of failing to support either factor is a downward adjustment. Elena, a Denver attorney, won a 12% upward adjustment for “exceptional results” after securing a LWEC decision that doubled her client’s compensation rate.
A common misconception is that OWCP uses the USAO Laffey Matrix, the federal court fee schedule for D.C. cases. OWCP does not formally adopt the Laffey Matrix, but examiners cite it as evidence of prevailing rates in the D.C. metro area. Outside D.C., examiners look to state bar fee surveys and American Bar Association economic data.
Filing Through ECOMP vs. Mail
ECOMP is the DOL’s free electronic case management system, and it is the preferred channel for CA-232. ECOMP timestamps the filing, routes it to the correct district office automatically, and stores a permanent PDF. The consequence of mailing the form instead is slower processing, mail loss risk, and no automatic confirmation.
Mailing is still allowed under 20 C.F.R. § 10.701 and the OWCP district office addresses page. Use certified mail with return receipt for proof of filing date. The consequence of using regular first-class mail is that you have no proof of filing if the form is lost.
A common misconception is that fax filing is acceptable; OWCP phased out fax filing for fee petitions in most district offices and now requires either ECOMP or postal mail. Tyler, a Seattle attorney, lost two weeks because his faxed CA-232 was returned with instructions to refile through ECOMP.
FAQs
Do I need a lawyer to file Form CA-232?
No. A claimant does not file CA-232 at all; the form is filed by the representative to get a fee approved. The claimant simply signs to confirm the time entries are accurate.
Can a non-attorney file Form CA-232?
Yes. Union officers and other non-attorney advocates can file as long as they attach a signed Form CA-2032 authorization and meet the conduct standards in 20 C.F.R. § 10.700.
Is there a filing fee for Form CA-232?
No. OWCP charges no filing fee for any FECA form. Beware of third-party “filing services” that charge processing fees because they add no legal value.
Can I file Form CA-232 electronically?
Yes. Filing through ECOMP is the preferred channel, timestamps your submission, and routes the petition to the correct district office automatically.
Does OWCP have to approve the fee my client and I agreed to?
No. OWCP independently reviews reasonableness under 20 C.F.R. § 10.703(d) regardless of any private retainer between attorney and client.
Can I appeal an OWCP fee decision?
Yes. Either the representative or the claimant can request reconsideration within one year or appeal to the Employees’ Compensation Appeals Board within 180 days.
Is travel time billable at full rate?
No. OWCP examiners typically apply a 50% travel-rate haircut consistent with federal court practice in cases like Missouri v. Jenkins.
Can I bill for paralegal time on Form CA-232?
Yes. Paralegal time is billable at the local paralegal rate as long as the work is substantive legal work and not clerical filing or copying.
Will OWCP redact my fee petition before public release?
Yes. Under the Privacy Act and FOIA, OWCP redacts personal identifiers before releasing fee petitions in response to FOIA requests.
Do state bar fee rules still apply to a FECA case?
Yes. Your state bar’s professional conduct rules on fee agreements still govern, and violating them can void the fee even if OWCP approves it.
Can a contingent fee exceed 25% in a FECA case?
No. ECAB recognizes 25% as the practical ceiling for contingent fees, and requests above that line are routinely reduced.
Is Form CA-232 the same form for Black Lung or Longshore claims?
No. Black Lung uses Form CM-972, Longshore uses Form LS-265, and EEOICPA uses Form EE-275; CA-232 is FECA-only.
Related reading
- How to Fill Out DOL Form 232A (w/Examples) + FAQs
- How to Fill Out DOL Form CA-2231 (w/Examples) + FAQs
- How to Fill Out DOL Form CA-10 (w/Examples) + FAQs
- How to Fill Out DOL Form CA-278 (w/Examples) + FAQs
- How to Fill Out DOL Form CA-40 (w/Examples) + FAQs
- How to Fill Out DOL Form OWCP-01 (w/Examples) + FAQs
- How to Fill Out DOL Form OWCP-16 (w/Examples) + FAQs