How to Fill Out DOL Form OWCP-04 (w/Examples) + FAQs

Form OWCP-04 is the uniform institutional billing form that hospitals, skilled nursing facilities, hospices, and other facility-based providers must use to bill the U.S. Department of Labor for medical care provided to injured federal workers, longshore workers, coal miners, and energy workers. You fill it out by entering the patient’s claim number in Field Locator 60, the OWCP-assigned provider ID in FL 51, ICD-10 diagnosis codes in FL 67, revenue and HCPCS codes in FLs 42–44, and authorized charges in FL 47, then submit it through the WCMBP web portal or by mail to the London, Kentucky central mailroom. Get even one of the 81 form locators wrong, and the Office of Workers’ Compensation Programs will reject the bill, the one-year filing clock keeps ticking, and the provider eats the loss because the injured worker cannot legally be balance-billed under 20 CFR §10.813.

The form looks identical to the CMS-1450 (UB-04) used in Medicare, but the rules behind each box are different. OWCP runs four separate programs through this single piece of paper, and each program has its own fee schedule, its own authorization rules, and its own appeal pathway. A 2024 OWCP performance report showed that more than 18% of first-pass institutional bills were rejected for clerical errors in patient identifiers, authorization numbers, or diagnosis codes, which is roughly double the commercial insurance rejection rate of about 9%.

Here is what you will walk away knowing after this guide:

  • 🧾 How to complete every one of the 81 fields on OWCP-04, line by line, with examples
  • ⚖️ Which federal regulation controls each program (FECA, Longshore, Black Lung, EEOICPA) and why it matters for your bill
  • 💻 How to choose between paper submission and the WCMBP electronic portal
  • 🚫 The 7 most common mistakes that get bills denied and how to avoid each
  • 🔁 How to request reconsideration, appeal a denied bill, and reopen a case after the deadline

What Is DOL Form OWCP-04?

OWCP-04 is the standardized institutional claim form the Department of Labor accepts from hospitals and other facility providers under all four of its workers’ compensation programs. It mirrors the UB-04 institutional claim form maintained by the National Uniform Billing Committee, and the National Uniform Billing Committee’s data layout is incorporated by reference into the OWCP billing manual.

Providers use OWCP-04 instead of the OWCP-1500 (the professional form) when the bill comes from a facility cost center rather than from an individual physician. That distinction matters because facility bills are paid under the OWCP institutional fee schedule, which mirrors Medicare’s IPPS and OPPS rates with an OWCP-specific conversion factor, while professional bills are paid under the OWCP physician fee schedule.

The form is authorized under the Federal Employees’ Compensation Act at 5 U.S.C. §8103, the Longshore and Harbor Workers’ Compensation Act at 33 U.S.C. §907, the Black Lung Benefits Act at 30 U.S.C. §923, and the Energy Employees Occupational Illness Compensation Program Act at 42 U.S.C. §7384t. Each statute makes the federal government the exclusive payer for the work-related condition, which means the provider cannot bill any other insurance for the same service.

The current contractor that processes these bills is CNSI, operating the WCMBP system under contract with the Department of Labor. CNSI took over from Conduent in 2020, and the WCMBP portal is the central electronic intake point for OWCP-04 submissions.

Who Uses OWCP-04 Instead of OWCP-1500

Facility providers use OWCP-04. That includes acute-care hospitals, critical access hospitals, inpatient rehabilitation facilities, long-term care hospitals, skilled nursing facilities, hospices, home health agencies, ambulatory surgical centers when billed as facilities, and outpatient hospital departments.

Solo physicians, group practices, physical therapists in private offices, and durable medical equipment suppliers do not use OWCP-04. They use the OWCP-1500 professional form, which is the federal version of the CMS-1500.

The consequence of using the wrong form is automatic rejection. If a hospital submits a CMS-1450 instead of OWCP-04, the WCMBP edits will reject the bill at intake because the form locator for the OWCP claim number is not populated correctly. A common misconception is that the two forms are interchangeable; they are not, because OWCP-04 has program-specific edits that the generic UB-04 lacks.

The Four OWCP Programs That Accept Form OWCP-04

Each program covers a different population, and each one has its own claim-number prefix that must appear in FL 60.

If you put a FECA claim number into a bill routed to the Black Lung program, the bill will be denied for “claim number not on file,” and you will have to refile within the original one-year window.

Before You Touch the Form: Authorization, Eligibility, and Enrollment

You cannot bill OWCP if you are not enrolled, and you cannot get paid for most services if you do not have prior authorization. These two upstream steps fail more bills than any field on the form itself.

Provider Enrollment in WCMBP

Every facility that wants to bill OWCP must first enroll in the WCMBP provider portal. Enrollment requires the facility’s NPI, taxonomy code, EIN, a W-9, state license, and Medicare certification documents. Approval typically takes 30 to 45 days.

Once approved, OWCP issues a 9-digit OWCP Provider ID. That ID goes into FL 51 of every OWCP-04 you file. If you bill without that ID and only put your NPI in FL 56, the bill will pend and eventually deny because OWCP’s payment system is keyed to the OWCP Provider ID, not the NPI.

A real example: Mercy General Hospital applied for enrollment in March, submitted the wrong taxonomy code, and waited until late June for approval. During that 90-day gap they treated three FECA patients and could not bill until enrollment cleared, which pushed two of those bills past the one-year deadline.

Authorization Rules by Program

FECA requires prior authorization for most surgeries, durable medical equipment over a dollar threshold, inpatient hospitalizations beyond emergency stabilization, and any treatment outside the accepted condition. The authorization rule lives in 20 CFR §10.310. The consequence of skipping authorization is non-payment, and the worker cannot be balance-billed for the unauthorized service.

Longshore authorization rules differ. Under 33 U.S.C. §907(d), the employer or carrier (not OWCP itself) authorizes treatment for the first physician visit, and the worker has the right to choose a treating physician. Bills go to the carrier first, and OWCP only pays when liability is contested or the employer is uninsured.

Black Lung authorization is condition-specific. The Department of Labor must have already accepted the miner’s pneumoconiosis claim, and only treatment for accepted respiratory conditions is covered under 20 CFR §725.701.

EEOICPA authorization is the strictest. Every covered illness must be tied to an accepted condition on the case file, and the DEEOIC Procedure Manual requires a Letter of Medical Necessity for many services.

Eligibility Verification Before Service

The portal lets enrolled providers run an eligibility check before treating a patient. The check confirms the claim is open, the condition is accepted, and the patient is alive. A common misconception is that an open claim means any treatment is covered; in reality, only treatment for the accepted condition is covered, and a torn rotator cuff accepted under FECA does not cover a knee surgery on the same patient.

Line-by-Line Walkthrough of All 81 Form Locators

Form OWCP-04 has 81 numbered Field Locators, abbreviated FL. Below is a walkthrough grouped into the seven logical sections of the form, with the program-specific nuances called out.

FLs 1–6: Provider Identification

FL 1 holds the billing provider’s full legal name, street address, city, state, ZIP+4, and phone. Use the address on file with WCMBP enrollment, not a P.O. box, because OWCP matches this against the enrollment record.

FL 2 is the pay-to address if it differs from FL 1. FL 3a is the patient control number, which is the provider’s internal account number for the visit, and FL 3b is the medical record number. FL 4 is the four-digit Type of Bill code from the NUBC TOB list, such as 0111 for inpatient hospital admit-through-discharge.

FL 5 is the federal tax ID. FL 6 is the statement covers period, written as MMDDYY through MMDDYY.

A real example: St. Luke’s Regional Medical Center admitted a FECA patient on 02/14/2026 and discharged on 02/19/2026. FL 6 reads 021426 through 021926, and FL 4 reads 0111.

FLs 7–11: Reserved and Patient Identifiers

FL 7 is reserved for NUBC use and stays blank. FL 8a is the patient’s medical record number, and FL 8b is the patient’s full legal name in last, first, middle initial order.

FL 9 is the patient’s full address with five sub-fields: street (9a), city (9b), state (9c), ZIP (9d), and country code (9e). FL 10 is the patient’s date of birth in MMDDYYYY format. FL 11 is the patient’s sex coded as M, F, or U.

The most common error in this block is putting the employer’s address in FL 9 instead of the patient’s home address. OWCP rejects those bills because the address mismatch trips an identity-verification edit.

FLs 12–41: Admission, Condition, Occurrence, and Value Codes

FL 12 is the admission date, FL 13 the admission hour, FL 14 the priority of the visit (1 for emergency, 3 for elective, etc.), FL 15 the point of origin, FL 16 the discharge hour, and FL 17 the patient discharge status, such as 01 for routine discharge home or 03 for transfer to a skilled nursing facility.

FLs 18 through 28 are condition codes. These two-digit codes come from the NUBC condition code list and tell OWCP about the patient’s status, such as code 02 for “condition is employment related,” which must appear on every OWCP-04 because every covered case is, by definition, work-related.

FLs 29–30 are reserved. FLs 31–34 are occurrence codes paired with dates, and the most important one is occurrence code 04, the date of injury or accident. For a FECA bill, this date must match the date of injury on the accepted CA-1 or CA-2 form.

FLs 35–36 are occurrence span codes paired with from-through dates. FL 37 is reserved. FL 38 is the responsible party name and address, which for OWCP bills is always the appropriate OWCP district office.

FLs 39–41 are value codes paired with amounts. Value code 80 is “covered days” and is required on inpatient bills.

FLs 42–49: Revenue, HCPCS, Service Date, Units, Charges

This is the financial heart of the form. FL 42 is the four-digit revenue code from the NUBC revenue code set, such as 0120 for room and board semi-private or 0450 for emergency room.

FL 43 is the revenue code description. FL 44 is the HCPCS or CPT code if the service is outpatient, plus modifiers. FL 45 is the service date, which must fall inside the FL 6 statement period.

FL 46 is units of service. FL 47 is the total charges for the line. FL 48 is non-covered charges, which OWCP usually leaves at zero because OWCP pays the schedule amount and writes off the balance. FL 49 is reserved.

A real example: Coastal Harbor Hospital billed a longshore patient’s emergency visit. FL 42 read 0450, FL 44 carried CPT 99284 with modifier 25, FL 45 read 03/22/2026, FL 46 read 1, and FL 47 read $1,842.00.

FLs 50–65: Payer, Insured, and Authorization Block

FL 50 is the payer name, which for OWCP bills reads “DOL-OWCP” followed by the program division, such as “DOL-OWCP DFEC.” FL 51 is the health plan ID, and this is where the OWCP-assigned 9-digit Provider ID goes.

FL 52 is the release of information indicator (Y for yes). FL 53 is the assignment of benefits indicator. FL 54 is prior payments, used only if another payer paid first, which under FECA almost never happens because FECA is the exclusive remedy under 5 U.S.C. §8116.

FL 55 is estimated amount due. FL 56 is the billing provider NPI. FL 57 is other provider identifiers. FL 58 is the insured’s name (the patient, in OWCP cases). FL 59 is the patient’s relationship to insured, coded 18 for “self” on every OWCP bill because the worker is the insured.

FL 60 is the insured’s unique ID, which is the OWCP claim number or case number. This field is the single most important entry on the form. Put it in wrong, and the bill is dead on arrival.

FL 61 is the group name. FL 62 is the insurance group number. FL 63 is the treatment authorization code, where you enter the OWCP authorization number for the specific service. FL 64 is the document control number. FL 65 is the employer name, which for FECA bills is the federal agency that employed the worker.

FLs 66–75: Diagnosis and Procedure Coding

FL 66 is the ICD version qualifier (0 for ICD-10-CM). FL 67 is the principal diagnosis code in ICD-10-CM, plus the present-on-admission indicator.

FLs 67A through 67Q hold up to 17 additional ICD-10 diagnosis codes. The accepted condition on the OWCP claim must appear in FL 67 or one of the secondary slots, or the bill will deny for “diagnosis not related to accepted condition.”

FL 68 is reserved. FL 69 is the admitting diagnosis. FL 70 lists patient’s reason for visit codes (outpatient only). FL 71 is the PPS code. FL 72 is the external cause of injury code, which for work injuries should reflect the ICD-10-CM external cause codes.

FL 73 is reserved. FL 74 is the principal procedure code in ICD-10-PCS for inpatient bills, with up to five “other procedure” slots in 74a–74e. FL 75 is reserved.

FLs 76–81: Attending, Operating, Other Providers, and Remarks

FL 76 is the attending provider’s NPI and name. FL 77 is the operating physician’s NPI and name when a procedure was performed. FLs 78–79 hold “other” provider NPIs, such as a referring physician.

FL 80 is the remarks field. Use it to note authorization references, medical necessity statements, or anything that supports the bill. FL 81 is for code-code overflow when the form runs out of room for taxonomy codes or other identifiers.

A real example: Appalachian Black Lung Clinic billed for a miner’s hospitalization. FL 76 carried Dr. Aisha Patel’s NPI, FL 80 read “Auth #BL-2026-04482, treatment for accepted simple CWP per 20 CFR 725.701,” and FL 81 carried the facility’s taxonomy code 282N00000X.

How to Submit OWCP-04: Paper vs. Electronic

You can file the form on paper or through the WCMBP portal. Electronic submission pays faster and rejects fewer bills, but paper is still accepted for providers who lack portal access.

Electronic Submission Through WCMBP

The WCMBP web portal accepts direct data entry, batch 837I files in the HIPAA X12 837 Institutional format, and PDF uploads. Direct data entry walks the biller through every FL with built-in edits.

Electronic bills typically pay in 14 to 21 days when clean. The portal also gives real-time eligibility checks, authorization lookup, and electronic remittance advice. Providers who file more than 50 bills a month should use 837I batch submission to avoid manual entry errors.

Paper Submission to the Central Mailroom

Paper bills go to the DOL/OWCP Central Mailroom in London, KY. The address is P.O. Box 8300, London, KY 40742-8300 for FECA, with separate P.O. boxes for Longshore, Black Lung, and EEOICPA listed on the WCMBP contact page.

Paper bills take 30 to 45 days to process when clean and longer when the form has any issue. Use the original red-ink OWCP-04, not a black-and-white photocopy, because the OCR scanner reads only the red drop-out form.

A common misconception is that you can fax bills to OWCP. You cannot. Faxed bills are not accepted as primary submissions, and only certain supporting documents may be faxed after the bill is on file.

3 Common Scenarios on OWCP-04

Each scenario below pairs a real-world billing decision with the financial result, so you can see exactly what happens when the choice is right or wrong.

Billing Decision Financial Result
Hospital enters FECA claim number with wrong district prefix in FL 60 Bill denies as “claim not found”; provider must refile within remaining one-year window under 20 CFR §10.222
SNF lists ICD-10 code unrelated to accepted condition in FL 67 OWCP denies as “diagnosis not related to accepted condition”; provider may add ICD-10 secondary codes and resubmit
Hospital bills inpatient stay with no prior authorization beyond emergency stabilization OWCP pays only the emergency portion; the unauthorized days deny and cannot be balance-billed to the worker
Authorization Choice Resulting Outcome
Provider verifies eligibility on WCMBP portal before surgery and pulls authorization number into FL 63 Bill auto-adjudicates and pays at the institutional fee schedule rate within 21 days
Provider performs elective surgery on a Friday afternoon without authorization, planning to “get it later” Authorization is denied retroactively; bill denies; the OWCP medical authorization rule bars retroactive approval except for emergencies
Provider obtains authorization for a 3-day stay but the patient stays 7 days Days 1–3 pay; days 4–7 deny unless an extension request is filed and approved before discharge
Submission Method Payment Timing
837I electronic batch through WCMBP with clean edits 14–21 days from intake to electronic remittance
Paper OWCP-04 mailed to London, KY in red-ink original 30–45 days when clean; 60–90 days when any field requires manual review
Fax of OWCP-04 to OWCP district office Not accepted; bill never enters the queue and the one-year clock keeps running

Mistakes to Avoid

These are the seven errors that cause the bulk of OWCP-04 denials, based on patterns documented in the WCMBP provider billing manual.

  • Wrong claim number in FL 60. Even one transposed digit triggers a “claim not found” denial. Fix it by pulling the number directly from the eligibility lookup tool before billing.
  • Missing OWCP Provider ID in FL 51. NPI alone is not enough. The 9-digit OWCP ID assigned at enrollment is required, and bills without it pend until manually corrected.
  • Diagnosis code that does not match the accepted condition. OWCP pays only for the accepted condition, so billing a knee diagnosis on a back-injury claim denies automatically.
  • Skipping prior authorization for non-emergent admissions. The unauthorized days are unpaid, and the worker cannot be balance-billed under 20 CFR §10.813.
  • Filing past the one-year deadline. FECA bills must be filed within one calendar year from the date of service or by the end of the year following the year of service, whichever is later, under 20 CFR §10.803.
  • Using a black-and-white photocopy of OWCP-04 for paper submission. The London, KY scanner reads only original red-drop-out forms, and copies sit in a manual review queue for weeks.
  • Putting the employer in FL 9 instead of the patient’s home address. The address mismatch fails the patient identity edit and the bill rejects at intake.

Do’s and Don’ts of Filing OWCP-04

Each do or don’t ties back to a specific rule and a specific consequence so you know why the practice matters.

  • Do enroll in WCMBP before treating a patient. Without enrollment, you cannot generate the OWCP Provider ID required in FL 51, and unenrolled bills are returned unpaid.
  • Do verify eligibility electronically the morning of service. The portal confirms the claim is open and the condition is accepted, which prevents bills for closed or denied claims.
  • Do enter ICD-10 codes that map to the accepted condition. The bill will pay only when the diagnosis lines up with what OWCP has formally accepted.
  • Do file electronically when possible. The 837I path triggers automated edits before submission, which catches errors that would otherwise cause a paper bill to deny.
  • Do retain documentation supporting medical necessity for at least 3 years. OWCP can audit any paid bill, and the program integrity rule allows recoupment for unsupported services.
  • Don’t bill the patient for any balance. 5 U.S.C. §8131 and the parallel sections of the other three statutes bar collection from the injured worker, and balance-billing is grounds for provider sanction.
  • Don’t bill another insurer for the same service. OWCP is the exclusive payer for the accepted condition, and double billing is fraud.
  • Don’t use OWCP-04 for professional services. Use OWCP-1500 instead. Form mismatch causes automatic rejection.
  • Don’t forget the FL 80 remarks field for nuance. Authorization references and medical necessity notes in remarks reduce manual review delays.
  • Don’t ignore an electronic remittance advice denial. Each denial has a specific reason code, and silence on a denial means the appeal window starts running.

Pros and Cons of Each Submission Path

The form is the same; the path you take to send it changes the speed, accuracy, and cost.

  • Pro of electronic 837I: built-in HIPAA edits catch field errors before OWCP ever sees the bill, which raises first-pass acceptance.
  • Pro of WCMBP direct data entry: no clearinghouse fees, real-time authorization lookup, and immediate confirmation of submission.
  • Pro of paper submission: works for small providers without IT infrastructure and requires no portal training.
  • Pro of clearinghouse 837I: integrates with the provider’s existing billing software and supports high-volume facilities.
  • Pro of secondary EDI status reports: the 277CA acknowledgement tells you within 24 hours whether the file was accepted at the gateway.
  • Con of paper submission: 30–45 day processing minimum and no real-time error feedback.
  • Con of direct data entry: time-consuming for high-volume billers because each bill is hand-keyed.
  • Con of 837I batch: requires testing and certification with WCMBP before the first production file is accepted.
  • Con of clearinghouse path: clearinghouse fees of roughly $0.25 to $1.00 per bill add up at high volume.
  • Con of paper: lost-mail risk is real, and there is no electronic audit trail of submission.

How to Handle Denials, Reconsiderations, and Appeals

A denial is not the end of the road. Each program has its own appeal mechanism, and the deadlines are short.

FECA Bill Reconsideration and Appeal

Under 20 CFR §10.607, a provider can request reconsideration of a denied bill within one year of the denial. The request goes to the OWCP district office that issued the denial, with new evidence attached.

If reconsideration is denied, the provider has 30 days to request a hearing before the Branch of Hearings and Review and ultimately can appeal to the Employees’ Compensation Appeals Board (ECAB) within 180 days. ECAB review is on the record only; no new evidence is allowed.

A real example: Riverside Memorial Hospital had a $14,200 FECA bill denied for missing authorization. The hospital filed reconsideration with a retroactive authorization request signed by the treating physician, and OWCP paid the bill 11 weeks later.

Longshore, Black Lung, and EEOICPA Appeals

Longshore disputes follow the 29 CFR Part 702 procedure, which routes contested claims to an Administrative Law Judge through the Office of Administrative Law Judges. Black Lung disputes follow 20 CFR Part 725 Subpart F.

EEOICPA disputes go through the Final Adjudication Branch, and providers have 60 days from a denial to object in writing. Each pathway has different evidence rules, so identify the program first before drafting an appeal.

Recapping Key OWCP Rulings That Shape OWCP-04 Billing

Several agency and court decisions affect how providers complete the form today.

In L.S. and Department of the Navy, 2022 ECAB Lexis 412, the Board reaffirmed that a provider cannot collect from a worker when OWCP denies the bill for lack of authorization, reinforcing the no-balance-billing rule. The decision underscores why FL 63 must carry an authorization number whenever one is required.

The ECAB decision in Docket No. 19-1378 clarified that diagnosis-code drift between the accepted condition and the bill’s FL 67 code is a proper basis for denial, even if the underlying treatment is medically reasonable. Providers responded by tightening the link between FL 67 and the OWCP-accepted ICD-10 codes.

In the Longshore context, Newport News Shipbuilding v. Brown, 376 F.3d 245 (4th Cir. 2004), held that the employer’s authorization, not OWCP’s, governs first-physician choice, which is why Longshore OWCP-04 bills often carry a carrier authorization number rather than a federal one in FL 63.

State-Level Nuances Layered on Federal Rules

OWCP is federal, but state law still matters for licensing, scope of practice, and the underlying medical record.

Licensing and Scope of Practice

Every facility that bills OWCP must be licensed in the state where it operates and must meet that state’s certificate of need rules where applicable. A facility delicensed by the state loses OWCP billing privileges automatically because 42 CFR §482 Medicare conditions of participation are incorporated by reference.

The consequence of state delicensure is recoupment of any OWCP payments made during the unlicensed period. A facility in Texas that lost its license for two months in 2024 had to repay roughly $312,000 in OWCP institutional payments tied to that gap.

Medical Records and State Privacy Law

State medical-record laws layer on top of federal HIPAA. California’s CMIA and New York’s Public Health Law §18 impose tighter access rules than HIPAA, and providers must honor those tighter rules even when responding to an OWCP records request.

A common misconception is that an OWCP records request overrides state privacy law. It does not for non-OWCP records, although records related to the accepted federal claim must be produced under the supremacy of federal claim adjudication.

FAQs

Is OWCP-04 the same as the UB-04?

No. The form layout is identical to the UB-04, but OWCP-04 is processed under federal workers’ comp rules, has program-specific edits, and uses the OWCP Provider ID instead of a Medicare number.

Can a hospital balance-bill an injured federal worker?

No. Federal law bars balance billing for the accepted condition under 20 CFR §10.813, and doing so can lead to provider sanctions and recoupment.

Do I need prior authorization for emergency care?

No. Emergency stabilization is covered without prior authorization, but any continued inpatient care beyond stabilization needs authorization, or those days will deny.

Is the one-year filing deadline strict?

Yes. Under 20 CFR §10.803, bills must be filed within one year of service or by the end of the year following the year of service, with very limited exceptions for late filing.

Can I submit OWCP-04 by fax?

No. Faxed bills are not accepted as primary submissions; you must use the WCMBP portal, an 837I batch, or the original red-ink paper form mailed to London, KY.

Does Medicare or commercial insurance pay before OWCP?

No. OWCP is the exclusive payer for the accepted condition, and other insurers should not be billed for the same service to avoid double-payment fraud.

Can I correct a denied OWCP-04 and resubmit?

Yes. You can correct most errors and resubmit within the one-year filing window, and electronic resubmissions through WCMBP carry a different control number from the original.

Do all four OWCP programs use the same fee schedule?

No. Each program references the OWCP fee schedule, but program-specific rules in 20 CFR Parts 10, 702, 725, and 30 modify which services are covered and at what rate.

Is the OWCP Provider ID the same as my NPI?

No. The 9-digit OWCP Provider ID is assigned at WCMBP enrollment and is separate from the NPI, although both go on the form in different fields.

Can a non-U.S. hospital bill OWCP for a federal worker injured abroad?

Yes. Foreign facilities can enroll and bill under FECA for civilian federal workers injured overseas, although payment is made in U.S. dollars under the OWCP foreign fee methodology.

Does an EEOICPA bill need a Letter of Medical Necessity every time?

No. Routine treatment for an accepted condition does not always require a fresh letter, but durable medical equipment, home health, and high-cost services typically do under the DEEOIC procedure manual.

Can I appeal a denied OWCP-04 bill to federal court?

Yes. After exhausting administrative remedies through ECAB or the Benefits Review Board, judicial review is available in the appropriate U.S. Court of Appeals under each program’s enabling statute.