Anderson, a much more reliable approach is to write out comma-delimited qsam's from a cobol program. The append from works without a hitch. I wrote a large system in FPW for Bank of America and we received many files from different places, all in comma-delimited, and it went fine.
In fact, if you are unfamiliar with how to create a comma_delimited file from within a cobolII program, let me know and I will e-mail you a cobol program that does just that.