Voluntary Payments By MD. Employer Not 'Award'

An employer's voluntary payment of benefits to an injured employee does not trigger the five-year limit on modifying a workers' compensation award, ruled the Maryland Appellate Court last week.In Mona Electric Service, Inc. et al. v. Wade O. Shelton (No. 131, Sept. Term 2002, 10/09/03), Shelton sustained back and neck injuries in an on-the-job motor vehicle accident. The claim was initially challenged by the employer but later admitted. Shelton was paid TTD until September 1994, when it determined he had reached maximum medical improvement. Shelton filed for permanent partial disability benef...