Matter of Howard v. Facilities Maintenance Corporation
Shamira Bell appealed a Workers' Compensation Board (WCB) decision regarding reimbursement for lost wage payments from the Special Disability Fund. The WCB had determined that the employer's application for reimbursement was untimely, filed more than two years after the final decision that the case was subject to Workers' Compensation Law § 15 (8) (d). The Appellate Division affirmed the WCB's decision, rejecting Bell's argument that the two-year period for filing a claim under Workers' Compensation Law § 15 (8) (d) should commence only after a final administrative award determined the total reimbursement amount. The court clarified that the two-year period begins upon the Board's final determination that the case falls under the specified section of the Workers' Compensation Law. In this instance, the Board's August 2019 decision established this final determination, rendering the employer's July 2022 reimbursement application untimely.