In the Matter of the Claim of Miguel Juncal
Claimant Miguel Juncal suffered physical injuries from a fall at work in November 2021 and was awarded temporary total disability benefits. The employer and its carrier, Maspeth Remodeling Co. et al., appealed a Workers' Compensation Board decision that denied their request to retroactively reduce Juncal's benefits. The carrier sought a reduction based on an independent medical examination from August 2022, arguing that the reduction should be effective from the IME date or the RFA-2 filing date. The Board affirmed the WCLJ's decision, holding that benefits should continue at the temporary total disability rate until the March 2023 hearing, interpreting 12 NYCRR 300.23 (b) (2) as directory rather than mandatory regarding the 20-day hearing timeframe. The Appellate Division affirmed the Board's decision, finding no abuse of discretion.