Romano v. Franklin General Hospital
A claimant, injured in an auto accident in her employer's parking lot, received treatment from an employer-affiliated orthopedist for cervical myositis. A C-4 medical report was filed, and the employer billed its carrier for physical therapy. The carrier controverted the claim, citing a failure to timely file under Workers' Compensation Law § 28. The Workers' Compensation Board found that the employer had timely notice and that the medical services provided constituted an advance payment of compensation, thus waiving the § 28 requirement. The appellate court affirmed the Board's decision, concluding that the medical care was indeed an advance payment, and the employer was aware the injury was work-related, thereby supporting the waiver of the timely filing requirement.