Liberty Northwest Insurance v. Cotner

Employer seeks review of an order of the Workers’ Compensation Board (Board) awarding claimant temporary disability benefits, arguing that the Board lacked authority to order the payment of benefits beyond the date that claimant became medically stationary. The Board held that, under ORS 656.313(l)(a)(A), employer is obligated to continue paying temporary disability benefits until the date of closure. We hold that ORS 656.313(l)(a)(A) requires employers to pay only temporary disability benefits “that accrue from the date of the order appealed” and does not itself create entitlement to such…