Apple v. Guilford County

EAGLES, Judge.

G.S. 97-47 provides that within two years of the “date of the last payment of compensation pursuant to an award under this Article,” the Commission may, upon the application of any party in interest, or upon its own motion, review the award on the grounds of a change in condition. A validly executed I.C. Form 21 agreement constitutes an “award” under the North Carolina Workers’ Compensation Act. White v. Boat Corporation, 261 N.C. 495, 135 S.E. 2d 216 (1964). Moreover, the Commission found, and defendants do not dispute, that plaintiff did apply for a review of her award based…