Williams v. SAIF Corp. (In re Williams)

*329Claimant seeks review of an order of the Workers' Compensation Board assessing a penalty under former ORS 656.268(5)(d) (2013)1 based on SAIF's erroneous calculation of the range of motion component of claimant's award of impairment in a notice of closure. A correct calculation of the range of motion component resulted in an increase of two percent in the impairment award. The board determined that SAIF's miscalculation resulted in an unreasonable notice of closure under ORS 656.268(5)(d), and assessed a penalty based on the increased amount of the impairment award attributable to the…