Alaska Statutes
Alaska Stat. § 23.30.012 (2026)
Agreements in regard to claims
✓ current as of July 2026
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Sec. 23.30.012. Agreements in regard to claims.
(a) At any time after death, or after 30 days subsequent to the date of the injury, the employer and the employee or the beneficiary or beneficiaries, as the case may be, have the right to reach an agreement in regard to a claim for injury or death under this chapter, but a memorandum of the agreement in a form prescribed by the director shall be filed with the division. Otherwise, the agreement is void for any purpose. Except as provided in (b) of this section, an agreement filed with the division discharges the liability of the employer for the compensation, notwithstanding the provisions of AS 23.30.130, 23.30.160, and 23.30.245, and is enforceable as a compensation order.
(b) The agreement shall be reviewed by a panel of the board if the claimant or beneficiary is not represented by an attorney licensed to practice in this state, the beneficiary is a minor or incompetent, or the claimant is waiving future medical benefits. If approved by the board, the agreement is enforceable the same as an order or award of the board and discharges the liability of the employer for the compensation notwithstanding the provisions of AS 23.30.130, 23.30.160, and 23.30.245. The agreement shall be approved by the board only when the terms conform to the provisions of this chapter, and, if it involves or is likely to involve permanent disability, the board may require an impartial medical examination and a hearing in order to determine whether or not to approve the agreement. A lump-sum settlement may be approved when it appears to be to the best interest of the employee or beneficiary or beneficiaries.
(a) At any time after death, or after 30 days subsequent to the date of the injury, the employer and the employee or the beneficiary or beneficiaries, as the case may be, have the right to reach an agreement in regard to a claim for injury or death under this chapter, but a memorandum of the agreement in a form prescribed by the director shall be filed with the division. Otherwise, the agreement is void for any purpose. Except as provided in (b) of this section, an agreement filed with the division discharges the liability of the employer for the compensation, notwithstanding the provisions of AS 23.30.130, 23.30.160, and 23.30.245, and is enforceable as a compensation order.
(b) The agreement shall be reviewed by a panel of the board if the claimant or beneficiary is not represented by an attorney licensed to practice in this state, the beneficiary is a minor or incompetent, or the claimant is waiving future medical benefits. If approved by the board, the agreement is enforceable the same as an order or award of the board and discharges the liability of the employer for the compensation notwithstanding the provisions of AS 23.30.130, 23.30.160, and 23.30.245. The agreement shall be approved by the board only when the terms conform to the provisions of this chapter, and, if it involves or is likely to involve permanent disability, the board may require an impartial medical examination and a hearing in order to determine whether or not to approve the agreement. A lump-sum settlement may be approved when it appears to be to the best interest of the employee or beneficiary or beneficiaries.
Notes of Decisions
Cited in 25
cases (2 in the last 5 years), 1984–2025 · leading case: Mun. of Anchorage v. Stenseth, 361 P.3d 898 (Alaska 2015).
Mun. of Anchorage v. Stenseth, 361 P.3d 898 (Alaska 2015). “Rehbock suggested a "tender in exchange for releases to be simultaneously filed with the Board, so to meet any requirement of AS 23.30.012. 2 Heikes emailed Rehbock six days later, informing him of "an internal glitch," a "need to get higher ups to sign off.”
Leona Seal, as Pers. Rep. of the Est. of Nicholson J. Tinker v. Mark C. Welty d/b/a North Country Servs., 477 P.3d 613 (Alaska 2020). “Alleging that the settlement money “came from Allstate,” Michaelson’s insurer, “through the Alaska Workers’ Compensation Benefits Guaranty Fund,” Welty argued that the Board’s approval under AS 23.30.012 effectively made the settlement a final judgment of the Board and showed…”
Seybert v. Cominco Alaska Expl., 182 P.3d 1079 (Alaska 2008). “The Board Did Not Violate AS 23.30.012 when It Approved the C & R. Seybert contends that the board violated statutory and regulatory standards in approving the C & R.”
Adamson v. Univ. of Alaska, 819 P.2d 886 (Alaska 1991). “In this regard, the Board stated, While we reiterate our belief that we have no choice but to conclude as we have under AS 23.30.012, we need to take steps to minimize the potential turmoil where an oral agreement does not ultimately settle a claim.”
Smith v. CSK Auto, Inc., 204 P.3d 1001 (Alaska 2009). “26 He also argues that the partial C & R should be set aside because he did not have the opportunity to appear at the hearing before the Board approved the partial C & R and because the Board did not order an independent medical examination pursuant to AS 23.30.012. He…”
Barrington v. Alaska Commc'ns Sys. Grp., Inc., 198 P.3d 1122 (Alaska 2009). “AS 23.30.012(b); see Olsen Logging Co. v.”
Williams v. Abood, 53 P.3d 134 (Alaska 2002). “AS 23.30.012. 41 . 856 P.2d 1155 (Alaska 1993).”
Blanas v. Brower Co., 938 P.2d 1056 (Alaska 1997). “Whether the Board had jurisdiction or authority to set aside the C & R is a legal question involving the interpretation of AS 23.30.012. We review questions of statutory interpretation under the substitution of judgment standard.”
Cole v. Ketchikan Pulp Co., 850 P.2d 642 (Alaska 1993). “This matter requires us to address the appropriate standard of review regarding two issues: First, the Board’s interpretation of AS 23.30.012 and the statute’s im-plementating regulation, 8 AAC 45.”
Bouse v. Fireman's Fund Ins. Co., 932 P.2d 222 (Alaska 1997). “AS 23.30.012. Before approving an agreement, the Board must determine that the agreement is in the best interests of the worker.”
Warnke-Green v. Pro-West Contractors, LLC, 440 P.3d 283 (Alaska 2019). “Under AS 23.30.012(b), a workers' compensation settlement agreement between an unrepresented claimant and an employer must be reviewed and approved by the Board to be enforceable.”
Garner v. State, Dep't of Health & Soc. Servs., Div. of Med. Assistance, 63 P.3d 264 (Alaska 2003). “2d 1056, 1060 (Alaska 1997) (reviewing agency’s interpretation of AS 23.30.012). 9 . Chizmar v. Mackie, 896 P.”
— Alaska Stat. § 23.30.012(a) — 3 cases
Mun. of Anchorage v. Stenseth, 361 P.3d 898 (Alaska 2015). “Rehbock suggested a "tender in exchange for releases to be simultaneously filed with the Board, so to meet any requirement of AS 23.30.012. 2 Heikes emailed Rehbock six days later, informing him of "an internal glitch," a "need to get higher ups to sign off.”
Leona Seal, as Pers. Rep. of the Est. of Nicholson J. Tinker v. Mark C. Welty d/b/a North Country Servs., 477 P.3d 613 (Alaska 2020). “Alleging that the settlement money “came from Allstate,” Michaelson’s insurer, “through the Alaska Workers’ Compensation Benefits Guaranty Fund,” Welty argued that the Board’s approval under AS 23.30.012 effectively made the settlement a final judgment of the Board and showed…”
Charles McKee v. Alaska Functional Fitness LLC (Alaska 2019).
— Alaska Stat. § 23.30.012(b) — 8 cases
Barrington v. Alaska Commc'ns Sys. Grp., Inc., 198 P.3d 1122 (Alaska 2009). “AS 23.30.012(b); see Olsen Logging Co. v.”
Mun. of Anchorage v. Stenseth, 361 P.3d 898 (Alaska 2015). “Rehbock suggested a "tender in exchange for releases to be simultaneously filed with the Board, so to meet any requirement of AS 23.30.012. 2 Heikes emailed Rehbock six days later, informing him of "an internal glitch," a "need to get higher ups to sign off.”
Seybert v. Cominco Alaska Expl., 182 P.3d 1079 (Alaska 2008). “The Board Did Not Violate AS 23.30.012 when It Approved the C & R. Seybert contends that the board violated statutory and regulatory standards in approving the C & R.”
Leona Seal, as Pers. Rep. of the Est. of Nicholson J. Tinker v. Mark C. Welty d/b/a North Country Servs., 477 P.3d 613 (Alaska 2020). “Alleging that the settlement money “came from Allstate,” Michaelson’s insurer, “through the Alaska Workers’ Compensation Benefits Guaranty Fund,” Welty argued that the Board’s approval under AS 23.30.012 effectively made the settlement a final judgment of the Board and showed…”
Smith v. CSK Auto, Inc., 204 P.3d 1001 (Alaska 2009). “26 He also argues that the partial C & R should be set aside because he did not have the opportunity to appear at the hearing before the Board approved the partial C & R and because the Board did not order an independent medical examination pursuant to AS 23.30.012. He…”
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