Arkansas Code Annotated

Ark. Code Ann. § 11-9-809 (2026)

Interest

✓ current as of May 2026
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Compensation shall bear interest at the legal rate from the day an award is made by either an administrative law judge or the full Workers' Compensation Commission on all accrued and unpaid compensation.

History. Init. Meas. 1948, No. 4, § 19, Acts 1949, p. 1420; Acts 1959, No. 167, § 1; A.S.A. 1947, § 81-1319.

Case Notes

In General.

Workers' Compensation Rule 20, which was promulgated to implement a medical cost containment program with respect to compensable injuries, does not relieve a workers' compensation insurance carrier from the obligation to pay interest under this section. Burlington Indus. v. Pickett, 64 Ark. App. 67, 983 S.W.2d 126 (1998).

Computation.

Interest upon accrued and unpaid installments of compensation is to be computed from the dates when they should have been paid, beginning, however, not earlier than the date on which a referee or the full commission first enters an award allowing or denying the claim. Clemons v. Bearden Lumber Co., 240 Ark. 571, 401 S.W.2d 16 (1966).

Medical Payments.

Interest payable under this section includes interest on direct medical payments. Eureka Log Homes v. Mantonya, 28 Ark. App. 180, 772 S.W.2d 365 (1989).

Cited: Couch v. First State Bank, 49 Ark. App. 102, 898 S.W.2d 57 (1995).

Notes of Decisions
Cited in 8 cases, 1989–2016 · leading case: Christopher R. Brown, D.D.S., Inc. v. Decatur Cnty. Mem'l Hosp., 892 N.E.2d 642 (Ind. 2008).
Christopher R. Brown, D.D.S., Inc. v. Decatur Cnty. Mem'l Hosp., 892 N.E.2d 642 (Ind. 2008). · cites it 2× “See Ark.Code Ann. § 11-9-809 (2002); Cal. Lab.”
Burlington Indus. v. Pickett, 988 S.W.2d 3 (Ark. 1999). · cites it 2× “It also included an award for attorney’s fees and interest pursuant to Ark. Code Ann. § 11-9-809 (Repl. 1996). The matter returned to the attention of the Workers’ Compensation Commission in a March 1996 hearing.”
Skinner v. Tango Transp., Inc., 2016 Ark. App. 304 (Ark. Ct. App. 2016). · cites it 2× “This award shall bear interest at the legal rate pursuant to Ark. Code Ann. § 11-9-809 , until paid. Subsequently, on March 15, 2013, the Commission in a 2-1 majority opinion affirmed and adopted the ALJ’s opinion as its own.”
Nucor Corp. v. Rhine, 237 S.W.3d 52 (Ark. 2006). · cites it 2× “The Commission awarded appellee additional medical benefits and ordered that “[a]ll accrued benefits shall be paid in a lump sum without discount and with interest thereon at the lawful rate from the date of the [ALJ’s] decision in accordance with Ark.”
Couch v. First State Bank, 898 S.W.2d 57 (Ark. Ct. App. 1995). · cites it 3× “” Arkansas Code Annotated § 11-9-809 (1987) provides that accrued and unpaid compensation shall bear interest.”
O'Hara v. J. Christy Const. Co., Inc., 272 S.W.3d 842 (Ark. Ct. App. 2008). · cites it 4× “Arkansas Code Annotated section 11-9-809 (Repl.2002) specifically entitles Mr.”
Burlington Indus. v. Pickett, 983 S.W.2d 126 (Ark. Ct. App. 1998). · cites it 6× “Respondents #1 is Hable for interest, pursuant to Ark. Code Ann. § 11-9-809 , on incurred medical paid on behalf of claimant’s compensable injury by Providence [sic] Life Insurance; John Hancock Insurance and Medicare • — • Blue Cross/Blue Shield.”
Eureka Log Homes v. Mantonya, 772 S.W.2d 365 (Ark. Ct. App. 1989). · cites it 2× “” In turn, Arkansas Code Annotated Section 11-9-102(9) (1987) expressly states that “ ‘compensation’ means the money allowance payable to the employee or to his dependents and includes the allowances provided for in § 11-9-509 .”
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