N.C. Gen. Stat. » Chapter 97
NC General Statutes

N.C. Gen. Stat. § 97-25.1 (2026)

Limitation of duration of medical compensation

✓ current as of July 2026
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The right to medical compensation shall terminate two years after the employer's last payment of medical or indemnity compensation unless, prior to the expiration of this period, either: (i) the employee files with the Commission an application for additional medical compensation which is thereafter approved by the Commission, or (ii) the Commission on its own motion orders additional medical compensation. If the Commission determines that there is a substantial risk of the necessity of future medical compensation, the Commission shall provide by order for payment of future necessary medical compensation. (1993 (Reg. Sess., 1994), c. 679, s. 2.5.)

 

Notes of Decisions
Cited in 39 cases (7 in the last 5 years), 1999–2026 · leading case: Lewis v. Transit Mgmt. Of Charlotte, 792 S.E.2d 890 (N.C. Ct. App. 2016).
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Lewis v. Transit Mgmt. Of Charlotte, 792 S.E.2d 890 (N.C. Ct. App. 2016). · cites it 46× “Pursuant to the pre-trial agreement, the deputy commissioner considered only "the procedural issue of whether [p]laintiff [was] time-barred from seeking additional benefits under N.C. Gen. Stat. § 97-25.1 or § 97-47 or both.”
Effingham v. THE KROGER CO., 561 S.E.2d 287 (N.C. Ct. App. 2002). · cites it 6× “Defendants contend that the award should be subject to the limitations of N.C.G.S §§ 97-25.1 (two-year statute of limitations) and 97-2(19) (definition of medical compensation).”
Gregory v. W.A. Brown & Sons, 664 S.E.2d 589 (N.C. Ct. App. 2008). · cites it 14× “N.C. Gen.Stat. § 97-25.1 (2007) provides as follows: The right to medical compensation shall terminate two years after the employer's last payment of medical or indemnity compensation unless, prior to the expiration of this period, either: (i) the employee files with the…”
Fontenot v. Ammons Springmoor Assocs., 625 S.E.2d 862 (N.C. Ct. App. 2006). · cites it 16× “” 2 N.C. Gen. Stat. § 97-25.1 (2005). Pursuant to the Commission’s promulgated rules governing workers’ compensation cases, an “application” for the additional medical benefits available under section 97-25.”
Myles v. LMS Inc., 795 S.E.2d 288 (N.C. Ct. App. 2016). · cites it 12× “N.C. Gen. Stat. § 97-25.1 (2015). Here, the Commission made the following unchallenged findings of fact.”
North Carolina Ins. Guar. Ass'n v. Bd. of Trs., 691 S.E.2d 694 (N.C. 2010). · cites it 6× “Laws 394 , 399-400 (enacting N.C.G.S. § 97-25.1 (2007)). As noted by this Court, the Workers' Compensation Act is a remedial statutory scheme: Where radical and systematic changes have been made in setting up a system of such wide scope as we find in the Work[ers'] Compensation…”
Wilkes v. City of Greenville, 369 N.C. 730 (N.C. 2017). · cites it 3× “At that point, the right to medical compensation terminates, unless, before the end of that period: “(i) the employee files with the Commission an application for additional medical compensation which is thereafter approved by the Commission, or (ii) the Commission on its own…”
Guerrero v. Brodie Contractors, Inc., 582 S.E.2d 346 (N.C. Ct. App. 2003). · cites it 8× “N.C. Gen. Stat. § 97-25.1 (2001). The Commission concluded “[plaintiff is entitled to have Defendants pay for medical treatment incurred or to be incurred as a result of his compensable injury by accident of April 3, 1997.”
McAllister v. Wellman, Inc., 590 S.E.2d 311 (N.C. Ct. App. 2004). · cites it 6× “N.C. Gen. Stat. § 97-25.1 became effective upon ratification on 5 July 1994, and provides that the right to medical expenses terminates two years after the last payment to plaintiff, unless plaintiff applies for additional medical benefits within that period.”
Pomeroy v. Tanner Masonry, 565 S.E.2d 209 (N.C. Ct. App. 2002). · cites it 4× “In 1994, the General Assembly added N.C. Gen. Stat. § 97-25.1 , which provides that an injured employee’s “right to medical compensation shall terminate two years after the employer’s last payment of medical or indemnity compensation unless, prior to the expiration of this…”
Reinninger v. Prestige Fabricators, Inc., 523 S.E.2d 720 (N.C. Ct. App. 1999). · cites it 3× “N.C.G.S. § 97-25.1 (Supp. 1998). In an action for additional compensation for medical treatment, the medical treatment sought must be “directly related to the original compensable injury.”
Busque v. Mid-Am. Apt. Communities, 707 S.E.2d 692 (N.C. Ct. App. 2011). · cites it 7× “N.C. Gen. Stat. § 97-25.1 (2009). Applying the statute to the present case, the “last payment of medical or indemnity compensation” for the 18 January 2003 fall was a check issued to Ms.”
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