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

N.C. Gen. Stat. § 97-47 (2026)

Change of condition; modification of award

✓ current as of July 2026
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Upon its own motion or upon the application of any party in interest on the grounds of a change in condition, the Industrial Commission may review any award, and on such review may make an award  ending, diminishing, or increasing the compensation previously awarded, subject to the maximum or minimum provided in this Article, and shall immediately send to the parties a copy of the award. No such review shall affect such award as regards any moneys paid but no such review shall be made after two years from the date of the last payment of compensation pursuant to an award under this Article, except that in cases in which only medical or other treatment bills are paid, no such review shall be made after 12 months from the date of the last payment of bills for medical or other treatment, paid pursuant to this Article. (1929, c. 120, s. 46; 1931, c. 274, s. 6; 1947, c. 823; 1973, c. 1060, s. 2.)

 

Notes of Decisions
Cited in 133 cases, 1948–2020 · leading case: Hyler v. GTE Prods. Co., 425 S.E.2d 698 (N.C. 1993).
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Hyler v. GTE Prods. Co., 425 S.E.2d 698 (N.C. 1993). · cites it 146× “On 19 February 1986, the plaintiff sought to reopen his claim before the Industrial Commission, asking for additional compensation for his disability based on the grounds of a change of condition as provided in N.C.G.S. § 97-47. On 10 March 1987, the plaintiff further requested…”
Weaver v. Swedish Imports Maint., Inc., 354 S.E.2d 477 (N.C. 1987). · cites it 67× “In this workers' compensation case we must determine whether the Court of Appeals correctly affirmed the Industrial Commission's decision that: (1) claimant had suffered a change in condition entitling him to recover pursuant to N.C.G.S. § 97-47, and (2) claimant was entitled to…”
Perez v. Am. Airlines/AMR Corp., 620 S.E.2d 288 (N.C. Ct. App. 2005). · cites it 23× “Applicability of Section 97-47 Defendant asserts that plaintiffs claim for additional indemnity compensation was barred under the time limitations stated in N.C. Gen. Stat. § 97-47 . Section 97-47 provides, in pertinent part, that upon the application of any party in interest on…”
HAND BY HAND v. Fieldcrest Mills, Inc., 355 S.E.2d 141 (N.C. Ct. App. 1987). · cites it 86× “After a hearing, the Commission dismissed her request to reopen, finding that her claim for additional compensation was barred by the two-year statute of limitations in N.C.G.S. § 97-47, and further finding that the statute of limitations should not be waived on the basis of…”
Gore v. Myrtle/Mueller, 653 S.E.2d 400 (N.C. 2007). · cites it 20× “The Court then addressed what it calls the crux of the controversy, namely whether the Session Law referenced by the Commission, which amended N.C.G.S. § 97-47, had any applicability to the plaintiff's claim.”
Pomeroy v. Tanner Masonry, 565 S.E.2d 209 (N.C. Ct. App. 2002). · cites it 29× “See N.C. Gen. Stat. § 97-47 (2001). This second Form 28B also did not indicate the weekly wage at which Plaintiff had returned to work.”
Pittman v. Thomas & Howard, 468 S.E.2d 283 (N.C. Ct. App. 1996). · cites it 16× “As a result of deterioration in his condition and a medical recommendation for surgery, plaintiff subsequently filed both a “Request that Claim be Assigned for Hearing,” seeking payment for the recommended surgery and other medical expenses per N.”
Grantham v. R. G. Barry Corp., 491 S.E.2d 678 (N.C. Ct. App. 1997). · cites it 16× “In an opinion and award filed 9 August 1995, the deputy commissioner denied plaintiffs claim on the ground she had not suffered a change in condition within the meaning of section 97-47.”
Sharpe v. Rex Healthcare, 633 S.E.2d 702 (N.C. Ct. App. 2006). · cites it 28× “N.C. Gen.Stat. § 97-47. 4. Plaintiff failed to file a Form 18M, or otherwise make a claim, for additional medical compensation within two years of the employer's last payment of medical or indemnity compensation.”
Lewis v. Craven Reg'l Med. Ctr., 518 S.E.2d 1 (N.C. Ct. App. 1999). · cites it 16× “On 14 May 1992, Plaintiff asserted that his level of pain had increased, and sought additional compensation from Defendants pursuant to N.C. Gen.Stat. § 97-47, because of his alleged changed condition.”
Young v. Hickory Bus. Furniture, 527 S.E.2d 344 (N.C. Ct. App. 2000). · cites it 26× “" The Commission concluded that plaintiff met her burden of proof "when her physicians testify that the cause `could or might' have likely produced the effect.”
Meares v. Dana Corp., 666 S.E.2d 819 (N.C. Ct. App. 2008). · cites it 12× “Whether or not “a change of condition pursuant to N.C. Gen. Stat. § 97-47 [has occurred] is a question of law, and thus, is subject to de novo review.”
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