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

N.C. Gen. Stat. § 97-86.2 (2026)

Interest on awards after hearing

✓ current as of July 2026
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In any workers' compensation case in which an order is issued either granting or denying an award to the employee and where there is an appeal resulting in an ultimate award to the employee, the insurance carrier or employer shall pay interest on the final award or unpaid portion thereof from the date of the initial hearing on the claim, until paid at the legal rate of interest provided in G.S. 24-1. If interest is paid it shall not be a part of, or in any way increase attorneys' fees, but shall be paid in full to the claimant. (1981, c. 242, s. 1; 1985, c. 598; 1987, c. 729, s. 16.)

 

Notes of Decisions
Cited in 27 cases, 1983–2015 · leading case: Est. of Apple Ex Rel. Apple v. Com. Courier Express, Inc., 607 S.E.2d 14 (N.C. Ct. App. 2005).
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Est. of Apple Ex Rel. Apple v. Com. Courier Express, Inc., 607 S.E.2d 14 (N.C. Ct. App. 2005). · cites it 8× “Plaintiff also contends it has suffered an injury in fact because it has a pecuniary interest in the payment of interest on medical compensation under N.C. Gen.Stat. § 97-86.2. However, under N.”
Sprinkle v. Lilly Indus., Inc., 668 S.E.2d 378 (N.C. Ct. App. 2008). · cites it 35× “Specifically, the statute states: In any workers’ compensation case in which an order is issued either granting or denying an award to the employee and where there is an appeal resulting in an ultimate award to the employee, the insurance carrier or employer shall pay interest…”
Puckett v. Norandal USA, Inc., 710 S.E.2d 356 (N.C. Ct. App. 2011). · cites it 32× “In support of this motion, Plaintiff cited N.C. Gen. Stat. § 97-86.2 , which provides, in pertinent part, that: In any workers’ compensation case in which an order is issued either granting or denying an award to the employee and where there is an appeal resulting in an ultimate…”
Chandler v. Atl. Scrap & Processing, 720 S.E.2d 745 (N.C. Ct. App. 2011). · cites it 15× “On 20 November 2009, plaintiff moved the Commission to award interest on the past due attendant care pursuant to N.C. Gen. Stat. § 97-86.2 (2009), to be paid by defendants directly to Mr.”
Childress v. Trion, Inc., 481 S.E.2d 697 (N.C. Ct. App. 1997). · cites it 7× “Defendants contends that interest on an “award” pursuant to G.S. 97-86.2 is limited to compensation due an employee and does not include medical expenses.”
Boylan v. Verizon Wireless, 736 S.E.2d 773 (N.C. Ct. App. 2012). · cites it 18× “2d 541 (1997); N.C. Gen. Stat. §97-86.2 However, absent a compensatory purpose, an award of interest under N.”
Henke v. First Colony Builders, Inc., 486 S.E.2d 431 (N.C. Ct. App. 1997). · cites it 12× “*704 After the Full Commission refused to grant plaintiff any relief regarding the payment of attorney’s fees based on one-third (V3) of her ongoing disability compensation, on 22 June 1995, plaintiff filed a motion to declare section 97-86.2 of the North Carolina General…”
Cox v. City of Winston-Salem, 578 S.E.2d 669 (N.C. Ct. App. 2003). · cites it 4× “Plaintiff finally claims the Commission erred in failing to allow his motion for interest on the award to plaintiff from the date of the original hearing pursuant to N.C. Gen. Stat. § 97-86.2 (2001). Defendant does not dispute this contention.”
Glenn v. McDonald's, 425 S.E.2d 727 (N.C. Ct. App. 1993). · cites it 4× “…to pay interest on all sums which should have been paid since the parties entered into the settlement agreement. N.C.Gen.Stat. § 97-86.2.”
Christopher R. Brown, D.D.S., Inc. v. Decatur Cnty. Mem'l Hosp., 892 N.E.2d 642 (Ind. 2008). · cites it 2× “Law § 13 -g(1) (McKinney 2005); N.C. Gen.Stat. § 97-86.2 (2007); Okla. Stat.”
Myers v. Dep't of Crime Control & Pub. Saf., 313 S.E.2d 276 (N.C. Ct. App. 1984). · cites it 6× “1983) 2 , and the enactment of N.C. Gen. Stat. § 97-86.2 (Supp. 1983) 3 show a definite legislative intent to broaden a claimant’s right to recover post-judgment interest, and (b) the party having to pay the award may abuse the process by making frivolous appeals when the…”
Jordan v. Cent. Piedmont Cmty. Coll., 476 S.E.2d 410 (N.C. Ct. App. 1996). · cites it 2× “After receiving the Full Commission’s Opinion and Award, plaintiff’s attorney filed a motion for interest on the award, pursuant to N.C. Gen. Stat. § 97-86.2 and for attorney fees under N.”
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