Oregon Revised Statutes

Or. Rev. Stat. § 656.295 (2026)

Board review of Administrative Law Judge orders; application of standards for evaluation of disability

✓ current as of May 2026
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      656.295 Board review of Administrative Law Judge orders; application of standards for evaluation of disability. (1) The request for review by the Workers’ Compensation Board of an order of an Administrative Law Judge need only state that the party requests a review of the order.

      (2) The requests for review shall be mailed to the board and copies of the request shall be mailed to all parties to the proceeding before the Administrative Law Judge.

      (3) When review has been requested, the record of such oral proceedings at the hearings before the Administrative Law Judge as may be necessary for purposes of the review shall be transcribed at the expense of the board. The original transcript shall be certified to be true, accurate and complete by the transcriber. A list of all exhibits received by the Administrative Law Judge shall be furnished to the parties in interest along with a copy of the transcribed record.

      (4) Notice of the review shall be given to the parties by mail. The board shall set a date for review as expeditiously as possible. Review shall be scheduled for a date not later than 90 days after receipt by the board of the request for review. Review shall not be postponed except in extraordinary circumstances beyond the control of the requesting party.

      (5) The review by the board shall be based upon the record submitted to it under subsection (3) of this section and such oral or written argument as it may receive. Evaluation of the worker’s disability by the board shall be as of the date of issuance of the reconsideration order pursuant to ORS 656.268. Any finding of fact regarding the worker’s impairment must be established by medical evidence that is supported by objective findings. If the board finds that the claim has been closed prematurely, the board shall issue an order rescinding the notice of closure. The board shall apply to the review of the claim such standards for the evaluation of disability as may be adopted by the Director of the Department of Consumer and Business Services pursuant to ORS 656.726. Nothing in this section shall be construed to prevent or limit the right of a worker, insurer or self-insured employer to present evidence to establish by a preponderance of the evidence that the standards adopted pursuant to ORS 656.726 for evaluation of the worker’s permanent disability were incorrectly applied in the reconsideration order pursuant to ORS 656.268. However, if the board determines that a case has been improperly, incompletely or otherwise insufficiently developed or heard by the Administrative Law Judge, it may remand the case to the Administrative Law Judge for further evidence taking, correction or other necessary action.

      (6) The board may affirm, reverse, modify or supplement the order of the Administrative Law Judge and make such disposition of the case as it determines to be appropriate. It shall make its decision within 30 days after the review.

      (7) The order of the board shall be filed and a copy thereof sent by mail to the director and to the parties.

      (8) An order of the board is final unless within 30 days after the date of mailing of copies of such order to the parties, one of the parties appeals to the Court of Appeals for judicial review pursuant to ORS 656.298. The order shall contain a statement explaining the rights of the parties under this subsection and ORS 656.298. [1965 c.285 §35a; 1977 c.804 §10; 1987 c.884 §12; 1990 c.2 §22; 1991 c.293 §1; 1999 c.313 §8]

Notes of Decisions
Cited in 168 cases (6 in the last 5 years), 1968–2025 · leading case: Haskell Corp. v. Filippi, 953 P.2d 396 (Or. Ct. App. 1998).
Haskell Corp. v. Filippi, 953 P.2d 396 (Or. Ct. App. 1998). · cites it 20× “NOTES [1] Although Wausau's petition for judicial review had already been filed when the Board withdrew its order on review, the Board retained plenary authority under ORS 656.”
Hopkins v. SAIF Corp., 245 P.3d 90 (Or. 2010). · cites it 4× “298(1) provides: “Within the time limit specified in ORS 656.295, any party affected by an order of the Workers’ Compensation Board * * * may request judicial review of the order by the Court of Appeals.”
Westfall v. Rust Int'l & Underwriters Adjusting Co., 840 P.2d 700 (Or. 1992). · cites it 6× “5 Pursuant to its authority under ORS 656.295, the Board reversed the referee’s decision.”
Armstrong v. Asten-Hill Co., 752 P.2d 312 (Or. Ct. App. 1988). · cites it 2× “289; ORS 656.295. 6 Although the referee’s opinion and order is not subject to our review, we note that she attempted to identify and state separately the issue, her findings of fact and her conclusions and the reasons therefor.”
Sw. Forest Indus. v. Anders, 701 P.2d 432 (Or. 1985). · cites it 8× “As we noted earlier, the employer acknowledged that under Modoc the Court of Appeals probably had properly dismissed.”
Shubert v. Blue Chips, 951 P.2d 172 (Or. Ct. App. 1997). · cites it 9× “' ORS 656.295(5). "* * * * * "The promulgation of a temporary rule does not automatically result in a worker receiving an impairment value.”
Taylor v. SAIF, 329 Or. App. 135 (Or. Ct. App. 2023). · cites it 6× “See ORS 656.295 (describing procedural steps).”
SAIF Corp. v. Fisher, 785 P.2d 1082 (Or. Ct. App. 1990). · cites it 4× “ORS 656.295. With one exception, there is nothing in ORS 656.”
Compton v. Weyerhaeuser Co., 724 P.2d 814 (Or. 1986). · cites it 5× “ORS 656.295(3) and (5). If the circuit court is permitted to consider evidence of events subsequent to the hearing, it no longer conducts a review, but itself becomes a hearing officer, without having the benefit of either the hearing officer’s or the Workmen’s Compensation…”
Drews v. EBI Companies, 795 P.2d 531 (Or. 1990). “ORS 656.295(8). 12 B. Applying the Statutory Scheme to This Case The 1984 hearing order allowed and opened an aggravation claim, reversing a denial by EBI.”
Bailey v. State Accident Ins. Fund Corp., 672 P.2d 333 (Or. 1983). · cites it 22× “Subsequently, but prior to the Board's issuance of an order, claimant retained an attorney and filed a motion based on ORS 656.295(5) to remand the case for the taking of further evidence, alleging that the case had been "incompletely or otherwise insufficiently developed"…”
Erck v. Brown Oldsmobile & EBI Companies, 815 P.2d 1251 (Or. 1991). · cites it 4× “The referee who presides over the hearing is required to issue an order deciding the matter within 30 days of the hearing. ORS 656.289(1).”
— Or. Rev. Stat. § 656.295(1) — 2 cases
Hopkins v. SAIF Corp., 245 P.3d 90 (Or. 2010). “298(1) provides: “Within the time limit specified in ORS 656.295, any party affected by an order of the Workers’ Compensation Board * * * may request judicial review of the order by the Court of Appeals.”
Schulz v. State Comp. Dep't, 448 P.2d 551 (Or. 1968).
— Or. Rev. Stat. § 656.295(2) — 9 cases
Weyerhaeuser Co. v. Miller, 760 P.2d 1317 (Or. 1988).
Kahl v. SAIF Corp., 738 P.2d 999 (Or. Ct. App. 1987).
Kelsey v. Drushella-Klohk NCE, 874 P.2d 1349 (Or. Ct. App. 1994).
Roseburg Forest Prods. v. Humbert, 158 P.3d 21 (Or. Ct. App. 2007).
Argonaut Ins. v. King, 666 P.2d 865 (Or. Ct. App. 1983).
— Or. Rev. Stat. § 656.295(3) — 7 cases
Compton v. Weyerhaeuser Co., 724 P.2d 814 (Or. 1986). “ORS 656.295(3) and (5). If the circuit court is permitted to consider evidence of events subsequent to the hearing, it no longer conducts a review, but itself becomes a hearing officer, without having the benefit of either the hearing officer’s or the Workmen’s Compensation…”
Brown v. State Accident Ins. Fund Corp., 625 P.2d 1351 (Or. Ct. App. 1981).
McGuire v. SAIF, 507 P.3d 317 (Or. Ct. App. 2022).
Knupp v. State Accident Ins. Fund Corp., 719 P.2d 42 (Or. Ct. App. 1986).
Topolic v. Saif Corp., 857 P.2d 152 (Or. Ct. App. 1993).
— Or. Rev. Stat. § 656.295(4) — 2 cases
Roseburg Forest Prods. v. Humbert, 158 P.3d 21 (Or. Ct. App. 2007).
Fred Meyer Stores, Inc. v. Ernst, 79 P.3d 387 (Or. Ct. App. 2003).
— Or. Rev. Stat. § 656.295(5) — 51 cases
Shubert v. Blue Chips, 951 P.2d 172 (Or. Ct. App. 1997). “' ORS 656.295(5). "* * * * * "The promulgation of a temporary rule does not automatically result in a worker receiving an impairment value.”
Bailey v. State Accident Ins. Fund Corp., 672 P.2d 333 (Or. 1983). “Subsequently, but prior to the Board's issuance of an order, claimant retained an attorney and filed a motion based on ORS 656.295(5) to remand the case for the taking of further evidence, alleging that the case had been "incompletely or otherwise insufficiently developed"…”
Compton v. Weyerhaeuser Co., 724 P.2d 814 (Or. 1986). “ORS 656.295(3) and (5). If the circuit court is permitted to consider evidence of events subsequent to the hearing, it no longer conducts a review, but itself becomes a hearing officer, without having the benefit of either the hearing officer’s or the Workmen’s Compensation…”
Coday v. Willamette Tug & Barge Co., 440 P.2d 224 (Or. 1968).
Marvin Wood Prods. v. Callow, 14 P.3d 686 (Or. Ct. App. 2000).
— Or. Rev. Stat. § 656.295(6) — 20 cases
Taylor v. SAIF, 329 Or. App. 135 (Or. Ct. App. 2023). “See ORS 656.295 (describing procedural steps).”
Armstrong v. Asten-Hill Co., 752 P.2d 312 (Or. Ct. App. 1988). “289; ORS 656.295. 6 Although the referee’s opinion and order is not subject to our review, we note that she attempted to identify and state separately the issue, her findings of fact and her conclusions and the reasons therefor.”
Hopkins v. SAIF Corp., 245 P.3d 90 (Or. 2010). “298(1) provides: “Within the time limit specified in ORS 656.295, any party affected by an order of the Workers’ Compensation Board * * * may request judicial review of the order by the Court of Appeals.”
Williams v. Saif Corp., 797 P.2d 1036 (Or. 1990).
Erck v. Brown Oldsmobile & EBI Companies, 815 P.2d 1251 (Or. 1991). “The referee who presides over the hearing is required to issue an order deciding the matter within 30 days of the hearing. ORS 656.289(1).”
— Or. Rev. Stat. § 656.295(7) — 1 case
Haskell Corp. v. Filippi, 953 P.2d 396 (Or. Ct. App. 1998). “NOTES [1] Although Wausau's petition for judicial review had already been filed when the Board withdrew its order on review, the Board retained plenary authority under ORS 656.”
— Or. Rev. Stat. § 656.295(8) — 34 cases
Haskell Corp. v. Filippi, 953 P.2d 396 (Or. Ct. App. 1998). “NOTES [1] Although Wausau's petition for judicial review had already been filed when the Board withdrew its order on review, the Board retained plenary authority under ORS 656.”
Sw. Forest Indus. v. Anders, 701 P.2d 432 (Or. 1985). “As we noted earlier, the employer acknowledged that under Modoc the Court of Appeals probably had properly dismissed.”
Drews v. EBI Companies, 795 P.2d 531 (Or. 1990). “ORS 656.295(8). 12 B. Applying the Statutory Scheme to This Case The 1984 hearing order allowed and opened an aggravation claim, reversing a denial by EBI.”
Volk v. Am. West Airlines, 899 P.2d 746 (Or. Ct. App. 1995).
Liberty Nw. Ins. Corp. v. Koitzsch, 964 P.2d 1071 (Or. Ct. App. 1998).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.