Tennessee Code Annotated
Tenn. Code Ann. § 50-6-203 (2026)
Limitation of time, claims and actions
✓ current as of May 2026
- (a) No request for a hearing by a workers' compensation judge under this chapter shall be filed with the court of workers' compensation claims, other than a request for settlement approval, until a workers' compensation mediator has issued a dispute certification notice certifying issues in dispute for hearing before a workers' compensation judge.
- (b)
- (1) In instances when the employer has not paid workers' compensation benefits to or on behalf of the employee, the right to compensation under this chapter shall be forever barred, unless the notice required by § 50-6-201 is given to the employer and a petition for benefit determination is filed with the bureau on a form prescribed by the administrator within one (1) year after the accident resulting in injury.
- (2) In instances when the employer has voluntarily paid workers' compensation benefits, within one (1) year following the accident resulting in injury, the right to compensation is forever barred, unless a petition for benefit determination is filed with the bureau on a form prescribed by the administrator within one (1) year from the latter of the date of the last authorized treatment or the time the employer ceased to make payments of compensation to or on behalf of the employee.
- (c) For purposes of this section, the issuing date of the last payment of compensation by the employer, not the date of its receipt, shall constitute the time the employer ceased making payments and an employer or its insurer shall provide the date on request.
- (d) In case of physical or mental incapacity, other than minority, of the injured person or the injured person's dependents to perform or cause to be performed any action required within the time specified in this section, then the period of limitation in the case shall be extended for one (1) year from the date when the incapacity ceases.
- (e)
- (1) Unless a claim for death benefits is settled or voluntarily paid, the dependent or dependents of a deceased employee shall file a petition for benefit determination on a form prescribed by the administrator within one (1) year after the date of the employee's death.
- (2) In the event the deceased employee was a native of a foreign country and leaves no known dependent or dependents within the United States, it shall be the duty of the administrator to give written notice forthwith of the death to the duly accredited consular officer of the country of which the beneficiaries are citizens.
- (f) If the employee fails to appear and participate in alternative dispute resolution as scheduled by the bureau, a workers' compensation judge shall have the authority to dismiss the employee's claim by sending a copy of the order of dismissal by certified mail with return receipt requested to the employee's last known address. The order of dismissal for failure to participate in alternative dispute resolution shall become final and the claim shall be forever barred, unless the employee contacts the bureau to schedule mediation and attends mediation within sixty (60) days after the date on which the workers' compensation judge enters the order of dismissal. If the employee complies with the requirements of this subsection (f) within the timeframe provided, the workers' compensation judge shall rescind the order dismissing the employee's claim for failure to participate in alternative dispute resolution.
- (g) Proceedings to obtain a judgment in the case of the failure of the employer for thirty (30) days to pay any compensation due under any settlement or determination shall be filed within one (1) year after the default.
- (h) In any case where an employer has paid permanent partial disability benefits to an employee in an attempt to settle a claim for workers' compensation benefits but the employee and employer have not entered into a settlement agreement that has been approved by a workers' compensation judge, the statute of limitations for filing a claim to recover workers' compensation benefits pursuant to this chapter shall be extended for two (2) years from the date the last payment of permanent partial disability benefits was made to the employee.
Acts 1919, ch. 123, § 24; Shan. Supp., § 3608a173; Code 1932, § 6874; Acts 1947, ch. 139, § 4; C. Supp. 1950, § 6874; impl. am. Acts 1980, ch. 534, § 1; T.C.A. (orig. ed.), § 50-1003; Acts 1996, ch. 944, § 13; 1998, ch. 1024, §§ 1, 2; 1999, ch. 520, § 41; 2004, ch. 962, § 14; 2005, ch. 390, §§ 5, 6; 2008, ch. 1183, § 10; 2013, ch. 282, § 1; 2013, ch. 289, §§ 31 - 34; 2015, ch. 341, §§ 4, 15.
Notes of Decisions
Cited in 142
cases (53 in the last 5 years), 1983–2026 · leading case: Lon Cloyd v. Hartco Flooring Co., 274 S.W.3d 638 (Tenn. 2008).
Lon Cloyd v. Hartco Flooring Co., 274 S.W.3d 638 (Tenn. 2008). “Tenn. Code Ann. § 50-6-203 (a) (1999) (emphasis added).”
Lacey Chapman v. Davita, Inc., 380 S.W.3d 710 (Tenn. 2012). “The benefit review conference process is statutorily described as: (a)(1) Notwithstanding any provisions of this chapter to the contrary, in case of a dispute over or failure to agree upon compensation under this chapter, between the employer and employée or the dependent or…”
Bldg. Materials Corp. v. Britt, 211 S.W.3d 706 (Tenn. 2007). “Upon due consideration, we hold that the claim in this matter is not time-barred by the statute of limitations set forth in Tennessee Code Annotated section 50-6-203 because the statute does not begin to run until the employee is prevented from working due to the employee’s…”
Lynch v. City of Jellico, 205 S.W.3d 384 (Tenn. 2006). “See Tenn.Code Ann. § 50-6-203(a) (“[n]o claim for compensation under [the] Workers’ Compensation Law .”
Gerdau Ameristeel, Inc. v. Steven Ratliff, 368 S.W.3d 503 (Tenn. 2012). “Tenn.Code Ann. § 50-6-203 (1999). In 2004, the General Assembly amended the statute to require an injured employee to request a benefit review conference.”
Dye v. Witco Corp., 216 S.W.3d 317 (Tenn. 2007). “In 2004, the General Assembly significantly revised Tennessee Code Annotated section 50-6-203. The statute of limitations for workers’ compensation cases is now found at Tennessee Code Annotated 50-6-203(g)(2) (2005).”
In Re: Est. of Martha M. Tanner, 295 S.W.3d 610 (Tenn. 2009). “§ 47-13-120 (b) (2001); Tenn. Code Ann. §§ 50-6-203 (b)(1)-(2), 50-6-203(f), 50-6-306(a) (2008); Tenn.”
William H. Mansell v. Bridgestone Firestone North Am. Tire, LLC, 417 S.W.3d 393 (Tenn. 2013). “2012) (“The use of the word ‘shall’ in sections 50-6-203(a) and 50-6-225(a)(l) clearly indicates the legislature’s intention that exhaustion of the benefit review conference process is a mandatory prerequisite to filing a cause of action.”
Davidson v. Lewis Bros. Bakery, 227 S.W.3d 17 (Tenn. 2007). “On March 15, 2005, the Fund answered, asserting that it was not liable to Employee because the one-year statute of limitation had expired pursuant to Tennessee Code Annotated section 50-6-203(b)(1) (1999). Further, the Fund ar *19 gued in a pre-trial brief that Tennessee Code…”
Walter Word v. Metro Air Servs., Inc., 377 S.W.3d 671 (Tenn. 2012). “n law allows for either party to file suit — and in potentially different venues: In the event the parties are unable to reach an agreement at the benefit review conference as to all issues related to the claim or the benefit review conference process is otherwise exhausted…”
Christopher Furlough v. Spherion Atl. Workforce, LLC, 397 S.W.3d 114 (Tenn. 2013). “” Tenn.Code Ann. § 50-6-203(a)(l) (2008); see also Word, 377 S.”
Carpenter v. State, 838 S.W.2d 525 (Tenn. 1992). “The only issue we address in this workers’ compensation case is whether incapacitation pay and medical expenses paid by the federal government and Medicaid benefits paid by the state government are “voluntary payments of compensation”, which toll the one-year statute of…”
Tenn. Code Ann. § 50-6-203(a): 14 cases
Lynch v. City of Jellico, 205 S.W.3d 384 (Tenn. 2006). “See Tenn.Code Ann. § 50-6-203(a) (“[n]o claim for compensation under [the] Workers’ Compensation Law .”
Lacey Chapman v. Davita, Inc., 380 S.W.3d 710 (Tenn. 2012). “The benefit review conference process is statutorily described as: (a)(1) Notwithstanding any provisions of this chapter to the contrary, in case of a dispute over or failure to agree upon compensation under this chapter, between the employer and employée or the dependent or…”
Dye v. Witco Corp., 216 S.W.3d 317 (Tenn. 2007). “In 2004, the General Assembly significantly revised Tennessee Code Annotated section 50-6-203. The statute of limitations for workers’ compensation cases is now found at Tennessee Code Annotated 50-6-203(g)(2) (2005).”
Lon Cloyd v. Hartco Flooring Co., 274 S.W.3d 638 (Tenn. 2008). “Tenn. Code Ann. § 50-6-203 (a) (1999) (emphasis added).”
William H. Mansell v. Bridgestone Firestone North Am. Tire, LLC, 417 S.W.3d 393 (Tenn. 2013). “2012) (“The use of the word ‘shall’ in sections 50-6-203(a) and 50-6-225(a)(l) clearly indicates the legislature’s intention that exhaustion of the benefit review conference process is a mandatory prerequisite to filing a cause of action.”
Tenn. Code Ann. § 50-6-203(a)(l): 3 cases
William H. Mansell v. Bridgestone Firestone North Am. Tire, LLC, 417 S.W.3d 393 (Tenn. 2013). “2012) (“The use of the word ‘shall’ in sections 50-6-203(a) and 50-6-225(a)(l) clearly indicates the legislature’s intention that exhaustion of the benefit review conference process is a mandatory prerequisite to filing a cause of action.”
Christopher Furlough v. Spherion Atl. Workforce, LLC, 397 S.W.3d 114 (Tenn. 2013). “” Tenn.Code Ann. § 50-6-203(a)(l) (2008); see also Word, 377 S.”
Walter Word v. Metro Air Servs., Inc., 377 S.W.3d 671 (Tenn. 2012). “n law allows for either party to file suit — and in potentially different venues: In the event the parties are unable to reach an agreement at the benefit review conference as to all issues related to the claim or the benefit review conference process is otherwise exhausted…”
Tenn. Code Ann. § 50-6-203(b): 7 cases
Stitts, Vanessa v. ABB Powet Tech, 2017 TN WC 32 (Tenn. Ct. Work. Comp. Cl. 2017).
Crawford, Elsie v. Wal-Mart Assocs., Inc., 2021 TN WC App. 60 (Tenn. Work. Comp. App. Bd. 2021).
Bush, Amy v. Stones River Ctr./RHA Health Servs., 2019 TN WC 73 (Tenn. Ct. Work. Comp. Cl. 2019).
Sanders, Sherry v. Sevita Health d/b/a D&S Residential Servs., 2023 TN WC App. 35 (Tenn. Work. Comp. App. Bd. 2023).
Oldham, John v. Freeman Webb Co. Realtors d/b/a Sunnybrook, 2024 TN WC App. 41 (Tenn. Work. Comp. App. Bd. 2024).
Tenn. Code Ann. § 50-6-203(b)(1): 20 cases
Davidson v. Lewis Bros. Bakery, 227 S.W.3d 17 (Tenn. 2007). “On March 15, 2005, the Fund answered, asserting that it was not liable to Employee because the one-year statute of limitation had expired pursuant to Tennessee Code Annotated section 50-6-203(b)(1) (1999). Further, the Fund ar *19 gued in a pre-trial brief that Tennessee Code…”
Gerdau Ameristeel, Inc. v. Steven Ratliff, 368 S.W.3d 503 (Tenn. 2012). “Tenn.Code Ann. § 50-6-203 (1999). In 2004, the General Assembly amended the statute to require an injured employee to request a benefit review conference.”
Julie Geronimo v. Caterpillar Inc., 440 F. App'x 442 (6th Cir. 2011).
Ernstes, Arlene v. Printpack, Inc., 2023 TN WC App. 23 (Tenn. Work. Comp. App. Bd. 2023).
Kelso, Roxanna v. Five Star Food Serv., 2016 TN WC 99 (Tenn. Ct. Work. Comp. Cl. 2016).
Tenn. Code Ann. § 50-6-203(b)(2): 21 cases
Crawford, Elsie v. Wal-Mart Assocs., Inc., 2021 TN WC App. 60 (Tenn. Work. Comp. App. Bd. 2021).
Martin, Henry v. Kirby Bldg. Sys., LLC, 2026 TN WC App. 17 (Tenn. Work. Comp. App. Bd. 2026).
Taylor, Vincent v. Am. Tire Distributors, 2017 TN WC App. 46 (Tenn. Work. Comp. App. Bd. 2017).
Blank, Robert J. v. Estes Express Lines, 2021 TN WC 248 (Tenn. Ct. Work. Comp. Cl. 2021).
Craig, Devontay v. Shimmick Constr. Co., Inc., 2023 TN WC 80 (Tenn. Ct. Work. Comp. Cl. 2023).
Tenn. Code Ann. § 50-6-203(b)(2)(2020): 1 case
Bryant, Joshua v. Malco Theaters, Inc., 2021 TN WC 180 (Tenn. Ct. Work. Comp. Cl. 2021).
Tenn. Code Ann. § 50-6-203(b)(l): 4 cases
In Re: Est. of Martha M. Tanner, 295 S.W.3d 610 (Tenn. 2009). “§ 47-13-120 (b) (2001); Tenn. Code Ann. §§ 50-6-203 (b)(1)-(2), 50-6-203(f), 50-6-306(a) (2008); Tenn.”
Gerdau Ameristeel, Inc. v. Steven Ratliff, 368 S.W.3d 503 (Tenn. 2012). “Tenn.Code Ann. § 50-6-203 (1999). In 2004, the General Assembly amended the statute to require an injured employee to request a benefit review conference.”
Kelso, Roxanna v. Five Star Food Serv., 2016 TN WC App. 26 (Tenn. Work. Comp. App. Bd. 2016).
Raine, David v. White Castle, 2016 TN WC 292 (Tenn. Ct. Work. Comp. Cl. 2016).
Tenn. Code Ann. § 50-6-203(c): 4 cases
Vickers, Kimberly v. Amazon, 2019 TN WC 72 (Tenn. Ct. Work. Comp. Cl. 2019).
Moore, Terrence v. YRC, Inc., 2020 TN WC 34 (Tenn. Ct. Work. Comp. Cl. 2020).
Bryant, Joshua v. Malco Theaters, Inc., 2021 TN WC App. 70 (Tenn. Work. Comp. App. Bd. 2021).
Hopson, Cecilia v. Travelers Prop. Cas. Corp., 2022 TN WC 41 (Tenn. Ct. Work. Comp. Cl. 2022).
Tenn. Code Ann. § 50-6-203(d): 1 case
Swanson, Darold v. Facility Installation Serv., 2024 TN WC 29 (Tenn. Ct. Work. Comp. Cl. 2024).
Tenn. Code Ann. § 50-6-203(g)(2): 1 case
Bldg. Materials Corp. v. Britt, 211 S.W.3d 706 (Tenn. 2007). “Upon due consideration, we hold that the claim in this matter is not time-barred by the statute of limitations set forth in Tennessee Code Annotated section 50-6-203 because the statute does not begin to run until the employee is prevented from working due to the employee’s…”
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