Vermont Statutes Annotated

Vt. Stat. Ann. tit. 21, § 651 (2026)

✓ current as of May 2026

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(Cite as: 21 V.S.A. § 651)

§ 651. Voluntary payments

Payments made by an employer or his or her insurer to an injured worker during the period of his or her disability, or to his or her dependents, which, by the provisions of this chapter, were not due and payable when made, may, subject to the approval of the Commissioner, be deducted from the amount to be paid as compensation. (Amended 1977, No. 182 (Adj. Sess.), § 14, eff. May 3, 1978; 1981, No. 165 (Adj. Sess.), § 1.)

Notes of Decisions

Cited in 3 cases, 1982–2016 · leading case: Bishop v. Town of Barre, 442 A.2d 50 (Vt. 1982).

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Bishop v. Town of Barre, 442 A.2d 50 (Vt. 1982). “” 21 V.S.A. § 651. Thus, we affirm the Commissioner’s decision deducting the amount of overpaid temporary benefits from the permanent award.”

Sharon Conant v. Entergy Corp., 2016 VT 74 (Vt. 2016). · cites it 17× “She found that 21 V.S.A. §§ 651 and 693, read together, prohibit a claimant from being paid twice for the same benefit—once from the employer and once from its insurance carrier.”

Josef Knoff v. Josef Knoff Illuminating (Vt. 2011). “In addition to approving the carrier’s discontinuance of TTD, pursuant to 21 V.S.A. § 651, in light of her ruling, the Commissioner awarded the carrier a credit “against any future compensation” in the amount of $63,700 on account of the TTD benefits voluntarily advanced by the…”

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