Wyoming Statutes

Wyo. Stat. § 27-14-605 (2026)

Application for modification of benefits; time

✓ current as of May 2026

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limitation; grounds; termination of case; exceptions.

     (a) If a determination is made in favor of or on behalf of
an employee for any benefits under this act, an application may
be made to the division by any party within four (4) years from
the date of the last payment for additional benefits or for a
modification of the amount of benefits on the ground of increase
or decrease of incapacity due solely to the injury, or upon
grounds of mistake or fraud. The division may, upon the same
grounds and within the same time period, apply for modification
of medical and disability benefits to a hearing examiner or the
medical commission, as appropriate.
     (b) Any right to benefits shall be terminated and is no
longer under the jurisdiction of this act if a claim for any
benefit is not filed with the division within the four (4) year
limitation prescribed under subsection (a) of this section.

     (c) A claim for medical benefits which would otherwise be
terminated under subsection (b) of this section and barred under
W.S. 27-14-503(a) and (b) may be paid by the division if the
claimant:

          (i) Submits medical reports to the division
substantiating his claim;

          (ii) Proves by competent medical authority and to a
reasonable degree of medical certainty that the condition is
directly related to the original injury; and

          (iii) Submits to an examination by a health care
provider selected by the division and results of the examination
validate his claim.

Notes of Decisions

Cited in 86 cases, 1989–2018 · leading case: Carabajal v. State ex rel. Wyoming Workers' Saf. & Comp. Div., 119 P.3d 947 (Wyo. 2005).

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Carabajal v. State ex rel. Wyoming Workers' Saf. & Comp. Div., 119 P.3d 947 (Wyo. 2005). · cites it 30× “The Division allowed payment of medical benefits but denied TTD benefits The Division cited Wyo. Stat. Ann. § 27-14-605 (a) and (c) (Lex-isNexis 2001) as authority for its decision.”

Erhart v. Flint Eng'g & Constr., 939 P.2d 718 (Wyo. 1997). · cites it 42× “Whether Wyo. Stat. § 27-14-605 applies only when an injured employee has been awarded workers’ compensation benefits and whether it provides the exclusive means for modification of an administrative determination of a claim for workers’ compensation benefits.”

In Re Kaczmarek, 2009 WY 110 (Wyo. 2009). · cites it 26× “[¶ 6] The appellee submitted his medical bills to the Division and on October 31, 2006, the Division denied his claim for benefits finding that he failed to meet the requirements of Wyo. Stat. Ann. § 27-14-605 , which statute governs modification of benefits previously awarded.”

State ex rel. Dep't of Workforce Servs. v. Hall (In re Hall), 414 P.3d 622 (Wyo. 2018). · cites it 53× “Hall's application for temporary total disability (TTD) benefits, alleging that Wyo. Stat. Ann. § 27-14-605 (b) terminated Mr.”

Casper Oil Co. v. Evenson, 888 P.2d 221 (Wyo. 1995). · cites it 12× “Second Sbrgery Not Reasonably Contemplated Casper Oil also argues that Evenson’s case is subject to the “reopening” requirements of Wyo.Stat. § 27-14-605 (1991). The hearing examiner and the district court rejected this argument.”

Smith v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 965 P.2d 687 (Wyo. 1998). · cites it 48× “Only error relating to material facts, not agency procedure may be challenged by a motion under Wyo. Stat. § 27-14-605 (1994). See [ Matter of Worker's Compensation Claim of] Howton, 899 P.”

Jacobs v. State Ex Rel. Workers'comp. Div., 2009 WY 118 (Wyo. 2009). · cites it 13× “Did the OAH properly conclude that the appellant's claim for benefits relating to chronic abdominal pain was barred under the doctrine of collateral estoppel? 2.”

Worker's Comp. Claim of Newman v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2002 WY 91 (Wyo. 2002). · cites it 4× “The statutory language of the Wyoming Workers' Compensation Act confers finality on the benefits paid to the employee through uncontested determinations, subject to the exceptions found in Wyo. Stat. Ann. § 27-14-605 . The statutory language, however, does not guarantee a…”

Claim of Shaffer v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 960 P.2d 504 (Wyo. 1998). · cites it 14× “Section 27-14-605 The claimant contends that the hearing examiner erred when it refused to allow him to reopen his case.”

Kebschull v. State ex rel. Dep't of Workforce Servs., Workers' Comp. Div., 399 P.3d 1249 (Wyo. 2017). · cites it 25× “He claim's that he should receive such benefits pursuant to Wyo. Stat. Ann. § 27-14-605 (a) (LexisNexis 2017) and the second com-pensable injury rule.”

David v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2007 WY 22 (Wyo. 2007). · cites it 11× “In his disclosure statement, David countered that Wyo. Stat. Ann. § 27-14-601 (b) did not give the Division the authority to terminate benefits and, since benefits had been awarded, the burden was on the Division to seek modification pursuant to Wyo.”

State ex rel. Wyoming Workers' Saf. & Comp. Div. v. Kaczmarek, 215 P.3d 277 (Wyo. 2009). · cites it 22× “2 Both the statute and the second compensable injury rule govern claims for benefits following a compensable injury; however, each applies in different circumstances and carries a distinct burden of proof.”

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— Wyo. Stat. § 27-14-605(2) — 3 cases

State ex rel. Wyoming Workers' Saf. & Comp. Div. v. Henriksen, 21 P.3d 1185 (Wyo. 2001).

Worker's Comp. Claim of Glaze v. State ex rel. Wyoming Workers' Saf. & Comp. Div., 214 P.3d 228 (Wyo. 2009).

Osenbaugh v. State ex rel. Wyoming Workers' Saf. & Comp. Div., 10 P.3d 544 (Wyo. 2000).

— Wyo. Stat. § 27-14-605(a) — 43 cases

Erhart v. Flint Eng'g & Constr., 939 P.2d 718 (Wyo. 1997). “Whether Wyo. Stat. § 27-14-605 applies only when an injured employee has been awarded workers’ compensation benefits and whether it provides the exclusive means for modification of an administrative determination of a claim for workers’ compensation benefits.”

Smith v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 965 P.2d 687 (Wyo. 1998). “Only error relating to material facts, not agency procedure may be challenged by a motion under Wyo. Stat. § 27-14-605 (1994). See [ Matter of Worker's Compensation Claim of] Howton, 899 P.”

Claim of Shaffer v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 960 P.2d 504 (Wyo. 1998). “Section 27-14-605 The claimant contends that the hearing examiner erred when it refused to allow him to reopen his case.”

Worker's Comp. Claim of Forni v. Pathfinder Mines, 834 P.2d 688 (Wyo. 1992).

David v. State Ex Rel. Wyoming Workers' Saf. & Comp. Div., 2007 WY 22 (Wyo. 2007). “In his disclosure statement, David countered that Wyo. Stat. Ann. § 27-14-601 (b) did not give the Division the authority to terminate benefits and, since benefits had been awarded, the burden was on the Division to seek modification pursuant to Wyo.”

— Wyo. Stat. § 27-14-605(b) — 2 cases

State ex rel. Dep't of Workforce Servs. v. Hall (In re Hall), 414 P.3d 622 (Wyo. 2018). “Hall's application for temporary total disability (TTD) benefits, alleging that Wyo. Stat. Ann. § 27-14-605 (b) terminated Mr.”

Carabajal v. State ex rel. Wyoming Workers' Saf. & Comp. Div., 119 P.3d 947 (Wyo. 2005). “The Division allowed payment of medical benefits but denied TTD benefits The Division cited Wyo. Stat. Ann. § 27-14-605 (a) and (c) (Lex-isNexis 2001) as authority for its decision.”

— Wyo. Stat. § 27-14-605(c) — 4 cases

Stockdale v. Transystems Servs., Inc., 908 P.2d 980 (Wyo. 1995).

State ex rel. Wyoming Workers' Comp. Div. v. Halstead, 795 P.2d 760 (Wyo. 1990).

— Wyo. Stat. § 27-14-605(e)(ii) — 1 case

Walsh v. Holly Sugar Corp., 931 P.2d 241 (Wyo. 1997).

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