In Geiger v. Workmen's Compensation Appeal Board (Circle Fine Art Corp.), 654 A.2d 19 (Pa. Cmwlth. 1994), the Court stated that while the term "prompt investigation" is not defined in the Act, the employer is required to take some affirmative action to investigate claim within a reasonable time period. Id. at 21. In Armstrong v. Workers' Compensation Appeal Board (Haines & Kibblehouse, Inc.), 931 A.2d 827 (Pa. Cmwlth. 2007), the Court held that the creation of the NTCP was to afford employers more than twenty-one days in order to investigate a claim and determine its position with regard to the claim's compensability. The Court upheld an award of penalties where the employer failed to investigate the claimant's injury prior to receiving a statement from the claimant's doctor, five months after the injury, that claimant's injury was work-related. In that case, the Court recognized that Section 406.1 requires an employer to take some affirmative action to investigate a reported work injury within a reasonable time period.