Spangler v. WCAB (Ford)

In Spangler v. Workmen's Comp. Appeal Bd. (Ford), 145 Pa. Commw. 56, 602 A.2d 446, 448 (Pa. Cmwlth. 1992), penalties were imposed where the employer did not file an NCP until approximately 11 months after the claimant's injury. In upholding the penalty, the Court noted the employer's contest of the claim did not relieve it of its duty under Section 406.1(a) to promptly investigate the claimant's injury.