American Airlines v. Hickman
In American Airlines v. Hickman, 2007 OK 59, 164 P.3d 146, the Oklahoma Supreme Court held that, even for an injury occurring prior to the 2005 amendment of 43(A), payment for authorized medical treatment was not required, and the provision of "authorized medical treatment was enough to toll the statute of limitations."
"'A statute-of-limitation issue ordinarily presents a mixed question of fact and law.'"
That is to say:
. . . If supported by any competent evidence, the panel's factual determinations relative to the statutory time bar will not be independently reviewed. However, application of the time bar provided in 43 of title 85 to render a claim not remediable is a conclusion of law and subject to de novo review by this Court. See, Sneed, 1999 OK 84, P9, 991 P.2d at 1004. Id.