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In Brown v. Decatur County Memorial Hospital, the plaintiff, a dentist, filed an Application for Adjustment of Claim for Provider Fee with the Indiana Worker's Compensation Board to recover the unpaid balance due for medical services provided to the employee. On August 9, 2007, the Court of Appeals of Indiana held that there is no provision in the Indiana Worker's Compensation Act or case law that provides for the payment of prejudgment interest for belated payments for services rendered under the Worker's Compensation Act.

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