287.470. Commission may review and change award.
Commission may review and change award.
287.470. Upon its own motion or upon the application of anyparty in interest on the ground of a change in condition, thecommission may at any time upon a rehearing after due notice tothe parties interested review any award and on such review maymake an award ending, diminishing or increasing the compensationpreviously awarded, subject to the maximum or minimum provided inthis chapter, and shall immediately send to the parties and theemployer's insurer a copy of the award. No such review shallaffect such award as regards any moneys paid.
(RSMo 1939 § 3730)Prior revision: 1929 § 3340
(1951) In order to obtain award on ground of change in condition, injured employee must show his condition has grown worse, not that it was always worse than commission found it to be. Brammer v. Binkley Mining Co. (A.), 244 S.W.2d 584.
(1963) Commission's finding that claimant, previously found to be totally and permanently disabled, who had become satisfactory full time employee of state hospital, had undergone substantial change in condition was supported by substantial evidence. Vandaveer v. Reinhart & Donovan Construction Co. (A.), 370 S.W.2d 156.
(1981) The Labor and Industrial Relations Commission does not have jurisdiction to reopen a workers' compensation award after payment period has ended. Yokel v. Beta Corp. (A.), 615 S.W.2d 78.
(1985) The term "at any time" as it appears in this section means before payment of the award or before the expiration of the time during which the award is to be paid, whichever is later. Holman v. Normandy Osteopathic Hospital (A.), 691 S.W.2d 360.