Khan, Irfan

Following a death claim Findings and Award issued 12/13/2021 in favor of the deceased employee's dependents, the defendant paid the award itself on 3/16/2022 (after reconsideration was denied 3/7/2022) but failed to pay the interest due under Labor Code section 5800 until 6/13/2023. The WCJ awarded a 25% penalty under section 5814 for the unreasonable ~15-month delay in paying interest, plus attorney's fees under section 5814.5, but denied sanctions under section 5813 and an additional penalty under section 4650(d). Applicants petitioned for reconsideration, arguing the penalty should apply to the entire award, and that section 4650(d) and 5813 sanctions should have been awarded. The Board adopted and incorporated the WCJ's Report and Opinion and denied reconsideration, holding the 25% penalty correctly applied only to the delayed interest, the 4650(d) penalty was subsumed within the 5814 penalty per section 5814(d), and no evidence supported sanctions.