The CRB has taken that view in the private-sector setting. See Capitol Hill Hosp. v. District of Columbia Dep't of Emp't Servs. , 726 A.2d 682, 686 (D.C. 1999) (deferring to CRB's conclusion that claimant can bring claim for permanent partial disability award under compensation schedule despite having previously obtained temporary benefits; court states that it would "make[ ] no sense" to interpret statutory time limits to make claimant ineligible to obtain permanent disability benefits before claimant became eligible for them). I realize that the private-sector workers' compensation provisions vary in some respects from the public-sector provisions, so that a holding from one context does not necessarily carry over to the other.
WMATA did not reach the different question presented in this case, whether a request for modification is the sole avenue for relief available to a claimant who develops new or aggravated injuries caused by a covered work accident with respect to which a claim for compensation has already been adjudicated, but for a different injury. The only other case to consider a subsequent claim following the same accident at work, and the one we find most instructive, is Capitol Hill Hosp. v. D.C. Dep't of Employment Servs., 726 A.2d 682 (D.C. 1999). There, after the claimant had suffered an injury and been awarded temporary total disability benefits, it was determined that the injury resulted in a permanent ten percent physical impairment, and the claimant sought compensation for the resulting loss.