You fill out DOL Form LS-570 — the Notice of Controversion of Right to Compensation — by entering the injured worker’s identifying information, the employer and carrier details, the date of injury, the date you stopped or refused payment, and the specific factual and legal grounds for denying benefits, then filing it with the U.S. Department of Labor’s Office of Workers’ Compensation Programs (OWCP) district office within 14 days of learning of the injury or death. This single one-page form is the controlling document an employer or insurance carrier must use under Section 14(d) of the Longshore and Harbor Workers’ Compensation Act to formally dispute a claim, and a missed deadline triggers an automatic 10% additional compensation penalty under Section 14(e) of the Act.
The problem LS-570 addresses is simple to describe but hard to live with. The Longshore Act presumes that an injured maritime worker is entitled to compensation the moment the employer learns of a disability, and payment must start on the 14th day after the employer’s knowledge. If the employer or carrier wants to stop the clock and refuse payment, it must speak through this exact form. Filing the form late, leaving boxes blank, or stating vague reasons can cost the employer thousands of dollars in penalties, attorney fees under Section 28, and even contempt sanctions from an administrative law judge.
According to the DOL’s most recent LHWCA statistics, roughly 26,000 lost-time injuries are reported to OWCP each year, and carriers file controversions in close to one-third of those cases. That makes LS-570 one of the most heavily used dispute forms in the federal workers’ compensation system.
Here is what you will learn in this guide:
- 📝 How to complete every line of LS-570 without triggering a Section 14(e) penalty
- ⚖️ The exact statutory and regulatory deadlines under 33 U.S.C. § 914 and 20 C.F.R. § 702.251
- 🛡️ Defense strategies for Defense Base Act, OCSLA, and Nonappropriated Fund extensions
- 🚫 The 7 most common filing mistakes carriers make and the consequences of each
- 💼 Three real-world named scenarios showing claimant, employer, and attorney perspectives
What Form LS-570 Is and Why It Exists
Form LS-570, titled Notice of Controversion of Right to Compensation, is the official U.S. Department of Labor document an employer or insurance carrier files to tell the Office of Workers’ Compensation Programs that it is denying or stopping benefits in a longshore claim. The form lives inside the broader LHWCA forms library maintained by the Division of Longshore and Harbor Workers’ Compensation (DLHWC). The plain-English purpose is to put the agency, the worker, and the worker’s attorney on notice that the carrier is disputing the claim and to state why.
The consequence of not filing the form when you intend to dispute a claim is severe. Under Section 14(d) of the LHWCA, the employer must either start paying compensation by the 14th day after it learns of the injury or file LS-570. If neither happens, Section 14(e) tacks a 10% penalty onto every late dollar, and that penalty is not dischargeable in bankruptcy and not reimbursable from the Special Fund.
Consider Maria Alvarez, a crane signaler at the Port of Los Angeles who tears her rotator cuff on March 1. Her employer’s carrier learns about the injury on March 3 but believes she was horsing around. The carrier has until March 17 to either pay temporary total disability or file LS-570 explaining the willful intention to injure defense under Section 3(c). If the carrier waits until March 25, Maria automatically gains a 10% penalty on every weekly check the administrative law judge later orders.
A common misconception is that LS-570 is a “denial letter” the carrier can write in any format. It is not. The DOL requires the official form, and a letter, email, or fax in narrative form does not satisfy the controversion duty under 20 C.F.R. § 702.251.
Statutory Authority Behind LS-570
The form draws its legal force from three layers of authority. First, the LHWCA itself at 33 U.S.C. § 914(d) creates the duty to controvert. Second, 20 C.F.R. Part 702 gives the procedural rules. Third, the DLHWC Procedure Manual gives line-by-line claims-examiner guidance.
The consequence of confusing these layers is real. A carrier that relies only on the statute may miss the regulatory requirement that the form be served on the claimant by mail the same day it is filed, as required by 20 C.F.R. § 702.252. Service failure is itself grounds for an Order to Show Cause and 10% penalty.
For example, claims examiner James O’Connor at the Jacksonville District Office regularly issues 14(e) penalty assessments when carriers file LS-570 timely but forget to mail a copy to the worker. The misconception that “filing equals service” has cost carriers tens of thousands in penalties.
Which Programs Use LS-570
LS-570 is the controversion form for every program administered by DLHWC, not just traditional longshore claims. The same form covers the Defense Base Act for overseas contractor injuries, the Outer Continental Shelf Lands Act for offshore oil and gas workers, the Nonappropriated Fund Instrumentalities Act for military post-exchange employees, and the District of Columbia Workmen’s Compensation Act for pre-1982 D.C. injuries.
The consequence of using the wrong form on the wrong program is rejection. A carrier that files an LS-207 (Notice of Final Payment) when it meant to controvert will see the OWCP treat the case as accepted and demand back-payment with penalties.
A real example: a defense contractor’s carrier in Kabul handling a TPA claim for translator Hamid Khan filed an internal denial memo instead of LS-570. The OWCP Jacksonville office, which handles all DBA claims, treated the silence as nonpayment and assessed a 14(e) penalty plus attorney fees under Section 28(a).
When You Must File LS-570 and the 14-Day Rule
You must file LS-570 within 14 calendar days after the employer first has knowledge of the injury or death, as fixed by 33 U.S.C. § 914(d). The clock does not start when the carrier learns of the claim. It starts when any supervisor, manager, or owner of the employer learns the worker is hurt and unable to work. Knowledge is imputed broadly, and courts construe it in the worker’s favor under Director, OWCP v. Newport News Shipbuilding.
The consequence of treating “knowledge” narrowly is a guaranteed penalty. Carriers who argue that only the claims department’s knowledge counts lose this argument almost every time at the Benefits Review Board.
Take the example of David Chen, a pile-driver foreman in Seattle who tells his crew supervisor on May 1 that his back is “killing him.” The supervisor never reports it. Chen stops work on May 20, and the carrier learns on May 22. The 14-day clock began on May 1, not May 22, because the supervisor’s knowledge is the employer’s knowledge. The misconception that “the carrier needs to be told” has been rejected repeatedly by the Fourth Circuit and the Fifth Circuit.
Counting the 14 Days Correctly
The 14 days are calendar days, not business days, and there is no weekend or holiday extension. 20 C.F.R. § 702.224 governs time computation. Day 1 is the day after knowledge attaches.
The consequence of miscounting is automatic. If day 14 falls on a Sunday and the carrier files Monday, the filing is late unless Monday is a federal holiday immediately following the weekend.
For example, if injury knowledge attaches on Friday, July 4, 2025, day 14 is Friday, July 18, 2025. Filing on Saturday, July 19, blows the deadline. Internal compliance officer Priya Patel of a Houston OCSLA carrier built a calendaring rule that always uses day 12 as the internal target to leave a buffer.
Subsequent Controversions and Suspension of Payments
LS-570 is not just for the initial denial. A carrier may also file the form to controvert a new period of disability, a new body part, a request for surgery, or a death benefit claim that arises later. This is sometimes called a “rolling” or “issue-specific” controversion under 20 C.F.R. § 702.251.
The consequence of failing to file a subsequent LS-570 when stopping checks is that the suspension itself becomes an unauthorized termination. The carrier must also file LS-208 Notice of Payment Suspension when stopping voluntary payments.
A real example involves Renee Boudreaux, an offshore galley hand. After two years of voluntary payments, the carrier received an IME report saying she had reached maximum medical improvement. The carrier stopped paying but filed only LS-208, not LS-570. The administrative law judge ordered reinstatement and a 14(e) penalty.
Line-by-Line Walkthrough of LS-570
The form contains roughly 18 numbered fields plus a signature block, and every field matters. Below is each line with the plain-English meaning, the consequence of error, an example, and a misconception.
Field 1 — OWCP Case Number
You enter the seven-digit OWCP case number assigned when the worker filed LS-203 Employee’s Claim. If no number has issued yet, write “Pending” or leave blank and attach the LS-202 Employer’s First Report.
The consequence of guessing or making up a number is misrouting. The form lands in the wrong claim file and the deadline is treated as missed for the correct case. Carrier specialist Anita Rodriguez at a Norfolk shipyard once typed the wrong digit and triggered a $4,200 14(e) penalty.
A common misconception is that the case number is the carrier’s internal claim number. It is not. It is the federal docket number assigned by the district director.
Field 2 — Carrier File Number
You enter the carrier’s internal claim number here. This is for internal cross-reference only.
The consequence of leaving it blank is delayed adjuster contact, but it does not invalidate the form. Still, district offices flag blank fields and may issue a deficiency letter under 20 C.F.R. § 702.221.
For example, Liberty Mutual files thousands of LS-570s per year and uses an automated number that begins with the policy year. A deficient number triggers a 30-day cure window.
Field 3 — Name of Injured/Deceased Employee
Enter the legal first, middle, and last name as it appears on government identification. Match the spelling on LS-203.
The consequence of misspelling is a mismatch in the OWCP database that can delay processing by weeks. In a death claim, the field reads “Deceased Employee” and the survivor’s name goes in Field 4 only if the claim is for survivor benefits under Section 9.
A misconception worth flagging: nicknames like “Bob” for “Robert” cause a database mismatch. Always use the legal name.
Field 4 — Address of Employee/Survivor
Enter the worker’s current mailing address. The carrier must mail a copy of LS-570 to this address the same day it files with OWCP, per 20 C.F.R. § 702.252.
The consequence of an outdated address is failed service, which the Benefits Review Board treats as no service at all. Carriers should confirm address through the most recent wage statement or human-resources file.
For example, claimant Marcus Williams moved twice after his injury. The carrier mailed LS-570 to the address on the original LS-202. The ALJ ordered a 10% penalty for failed service.
Field 5 — Date of Injury or Death
Enter the exact calendar date the injury occurred or the date of death. For occupational disease claims, use the date of last exposure or the date of awareness under the Pillsbury discovery rule.
The consequence of an inaccurate date is loss of statute-of-limitations defenses. If the carrier writes a wrong date that is earlier than the true date, it may waive the Section 13 one-year filing defense.
Misconception: cumulative trauma claims have a single “date of injury.” They do not. They have a date of awareness, which is fact-specific and litigated heavily.
Field 6 — Employer Name and Address
Enter the legal entity name of the insured employer, not the parent corporation. Match the name listed on the LHWCA insurance policy declarations page.
The consequence of naming the wrong entity is coverage denial. The Special Fund may assume the claim if no covered employer is identified.
A real example: SSA Marine Terminals operates through dozens of subsidiaries. Filing in the name of the parent rather than the terminal LLC creates coverage gaps and litigation under Section 4.
Field 7 — Insurance Carrier Name and Address
Enter the authorized LHWCA carrier as listed on the DOL’s Authorized Insurance Carriers list. Self-insured employers list their authorization number from DOL’s self-insurance program.
The consequence of naming an unauthorized carrier is potentially personal liability for the employer’s officers under Section 38.
Misconception: a state workers’ compensation carrier covers longshore claims automatically. It does not. LHWCA coverage requires a separate authorization.
Field 8 — Date Employer First Had Knowledge
Enter the date any supervisor, manager, or HR officer first learned of the injury. This field is heavily scrutinized because it sets the 14-day clock.
The consequence of understating this date is that the worker can use the carrier’s own form against it under the admissions doctrine.
For example, supervisor knowledge admitted in Field 8 was the dispositive proof in a recent Fifth Circuit case where an employer tried to argue late notice under Section 12.
Field 9 — Date of First Payment of Compensation
If any payment was made before the controversion, enter the date. If no payment, write “None.”
The consequence of leaving this blank when payments were made is suggesting a de facto acceptance, which can waive defenses.
Misconception: salary continuation counts as compensation. Under Mijangos v. Avondale Shipyards, it does only if it is paid in lieu of compensation and noted as such.
Field 10 — Date of Suspension of Compensation
If the controversion is suspending an existing payment, enter the date payments stop. Combine this with LS-208.
The consequence of unilateral suspension without LS-570 plus LS-208 is automatic 14(e) liability and possible attorney-fee shifting under Section 28(b).
Field 11 — Reason for Controversion
This is the most important field on the form. State the factual and legal basis with specificity. Generic language like “claim not compensable” is rejected by most district offices.
The consequence of vagueness is a deficiency notice, a 30-day cure period, and possible de facto acceptance if the cure is not made.
Acceptable language reads like this: “Carrier controverts on the grounds that claimant’s injury did not arise out of and in the course of employment under 33 U.S.C. § 902(2). Specifically, claimant was on a personal errand off premises at the time of injury, defeating the going-and-coming rule presumption.”
Misconception: a carrier can list “all defenses” to preserve them. Federal regulations at 20 C.F.R. § 702.251 require a specific reason. “Boilerplate” defenses can be deemed waived.
Field 12 — Average Weekly Wage
If wage is disputed, list the carrier’s calculation under Section 10. If not disputed, list the agreed AWW.
The consequence of omitting AWW when contesting wage is treating the worker’s number as admitted. The Benefits Review Board has held in Wausau Insurance v. Director that silence on AWW equals concession.
Field 13 — Type of Disability Controverted
Check the appropriate box: Temporary Total, Temporary Partial, Permanent Total, Permanent Partial, Death, or Medical only. Multiple boxes may be checked.
The consequence of checking the wrong box is preserving the wrong defense. A carrier that checks only “Temporary Total” cannot later contest permanency without filing a fresh LS-570.
Field 14 — Medical Benefits Controverted
State whether Section 7 medical benefits are also being denied. Medical and indemnity controversions are independent.
The consequence of denying indemnity but staying silent on medical is continued liability for medical bills, including emergency-room charges that may exceed $50,000.
Fields 15–17 — Carrier Contact, Adjuster, and Phone
Enter the adjuster’s name, direct phone, and email. The OWCP claims examiner uses these for informal conferences under 20 C.F.R. § 702.311.
The consequence of stale contact information is a missed informal conference and possible default recommendation against the carrier.
Field 18 — Signature, Title, Date
The form must be signed by an authorized representative — the adjuster, attorney, or self-insured employer’s risk manager. Electronic signatures are accepted via the SEAPortal e-filing system.
The consequence of an unsigned form is rejection as if never filed. The 14-day clock keeps running, and the penalty attaches.
Three Real-World Filing Scenarios
The following named scenarios show how the form plays out in practice.
Scenario A — Disputed Course of Employment
| Filing Move by Carrier | Outcome for Claimant Sofia Reyes |
|---|---|
| Carrier files LS-570 on day 12 stating Reyes was on a lunch-break personal errand | OWCP schedules informal conference; benefits paused |
| Carrier waits until day 22 with same defense | 10% Section 14(e) penalty on every owed week, plus attorney fees |
| Carrier files LS-570 with vague “claim not compensable” language | District director issues deficiency; cure required in 30 days |
Scenario B — Defense Base Act Overseas Injury
| Carrier Action in Iraq Claim of Ahmed Hassan | Legal Consequence |
|---|---|
| Files LS-570 within 14 days citing zone-of-special-danger doctrine | Defense preserved; case proceeds to ALJ on merits |
| Files denial via internal email only | OWCP treats claim as accepted; carrier liable for full DBA benefits |
| Files LS-570 but fails to mail copy to Hassan’s stateside address | Service failure; 14(e) penalty assessed by Jacksonville District Office |
Scenario C — Suspension After IME
| Decision in Claim of Tyler Brooks | Effect on Benefits |
|---|---|
| Carrier files LS-570 plus LS-208 same day after IME | Suspension valid pending ALJ review |
| Carrier files only LS-208 | Suspension invalid; reinstatement plus 14(e) penalty |
| Carrier files LS-570 but adjuster signs without authority | Form rejected; clock continues |
Mistakes to Avoid When Filing LS-570
Below are the most common errors and the negative outcome each one produces.
- Missing the 14-day deadline. Triggers automatic 10% Section 14(e) penalty on every late dollar of compensation.
- Filing with OWCP but not serving the worker. Counts as no filing under 20 C.F.R. § 702.252 and produces full penalties.
- Using vague language in Field 11. Leads to a deficiency letter and risks waiver of unstated defenses.
- Listing the wrong employer entity. Creates coverage gaps and possible personal liability under Section 38.
- Forgetting to controvert medical benefits separately. Leaves the carrier liable for thousands in Section 7 medical bills.
- Failing to file a fresh LS-570 for new disability periods. Treats the suspension as unauthorized termination.
- Signing without authority. Voids the form and the deadline runs as if nothing was filed.
- Confusing salary continuation with compensation. Misstates Field 9 and may waive late-payment defenses.
- Using the wrong AWW or leaving Field 12 blank. Concedes wage rate under BRB precedent.
- Mailing to an outdated claimant address. Service is invalid and 14(e) penalty applies.
Do’s and Don’ts of Filing LS-570
Do’s
- Do calendar the 14-day deadline using day 12 as the internal target so you have a buffer before the statutory drop-dead date.
- Do state every legal and factual ground for denial in Field 11 with citation to 33 U.S.C. § 902 or other governing law because vagueness leads to waiver.
- Do mail a copy to the claimant the same day you file with OWCP because 20 C.F.R. § 702.252 treats service failure as no filing.
- Do use the SEAPortal e-filing system for date-stamped proof of submission to avoid lost-mail disputes.
- Do attach supporting documents like IME reports and surveillance summaries because the district director will weigh them at the informal conference.
Don’ts
- Don’t controvert with a letter, email, or fax in narrative form because only the official LS-570 satisfies Section 14(d).
- Don’t assume “carrier knowledge” starts the 14-day clock because the law uses employer knowledge, which is much broader.
- Don’t stop voluntary payments without filing both LS-570 and LS-208 on the same day.
- Don’t rely on boilerplate “all defenses preserved” language because federal regulations require specificity.
- Don’t sign without express authority from the carrier or self-insured employer because an unauthorized signature voids the form.
Pros and Cons of Filing LS-570
Pros
- Stops the 14-day clock and prevents automatic 10% Section 14(e) penalty exposure.
- Preserves defenses like statute of limitations under Section 13 and willful intent under Section 3(c).
- Triggers an informal conference at the district office where most cases settle without an ALJ hearing.
- Documents the carrier’s good-faith dispute and reduces exposure to attorney-fee shifting under Section 28(b).
- Forces the claimant to develop evidence and respond, narrowing the issues for any BRB appeal.
Cons
- Invites litigation because the worker will almost always retain counsel after a controversion.
- Generates attorney-fee exposure if the carrier loses any single issue under the Newport News Shipbuilding fee-shifting rule.
- Locks in the stated defenses because adding new defenses later requires either amendment or a fresh LS-570.
- Creates discovery obligations for the carrier including production of the claim file and adjuster notes.
- Risks bad-faith claims at state level for self-insured employers in jurisdictions like California and Texas.
Key Entities You Should Know
The longshore claims system has many moving parts, and LS-570 sits at the center of them. The Office of Workers’ Compensation Programs (OWCP) is the parent agency inside the U.S. Department of Labor that runs the longshore program. Its Division of Longshore and Harbor Workers’ Compensation (DLHWC) operates twelve district offices including New York, Norfolk, Jacksonville, New Orleans, Houston, Long Beach, San Francisco, Seattle, Honolulu, Boston, Baltimore, and Chicago.
The district director is the senior official in each office and oversees the claims examiners who first review LS-570 filings. When a case cannot be resolved informally, it transfers to the Office of Administrative Law Judges (OALJ). Appeals from OALJ go to the Benefits Review Board (BRB), and from there to the federal circuit court of appeals where the injury occurred.
The Special Fund created under Section 44 pays second-injury benefits and provides relief in narrow circumstances. The Solicitor of Labor represents the Director, OWCP, in litigation. Major LHWCA carriers include Liberty Mutual, Signal Mutual, AIG, and Zurich, all listed on the authorized carriers roster.
Court Rulings That Shape LS-570 Practice
Several court decisions affect how carriers fill out and defend LS-570 filings. In Director, OWCP v. Newport News Shipbuilding, 514 U.S. 122 (1995), the Supreme Court limited who counts as a “person adversely affected” for appeals, narrowing carrier standing in some disputes.
In Potomac Electric Power Co. v. Director, 449 U.S. 268 (1980), the Court resolved how scheduled and unscheduled permanent partial disabilities interact, which directly affects what a carrier should write in Field 13.
In Roberts v. Sea-Land Services, 566 U.S. 93 (2012), the Court interpreted the Section 6(c) cap on weekly compensation, fixing how Field 12 average weekly wage interacts with the maximum compensation rate. The 2026 maximum compensation rate is $1,798.61 per week per the DOL’s annual NAWW notice.
The Fifth Circuit in Ingalls Shipbuilding v. Director held that supervisor knowledge alone starts the 14-day clock, reinforcing the importance of accurate Field 8 entries. The Fourth Circuit in Newport News Shipbuilding v. Holiday confirmed that vague controversion language in Field 11 can waive defenses.
State Nuances and Concurrent Jurisdiction
Although LHWCA is a federal program, state workers’ compensation laws can run parallel under the Sun Ship concurrent-jurisdiction doctrine from Sun Ship, Inc. v. Pennsylvania, 447 U.S. 715 (1980). A worker may file in both forums, and the carrier may need to file LS-570 federally even while contesting at the state level.
In Louisiana, the Office of Workers’ Compensation Administration requires its own state-form denial in addition to LS-570. In Texas, an LHWCA-only injury still requires reporting under the Division of Workers’ Compensation if the carrier is also a Texas carrier. Failing to file dual denials in concurrent-jurisdiction states triggers state-law penalties on top of federal Section 14(e) penalties.
In Washington, the Department of Labor & Industries handles state claims, and a worker on the Seattle waterfront often pursues both. The carrier’s federal LS-570 must be coordinated with the state denial to avoid inconsistent positions that can be used as admissions.
FAQs
Is LS-570 the only way to formally deny a longshore claim?
Yes. Under Section 14(d) and 20 C.F.R. § 702.251, only the official Notice of Controversion satisfies the duty to dispute; letters and emails do not.
Can a worker file LS-570?
No. The form is exclusively for employers and insurance carriers; workers use LS-203 to file a claim, not to controvert.
Does filing LS-570 stop the 14-day clock?
Yes. A timely and complete filing stops the Section 14(e) penalty clock and shifts the case to an informal conference at the district office.
Must LS-570 be filed electronically?
No. Paper filing is still allowed, though SEAPortal electronic filing is faster, date-stamped, and strongly preferred by district directors.
Is the 10% Section 14(e) penalty automatic?
Yes. If LS-570 is not filed within 14 days and payment has not started, the penalty attaches by operation of law and cannot be waived by the claims examiner.
Can a carrier amend LS-570 after filing?
Yes. A carrier can file an amended LS-570 to add defenses or correct errors, but the original 14-day deadline cannot be cured retroactively.
Does LS-570 cover Defense Base Act claims?
Yes. The same form is used for DBA, OCSLA, and Nonappropriated Fund claims because all extensions incorporate the LHWCA procedure.
Is medical-only controversion possible?
Yes. A carrier can deny Section 7 medical while accepting indemnity, but it must check the right box in Field 14 and explain the reason.
Can the worker recover attorney fees if the carrier loses?
Yes. Under Section 28, a successful claimant recovers reasonable attorney fees, and a controversion that is later overturned shifts fees to the carrier.
Does an unauthorized signature void LS-570?
Yes. A form signed without authority is a nullity, and the 14-day clock continues to run as if nothing was filed.
Can a self-insured employer file LS-570 directly?
Yes. Authorized self-insured employers file directly through their risk manager or longshore counsel without involving an outside carrier.
Does LS-570 affect state workers’ compensation rights?
No. Under Sun Ship concurrent jurisdiction, a federal controversion does not bar state benefits, though offsets apply under Section 3(e).
Related reading
- How to Fill Out DOL Form LS-1 (w/Examples) + FAQs
- How to Fill Out DOL Form LS-267 (w/Examples) + FAQs
- How to Fill Out DOL Form LS-274 (w/Examples) + FAQs
- How to Fill Out DOL Form LS-276 (w/Examples) + FAQs
- How to Fill Out DOL Form LS-33 (w/Examples) + FAQs
- How to Fill Out DOL Form LS-801 (w/Examples) + FAQs
- How to Fill Out DOL Form OWCP-16 (w/Examples) + FAQs