In Harris v. M-K Rivers, slip op. 6876 (March 14, 2014), the Alaska Supreme Court held that the Workers’ Compensation Act permits "imposition of a penalty on a medical benefit that has been prescribed but not yet paid" where a bad faith denial delayed receipt of prescribed medical treatment. To reach that decision, the Court held that "medical benefits become due for purposes of controversion and penalties when the employer has notice they have been prescribed by a doctor." T