Medical expenses in contested workers’ compensation cases are now a significant and troublesome issue resulting in uncertainty, delay, and potential future liability: the recent NJ Supreme Court decision, University of Mass. Memorial Hospital v. Christodoulou, 180 N.J. 334 (2004) has left the question of how to adjudicate medical benefits that were conditionally paid or paid in error. Presently there is no exclusively defined procedure to determine the allocation and apportionment of primary responsibility for unauthorized medical expenses and reimbursement.