concurring in part and dissenting in part.
Although I agree with the majority’s conclusion upholding the award of permanent total disability benefits to Thomas Bordeaux (“Bordeaux”) and the denial of the motion to compel, I write to express my disagreement with the majority’s reversal of the attorney-fee award. Both the Administrative Law Judge (“ALJ”) and the Benefits Review Board (“BRB”) concluded that Bordeaux was entitled to recover attorney fees, albeit on different grounds. Although the statutory scheme’s complexity may hinder identification of the proper statutory basis for a fee award, one thing is conclusive: Bordeaux is entitled to attorney fees. Denying fees to Bordeaux based on rigid formalities that are not expressly mandated by the statute is contrary to two of the primary concerns underlying the Longshore and Harbor Workers’ Compensation Act (“the Act”), 33 U.S.C. §§ 901-950: the availability of quick recovery for valid workplace-injury claims without resort to the courts, and when this fails, claimants’ full recovery of statutory benefits without reduction by the cost of legal services. See, e.g., Newport *268News Shipbldg. & Dry Dock Co. v. Brown, 376 F.3d 245, 250 (4th Cir.2004); Hunt v. Dir., Office of Workers’ Comp. Programs, 999 F.2d 419, 424 (9th Cir.1993); Oilfield Safety & Mach. Specialties, Inc. v. Har-man Unlimited, Inc., 625 F.2d 1248, 1257 (5th Cir.1980); Universal Terminal & Ste-vedoring Corp. v. Parker, 587 F.2d 608, 611 (3d Cir.1978). Because it is well established that the Act “must be liberally construed in conformance with its purpose, and in a way which avoids harsh and incongruous results,” Dir., Office of Workers’ Comp. Programs v. Perini N. River As-socs., 459 U.S. 297, 315-16, 103 S.Ct. 634, 74 L.Ed.2d 465 (1983) (internal quotation marks omitted) (collecting cases), I respectfully dissent from the majority’s reversal of the fee award.
I. 33 U.S.C. § 928(a)
A. Basic Contours
Title 33 U.S.C. § 928(a) awards attorney fees when “the employer or carrier declines to pay any compensation on or before the thirtieth day after receiving written notice of a claim for compensation having been filed from the deputy commissioner, on the ground that there is no liability for compensation within the provisions of this chapter, and the person seeking benefits shall thereafter have utilized the services of an attorney at law in the successful prosecution of his claim.” 33 U.S.C. § 928(a). The majority interprets this provision to be inapplicable when the employer pays some amount of compensation within thirty days after receiving notice of the claim. The majority, however, provides no reasoning and cites no authority to support this conclusion.1 This is a question of first impression in our court, and there is a split among our sister circuits on this issue. Compare FMC Corp. v. Perez, 128 F.3d 908, 910 (5th Cir.1997) (considering a claim under § 928(a) when the employer paid one kind of disability benefit but refused to pay another kind), Nat’l Steel & Shipbldg. Co. v. U.S. Dep’t of Labor, Office of Workers’ Comp. Programs, 606 F.2d 875, 883 (9th Cir.1979) (suggesting that partial refusal could be a basis for recovery under § 928(a) when the employer paid temporary total disability benefits but refused to pay permanent partial disability payments), and Presley v. Tinsley Maint. Seru., 529 F.2d 433, 437 (5th Cir.1976) (considering a claim under § 928(a) when the employer paid permanent total disability benefits but not permanent partial disability benefits, but denying the claim because additional permanent disability benefits were not awarded), with Va. Int’l Terminals, Inc., v. Edwards, 398 F.3d 313, 316-18 (4th Cir.2005) (suggesting that § 928(a) is inapplicable when employer paid some benefits), and Savannah Mach. & Shipyard Co. v. Dir., Office of Workers’ Comp. Programs, 642 F.2d 887, 889 (5th Cir.1981) (holding that the employer’s partial tender of compensation renders § 928(a) inapplicable).
B. Employer’s Refusal to Pay One Type of Benefit as “Declin[ing] to [P]ay [A]ny [Compensation”
Two theories support Bordeaux’s claim for attorney fees under § 928(a). The *269first theory, as explained by the Fifth Circuit, holds that when, as here, the employer voluntarily paid one type of benefit, temporary total disability, but contested another type of benefit, permanent total disability, “this may be the equivalent of not paying ‘any compensation’ within the meaning of Section 28(a).” FMC Corp., 128 F.3d at 910; see also Nat’l Steel & Shipbldg. Co., 606 F.2d at 883 (9th Cir.) (stating that when the employee sought “compensation different in kind as well as amount from that he had received previously, and the very existence of liability for that compensation was disputed by [the employer,]” attorney fees might be appropriate under § 928(a)). The Fifth Circuit in FMC found that an award was not proper in the case before it, however, because the amount of benefits paid per month for either temporary or permanent total disability benefits was the same.
The result in FMC is not dictated here. Bordeaux was awarded $425.47 per month for permanent total disability benefits, and his employer, Pittsburgh & Conneaut Dock (“P & C Dock”), had been paying him $425.01 per month for temporary disability benefits. This difference in payment is not a mere matter of forty-six cents; rather, it points to a qualitative difference in the benefits actually paid to Bordeaux and the benefits to which he was legally entitled and that he was ultimately awarded. Unlike temporary disability benefits, permanent disability benefits are increased each year on October 1 by an annual adjustment under 33 U.S.C. § 910(f). Additionally, temporary disability benefits can be ceased at the employer’s whim, whereas permanent benefits are required to be paid on an ongoing basis. These two substantial differences in the type of benefits that P & C Dock voluntarily paid and that P & C Dock refused to pay support an award of attorney fees pursuant to § 928(a) because P & C Dock’s complete refusal to pay permanent disability benefits constitutes a failure “to pay any compensation” under § 928(a). See FMC Corp., 128 F.3d at 910; Nat’l Steel & Shipbldg. Co., 606 F.2d at 883.
C. A Request for an Informal Conference as a Claim for Compensation
The second theory supporting Bordeaux’s claim under § 928(a) is that even after the employee has applied for and received temporary disability benefits, the employee’s later claim for permanent disability benefits through an informal conference of which the employer receives written notice constitutes “filing a claim” under § 928(a). Thus the employer’s refusal to pay this claim permits a fee award under § 928(a). The majority cites a recent Fourth Circuit decision, Virginia International Terminals, 398 F.3d at 316-17, to support its rejection of this theory.2 However, the reasoning of that case is flawed. In Virginia International Terminals, the Fourth Circuit held that an “informal” letter requesting a conference on the issue of benefits for the three days in between when the employee was injured and when the employer began paying benefits could not be considered “filing a claim” under § 928(a). Id. at 315. The Fourth Circuit explained that the “most natural reading of the phrase ‘filing a claim’ refers to a formal action that initiates a legal proceeding, rather than an informal action that seeks to alter or *270amend a pre-existing settlement on a prior claim.” Id. at 316. However, both the regulations and case law explain that the initiation of a claim requires little in the way of formality, thus undermining the Fourth Circuit’s contention that “filing a claim” refers to “a formal action.” See 20 C.F.R. § 702.221(a) (requiring only that a claim be in writing and filed within one year of the injury3); Fireman’s Fund Ins. Co. v. Bergeron, 493 F.2d 545, 546-47 (5th Cir.1974) (explaining that “[n]o particular form of claim need be used” and that “[t]he requirement of a claim is met if a writing, even though an informal one, of the injured employee or his attorney discloses an intention to assert a right to compensation”) (quoting Employers Liab. Assurance Corp. v. Donovan, 279 F.2d 76, 78 (5th Cir.1960)). In fact, one of the primary goals of the Act is to avoid legal formalities and to address conflicts informally. See, e.g., Universal Terminal & Stevedoring Corp., 587 F.2d at 611. The majority’s denial of a fee award on this basis undermines the policy of “not encouraging premature claims of permanent disability.” J.M. Martinac Shipbldg. v. Dir., Office of Workers Comp. Programs, 900 F.2d 180, 184 (9th Cir.1990). Given that P & C Dock received written notice of the informal conference, Bordeaux’s request for permanent total disability benefits constituted “filing a claim” under § 928(a).
The Fourth Circuit in Virginia International Terminals also reasoned that § 928(b) is the exclusive avenue by which to recover attorney fees in cases in which the employee seeks “additional” or “supplemental” benefits because otherwise § 928(b) and its “more stringent conditions ... would be rendered superfluous.” 4 398 F.3d at 317. However, the Ninth Circuit has acknowledged that sections 928(a) and 928(b) are not mutually exclusive and may overlap. Nat’l Steel & Shipbldg. Co., 606 F.2d at 883; see also Barker v. U.S. Dep’t of Labor, 138 F.3d 431, 438 n. 6 (1st Cir. 1998). In addition, this case is unlike Virginia International Terminals in that it does not involve an attempt “to alter or amend a pre-existing settlement on a prior claim.” Va. Int’l Terminals, 398 F.3d at 316. In this case, there was no preexisting settlement regarding permanent total disability benefits. From the record before us, it appears that Bordeaux originally filed only for temporary total disability benefits because he did not know he would be permanently disabled at the time he filed his initial claim. Bordeaux’s request for an informal conference, of which the employer was given written notice, came about when he became aware of a new type of injury — permanent total disability — and a new type of benefit for which he qualified — permanent total disability— based on information that he could not have had when he filed his initial claim. *271The employer did not controvert his initial claim for temporary disability benefits, but did controvert, in its entirety, Bordeaux’s later claim for permanent disability benefits. Therefore, although the later claim was based on the same work-related injury, this was not simply a claim for supplemental benefits. Allowing an award under § 928(a) for a claim like Bordeaux’s, in which a different kind of benefit is requested based on a newly recognized kind of injury, does not open the floodgates to allow any supplemental claim to proceed under § 928(a).
On these grounds, I find the Fourth Circuit’s decision to be unpersuasive, and instead would consider Bordeaux’s request for an informal conference to have been the “filing [of] a claim” under § 928(a). P & C Dock’s refusal to pay this claim warrants an attorney-fee award under § 928(a).
II. 33 U.S.C. § 928(b)
A. Statutory Text
Section 928(b) states that if an employer pays benefits to an employee without an award,
and thereafter a controversy develops over the amount of additional compensation, if any, to which the employee may be entitled, the deputy commissioner or Board shall set the matter for an informal conference and following such conference the deputy commissioner or Board shall recommend in writing a disposition of the controversy. If the employer or carrier refuse to accept such written recommendation, within fourteen days after its receipt by them, they shall pay or tender to the employee in writing the additional compensation, if any, to which they believe the employee is entitled.
33 U.S.C. § 928(b). If the employee then does not accept the employer’s offer of compensation, and thereafter relies on an attorney to attain compensation greater than what the employer offered, an attorney-fee award is appropriate. Id.
B. § 928(b) Formalities as Preconditions to Recovery
The majority concludes that to secure an award pursuant to § 928(b), four conditions must be met: an informal conference, a written recommendation, the employer’s rejection of the recommendation, and the claimant’s use of an attorney to recover an award in excess of what the employer would have paid. The majority rejects the BRB’s reliance on he Ninth Circuit’s view that such terms included within the text are not preconditions to an award.5 See Everitt v. Dir., Office of Workers Comp. Programs, 107 Fed.Appx. 750, 753 n. 4 (9th Cir.2004) (rejecting the argument that formalities are required to recover an award under § 928(b)); Matulic v. Dir., Office of Workers Comp. Programs, 154 F.3d 1052, 1060-61 (9th Cir.1998) (upholding a fee award under § 928(b) despite the fact that no informal conference had been held); Nat’l Steel & Shipbldg. Co., 606 F.2d at 882 (upholding a fee award under § 928(b) when no written recommendation was issued). While I agree with the ma*272jority that the Ninth Circuit’s reliance on the legislative history for its position is misplaced because the legislative history is inconclusive on this issue, I disagree with the majority’s conclusion that the plain language of the statute bars Bordeaux from a fee award under § 928(b).
The statute mentions these formalities, but it does not state that they are preconditions to an award under § 928(b). Therefore, the plain language of the statute does not address the situation, when, as here, the formalities were lacking through no fault of the claimant, but rather as a result of the agency’s failure to follow its duties. Bordeaux requested and participated in the informal conference. The memorandum memorializing the events of the September 19, 2002 informal conference states the “issues” as: “[d]is-cuss settlement” and “[ejxtent of permanent disability.” Joint Appendix (“J.A.”) at 241 (Memo, of Informal Conference). Under the “recommendation” section, the claims review officer wrote “[a]s a settlement cures all ills, issues and disputes, no recommendation will be made at the current time,” and instead provided “ ‘ballpark’ settlement amounts ... as a starting point for negotiations.” Id. Section 928(b) states that “following [the informal] conference the deputy commissioner or Board shall recommend in writing a disposition of the controversy. ”6 33 U.S.C. § 928(b) (emphasis added). Here, the claims officer failed to follow his statutory obligation of making a recommendation disposing of the controversy and instead directly contravened the statute by stating that he was making “no recommendation.” J.A. at 241 (Memo, of Informal Conference). It is no fault of Bordeaux that the claims review officer did not make a recommendation on the disputed issue.7 The employer should not secure a windfall because the claims officer shirked his statutory duty, particularly when nothing in the statute mandates that we enforce such preconditions to recovery. P & C Dock’s failure to raise the issue of the lack of a written recommendation until it was contesting the fee award “thwarted any possibility of achieving a timely compliance with the statute and does not constitute ground for setting aside the fee award.” See Nat’l Steel & Shipbldg. Co., 606 F.2d at 882.
When the language of a statute leads to an “unreasonable” result “plainly at variance with the policy of the legislation as a whole,” we are to “follow[] that purpose rather than the literal words.” United States v. Am. Trucking Ass’ns, Inc., 310 U.S. 534, 543-44 & n. 21, 60 S.Ct. 1059, 84 L.Ed. 1345 (1940) (collecting cases). Be*273cause denying Bordeaux a fee award based on the language of § 928(b) would be at odds with the policies underlying the Act, Bordeaux should recover under § 928(b).
III. BLOCK BILLING
P & C Dock’s objection to the format of Bordeaux’s applications for attorney fees to the ALJ and the BRB is without merit. Sections 928(a) and 928(b) merely state that any attorney fee awarded must be “reasonable.”8 33 U.S.C. § 928(a), (b). P & C Dock has cited no authority to support its argument that the use of block billing is contrary to the award of a reasonable attorney fee under § 928, and, in fact, our sister circuits have rejected block-billing objections to fee awards in a number of contexts. Farfaros v. Citizens Bank & Trust of Chi, 433 F.3d 558, 569 (7th Cir.2006) (Title VII); Trulock v. Hotel Victorville, 92 FedAppx. 433, 434 (9th Cir. 2004) (Americans with Disabilities Act) (citing Fischer v. SJB-P.D. Inc., 214 F.3d 1115, 1121 (9th Cir.2000)); Cadena v. Pacesetter Corp., 224 F.3d 1203, 1215 (10th Cir.2000) (Title VII). In a ease awarding fees under 42 U.S.C. § 1988, which is also governed by a reasonableness standard, the Supreme Court held that “[pjlaintiffs counsel, of course, is not required to record in great detail how each minute of his time was expended,” but rather “should identify the general subject matter of his time expenditures.” Hensley v. Ecker-hart, 461 U.S. 424, 437 n. 12, 103 S.Ct. 1933, 76 L.Ed.2d 40 (1983). Therefore, counsel’s detailed descriptions of his activities, although not further described by time spent on each individual activity, is sufficient to assess whether the cost o the service is reasonably related to the quality or extent of service, as required by the regulations.9 See 20 C.F.R. §§ 702.132(a), 802.203(e).
IV. CONCLUSION
Because the text of § 928(a) and § 928(b) and the policies underlying the Act support a fee award, I would uphold the award under either § 928(a) or § 928(b). Accordingly, I respectfully dissent.
. The legislative history leaves the question open. It should be noted, however, that the House Report regarding § 928(a) omits "any" from its statement of the employer's refusal to pay compensation. H.R.Rep. No. 92-1441, 92d Cong., 2d Sess. 3, reprinted in 1972 U.S.Code Congressional and Administrative News 4698, 4717 ("A new provision is added directing an award of a reasonable attorney fee against an employer or carrier to be paid directly to the attorney in a lump sum, where such employer or carrier has declined to pay compensation within 30 days after notice that a claim has been filed on the ground of nonli-ability, and such claim is successful.”).
. The majority wrongly cites Savannah Machine & Shipyard Company, 642 F.2d at 889, as holding that a request for an informal conference is not a claim for compensation. In that case, the employee did not request an informal conference. Rather, the employer requested a hearing. The case only held that § 928(a) does not apply because the employer had tendered partial compensation.
. This one-year time limit does not bar Bordeaux’s claim because he requested the informal conference within one year of realizing that his injury was permanent. See 33 U.S.C. § 913(a) (stating that "[t]he time for filing a claim shall not begin to run until the employee or beneficiary is aware, or by the exercise of reasonable diligence should have been aware, of the relationship between the injury or death and the employment”); J.M. Marti-nac Shipbldg. v. Dir., Office of Workers Comp. Programs, 900 F.2d 180, 183-84 (9th Cir. 1990) (tolling one-year statute of limitations until employee recognized that injury was permanent because "an injured employee is not injured for purposes of the statute of limitations until he [becomes] aware of the full character, extent, and impact of the harm done to him” (internal quotation marks omitted)).
. Given that, as I conclude below, the formalities mentioned in § 928(b) are not prerequisites to an award under that provision, the Fourth Circuit's argument on this ground carries little weight.
. In noting that our sister circuits are split on this issue, the majority erroneously asserts that the Fifth Circuit has rejected the Ninth Circuit's position. The Fifth Circuit has issued a number of decisions that do not consider these formalities to be prerequisites to a fee award. See James Flanagan Stevedores, Inc. v. Gallagher, 219 F.3d 426, 435-36 (5th Cir.2000) (upholding a fee award under § 928(b) without a written recommendation and placing the burden on the employer to show the substance of the written recommendation); Boland Marine & Mfg. Co. v. Rihner, 41 F.3d 997, 1006-07 (5th Cir.1995) (upholding a fee award under § 928(b) without discussing whether formalities had been met).
. The regulations further require that ”[w]hen it becomes apparent during the course of the informal conference that agreement on all issues cannot be reached, the district director shall bring the conference to a close, shall evaluate all evidence available to him or her, and after such evaluation shall prepare a memorandum of conference setting forth all outstanding issues, such facts or allegations as appear material and his or her recommendations and rationale for resolution of such issues.” 20 C.F.R. § 702.316 (emphasis added).
. This case is distinguishable thus from those cases cited by the majority that denied an award for lack of an informal conference, see Va. Int'l Terminals, Inc., 398 F.3d at 318; Pool Co. & Carrier v. Signal Mut. Indem. Ass’n, 274 F.3d 173, 186 (5th Cir.2001); FMC Corp., 128 F.3d at 909, because the employees in those cases likely had some control over requesting the conference. In this vein, Staf-tex Staffing v. Director, Office of Worker’s Compensation Programs, 237 F.3d 404, 409 (5th Cir.2000), is particularly inapposite because there the court held that attorney fees could not be awarded under § 928(b) because the employee failed to raise an issue at an informal conference. By contrast, the lack of a written recommendation was in no way a result of any deficiency on the part of Bordeaux.
. The regulations require that fee applications submitted to the ALJ “shall be supported by a complete statement of the extent and character of the necessary work done ... and the hours devoted by each such person to each category of work.” 20 C.F.R. § 702.132(a). The regulations further mandate that fee applications submitted to the BRB shall contain "[a] complete statement of the extent and character of the necessary work done” and "[t]he number of hours, in 1/4 hour increments, devoted by each person who performed services on behalf of the claimant and the dates on which such services were performed in each category of work,” 20 C.F.R. § 802.203(d)(1), (3).
. The ALJ considered a number of P & C Dock's objections to individual entries and discarded those entries that lacked the requisite specificity.