CONCURRING OPINION BY
Senior Judge KELLEY.I concur in the result reached by the majority.
Like the majority, I believe that the Claimant waived any objection to the WCJ’s treatment of his challenge under Section 413(c) of the Workers’ Compensation Act (Act)1 as a request for a suspension and termination by the Employer under Section 413(a) of the Act2. See *1042Majority Opinion at 1040. As noted by the majority, the Claimant failed to object to the WC^s actions in this regard at any time throughout the proceedings. See Id. at 1037-39. I -write separately, however, because I strongly disagree with the dicta expressed by the majority with respect to the propriety of the WCJ’s actions in this regard. See Id. at 1040.3
Pursuant to Section 413(a) of the Act, a WCJ may, at any time, modify, reinstate, suspend, or terminate a claimant’s compensation benefit awarded pursuant ,to a notice of compensation payable, an original or supplemental agreement or an award of the WCJ, upon the filing of a petition by either party. Pursuant to Section 413(a.l)4 of the Act, the filing of such a petition acts as an automatic request by an *1043employer for a supersedeas where the petition alleges that the claimant is fully recovered and it is accompanied by a physician’s affidavit to that effect. Section 413(a.l) further provides that, at the hearing on this automatic request for a special supersedeas, “[a]ll parties to the special supersedeas hearing shall have the right to submit, and the [WCJ] may consider testimony of any party or witness; the record of any physician; the records of any physician, hospital, clinic or similar entity; the written statements or reports of any other person expected to be called by any party at the hearing of the case; and any other relevant materials.” 77 P.S. § 774(1).
In addition, and quite importantly, Section 413(a.l) also provides that an employer is entitled to such a supersedeas from the payment of compensation benefits only when it establishes “[p]rima facia evidence of a change in the medical status or of any other fact which would serve to modify or terminate payment of compensation ... ”, and only if the claimant fails to establish “[b]y a preponderance of the evidence, a likelihood of prevailing on the merits of his defense ...” 77 P.S. § 774(1). This provision is in line with the general proposition that once an employer has accepted liability for a work-related injury, it may not cease the payment of compensation benefits in the absence of a supplemental agreement, a final receipt or a WCJ’s order. See, e.g., Gillis v. Workers’ Compensation Appeal Board (Willits Roofing, Inc.), 725 A.2d 257, 259-260 (Pa.Cmwlth. 1999) (“[T]he law is well settled that an employer who is obligated to pay a claimant benefits can cease paying benefits if it satisfies any of the following conditions: (1) submits a supplemental agreement pursuant to Section 408 of the Act, 77 P.S. § 732; (2) submits a final receipt signed by the claimant pursuant to Section 434 of the Act, 77 P.S. § 1001; (3) secures an interlocutory order from a WCJ granting a discretionary supersedeas pursuant to Sections 413(a.l) and 413(a.2) of the Act, 77 P.S. § 774; (4) files a petition to suspend compensation with an accompanying affidavit from the insurer that the claimant has returned to work at wages greater than or equal to his pre-injury wage pursuant to Section 413(c) of the Act, 77 P.S. § 774.2; or (5) secures a final order from a WCJ terminating a claimant’s benefits. Sheridan v. Workers’ Compensation Appeal Board (Anzon, Inc.), 713 A.2d 182 (Pa.Cmwlth.1998). Until one of the above events occurs, an employer is under a continuing obligation to pay a Claimant benefits properly owed to him. Id.”).
In contrast, Section 413(c) of the Act confers upon an employer the power to unilaterally suspend a claimant’s compensation benefits, without a prior hearing or a WCJ’s determination, based upon an allegation that the claimant has returned to work at his prior or increased wages. Subsection (1) of Section 413(c) permits the claimant to challenge this unilateral suspension by requesting a special super-sedeas hearing. Unlike Section 413(a.l), Section 413(c) does not contain any all-encompassing evidentiary provision. This is quite logical as the factual allegations underlying a Section 413(c) are extremely limited; namely, the claimant’s return to work at his prior or increased wages.5
*1044Thus, unlike the majority, I believe that where an employer seeks a suspension, modification or termination of a claimant’s disability benefits for reasons unrelated to those encompassed in Section 413(c) of the Act, that employer should be required to file the appropriate petition under Section 413(a) and to proceed accordingly. By opening a Section 413(c) hearing to irrelevant issues and evidence, the majority would allow an employer to unilaterally suspend a claimant’s disability benefits under Section 413(c), only to proceed on a different Section 413(a) theory at the hearing. All the while, the claimant’s benefits have been suspended, and the employer has availed itself of a supersedeas to which it is not entitled. In short, Section 413(c) provides a very limited form of self-help to employers based upon a very limited factual predicate. I firmly believe that the dicta expressed by the majority would inappropriately expand the provisions of Section 413(c) beyond these quite limited boundaries. Nonetheless, as properly noted by the majority, the Claimant has waived any allegation of error in this regard.
Accordingly, like the majority, I believe that the Board’s order should be affirmed.
. Act of June 2, 1915, P.L. 736, as amended, 77 P.S. § 774.2, added by the Act of July 1, 1978, as amended. Section 413(c) states the following, in pertinent part:
Notwithstanding any provision of this act, an insurer may suspend the compensation during the time the employe has returned to work at his prior or increased earnings upon written notification of suspension by the insurer to the employe and the department, on a form prescribed by the department for this purpose. The notification of suspension shall include an affidavit by the insurer that compensation has been suspended because the employe has returned to work at prior or increased earnings. The insurer must mail the notification of suspension to the employe and the department within seven days of the insurer suspending compensation.
(1) If the employe contests the averments of the insurer's affidavit, a special superse-deas hearing before a workers’ compensation judge may be requested by the employe indicating by a checkoff on the notification form that the suspension of benefits is being challenged and filing the notification of challenge with the department within twenty days of receipt of the notification of suspension from the insurer. The special su-persedeas hearing shall be held within twenty-one days of the employe’s filing of the notification of challenge.
77 P.S. § 774.2(1).
. Section 413(a) of the Act provides, in pertinent part:
A workers' compensation judge may, at any time, review and modify or set aside a notice of compensation payable and an original or supplemental agreement or upon petition filed by either party with the department, or in the course of the proceedings under any petition pending before such workers’ compensation judge, if it be proved that such notice of compensation *1042payable or agreement was in any material respect incorrect.
77 P.S. § 771.
Section 413(a) also provides, in pertinent part:
A workers' compensation judge designated by the department may, at any time, modify, reinstate, suspend, or terminate a notice of compensation payable, an original or supplemental agreement or an award of the department or its workers' compensation judge, upon petition filed by either party with the department, upon proof that the disability of an injured employe has increased, decreased, recurred, or has temporarily or finally ceased, or that the status of any dependent has changed. Such modification, reinstatement, suspension, or termination shall be made as of the date upon which it is shown that the disability of the injured employe has increased, decreased, recurred, or has temporarily or finally ceased, or upon which it is shown that the status of any dependent has changed ... And provided further, That where compensation has been suspended because the employe’s earnings are equal to or in excess of his wages prior to the injury that payments under the agreement or award may be resumed at any time during the period for which compensation for partial disability is payable, unless it be shown that the loss in earnings does not result from the disability due to the injury.
77 P.S. § 772.
. Specifically, the majority states the following, in pertinent part:
The WCJ is allowed to waive or modify the special rules of practice. 34 Pa.Code § 131.3(a). However, where there is neither formal petition nor formal answer, an oral amendment carries the dual risks of imprecision and digression. In special su-persedeas cases, which require expedited resolution, the mischief from digression and concomitant delay is particularly pronounced. For this reason, we view with disfavor oral amendments in special super-sedeas cases, and we encourage WCJs to require written petitions to memorialize issues beyond those expressly excused from formal’ pleadings by statute. Nevertheless, our interpretation of the Act does not compel a different result here.
Id.
. Section 413(a.l) of the Act provides, in pertinent part:
(1) The filing of a petition to terminate, suspend or modify a notice of compensation payable or a compensation agreement or award as provided in this section shall automatically operate as a request for a super-sedeas to suspend the payment of compensation fixed in the agreement or the award where the petition alleges that the employe has fully recovered and is accompanied by an affidavit of a physician on a form prescribed by the department to that effect, which is based upon an examination made within twenty-one days of the filing of the petition. A special supersedeas hearing before a workers’ compensation judge shall be held within twenty-one days of the assignment of such petition. All parties to the special supersedeas hearing shall have the right to submit, and the workers’ compensation judge may consider testimony of any party or witness; the record of any physician; the records of any physician, hospital, clinic or similar entity; the written statements or reports of any other person expected to be called by any party at the hearing of the case; and any other relevant materials. The workers' compensation judge shall rule on the request for superse-deas within seven days of the hearing and shall approve the request if prima facia evidence of a change in the medical status *1043or of any other fact which would serve to modify or terminate payment of compensation is submitted at the hearing, unless the employe establishes, by a preponderance of the evidence, a likelihood of prevailing on the merits of his defense ...
77 P.S. § 774(1).
. See also Section 131.50a of the Department’s regulations governing hearings conducted pursuant to Section 413(c), which states the following:
(a) This section governs the disposition of an employe’s request for a special superse-deas hearing made in connection with a *1044challenge to the suspension or modification of workers’ compensation, benefits under section 413(c) and (d) of the act (77 P.S. §§ 774.2 and 774.3).
(b) A special supersedeas hearing will be held within 21 days of the employe’s filing of the notice of challenge.
(c) The workers’ compensation judge to whom the notice of challenge has been assigned will issue a written order on the challenge within 14 days of the hearing.
(d)If the judge fails to hold a hearing within 21 days or fails to issue a written order approving the suspension or modification of benefits within 14 days of the hearing, the insurer shall reinstate the employe’s workers’ compensation benefits at the weekly rate the employe received prior to the insurer’s suspension or modification of benefits under section 413(c) or (d) of the act.
34 Pa.Code § 131.50a.