GRAHAM, J.
At issue is whether a two-year limitations period, established by a regulation of the Department of Industrial Accidents (department), see 452 Code Mass. Regs. § 3.03(3) (1999), should be applied to bar certain claims of Harvard University (Harvard), a self-insurer, for reimbursement of cost of living adjustments (COLA) from the Workers' Compensation Trust Fund (Fund), pursuant to G. L. c. 152, § 34B, as amended
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