Workers' Compensation Trust

Transitional Modified Light Duty, Job Descriptions, and Job Offers

Guidance for PSWCT/UP Member Districts
Revision Date September 2026 

Early and medically appropriate return to work can support an injured worker’s recovery.  When an injured worker cannot temporarily perform the job of injury, a district may be able to provide meaningful modified or transitional work within the worker’s documented restrictions. 

Washington State law requires an adequate description of available work and attending-provider review. PSWCT/UP also uses job offers to document the specific terms communicated to the worker.  These are related documents, but they serve different purposes. 

What Washington Law Requires 

Under RCW 51.32.090(4)(b), when the employer of injury asks the attending provider to determine whether a worker can perform available work other than the usual job, the employer must provide the attending provider, with a copy to the worker, a statement describing the available work in terms that allow the provider to relate the job activities to the worker’s disability. The attending provider then determines whether the worker can perform the described work. 

The employer may prepare a light duty job description. L&I distinguishes an employer-prepared job description from a formal job analysis, which its public guidance states only a credentialed vocational rehabilitation specialist may complete. 

RCW 51.32.090(4) does not expressly require a separate job offer for every temporary modified-duty assignment. A job offer is nevertheless a PSWCT/UP claim-management practice and an important method for documenting the approved assignment, reporting instructions, and the worker’s response. 

Modified Duty Process 

1. Review of current medical information is critical. Confirm the worker’s current restrictions, treatment status, expected duration of restrictions, and any limits involving hours, environment, cognition, behavior, or safety. 

2. Identify available work. Identify appropriate work the district can provide and supervise. 

3. Prepare the transitional, modified, or light duty job analysis. Describe the actual duties, schedule, work setting, supervision, equipment, physical and cognitive demands, and each modification the district will provide. Use a formal job analysis when the claim or assignment warrants vocational analysis. 

4. Provide analysis for review concurrently. Send the work description or formal job analysis to the attending provider and provide a copy to the injured worker at the same time. Keep documentation of when and how each copy was provided. 

5. Address the provider’s response. Confirm written approval of the specific assignment. If the provider adds conditions, confirm that the district can provide them and revise the work description or job offer as needed. Do not treat an unsigned or incomplete response as approval. 

6. Prepare the job offer. After medical approval, prepare a job offer that matches the approved work.  

7. Monitor the assignment continuously. Ensure that the worker performs only the approved work and receives the agreed schedule, wage, supervision, and modifications.  

Job Offer Contents 

For PSWCT/UP claims, the job offer should identify: 

  • the position or modified assignment and confirmation that it is with the employer of injury
  • the provider-approved duties and restrictions, with the approved work description or formal job analysis attached or incorporated
  • the days, hours, breaks, wage rate, and any planned progression
  • the supervisor, reporting location, start date, and reporting time
  • the expected duration of a temporary assignment and each modification the district will provide
  • a reasonable response deadline and method for accepting, declining, or asking questions
  • district and PSWCT/UP contact information

Neither RCW 51.32.090 nor the applicable WAC establishes one universal three-day or five-day response period for every modified-duty job offer. Follow PSWCT/UP’s current procedure and provide a reasonable opportunity to respond based on the delivery method, proposed start date, representation, language-access needs, and other claim-specific circumstances. 

Changes to Approved Work 

WAC 296-20-01002 provides that an employer may not increase the physical requirements of approved modified work without requesting the attending provider’s opinion about the worker’s ability to perform the additional work. RCW 51.32.090(4)(j) further provides that, after the worker returns under this process, the employer may not assign work other than the work described without the worker’s written consent or the attending provider’s prior review and approval. 

Before changing duties, physical or cognitive demands, hours, schedule, location, work setting, or modifications, coordinate with PSWCT/UP to determine whether an updated work description, attending-provider review, and a job offer are needed. 

Acceptance Refusal and Benefits 

If the worker accepts. Confirm the start date and provide the supervisor with the approved assignment and restrictions. Under RCW 51.32.090(4)(b), temporary total disability payments continue until the worker is released by the attending provider for the available work and begins that work. Reduced hours or wages may support a separate loss-of-earning-power determination. 

If the worker declines. Promptly provide the response to PSWCT/UP. A worker who declines work that was adequately described and approved by the attending provider may no longer be entitled to time-loss compensation, although loss-of-earning-power benefits may still be considered. The district should not independently discontinue workers’ compensation benefits. The PSWCT/UP claims team will determine and communicate the appropriate claim action. 

If the worker does not respond. Provide PSWCT/UP with documentation of delivery and non-response. Non-response should not be treated as an automatic refusal without reviewing delivery, the response deadline, and other claim-specific facts. 

If the validity of the offered work or the worker’s ability to perform it is disputed, the Department of Labor and Industries makes the final determination under RCW 51.32.090(4)(l). A self-insurer’s action starting, stopping, or denying time-loss or loss-of-earning-power compensation must be communicated using the Department’s required process under WAC 296-15-425. 

Separate Incentive Program Requirements 

PSWCT/UP’s Return-to-Work Incentive Program is a separate internal reimbursement program. Its eligibility and documentation requirements do not define whether offered work complies with RCW 51.32.090(4), and compliance with the statute does not establish reimbursement eligibility. Consult the current incentive-program materials for reimbursement requirements. 

PSWCT/UP Assistance 

PSWCT/UP may assist member districts with identifying modified duty options, preparing work descriptions and formal job analyses, coordinating attending-provider review, drafting job offers, and addressing changes or disputes. Contact the assigned Claims Consultant or Return to Work Manager before presenting a job offer that may support a change in wage-replacement benefits. 

Authorities and References 

General Guidance. This article distinguishes Washington legal requirements from PSWCT/UP claim-management practices and recommendations. It does not replace claim-specific advice, applicable collective bargaining agreements, district policies, or current Washington law.

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