If you’re a Georgia employer, you’ve always had responsibilities for injured employees, especially with light duty. But a recent State Board of Workers’ Compensation clarification, which took effect January 1, 2026, puts a new spotlight on your duties for modified work. It’s meant to help both the injured worker and your business by setting clearer rules. So what do these updates actually mean for you?
Key Takeaways
- You have to give a specific, written job description for any light duty offer, spelling out the tasks and physical requirements.
- The State Board now says you have to keep detailed records of all light duty offers and the employee’s response for at least five years.
- If you don’t offer suitable light duty when it’s available and medically okay, you could be on the hook for full temporary total disability benefits.
- The updated rules make it clear: the light duty job has to match the doctor’s restrictions on the Form WC-205 exactly.
- You need to get your return-to-work protocols reviewed and updated by Q2 2026 to make sure you’re compliant with these new interpretations.
Understanding the Latest State Board Guidance on Light Duty Offers
The State Board of Workers’ Compensation (SBWC) put out Administrative Rule 205.1(c) late in 2025, and it kicked in at the start of this year. It’s a refinement of the old rules for offering modified or light duty work. While employers were always supposed to offer work within an employee’s restrictions, this new guidance puts real teeth into the requirements for documentation and being specific. According to SBWC Chairman Mark Johnson’s press release from November 2025, the whole point is to cut down on the fights that start over vague job offers and make sure people aren’t pushed into jobs that go beyond their medical limits. The Board is trying to fix the gray areas that were fueling so many lawsuits in workers’ compensation claims across the state.
Detailed Job Descriptions are Now Non-Negotiable
The biggest change with Rule 205.1(c) is the absolute requirement for detailed job descriptions for any light duty offer. You can’t just say, “we have light duty available” anymore, that’s over. Now you have to provide a written description of the job that lists out the specific tasks, the hours, the pay, and most importantly, a clear breakdown of the physical demands. That description has to state that the job fits within the doctor’s restrictions from the Form WC-205, the Physician’s Work Status Report.
So if the doctor says no lifting more than 10 pounds, your job description has to spell out that no task in the role requires lifting over 10 pounds. Vague phrases like “light office work” won’t cut it. A good description would break it down into tasks like “answering phones (seated, no lifting),” “data entry (seated, keyboard use),” and “filing documents (reaching below waist, no lifting over 2 lbs).” That level of detail is what the Board is looking for now. Every employer in Georgia, whether you’re running a plant in Dalton or a tech company in Midtown Atlanta, should be updating their return-to-work packets right now to meet these standards.
Documentation and Record-Keeping: A Heightened Standard
The SBWC’s new guidance also seriously ups the ante on documentation and record-keeping. You’re now required to keep a complete file for every single light duty offer. That file needs the date of the offer, the detailed job description you gave the employee, all communication about the offer, and the employee’s answer. You have to keep these records for at least five years from the day you made the offer. This is now a hard-and-fast regulatory requirement.
Let’s say you have an employee at your logistics company near Hartsfield-Jackson Airport who hurts their back, and you offer them a light duty job in dispatch. With this new rule, you have to save a copy of the written offer, the job description, proof the employee got it (like a certified mail receipt or a signature), and any emails or texts about the offer. This paper trail becomes your best evidence if a dispute over the job’s suitability or the employee’s refusal ever comes up. If you don’t have those records, you’ll have a tough time defending yourself against a TTD claim, even if you had a perfectly good job available.
Consequences of Non-Compliance: What Employers Stand to Lose
Not following these new rules can cost you, a lot. If you fail to offer a suitable light duty job that matches the doctor’s restrictions, or if your offer isn’t detailed enough, you could get stuck paying temporary total disability (TTD) benefits. That’s two-thirds of the worker’s average weekly wage, up to the max, for as long as they’re out. This can happen even if you thought you had a light duty job ready, but you just didn’t document it or describe it the way the Board now requires.
An Administrative Law Judge (ALJ) can look at a poorly described light duty offer and decide it’s the same as making no offer at all, which leaves you completely exposed. For smaller Georgia businesses without big HR or risk departments, getting these details right is everything. I’ve personally seen so many cases where employers with good intentions get hit with major penalties simply because their internal process for handling light duty wasn’t buttoned up enough for the SBWC. It’s an expensive mistake, and it’s one you can avoid if you’re prepared.
Aligning Light Duty with Medical Restrictions: The WC-205 Form
Everything comes back to the Form WC-205. The new guidance hammers this home: any light duty job you offer has to precisely align with the medical restrictions the doctor puts on that form. Think of the WC-205 as the blueprint for any return-to-work plan in a Georgia comp case. You should be getting an updated WC-205 after every single doctor’s appointment where the employee’s work status is discussed. Even a small mismatch between your job offer and the doctor’s restrictions can make your offer totally invalid.
It’s simple stuff, really. If the WC-205 says “no overhead reaching” and your light duty job involves “retrieving files from the top shelf,” that’s not a suitable offer. If you’re ever unsure about the restrictions or need to know if a specific job will work, just call the doctor’s office and ask for clarification. Talking to them upfront can head off a lot of arguments down the road. Remember, the State Board puts the burden on you, the employer, to prove the job was within the medical limits. Without a clean WC-205 and a job description that mirrors it, proving your case is going to be almost impossible.
Practical Steps for Georgia Employers
So, what should Georgia employers do right now to get compliant and reduce their risk?
- Review and Update Your RTW Policies: Get your existing return-to-work policies in front of you and update them by Q2 2026 to include these new rules for detailed job descriptions and record-keeping.
- Build a Job Description Library: Start creating a set of pre-approved light duty job descriptions for your company. They should be general enough to work for different injuries but very specific about the physical tasks involved.
- Train Your People: Make sure every supervisor, HR manager, and safety person who deals with injured workers knows these new rules for offering and documenting light duty inside and out.
- Talk to the Doctors: Set up a clear process for communicating with the authorized treating physicians. You need to get those WC-205 forms quickly and be able to ask them questions. It’s a good idea to even send them your potential light duty job descriptions to get their sign-off.
- Keep Impeccable Records: Put a solid system in place for tracking every light duty offer, the dates, the descriptions, proof the employee saw it, and all follow-up. Using digital records with backups is your best bet.
- Call Your Lawyer: If you’re not 100% sure about a light duty offer or if an employee pushes back, get an experienced Georgia workers’ comp attorney on the phone. These rules are complicated, and one wrong move can be very expensive.
The message from the State Board is loud and clear: they want more transparency and detail in the light duty process. If you get on board with this quickly, you’ll have an easier time managing claims and will spend less time and money on lawsuits.
Conclusion
Bottom line: the State Board’s new guidance on light duty, which started January 1, 2026, means every employer in Georgia needs to update their return-to-work process. If you create detailed job descriptions, keep good records, and make sure every job offer matches the medical restrictions to a T, you will lower your risk of expensive temporary total disability claims and help your injured employees get back to work with less friction.
What is a Form WC-205 and why is it important for light duty?
The Form WC-205 is the “Physician’s Work Status Report” from the authorized treating doctor. It’s everything in a light duty situation because it officially lays out the employee’s medical restrictions, what they can and can’t do. Your light duty offer has to be built around those specific limits, like how much they can lift, if they can stand or sit, or what movements to avoid.
How long do employers need to keep records of light duty offers in Georgia?
In Georgia, you now have to keep all records of your light duty offers for a minimum of five years from the date you made the offer. This includes the job description you sent and what the employee said back. This paperwork is your proof if there’s ever a dispute.
Can an employer be penalized for offering light duty that exceeds a worker’s restrictions?
Yes, definitely. If you offer a light duty job that goes beyond the medical restrictions on the WC-205, the State Board can rule that your offer was unsuitable. When that happens, it’s as if you never made an offer, and you could be forced to pay temporary total disability benefits.
What should a detailed light duty job description include?
It needs to have the specific job tasks, the hours, the pay, and a very clear breakdown of the physical requirements. It has to explicitly state that the job fits within the doctor’s written restrictions. Don’t use general terms. Instead, be specific: “seated work for 4 hours a day,” “no lifting objects over 5 pounds,” or “no repetitive reaching above shoulder height.”
What if an injured employee refuses a suitable light duty offer?
If you’ve done your part, made a suitable light duty offer that’s within the medical restrictions and documented it all perfectly with a detailed job description, and the employee refuses it without a good reason, their temporary total disability benefits can be suspended. You’d then file the right paperwork, like a Form WC-200, with the State Board to reflect that change.
