Approved-Dates-Only Tracking: The Rule That Protects Your Reimbursement

The Day That Almost Killed the Application

A coordinator at a mid-size warehouse operation had done most things right. She had the physician's written approval for the transitional job description, the light-duty offer letter was signed, and the worker had completed sixty-two days in a restricted role. When the Washington Stay-at-Work reimbursement packet came back, the application was partially disallowed.

The problem: twelve of those sixty-two days included hours the physician had not approved. On six of them, the worker clocked six hours when the attending provider had authorized only four. On the other six, the worker had come in on a day when the approved schedule had lapsed between restriction updates. L&I's rule is unambiguous — a day worked outside the approved job description or approved hours is ineligible, and a six-hour day when four hours were approved disqualifies that full day's count. (ERNwest, 2025)

She recovered reimbursement on fifty of sixty-two days instead of all sixty-two. That gap was not a paperwork technicality. It was a direct reduction in recoverable wages.

This article explains exactly which days count under approved-dates-only tracking, why the rule exists, and how to build a log that survives a carrier or agency review from the first day of light duty forward.

---

What "Approved Dates Only" Actually Means

Approved-dates-only tracking is the discipline of recording reimbursable light-duty days based on three simultaneous conditions — not two, not one:

1. A written, physician-approved job description is active for the role the worker performed that day.
2. The worker performed work within the approved hours documented in that description.
3. The day falls within the program's allowable window (for Washington SAW: up to 120 days worked on or after January 1, 2025, with the application filed within one year after the light-duty work is complete). (WA L&I, 2025; AGC of Washington, 2025)

All three conditions must be true simultaneously. If the physician approved four hours but the worker worked six, condition two fails and the day is ineligible — the full day, not just the two excess hours. (WA L&I Complete Stay at Work Guide, 2024) If the worker came in on a Tuesday that fell between two restriction periods because no one re-confirmed the active window, condition one fails. If an employer submits an application more than one year after the last eligible light-duty day was worked, condition three fails retroactively for the entire claim. (WA L&I, 2025)

The practical definition: a reimbursable day is a day with documented, contemporaneous evidence that all three conditions were met. A partial day counts as one reimbursable day toward the cap, provided conditions one and two are satisfied. (WA L&I Complete Stay at Work Guide, 2024)

---

Why Programs Audit on These Conditions

State reimbursement programs are funded from dedicated workers' benefit accounts — in Washington, through the Stay-at-Work fund — and administered under auditable rules. When L&I processes a SAW application, reviewers cross-reference the submitted day log against the approved job description dates, the hours authorized, and any restriction updates on file with the attending provider. An application that logs days outside those parameters is not just incomplete — it signals that the employer's internal tracking system did not control for eligibility in real time, which raises the question of what else may have been miscounted.

The consequence of a disallowed day is not just a reduced reimbursement on the current claim. A disallowance pattern can prompt a closer review of prior applications and, in a multi-claim operation, can affect the credibility of future submissions.

The reimbursement stakes are material. Under Washington's program (injuries on or after January 1, 2025), SAW reimburses 50% of base wages for up to 120 days worked, with a maximum of $25,000 per claim — nearly triple the prior cap of $10,000 over 66 days. Combined with the Preferred Worker Program, the total reimbursement opportunity can reach $75,000 per claim. (AGC of Washington, 2025) At that scale, a tracking gap that disqualifies twelve days is a quantifiable loss, not a rounding error.

The reimbursement application is due within one year after the light-duty work is done. Days worked more than one year before the application date are not reimbursable regardless of how well they were tracked. (WA L&I, 2025)

---

The Four Most Common Tracking Failures

Understanding where logs break down in practice makes it easier to design around the failure modes.

1. Hours creep above the approved amount. The most common failure. A worker finishes a task quickly, the supervisor asks them to stay and help elsewhere, and the timesheet reflects six hours instead of four. No one flags it. The day is ineligible.

Control: The approved hours from the physician's job description approval must live on the same record as the timesheet entry. Anyone approving a timesheet for a light-duty worker should have the approved-hours ceiling in view at the time of approval — not in a separate binder consulted weekly.

2. Work continues during a gap between restriction updates. Physicians issue restrictions for defined periods. When one restriction period ends and the employer has not confirmed a renewal or extension in writing, the worker is technically operating without an active physician-approved job description. Days worked in that gap are ineligible.

Control: Track restriction end dates alongside day counts. When a restriction period has fewer than five business days remaining, the file should generate a task to confirm the extension or suspension of light duty — before the gap occurs, not after.

3. The job description changes but the physician approval does not. Operational needs shift. A modified duty role that started at bench assembly gets expanded informally to include loading because the assembly work is complete. If the attending provider has not approved the new tasks in writing, work performed under the expanded role is not covered by the original job description approval.

Control: Treat every material change to the transitional role — tasks, location, tools, weight limits, or schedule — as a new job description requiring a fresh physician sign-off before the worker performs the modified work.

4. Days are logged from memory at the end of the claim rather than contemporaneously. End-of-claim reconstruction is the highest-risk logging method. Timesheets may exist, but connecting them to the specific approved restriction window, the specific job description version, and the specific hours ceiling requires that all three records be cross-referenced — often weeks or months after the fact. Gaps in any one record create ambiguity that defaults against the employer at review.

Control: Log each eligible day at the end of that workday or the following morning. The log entry should record: the date, hours worked, hours approved, the job description version active that day (by date of physician sign-off), and the name of the supervisor who confirmed the hours were within the approved ceiling.

---

Building an Approved-Dates Log That Holds Up

A compliant approved-dates log is not a standalone timesheet. It is a joined record that connects four data streams on a per-day basis:

Log Field	Source Document	Why It Matters
Date worked	Timesheet / sign-in	Establishes the day falls within the claim's active window
Hours worked	Timesheet / supervisor sign-off	Must not exceed approved hours
Hours approved	Physician-approved job description (active version)	Ceiling for that date
Job description version (date of physician approval)	Written physician sign-off	Confirms the active JD covers the tasks performed
Supervisor confirmation	Daily log or timesheet counter-signature	Documents real-time oversight of hours and tasks

This structure makes disqualifying a day visible in real time. If hours worked exceed hours approved in the same row, the discrepancy is immediate — not discovered at packet assembly six months later.

For Washington SAW, the attending provider must approve the transitional job description in writing, and the employer should submit that job description to the provider as early as possible rather than waiting until the application phase. (WA L&I Complete Stay at Work Guide, 2024) The approved job description is a prerequisite, not supporting documentation — logging eligible days before it exists creates an uncurable gap.

For a full breakdown of what goes into a complete SAW packet, see the WA SAW Reimbursement Packet Checklist. For the broader program parameters — the 120-day cap, the 50%-of-base-wages calculation, and the one-year filing deadline — see the Washington Stay-at-Work Reimbursement Guide.

---

Approved-Dates Tracking Across Multiple Concurrent Cases

The tracking discipline described above is manageable for a single claim. It becomes structurally unstable when three or more transitional cases run simultaneously, each with different restriction end dates, different physician-approved job descriptions, and different approved-hours ceilings.

At that volume, a paper log or a single shared spreadsheet will eventually produce a condition where:

• Two cases share the same supervisor, and the supervisor applies one worker's approved hours ceiling to the other worker's timesheet.
• A restriction renewal for one case is filed correctly but recorded in the wrong case's folder.
• One case's day count hits the program cap but continues accruing — adding ineligible days that inflate the apparent total and complicate the packet.

The Return-to-Work Case Management Guide covers the broader coordination framework for managing concurrent cases. For state program parameters beyond Washington — Oregon's EAIP, Texas's bona fide offer rules, and Ohio's transitional work grants — the State Reimbursement Programs Hub organizes the comparison.

If you are managing five or more concurrent transitional cases and tracking them in a spreadsheet, the structural risk is not the spreadsheet's age — it is the absence of a case-state model that enforces the three eligibility conditions in real time rather than relying on a coordinator to check them manually across every row, every day.

---

What to Do Before the First Day of Light Duty

Approved-dates-only tracking is most effective when the log structure is in place before the worker returns, not constructed retroactively. A pre-return checklist for every transitional case:

1. Obtain the physician's written approval for the specific job description — tasks, location, weight limits, hours — before the worker's first day back. (WA L&I Complete Stay at Work Guide, 2024)
2. Record the approved hours ceiling in the day log template for this case.
3. Note the restriction period end date and set a review task for five business days before it expires.
4. Confirm the supervisor responsible for daily hour verification has the approved ceiling in writing.
5. Establish the log structure — date, hours worked, hours approved, JD version, supervisor confirmation — and commit to completing it each workday, not weekly.
6. Note the one-year application deadline from the date the light-duty work will conclude, and calendar a packet-assembly trigger date well before it. (WA L&I, 2025)

The Transitional Duty Case Tracking Workbook is structured around this pre-return setup, with a per-case day log that joins the four data streams above and flags when hours approach or exceed the approved ceiling.

---

Start Tracking the Right Way

Approved-dates-only tracking is not a filing strategy — it is a real-time operational discipline that determines which days the program will reimburse before the application is ever assembled. The coordinator in the opening scenario recovered fifty of sixty-two days. With a joined log in place from day one, the number would have been sixty-two.

If you are managing transitional cases across multiple claims and want a system that enforces eligibility conditions at the case level rather than at packet-assembly time, start a free trial of Transitional Duty Manager and see how the day-log structure maps to your current cases.