Despite being complimented by Davies for his much improved fitness, McGugan found himself on the bench in the first half of the 2009–10 season, with Paul McKenna, Guy Moussi and Radosław Majewski all being preferred ahead of him. He also missed six weeks after sustaining a fractured cheekbone in a defeat to Watford. He was limited to just six league starts over the campaign, and though Forest qualified for the play-offs, McGugan made only a cameo appearance in the semi-final defeat to Blackpool.