Introduction
As more participants choose plan-managed funding, Plan Managers have effectively become the gatekeepers of NDIS claims. They’re under tight scrutiny and are in the position of having to chase the provider to pay back funds that have been erroneously claimed. If a provider submits an invalid claim, the NDIA actually withholds payment to the Plan Manager. This means the Plan Manager’s business carries the financial risk until they can recover the funds from the provider.
Along with the challenges of NDIS pricing and the policy and rule changes that come with the PAPL, comes the question of how to invoice for the best chance of efficient payment. With most of our Participants being Plan Managed, Plan Managers are also learning (just like we are) how the new rules apply and what evidence is required to pay invoices. When invoices are prepared in a way that answers those questions upfront, without clarification being required, everyone is happy.
We asked some Plan Managers for their perspective of how we can get our invoices right, and what other things we can do to work together to make everyone’s job easier. We thank Freedom Plan Management particularly for their time and patience as what started as just a few questions turned into many, many more questions as our conversation went along over the course of a week.
1. Do your best to know the rules
Just this week I have had my own experience with where my interpretation of the way that a support could be delivered and claimed has differed to others. It happens. However, doing your best to understand what you can and can’t claim for, and how it needs to look on your invoice will put you in the best position to have that invoice processed quickly, supporting your cash flow and not adding to your admin costs when it bounces back requiring changes.
2. Formatting invoices
A. Qualifications
Stating the qualifications of the treating professional on the invoice is not mandatory but it is extremely helpful, especially if the claim is for the ‘Other Professionals’ line. We hear that many PMs have received invoices from non – Allied Health professionals claiming what they are doing is ‘therapy’ when it clearly is not. Remove the ambiguity and pop the quals on there. Some people use their AHPRA or Medicare provider number as an option for this too.
B. Allied Health Assistant
Some Plan Managers are asking for the qualifications of the person who is supervising the AHA as this is how the PAPL is worded. Honestly, I think this is a good thing, as AHA’s are supposed to be working to a Therapy Plan that has been signed off by an AHP and this adds an extra safeguard for that.
C. Date Formatting
Some Plan Managers are implementing AI to read their invoices and the date of service for this seems to need to be in DD-MM-YYYY format. It’s logical to assume the use of AI will only continue to expand, so if you are using other formats to indicate the date of service, it’s probably worth switching to a numeric only format going forward.
D. Pricing using the hourly rate as the base number
Your claiming must be written as a quantity of units or hours. Some Plan Managers are receiving invoices denoted in 1 or 6-minute blocks – the message is clearly ‘please don’t do this’. Use the hourly rate, for example 193.99 and multiply that by the time, for example a 45-minute session would be 0.75 x 193.99 or a 90-minute session would be 1.5 x 193.99.
Also, please round to 2 decimal places at the most.
E. Group Pricing / Programs of Support
Group claims must include the ratio of therapists to Participants. I was shown an example of an invoice that was successfully claimed under POS, which set out what was included in the amount — such as non-F2F planning and preparation, post-session non-F2F time, and the length of the F2F session — as well as noting the therapist-to-child ratio (x therapists to y children). The amount was then listed against the relevant line item as a portion of the hourly rate (which may be less than or greater than 1). It’s a long-winded description, but in my view, if that’s what it takes for the invoice to be processed quickly, then so be it.
F. Capped Priced Programs
While it’s ideal for us to package a product that includes report writing, non-face-to-face time and face-to-face time, Plan Managers generally can’t process claims this way (with the exception of Program of Supports).
For example, while we might love to have a menu of products such as this below:
Assessment includes face to face time, non-face to face scoring and analysing time, report writing, research time, communication with broader team plus review in three months time = 6 hours of funding
Plan Managers simply can’t process an invoice that looks like this. The items that were ACTUALLY delivered need to be separated out and those that are in the future cannot be claimed in advance.
G. Separate out your items
The Agency require Plan Managers to put claims through with separate line items that include – face to face time; non face to face time; report writing, travel and mileage (non-labour travel). We imagine that this is relevant to a data collection exercise by the Agency rather than a compliance check by Plan Managers.
H. Include your contact details
Plan Managers tell us that an astounding number of invoices do not include contact details for you which makes it very difficult for them to let you know if something needs further clarification. I suggest you get your phone number and email onto that template.
I. Use the Line-Item code
This is not mandatory – but why not make it easy for the Plan Manager to see which part of the plan you are drawing from? Add the relevant line-item codes (from the NDIS Price Guide) to your accounting software / CRM invoice templates where you can. If not, your item description needs to be extremely clear so that the PM can easily see what you are claiming for and where on the Plan it needs to come from.
3. Invoice Daily
With funding periods now in place, if you’re not invoicing daily you risk rejection due to funding being exhausted when a period ends. Invoices are processed in the order that they are received. We are still not sure whether they will be paid after those funds roll over into the next period. Invoice. Daily.
4. Replacement Supports
The Plan Manager cannot approve a claim for a replacement support if it has not been approved by the Agency. A letter of support from an AHP to a Plan Manager will not support the payment of that claim. Any support that is on the ‘NO’ list will automatically be declined unless the Agency has given clear written approval. Your invoice for the writing of the report or letter to the Plan Manager may still be processed but those funds would have been better spent following the correct Replacement Support process.
5. Reconcile your accounts
Plan Managers have expressed frustration at their inboxes being filled with reminders for claims that have already been paid. Reducing these would go a long way to improving the provider–Plan Manager relationship (she types with guilty fingers…).
6. Service Agreements
Some Plan Managers have indicated that they no longer have the resources to support budget management against individual service agreements, while others still have software that allows them to do so. The suggestion is that Service Agreements are now as important as they ever have been (particularly in light of the Section 33 changes) even as a place to stop and chat to your clients about the budget allocation to your business as opposed to the other businesses who are drawing from the same line item. If you are working with a Plan Manager who will do their best to monitor a budget against your Service Agreement, then send it along. At least if they see straight away that the funding will not support what has been agreed to they can let you know.
7. Client Data
A Plan Manager can no more provide you with client data (like what services the Participant needs) than you can talk to them about your clinical work. The request is to please stop asking them – and ask your clients directly.
8. Disability Related Health Supports
These were supposed to be leaving the PAPL this year but have remained. However, Plan Managers are telling us that they can only process these claims if they are written directly into a Plan. No more using this item if Capacity Building budget has been exhausted.
Last but not least, we know that it’s frustrating when claiming processes that were working before are no longer working. Let’s try and remember that Plan Managers are playing catch up just as much as we are and their businesses (just like ours) are also carrying more risk than they ever were. Conflict will not get you paid faster. Working together as best we can will move us towards a more efficient payment system.
Final Note
Getting your invoicing right is just one part of running a strong Allied Health business. If you want to see how your business stacks up across the bigger picture, take our Allied Health Biz Quiz today and find out.
