Understand October 2026 older-claim checks and the December NDIS 90-day claim window, with practical steps for psychology invoices and reports.
Educational information, not individual clinical, legal or regulatory advice. No independent review is identified for this article. Editorial policy and corrections.
Scheduled review: 24 November 2026. This is not a completed review date.
An appointment finishes, but the invoice sits in drafts. A report takes three months to complete. A corrected invoice is emailed to a plan manager, yet no one checks whether it has actually been claimed.
Every one of those gaps sits between the work you have done and the money reaching the practice. From now on, that gap needs the same attention as unpaid invoices.
Two separate changes are in play.
From 15 October 2026, the NDIA applies extra checks to any claim lodged more than 90 days after the support was delivered. Those older claims can be held for up to 28 days and the NDIA may ask for further evidence. Rejection still comes with written reasons. [1]
Then, from 1 December 2026, the Securing the NDIS for Future Generations Act 2026 shortens the time allowed to make a claim from two years to 90 days. Participants or their plan managers will need to lodge claims within that window. [2]
The October checks are not automatic rejection on day 91. They are additional scrutiny. The December change shortens the statutory claiming period, subject to the Act’s exceptional-circumstances discretion. Keep the two changes distinct and plan for both. [3]
Checked 17 October 2026. The NDIA’s Guide to getting paid still listed a two-year window when last reviewed (page current as of 12 October). The NDIA site now carries a notice that pages are being updated for the new legislation. The Government has confirmed the claim window drops to 90 days from 1 December 2026. The amending Act confirms commencement on 1 December. Section 45A(6) also provides discretion for late claims in exceptional circumstances. The operational treatment of supports delivered before commencement still needs confirmation; do not assume those supports are grandfathered. [4] [3] The workflows and reminder intervals below are practical suggestions, not NDIA rules.
The NDIA’s 5 October announcement is straightforward: claims submitted within 90 days of delivery continue through the normal process. Claims older than 90 days can attract extra checks and may be held for up to 28 days. If a claim is rejected, the NDIA says it will explain why. [1]
Submitting inside 90 days does not guarantee payment. The claim still has to be accurate, valid and consistent with the support and funding rules that apply. [5]
For a practice the immediate job is simple: find any completed work that has not yet been invoiced or claimed, fix missing information, and follow it through to actual submission.
The announcement measures claim age from the date the support was delivered, not from the date the invoice was created. The provider payment guide also talks about a support being delivered in full. [1] [5]
For a single finished appointment the delivery date is usually clear. Work spread across several dates needs closer attention to how the service is structured and to the current claiming instructions.
Keep these dates separate:
| Date | What it records |
|---|---|
| Support-delivery date or period | When the work actually happened |
| Invoice date | When the invoice was issued |
| Invoice-received date | When the participant or plan manager received it |
| Claim-submission date | When the payment request was lodged with the NDIA |
| Payment date | When the money arrived |
Issuing an invoice today does not change when last month’s appointment occurred. Correcting an invoice also does not let you rewrite the delivery date.
For multi-stage work, get clarification if the correct delivery period or completion date is unclear. Do not assume the final report date resets the age of everything that came before it.
With plan-managed funding the practice sends the invoice to the plan manager, who then processes and lodges the claim. With NDIA-managed funding the provider submits the payment request directly. Self-managed participants handle payment and claiming themselves. [5] [6]
An email that says “sent” therefore does not prove a plan-managed claim has been lodged.
Plan-managed invoices also need a valid ABN (or a statement by supplier form if you are exempt). A missing ABN is an avoidable reason for delay. [5]
A workable process is to confirm the correct billing destination at the start of services, send complete invoices promptly, and agree who follows up missing or disputed information. Note when a correction is requested and when the revised invoice is acknowledged.
Ask the plan manager about their actual processing arrangements rather than assuming their advertised turnaround covers every invoice query or NDIA review.
For the separate question of which activities can be billed, see what psychologists can charge the NDIS for.
A report can involve interviews, assessment, scoring, liaison, drafting and a final review, all on different dates. Not every activity necessarily uses the same claiming pathway.
Separate two questions:
Timely invoicing cannot turn an ineligible activity into a claimable one. Nor does the report’s finalisation date automatically set the correct claiming date for every earlier component.
Where staged billing makes sense, explain it before the work starts. Agree the activities, estimated time, rate, budget and invoicing points. Check the current rules and the plan manager’s requirements if relevant.
The 1 December change makes this more urgent. If the 90-day window runs from each delivered component, waiting until the final report is finished before invoicing the early assessment work could push those components outside the window. Official guidance on this point is not yet clear, so ask the NDIA before relying on either interpretation.
Assessment appointments happen in July, scoring in August, and the report is finalised in September. This is only an illustration, not a ruling on claim eligibility.
The practice should keep the actual dates and durations. Before waiting until September to invoice everything, it should work out whether any eligible completed activities should be invoiced earlier and how to record a support that was delivered over time.
Do not shift July appointments to September on the invoice. Equally, do not break an incomplete support into artificial pieces simply to avoid older-claim checks. Seek clarification when the structure of the support makes the correct approach uncertain.
The NDIA requires complete and accurate records of the supports that were delivered. Relevant records include invoices, case notes, support logs and service agreements, with identifying information, delivery dates, support type and quantities. Case notes should show the activity and how it relates to the support item and the participant’s goals. [7]
For psychology work a useful internal check asks:
For practical documentation structure, see how to write psychology progress notes and the NDIS report template checklist.
Keep information secure. An evidence request does not mean the whole clinical file should be attached to every invoice. Check what has been asked for, the authority for disclosure, and the information actually needed.
Do not reconstruct records as if they were written at the time. If a later clarification is needed, label and date it accurately.
Section 45B sets default claim-record periods of seven years for NDIS providers, three for participant claimants and five for other claimants. These apply to prescribed record types, run from the claim date and can be shortened by rules. Do not assume all plan managers fall under the participant period. Check their legal role and applicable rules. Clinical-record obligations may require longer retention. [3]
These statutory categories are not a general instruction to destroy records after three years. The NDIA’s current self-management guide still advises keeping spending records for five years. Follow the applicable requirements and current guidance rather than shortening retention based on this article alone. [6]
A hold is not the same as a rejection. Establish the actual status before lodging another request.
The NDIA’s provider guide says information requests are made in writing and give at least 14 days to respond; requests for extra time should also be made in writing. Rejected claims receive written reasons. [5] If you upload claims in bulk, only the claim under review stays open; the rest are paid under normal terms. [5]
A practical response is:
Do not keep lodging duplicate claims while the original is under review. Where resubmission is required, keep a clear link between the original claim and the correction, and check whether any payment has already been made.
Section 45A(1) links payment to a compliant claim. Section 45A(6) allows the CEO to accept a late claim where exceptional circumstances justify the delay and it was lodged within a reasonable period in those circumstances. This is discretion, not a guaranteed extension. Ask the NDIA about the evidence and process; do not assume routine invoice delays qualify. The December amendment changes the time limit in section 45A(5)(a), without removing subsection (6). [4] [3]
The older-claim announcement does not decide who is liable for a particular unpaid invoice. It does not automatically make a participant responsible for a provider’s delay, and it does not cancel every unpaid contractual debt. From 1 December the Government expects participants or their plan managers to lodge claims within the 90-day window, so a delayed invoice to a plan manager becomes a real risk. [2]
The reason for non-payment, the service agreement, the communication history and the applicable law can all matter. Obtain advice when responsibility is disputed rather than treating a failed NDIS claim as an automatic instruction to charge the participant privately.
The NDIA’s current service-agreement guidance says agreements should explain payment, responsibilities and how disagreements are handled. Providers cannot use an agreement to contract out of their NDIS Code of Conduct or Australian Consumer Law obligations. [8]
Review the billing terms before a dispute arises. Include when invoices will be issued, where they go, how queries are handled, and how participants will be told about any unresolved charges.
If an unexpectedly old invoice arrives, ask for the delivery dates, an itemised explanation and any previous billing history. Compare it with the services actually received and the payments already made.
For plan-managed supports, ask the plan manager whether the invoice has been received, queried, submitted, held or rejected. For self-management, keep invoices, receipts and correspondence together and seek NDIA clarification if the payment request is unclear. The NDIA’s self-management guidance also notes possible reviews of claims submitted after 90 days. [6]
Do not assume an old invoice should simply be charged against the current plan because it arrived during that plan. Ask which funding arrangements apply to the actual delivery dates. A budget that is visible today does not answer that question.
If the dispute risks interrupting essential support, ask the provider to discuss continuity arrangements while the billing issue is sorted out. Seek independent support if needed.
These intervals are suggested practice-management reminders. They are not official grace periods or guarantees of payment.
| Age from recorded support delivery | Suggested internal action |
|---|---|
| Within a week | Aim to send complete invoices for completed eligible work to the correct recipient |
| By 30 days | Confirm receipt and investigate anything still unsubmitted or queried |
| 60 days | Investigate anything still unsubmitted or unresolved |
| 75 days | Allocate responsibility for missing information or corrections |
| 85 days | Follow up urgently and confirm whether submission has occurred |
| Over 90 days | Verify claim status, assemble supporting evidence and respond to any NDIA request. From 1 December, check whether the claim can still be made |
Leaving first follow-up until day 85 gives a plan manager very little time to resolve errors and lodge the claim. Use that reminder as a final escalation, not the start of routine follow-up. Sending invoices within a week is a suggested internal target, not a statutory invoicing deadline.
An invoice-age register can include a secure participant reference, service dates, invoice number, amount, management type, submission date, status, evidence location and next action. Keep clinical detail out of general billing dashboards unless it is needed and properly protected.
For reports, track the age of completed activities as well as the project’s final deadline. For plan-managed services, track submission separately from invoice dispatch. Reconcile payments so resolved invoices do not stay in the follow-up queue.
For the broader question of whether psychology support can still be funded, see Does the NDIS Still Fund Psychology in 2026?.
If you are reviewing your documentation workflow, browse NDIS resources and the Therapist Resources topic hub. Check each resource’s purpose and licence. A template cannot establish claimability or extend a claiming deadline.
This article provides general information. It does not decide whether any individual activity is claimable or who owes a disputed invoice. Confirm current claiming instructions, the participant’s funding arrangements and relevant contractual or legal advice for a specific case.
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