Allied health providers working under the NDIS have always had to navigate complex billing rules, but the 2025-26 pricing arrangements introduced some of the most significant changes in years. New travel claiming caps, profession-specific line item requirements, and tighter documentation standards have left many occupational therapists, physiotherapists, speech pathologists, and psychologists second-guessing their invoices. And with the NDIS Quality and Safeguards Commission running a 214% year-on-year increase in compliance and enforcement activity, getting your billing wrong has real consequences.
This guide walks through exactly what you can bill for, what you cannot, and how to make sure your claiming practices hold up under scrutiny.
The 2025-26 Price Guide Changes That Affect You Most
The updated NDIS Pricing Arrangements and Price Limits that took effect from 1 July 2025 included several changes that directly affect how allied health providers claim.
The biggest change for most practitioners is the travel claiming cap. From 1 July 2025, allied health professionals can only claim 50% of their hourly rate for travel time to and from a participant's location. That means if you charge $200 per hour for therapy, you can only claim $100 per hour for the time you spend driving there. Regional caps still apply, and providers delivering supports in rural and remote areas should check the specific arrangements for their location.
The second significant change is the end of generic "Other Professional" line items. After 31 July 2025, any invoice that used 2024-25 item codes was automatically rejected in the NDIS portal. More importantly, providers must now bill under their registered profession, meaning an occupational therapist must claim under the Occupational Therapy line items, not a catch-all professional category. This increases accountability on both sides and means your qualifications need to match what you are claiming.
Support worker rates also increased by 3.95% to reflect the SCHADS Award wage movements, including minimum wage rises and updated superannuation rates. If you employ support workers as part of a mixed-delivery model, you will need to make sure your rates and service agreements reflect the updated limits.
Non-Face-to-Face Billing: The Rules in Plain English
This is the area where the most confusion lives, and also where compliance issues are most likely to arise during an NDIS audit.
The NDIS does allow allied health providers to bill for non-face-to-face time, but only under specific conditions. The golden rule is that every billable non-face-to-face activity must be directly related to the delivery of a specific disability support to a named participant. General administration, business development, internal meetings, and training junior staff members do not qualify, even if those activities ultimately benefit your participants.
What can you actually bill for? Report writing is the clearest example. Writing an NDIA-required assessment report, a functional capacity assessment, or progress reports that update a participant's goals and support needs are all billable. Phone calls and emails with the participant, their family, support coordinators, or other treating providers are billable if they relate directly to that participant's NDIS supports. Case meetings with other providers, where the focus is on coordinating a specific participant's care, also qualify.
What cannot be billed? Booking and cancelling appointments, processing invoices, writing generic template policies, or attending sector-wide professional development are not NDIS-billable activities. Time spent on these things is real and important, but it falls under the cost of running your practice, not service delivery for a participant.
The line can feel blurry, and that is by design: the NDIS expects providers to use professional judgment about what is "reasonable and necessary." The practical test is to ask yourself whether a reasonable person looking at your time records would agree that the activity directly helped that specific participant receive a better service. If you can make that case clearly in your notes, you are on solid ground.
What Your Service Agreement Must Cover
Here is where many allied health providers trip up. Even if a non-face-to-face activity is legitimately billable, you cannot invoice for it unless your service agreement with the participant explicitly covers it.
Your service agreement needs to describe the types of non-face-to-face supports you may deliver and charge for, at what rate, and roughly how often you expect to provide them. If you want to bill for report writing at your standard hourly rate, that needs to be stated. If you intend to charge for care coordination calls with other providers, that needs to be included too.
This is also where the 2025-26 changes bite: charging a new or updated rate without a signed, updated service agreement is a breach of the NDIS Terms of Business. If you have not reviewed and updated your service agreements since July 2025, do it now. Participants also have the right to receive their service agreements in a format they can understand, so make sure your language is clear and accessible.
A compliant service agreement for an allied health provider in 2026 should include the specific supports you will deliver, the NDIS line item codes for each support type, your hourly rate or session rates, how you will handle non-face-to-face time (including report writing and care coordination), your travel arrangements and how you will charge for travel, and your cancellation policy with the relevant NDIS cancellation rule applied.
The myID and RAM Transition: What Allied Health Providers Need to Do
While it is not strictly a billing issue, the PRODA to myID and Relationship Authorisation Manager (RAM) transition affects how you access the NDIS portal to submit claims, so it belongs in any 2026 compliance conversation.
From 10 November 2025, PRODA was discontinued and all providers need to use myID and RAM to access NDIS systems. If you or any authorised staff in your practice have not yet completed this transition, you need to act immediately. Business owners and sole traders require a "Strong" identity strength in myID, which means you need a valid Australian passport or one that expired within the last three years. Workers who access the portal on behalf of your practice need to be linked via RAM with appropriate authorisation levels.
If you are still trying to log in via PRODA, you will not be able to submit claims or access participant information. Contact Services Australia or the NDIS Commission directly if you are having trouble completing the transition.
Compliance Risks That Are Attracting Commission Attention
The NDIS Commission's 2025-26 regulatory priorities explicitly include strengthened oversight of unregistered providers and sole traders, and a focus on restrictive practices compliance. But the Commission is also ramping up scrutiny of claiming practices across the board.
The Australian National Audit Office reviewed the NDIS Commission's effectiveness in 2025 and found that complaints received by the Commission have grown from 1,422 in 2018-19 to 29,054 in 2023-24. The Commission accepted all 10 of the ANAO's recommendations for improvement, including strengthening its compliance and enforcement processes. A new Risk-Based Regulation Prioritisation Model rolled out in October 2025 is now guiding which providers get scrutinised first.
What does this mean for your practice? Providers with inconsistent claiming patterns, high ratios of non-face-to-face billing, or documentation that does not support their invoices are more likely to attract attention. The Commission now has better data tools to identify anomalies across the sector, and it is using them.
The safest approach is to treat every invoice as something that might need to be explained to an auditor. Your progress notes should substantiate the time you claimed. Your service agreements should pre-authorise every type of support you are billing for. And your internal policies should reflect the current 2025-26 NDIS Pricing Arrangements.
Staying Compliant Without Drowning in Paperwork
Good compliance does not have to mean hours of extra admin. The key is building the right habits into your day-to-day clinical practice rather than treating compliance as something you prepare for separately.
Write your progress notes at the end of each session while the details are fresh. Link each note to the NDIS goal or support item it relates to. When you have a care coordination call, note the participant's name, the date, who you spoke to, what was discussed, and how it benefited the participant's NDIS supports. That takes two minutes and creates an audit-proof record. Update your service agreements whenever your rates change or you plan to add new types of billable activities.
For multi-site allied health practices, a compliance management platform can make a significant difference. Having your policies, evidence, and documentation in one place means you can respond quickly to a compliance inquiry rather than scrambling across filing systems and email threads.
ClinicComply: Compliance Made Simple for NDIS Allied Health Providers
ClinicComply is built for Australian healthcare providers who want to stay on top of their NDIS compliance obligations without it taking over their week. Track your compliance status against the NDIS Practice Standards, store your evidence in one place, manage deadlines, and generate an evidence pack when your audit rolls around.
Whether you are a solo occupational therapist or a multi-site allied health group, ClinicComply keeps your compliance current and your records audit-ready. Learn more at cliniccomply.com.au/ndis-compliance-accreditation.
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Frequently Asked Questions
Can NDIS allied health providers bill for report writing?
Yes, NDIS-registered allied health providers can bill for report writing when the report is participant-specific and required to deliver or plan the participant's NDIS supports. This includes functional capacity assessments, progress reports, and NDIA-requested assessments. The charge must comply with the NDIS Pricing Arrangements and Price Limits, and the service agreement must pre-authorise this type of non-face-to-face billing.
What is the NDIS travel claiming rule for 2025-26?
From 1 July 2025, allied health professionals can only claim 50% of their standard hourly rate for travel time to and from a participant's location. Regional loading arrangements still apply in some rural and remote areas. Providers should check the current NDIS Pricing Arrangements document for the specific travel rules that apply to their registration group and geography.
Do I need to update my service agreements for the 2025-26 price guide changes?
Yes. If your rates have changed or you have added new types of billable activities (such as non-face-to-face support), you must update your service agreements before charging at the new rates. Charging a new rate without an updated and signed service agreement is a breach of the NDIS Terms of Business.
What happens if NDIS claims are audited and documentation is insufficient?
If the NDIS Commission or a compliance audit finds that your claims are not supported by adequate documentation, you may be required to repay the amounts claimed. In serious cases, the Commission can issue compliance notices, civil penalties, or banning orders. The Commission's risk-based regulation model introduced in October 2025 means providers with unusual claiming patterns are more likely to be selected for review.
Can unregistered NDIS providers bill for non-face-to-face allied health time?
Unregistered providers working with self-managed or plan-managed participants can deliver and invoice for non-face-to-face allied health supports, subject to the NDIS Code of Conduct and applicable pricing arrangements. However, they must still meet the same requirements around service agreements, documentation, and reasonable and necessary support. The NDIS Commission's increased focus on unregistered providers in 2025-26 means compliance obligations are the same even without formal registration.
Is booking and cancelling appointments billable under the NDIS?
No. Administrative tasks like booking appointments, processing invoices, and replying to general enquiries are not NDIS-billable activities. These fall under the operational costs of running your practice. Only time spent on activities that directly support a specific participant's NDIS goals and supports qualifies for non-face-to-face billing.