Why this matters for your practice
Non-face-to-face work is where allied health practices most often leave money unbilled or, at the other extreme, bill time that does not survive scrutiny. From 1 July 2026 the problem has a number attached to it. Before that date, travel, report writing, non-face-to-face time and the session all arrived under the same item number, so the mix was invisible in claim data. Now each is a separate row, which means your ratio of direct service to travel, reports and non-face-to-face time can be calculated for your practice, compared against every other provider in your discipline, and sorted. Nobody has to audit you to see it.
The point is not to claim less. Clinically required preparation, participant-specific reports and care coordination calls are legitimate supports, and the _NF item exists to pay for them at the full hourly rate. The point is to make sure each claim sits against the right item, is authorised by the service agreement, and is backed by a note that explains what you did and why it helped that participant.
One complication sits underneath all of this. The claiming rules are still those in the 2025-26 Pricing Arrangements and Price Limits, because the NDIA has not republished that document for 2026-27. Apply the 2025-26 non-face-to-face conditions, price at the 2026-27 rate, and document the basis of each claim. The 2026-27 conditions have not been reissued, and the NDIA has published no timeline for doing so.
What counts as a non-face-to-face support?
Non-face-to-face billing is allowed only for activities 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.
The NDIS expects providers to use professional judgment about what is reasonable and necessary. The practical test is whether a reasonable person looking at your time records would agree that the activity directly helped that specific participant receive a better service. That test is the boundary, and it is the one an assessor will apply to your invoice.
Reports are split across two items from 1 July 2026. An NDIA requested report is claimed against the discipline's _RR item at the full hourly rate, and other participant-specific report writing is claimed against the _NF non-face-to-face item. The distinction matters, because putting an NDIA requested report through _NF is a claim against the wrong item.
| Billable as non-face-to-face | Not billable |
|---|---|
| NDIA-required assessment reports and functional capacity assessments | Booking and cancelling appointments |
| Progress reports updating a participant's goals and support needs | Processing invoices |
| Phone calls and emails with the participant, family, support coordinators or other treating providers about that participant's supports | Writing generic template policies |
| Case meetings with other providers coordinating a specific participant's care | Sector-wide professional development |
| Clinically required preparation such as preparing a program | Business development and internal meetings |
| Training junior staff |
Which item does non-face-to-face time go against?
Non-face-to-face time goes against the discipline's _NF item, claimed at the full hourly rate. From 1 July 2026 each allied health discipline has six separate line items: direct service, cancellation (_CA), non-face-to-face (_NF), provider travel (_PT), NDIA requested reports (_RR) and telehealth (_TH). Claiming non-face-to-face time against the direct-service item is now a rejected claim, not a judgement call.
If the report is one the NDIA requested, it goes against _RR at the full hourly rate. Everything else participant-specific, from progress reports to care coordination calls, sits under _NF. For the mechanics of how these identifiers work, see the support item number entry.
What must the service agreement say?
Service agreement disclosure is a precondition, not a formality. 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. The 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. A clause that says "non-face-to-face supports may be claimed" without naming the activity, the rate or the expected frequency is not enough to support an invoice.
Charging a new or updated rate without a signed, updated service agreement is a breach of the NDIS Terms of Business. The NDIA is explicit that providers must discuss proposed changes with the participant and that the participant must agree before the change is made. Participants also have the right to receive their service agreements in a format they can understand.
What the regulator or assessor expects
Write progress notes at the end of each session while the details are fresh, and link each note to the NDIS goal or support item it relates to. For 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. Treat every invoice as something that might need to be explained to an auditor.
The scrutiny is not hypothetical. A Risk-Based Regulation Prioritisation Model rolled out in October 2025 now guides which providers get looked at first, and 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. Complaints received by the NDIS Commission grew from 1,422 in 2018-19 to 29,054 in 2023-24, and the Commission accepted all 10 of the ANAO's 2025 recommendations, including strengthening its compliance and enforcement processes.
If the NDIS Commission or a compliance audit finds that 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. Separately, under the National Disability Insurance Scheme Act 2013 a payment a provider was not entitled to can be recovered as a debt.
Unregistered providers are not exempt. 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, but must still meet the same requirements around service agreements, documentation, and reasonable and necessary support.
Common mistakes
Billing administration as non-face-to-face. Booking appointments, processing invoices and chasing payments are operational costs of running a practice, not service delivery for a participant. They do not become billable because they took time away from clinical work.
Billing legitimate participant work with no service agreement clause behind it. The activity may be exactly the kind of thing _NF exists for, but if the service agreement does not name the activity, the rate and the expected frequency, the invoice has no contractual basis.
Putting NDIA requested reports through _NF instead of _RR. From 1 July 2026 these are separate items, both at the full hourly rate, but the identifier matters. A report the NDIA requested belongs on _RR.
Recording time but not benefit. A note that says "45 minutes, phone call with support coordinator" records effort, not value. The note needs to say what was discussed and how it benefited the participant's NDIS supports.
Assuming a 2026-27 condition that has not been published. The 2026-27 PAPL rules document remains unpublished as at 3 September 2026. The working reference is the 2025-26 PAPL, applied at 2026-27 rates. Do not treat a condition you have not read as settled.
Treating a high non-face-to-face ratio as invisible. The ratio is now computable from claim data and comparable across your discipline. A high ratio is a risk signal rather than a breach in itself, but it is visible whether or not anyone audits you.
Frequently asked questions
What is non-face-to-face support under the NDIS?
Non-face-to-face support is clinically required activity away from the participant, such as preparing a program. It is claimable only when it is directly related to the delivery of a specific disability support to a named participant, and it must be authorised in that participant's service agreement.
Can NDIS allied health providers bill for report writing?
Yes. NDIA-required assessment reports, functional capacity assessments, and progress reports that update a participant's goals and support needs are billable. From 1 July 2026 an NDIA requested report goes against _RR, while other participant-specific report writing goes against _NF, both at the full hourly rate.
Is booking appointments or processing invoices billable under the NDIS?
No. Booking and cancelling appointments and processing invoices fall under the operational cost of running your practice, not service delivery for a participant. They do not qualify as non-face-to-face supports even though they occupy clinician or administrator time.
Do I need the service agreement to mention non-face-to-face time before I bill it?
Yes. The service agreement must describe the types of non-face-to-face supports you may deliver and charge for, at what rate, and roughly how often. Charging without that agreement in place, or at a rate the participant has not agreed to, is a breach of the NDIS Terms of Business.
Which item do I claim non-face-to-face time against?
The discipline's _NF item, at the full hourly rate. If the report was requested by the NDIA, claim it against _RR. Claiming non-face-to-face time against the direct-service item is a rejected claim from 1 July 2026.
Is there a limit on how much non-face-to-face time I can claim?
No sourced cap exists, either in hours or as a proportion of direct service. The constraint is the test that the activity directly relates to a specific participant's support, plus what the service agreement authorises. A high ratio of non-face-to-face billing is a visible risk signal, not a breach in itself.
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