The National Disability Insurance Scheme (NDIS) is evolving, and so are the demands on allied health providers. With therapy rates frozen at $193.99/hour since 2019 and rising business costs—insurance up 30%, wages, and CPD—many providers are rethinking how they bill for essential but previously unbilled tasks like preparation, clinical note-writing, and resource development. Social media platforms like LinkedIn are abuzz with discussions about this shift, as providers seek to sustain high-quality, participant-centered care amidst NDIS pricing constraints. But with some questioning whether tasks like writing clinical notes are billable, what’s the lay of the land? Here’s how allied health providers can charge for these tasks while staying compliant with NDIS rules, ensuring fairness for participants and viability for your practice.

The Context: Why Providers Are Reassessing Billings

Allied health providers, including speech pathologists, occupational therapists, and physiotherapists, often spend significant time on non-face-to-face tasks critical to therapy outcomes. These include:

Preparation: Reviewing client notes, planning sessions, and organising tools to tailor interventions.
Clinical Note-Writing: Documenting progress, updating NDIS reports, and sharing insights with stakeholders like parents or teachers.
Resource Development: Creating visual aids, social stories, or therapy-aligned activities.

Historically, many providers absorbed these costs under Medicare’s bundled model or NDIS’s frozen rates, but rising expenses and the NDIS Pricing Arrangements and Price Limits 2025-26 (effective 1 July 2025) are pushing a shift. The NDIS therapy rate ($193.99/hour for most disciplines, $183.99/hour for physiotherapy/podiatry) hasn’t kept pace with inflation, and travel rate cuts (50% of hourly rate, capped at 30 minutes each way) add pressure, especially in regional areas. Providers like those surveyed by Back to Basics Health Group report that unbilled tasks threaten financial sustainability, particularly for mobile or rural services.

NDIS Rules: Can You Bill for Clinical Notes and Non-Face-to-Face Tasks?

The NDIS Pricing Arrangements and Price Limits 2025-26 explicitly allow billing for non-face-to-face tasks, including clinical note-writing, preparation, and resource development, under specific conditions:

Directly Related to Participant Goals: Tasks must support the participant’s NDIS plan, such as writing progress notes for NDIS reporting, preparing tailored therapy plans, or developing resources (e.g., visual schedules) to meet goals like improved communication or self-regulation.
Reasonable and Necessary: Time billed must be justifiable, proportionate, and linked to outcomes. For example, notes shared with parents or teachers to align with an Individual Education Plan (IEP) are billable if they advance the participant’s goals.
Agreed in the Service Agreement: Participants or nominees (e.g., parents) must consent to billing for these tasks, clearly outlined in the service agreement.

Billing Specifics:

Non-face-to-face tasks are billed at the standard hourly rate (e.g., $193.99/hour for speech pathology, $86.79/hour for therapy assistants) under the relevant support category, such as Capacity Building – Improved Daily Living Skills (15_001_0128_1_3).
The NDIS rejected a proposed 10-minute billing increment, so providers must bill in decimal hours (e.g., 0.33 hours for 20 minutes of note-writing).
Documentation is key: Providers must record how tasks contribute to NDIS goals to justify billing during audits.

Addressing Misconceptions: Some providers and participants mistakenly believe clinical note-writing is unbillable, likely due to confusion with Medicare’s bundled model or outdated NDIS practices. However, the NDIS Pricing Arrangements confirm that progress notes, NDIS reports, or goal updates are billable if participant-specific and agreed in the service agreement. For example, Back to Basics Health Group notes that writing notes is “critical to success” and billable when it supports therapy outcomes.

Industry Trends: Adapting to Financial Pressures

Allied health providers are increasingly restructuring services to bill for non-face-to-face tasks:

Extended Session Models: Providers like Back to Basics Health Group use 70-minute sessions (45 minutes face-to-face, 25 minutes for notes/planning) at $226.32 for speech pathology/OT, ensuring all work is compensated. At Whiz Kids we have made explicit our charging practices, including charging for notes, resource development and planning.
Transparent Billing: Conway Consulting Group advises assessing revenue from travel vs. face-to-face services and explicitly billing for preparation and documentation to maintain viability under 2025-26 pricing changes.
Advocacy Push: Speech Pathology Australia (SPA), Occupational Therapy Australia, and the Australian Physiotherapy Association have criticized NDIS pricing cuts, arguing they threaten service delivery, especially in regional areas like the Kimberley or Pilbara. They advocate for fair billing practices, including non-face-to-face tasks, to reflect the true cost of care.

These changes align with the 2023 NDIS Review’s call for participant empowerment and transparency, encouraging providers to justify services through clear documentation and stakeholder collaboration, reducing adversarial planning.

Challenges and Risks

Participant Pushback: Families may question charges for non-face-to-face tasks if not clearly communicated. Transparent service agreements and explanations (e.g., how notes support IEP goals) are critical to maintain trust.
Regional Inequities: NDIS travel rate cuts and frozen therapy rates disproportionately affect rural providers, as noted by Connect Paediatric Services in Karratha. This risks reducing access for remote participants, potentially breaching the Disability Discrimination Act 1992.
Fraud Concerns: Media reports (e.g., A Current Affair) highlight NDIS fraud, raising scrutiny on billing practices. Providers must ensure robust documentation to avoid perceptions of overbilling, aligning with the NDIS Review’s focus on transparency.

How to Stay Compliant: Actionable Steps for Providers

To bill for non-face-to-face tasks like clinical notes while meeting NDIS requirements:

Update Service Agreements: Clearly outline non-face-to-face tasks (e.g., preparation, note-writing, resource development) in service agreements, specifying how they support NDIS goals. Obtain participant or nominee consent before billing.
Communicate Value: Explain to families how tasks like notes or planning enhance outcomes (e.g., aligning therapy with school IEPs). Use parent-friendly formats to demonstrate transparency.
Document Thoroughly: Record time spent on non-face-to-face tasks, linking them to specific NDIS goals (e.g., communication gains). Retain evidence for NDIS audits, such as notes shared with stakeholders.
Bill Accurately: Use decimal hours (e.g., 0.25 hours for 15 minutes) at the standard rate ($193.99/hour for therapy, $86.79/hour for assistants). Ensure tasks are billed under the correct support category (e.g., 15_001_0128_1_3).
Engage with Professional Bodies: Join SPA’s NDIS working group (policy@speechpathologyaustralia.org.au) or Allied Health Professions Australia (admin@ahpa.com.au) to advocate for fair pricing that includes non-face-to-face tasks. Share your billing model as a case study.
Monitor NDIS Updates: Regularly check the NDIS Pricing Arrangements and Price Limits 2025-26 (ndis.gov.au) for changes to non-face-to-face billing rules, especially post-1 July 2025.
Advocate for Equity: Participate in NDIS consultations (engage.dss.gov.au) to push for sustainable funding, particularly for regional/rural services, ensuring access for all participants.

Building a Sustainable Future

Billing for previously unbilled tasks isn’t just about keeping your practice afloat—it’s about valuing the expertise and effort allied health providers bring to participant outcomes. Our university training in allied health, teaches us to prioritise people over profit, and we deliver high-quality care as equitably possible in the places we live and work. NDIS pricing pressures demand smarter admin and IT to stay sustainable. As Carmen Lawrence, WA’s first female Premier, said, “Politics is not just about power; it’s about making a difference.” Learn more about her story on our website where the fraud of the Burke government’s WA Inc. scandal wrecked countless lives. The strength and integrity of this glorious human and her stand against that corruption at great personal cost is a source of inspiration. Let’s shape a NDIS that champions our communities, our relationships, our knowledge – we are all mothers and daughter, fathers and sons, cared for and carers, strong and weak, empowered and powerless, lovers and dreamers.

Sources:

NDIS Pricing Arrangements and Price Limits 2025-26 (2025). National Disability Insurance Agency. Back to Basics Health Group (2025). July 2025 Price Changes Explained.
Conway Consulting Group (2025). NDIS Pricing Changes Confirmed for July 1. conwaygroup.com.au.
Occupational Therapy Australia(2025). Allied Health NDIS Price Cuts Joint Public Statement. otaus.com.au.
ABC News (2025). Allied Health Providers Say NDIS Price, Travel Review Will Hurt Vulnerable in Kimberley, Pilbara. abc.net.au.
NDIS Review (2023). Working Together to Deliver the NDIS. Commonwealth of Australia.

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