From 1 December 2026 an NDIS support has to be claimed within 90 days of the date it was delivered. Until now the window was two years. The clock runs from the appointment, not from the invoice, and not from the day a plan manager gets round to lodging it. For an allied health practice that means something new: a completed session that nobody invoiced is no longer money waiting to be billed. It is money with an expiry date, and when the date passes the money is gone.
Most practices have at least a few of these sessions in the diary right now. They are marked Completed, the clinician did the work, and no invoice was ever raised against them. Under a two-year window that was an annoying reconciliation job for the end of the quarter. Under a 90-day window it is the single most expensive thing in the billing system to miss, because every other leak can still be fixed late. Here is what is changing, from the official sources, and what it does to the way a practice should run its invoicing.
What is changing on 1 December
The National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Act 2026 passed in August 2026. Among a long list of reforms, it cuts the time a provider has to make a claim for a support under a participant's plan from two years to 90 days. The Department of Health, Disability and Ageing's own summary puts it in one line: the time to make a claim will be reduced from 2 years to 90 days from 1 December 2026.
Three details matter more than the headline:
- The clock starts at the service date. Not the invoice date, not the date a plan manager receives the invoice, not the date you are paid. Ninety days from the day the participant sat in the room.
- Late claims are not expected to be paid. The published guidance allows for exceptional circumstances, which is a case to argue rather than a process to rely on.
- Older claims are already being held. Since 16 July 2026 the NDIA has applied extra integrity checks to claims lodged six months or more after the support was delivered, holding them for up to 28 days while it asks for evidence. The direction of travel was set before the Act passed.
One thing the NDIA has not yet published is how supports delivered before 1 December are treated once the new window applies. The cautious reading, and the one we would plan around, is that anything already older than 90 days on 1 December needs to be claimed before that date.
The pricing determination landed in the same quarter
The claim window is not the only NDIS change this spring. On 24 September 2026 the Minister made the first pricing determination under the new legislation, setting the maximum prices for 2026-27 in what is now called the NDIS Pricing Schedule. A further update to several support items follows on 1 December, driven by the Fair Work Commission's SCHADS award decision. If you checked your fee schedule against the July changes, it is worth checking it again now, and diarising a third look for the first week of December.
Why the uninvoiced session is the one that hurts
Think about the chain between a session and the money. The clinician completes the appointment. Someone raises an invoice. For a plan-managed participant that invoice goes to the plan manager, who lodges the claim with the NDIA and pays the practice when it clears. For an agency-managed participant the practice lodges the payment request itself. Every link in that chain has a delay, and every delay now eats into the same 90 days.
A session that was never invoiced breaks the chain at the first link. Nothing goes to the plan manager. Nothing is lodged. There is no rejection to notice, no remittance that is short, no email from anyone. The appointment just sits in the practice software marked Completed, looking exactly like the hundred sessions around it that were billed properly. In our experience of reading practice data, this is the most common leak in allied health and the quietest: a clinic can run for months with a steady trickle of sessions that were done and never billed, and nothing in the software will say so.
Under the old rules that quietness was survivable. The session would surface eventually, at a quarterly reconciliation or when a client's plan was reviewed, and the invoice could still be raised and claimed. From 1 December the same session surfaces at the same quarterly review and is worth nothing. The leak did not get bigger. The time you have to catch it got shorter.
It gets tighter again for plan-managed clients, because the practice does not control the last link. If a plan manager takes two weeks to lodge, the practice's real window is closer to 75 days. Add the normal fortnight of billing lag that most clinics run on and the comfortable margin is gone. Ninety days sounds like a quarter. In practice it is a month and a half of slack.
What to do before 1 December
- Sweep the diary now. Pull every appointment since 1 July marked Completed (or Arrived) for an NDIS-funded client and check each one has an invoice. Anything older than 90 days should be invoiced and lodged before 1 December, while the two-year window still applies.
- Invoice weekly, not monthly. A monthly billing run can leave a session 30 days old before anyone looks at it. Weekly keeps every session inside the first third of its window.
- Set an internal deadline well short of 90. Sixty days is a reasonable line: it leaves room for a plan manager's turnaround and a correction if the first claim bounces.
- Make the diary-versus-invoice check a daily habit. Our end-of-month checklist and billing audit both start with the same step: list completed appointments with no invoice. From December that check is worth running every morning, not once a month.
- Ask your plan managers how fast they lodge. You are now sharing a deadline with them. A plan manager that sits on invoices for three weeks is a plan manager you need to invoice first.
- Keep the evidence close. Session notes, service agreements and rosters are what the NDIA asks for when it holds a claim. Older claims are already being checked more closely, so the paper trail matters more than it did.
A check that software should be running for you
Everything above is a comparison between two lists your practice software already holds: appointments that were completed and invoices that were raised. Doing that comparison by hand once a month was fine when the cost of missing one was a late invoice. When the cost is the whole session, it is the kind of check that should run daily, count the days, and tell someone before the window closes rather than after.
That is what we have built into RIFT, and the product news post explains how it works: a countdown on every uninvoiced NDIS session, an alert a week before the window closes, and an honest record of any that got away. The first leak report is free and will tell you, today, how many of those sessions are sitting in your diary.