Tuesday 13 October 2026  •  By Timothy, CPA — Managing Director, Professional Financelink (PFL)

From Thursday, an NDIS Claim Older Than 90 Days Can Sit for Up to 28 Days Before It Is Paid. Here's the Weekly Report That Sees It Coming

An unbilled-services ageing report is a cash-flow control, not a billing chore — and it is now the cheapest insurance an NDIS provider can buy.

On 5 October the NDIA published a short notice with a disproportionate consequence. From 15 October 2026, claims submitted more than 90 days after a support was delivered get extra integrity checks, and those claims may be held for up to 28 days while the checks are done. The agency may ask for more information or evidence before an older claim is paid.

Read that as a finance person rather than a billing person. Nothing about your entitlement has changed. What has changed is the timing distribution of your receipts. A claim that used to convert to cash on a predictable cycle can now take up to four weeks longer, and because the notice says older claims may be held, you find out which ones only after you have submitted them.

For a provider carrying a few weeks of payroll in reserve, that is an inconvenience. For a provider funding fortnightly SCHADS payroll out of claim receipts, a 28-day hold on an unknown share of a month's billing is the kind of thing that can turn a tight week into a facility call.

Two different 90-day rules, and you need to keep them apart

There are now two separate things in the NDIS environment with "90 days" in them, and conflating them leads to the wrong operational response.

The first is the one starting Thursday: an administrative integrity check. For now, claims older than 90 days can still be submitted. They may be held and examined, and may require supporting evidence. The NDIA's notice lists no exemptions, and states that where a claim is rejected the reason will be given.

The second is the statutory claim window introduced by the NDIS Amendment (Securing the NDIS for Future Generations) legislation, which passed Parliament on 19 August 2026 and requires claims to be made within 90 days of service delivery. The NDIA's own page on the new laws lists it under changes from December 2026 — "Claims must be submitted within 90 days of delivering a support" — and 1 December is the start date in general use. What that page does not yet set out is the operational detail, including how supports delivered before the start date will be treated, so confirm the detail with the NDIA before you build a hard stop into a system. We looked at the window itself in this earlier piece.

The practical point: one rule delays payment; the other puts the claim itself at risk. Both are solved by the same operational habit, which is why there is no reason to wait for the second before fixing the first.

15 October Extra integrity checks begin on claims submitted more than 90 days after a support is delivered

up to 28 days How long an older claim may be held while those checks are completed

The report most providers don't have

Almost every NDIS provider can produce an aged receivables report. Far fewer can produce an aged unbilled services report — services delivered, evidenced in a roster or progress note, and not yet converted into a claim.

That is the gap where the 90-day exposure lives. Receivables ageing starts when you claim. The clock the NDIA is now watching starts when you deliver. If the only ageing report in your pack starts at the wrong event, your reporting is structurally blind to the risk.

The report itself is not complicated. One row per delivered, unclaimed service. Minimum columns: service date, days since service date, participant or plan reference, support item, dollar value, the reason it is unclaimed, and who owns clearing it. Then bucket by age.

The buckets are where the judgement sits, and I would set them tighter than the rule:

0–30 days. Normal. Watch the total, not the lines.

31–60 days. Investigate the reason, not the claim. Something is blocking conversion — a missing note, an unapproved timesheet, a service agreement question, a plan funding query. The pattern across this bucket is a process diagnosis.

61–90 days. Escalation bucket. Everything here needs a named owner and a date. This is the last window in which action is cheap.

Over 90 days. Assume a hold of up to 28 days. Move the expected receipt in your cash forecast accordingly, and make sure the supporting evidence is attached and findable before the claim goes in, not after someone asks.

The number that actually matters

Produce one figure from this report every week and put it in front of the executive: the dollar value sitting between day 60 and day 90. Not the total unbilled. Not the over-90 balance, which is already a problem you cannot prevent.

The 60-to-90 bucket is the only part of the population you can still influence. It is a forward-looking number in a pack otherwise full of backward-looking ones, and it has the useful property of being actionable by someone other than the finance team — which is what makes it survive as a weekly discipline rather than a monthly report nobody reads.

If you want a second figure, take the share of last month's claims that were submitted more than 90 days after delivery. That tells you what proportion of your revenue is now exposed to a 28-day hold, which is the input your cash forecast actually needs.

Where AI does the matching, and where a person signs

The hard part of this report is not the layout. It is that the delivered-services record and the claims record live in different places and rarely share an identifier. Reconciling a month of rosters or progress notes against a month of claim lines is high-volume comparison work across two inconsistent datasets — which is precisely the category where AI-assisted matching earns its keep.

Used well, it does three things: match service records to claim lines and produce the unmatched residue; normalise the dates, participant references and support items into one layout so the comparison is possible at all; and classify the unmatched items by apparent reason so the 31–60 bucket arrives pre-sorted into a process diagnosis.

What it must not do is decide that an unmatched line is immaterial, or clear an exception without a person seeing it. Treat every output as a proposed exception list, not a conclusion — the same approval boundary we drew around supplier statement reconciliation. The matching is the labour. The sign-off is the control, and the control is the part the NDIA will eventually ask about.

There is a specific trap worth naming. A matching tool that is allowed to "resolve" near-misses will quietly close the very lines you most need to see, because the hardest items to match are usually the ones with a genuine documentation problem underneath. Configure it to surface ambiguity rather than absorb it.

Before any participant data goes into an AI tool: service records, progress notes and claim lines contain participant information. Confirm in writing whether the vendor trains its models on customer inputs, what it retains, and for how long. The safest posture is a tool where your data is not retained for training. The Office of the Australian Information Commissioner's guidance goes further for publicly available generative AI tools: as a matter of best practice, do not enter personal information into them at all, and particularly not sensitive information. Where you cannot establish what a vendor does, strip participant identifiers before the data leaves your systems, or keep the matching inside platforms you already control.

Don't solve this by claiming earlier than you can evidence. The predictable wrong response to a 90-day clock is to push claims out before the supporting documentation exists. That converts a timing problem into a compliance problem, and the seven-year record-keeping period for providers under the new NDIS laws means the evidence has to still be there long after the claim is paid.

What to do before Thursday

Three things fit in a day. Pull every delivered service not yet claimed and age it from the service date. Identify the dollar value already past 90 days, because that may be submitting into a hold from Thursday and your forecast should say so. Then put the 60-to-90 figure on next week's agenda with a name against it.

The reporting pack change can follow. The number has to exist first.

This post is general commentary based on publicly available information and does not constitute legal or tax advice. Always seek independent professional advice before acting.

Related reading: The NDIS claim window is set to fall to 90 days  •  Your NDIS claims are registered — are they reconciled?  •  Reading the new NDIS Act as a schedule of revenue events

Do you know the dollar value of services you've delivered but not yet claimed?

If that number only appears after it becomes a receivable, your reporting starts the clock at the wrong event. PFL provides senior-level outsourced finance, management reporting, and AI automation for Australian NFP, NDIS, and SME organisations — including building the unbilled-services view and the weekly rhythm around it.

Talk to PFL →

Timothy, CPA is Managing Director of Professional Financelink (PFL), providing senior-level outsourced finance, management reporting, and AI automation for Australian NFP, NDIS, and SME organisations. 20+ years in finance leadership across NFP, NDIS and SME.

Sources

• NDIA — Increasing integrity checks on older claims (5 October 2026)
• Department of Health, Disability and Ageing — NDIS Amendment (Securing the NDIS for Future Generations) Bill 2026 fact sheet (May 2026)
• NDIA — Securing the NDIS for future generations (page current as of 1 October 2026)
• Office of the Australian Information Commissioner — Guidance on privacy and the use of commercially available AI products

Tomorrow: Victoria's new Working with Children Connect obligations start on 19 October, and they quietly turn your staff register into audit evidence.