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Fraud & Compliance: Your Responsibilities As Providers


At the end of March, the NDIA made changes to how it processes claims submitted for payment. This was part of a movement by the NDIA to reduce the risk of fraud and to better identify non-compliance in invoicing. 

While this has been well covered in previous blogs, the main takeaway from this is that invoice processing times have increased. For First2Care, this means that our average turnaround time on invoices has increased to payment within five business days of receiving invoices. We have also been working hard to implement procedures to reduce non-compliant invoices being submitted to the NDIA. 


What is fraud and non-compliance? 

Fraud is the willing and intentional act to submit invoices that do not accurately reflect services provided. This could be by invoicing for supports not delivered, or inflating the number of hours of work given. 

Non-compliance is the unintentional errors on an invoice that results in them being inaccurate. A significant majority of invoices with issues are due to non-compliance, often the result of typos or forgetting to fully update an invoice template with new information. 


How can I avoid non-compliance? 

The best way to ensure invoices are accurate and contain all the necessary information is to utilise an invoice template. First2Care have put together one such template for use: Invoice_Template.pdf ( 

We have also put together a useful checklist to ensure that all relevant details are included: Provider_InvoicingChecklist_V1 copy ( 

We recommend double checking every invoice before submitting them to First2Care to ensure that all details are accurate and correct. Errors often increase processing times while we chase up correct information, resulting in slower payments. 

Ensuring a service agreement is in place with a participant allows plan managers or the NDIA to determine how supports should be delivered. Any variations from this may identify any unintentional non-compliance with invoices. 


What are the consequences of fraud and non-compliance? 

The NDIA has zero tolerance for deliberate and wilful fraudulent activity. Suspicions of fraud are investigated with perpetrators prosecuted. 

More likely, the issue at hand will be an unintentional mistake causing non-compliance. First2Care as plan managers and the NDIA both recognise that mistakes can be made. Human error can result in invoices appearing inaccurate. 

There is no punishment or reprimand for non-compliant invoices beyond the slower processing times resulting in having to chase up for accurate information. Repeated errors may result in conversations to ensure that these mistakes are identified and eliminated going forward, as the same error appearing across multiple invoices may be seen as negligent behaviour by the NDIA. 


For providers who are concerned by the NDIA’s increased determination to remove fraudulent claims within the system, the old adage hold true: those with nothing to hide have nothing to fear. Fraud is a wilful and deliberate action. 

Mistakes can happen from time to time. First2Care and the NDIA are both aware of this and are happy to work with all providers who deliver quality and legitimate services to participants on the NDIA. We can also work with providers to ensure that non-compliance is reduced by providing all the necessary resources to ensuring invoices are correct and accurate. Our templates are a great place to start. 



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