NSW physiotherapists who treat injured workers and motor crash claimants work across two schemes that both sit under SIRA but bill in very different ways. In workers compensation, SIRA sets maximum fees in a gazetted order, you need both Ahpra registration and SIRA approval, and most treatment needs insurer pre-approval.
In CTP, SIRA doesn’t designate physiotherapy fees or require practitioner approval, so you work with the insurer on treatment that meets the Motor Accident Guidelines. Mixing the schemes up can mean invoice queries, reduced payments and, once a workers compensation claim is lodged, costs you can’t recover from the worker. This guide keeps the two schemes separate, covering approvals, fee limits, invoice requirements and the 30-day submission deadline, with a worked example and the misconceptions that most often cause problems.
Why SIRA fees matter to your practice
Getting the scheme wrong can cost you money that is hard to recover. Under the 2023 practice requirements, the employer is not liable for treatment costs above the SIRA maximum. Once a worker has lodged a claim, you must not bill them directly for relevant services.
In CTP, an insurer can deny liability or decline a treatment request, which can leave the client responsible for costs.
None of this works like Medicare or NDIS billing. If you also see those clients, the Medicare item numbers Allied Health practitioners actually need and the 2026–27 NDIS annual pricing review cover those rules.
How workers compensation billing works
Approval to treat
You need general registration with the Australian Health Practitioner Regulation Agency (Ahpra) and SIRA approval to treat in the scheme. Approval requires appropriate qualifications, completing SIRA's online training, a written application, and compliance with the conditions of approval. According to a SIRA guide, the approval period is listed as three years.
Maximum fees and pre-approval
The current order commenced 1 February 2026. The date of service decides which fee applies, not the injury date. You can charge less than the maximum, but never more. Under the 2023 edition, which has been in effect since February 2024, insurers could also set lower limits
Most treatment needs insurer pre-approval, requested through an Allied Health Treatment Request (AHTR). There are exceptions. For example, up to eight consultations may proceed without pre-approval if treatment starts within three months of the injury and no physiotherapist, chiropractor, osteopath, or accredited exercise physiologist has treated it before.
From 1 October 2026, the test for new claims changed to “reasonable and necessary”, and some services may no longer be approved .
How CTP billing differs
CTP has no SIRA fee order and no SIRA approval requirement for treating practitioners. The Motor Accident Guidelines v10.1 set the limit on treatment expenses at applicable Australian Medical Association (AMA) rates. To bill for 1 unit of a specific time-based physiotherapy code (e.g., manual therapy or therapeutic exercise), physiotherapists must have performed that specific procedure for at least 8 minutes.
Check with the insurer before treating. After you request approval, the insurer has 10 days to respond in writing. Treatment before a claim is made is discretionary and limited to the first 28 days after the accident. Insurers only pay for treatment that meets SIRA's five reasonable and necessary criteria, including being directly related to the crash and cost effective.
Source and invoice checklist
| Check | Workers compensation | CTP | Source version |
|---|---|---|---|
| Practitioner approval | Ahpra plus SIRA approval | SIRA approval not required | 2026 practice requirements; SIRA health providers page |
| Fee limit | Fees order maximums by date of service | No SIRA fee; AMA rates referenced | Effective 1 February 2026; Guidelines v10.1 (published 12 December 2025) |
| Approval before treating | AHTR, unless an exception applies | Ask the insurer; 10-day response | 2026 practice requirements; SIRA motor crash fees page |
| Invoice fields | Worker name, claim number, payee details, ABN, provider name, SIRA approval number or INT0000/EXT0000 where applicable, Ahpra or professional association number, SIRA code or AMA item where applicable, cost and duration where applicable, date of service, date of invoice | Claimant name, claim number, payee details (including EFT if available), ABN, provider name, Ahpra or professional association number, date of service, SIRA code or AMA item where applicable, cost, duration where applicable | SIRA workers compensation fees page; Motor Accident Guidelines v10.1, clause 4.112 |
Sources: workers compensation invoice requirements and CTP invoice requirements (v10.1, clause 4.112). Check the invoice submission time limits for both schemes.
Under the State Insurance Regulatory Authority (SIRA) rules in NSW, health and related service providers must submit invoices to insurers within 30 days of delivering a service for both Workers Compensation and Compulsory Third Party (CTP) schemes.
An example of workers compensation invoice
Sam is a fictional warehouse worker who hurt their shoulder four weeks ago. No other physiotherapist, chiropractor, osteopath, or exercise physiologist has treated it. The insurer has issued a claim number, and today is Sam's third session.
- Confirm the treating physiotherapist holds SIRA approval and general Ahpra registration.
- Check pre-approval. Treatment started within three months and this is consultation three of eight, so the exception applies.
- Choose the code. A subsequent consultation is PTA002, with a maximum of $100.90 excl GST for services from 1 February 2026
- Complete every required field, including Sam's claim number, your Ahpra number, your SIRA approval number where applicable, the date of service, and the date of invoice.
- Send the itemised invoice to the insurer, not to Sam.
A correct invoice gives the insurer less to query. It doesn't guarantee payment, because the insurer still assesses the claim.
A few common misconceptions
- “The fees order covers CTP.”
It doesn't. SIRA doesn't designate CTP physiotherapy fees.
- “Every session needs pre-approval.”
Workers compensation has defined exceptions. Read them before booking.
- “If the insurer is slow, bill the worker.”
Not once a claim is lodged.
- “Last year's fee still applies to an old injury.”
The date of service sets the fee.
Frequently asked questions
What is SIRA and how does it regulate physiotherapy fees?
SIRA is the NSW regulator for workers compensation and CTP, and for workers compensation it publishes a gazetted fees order that sets maximum physiotherapy fees. You can charge less but never more, and for CTP, SIRA doesn't designate physiotherapy fees, so you work with the insurer on approved treatment.
Where can NSW physiotherapists find the current fee order?
SIRA publishes the current fee order and practice requirements for physiotherapy, chiropractic, and osteopathy. The 2026 document is marked ‘Effective 1 February 2026’ and sets out the requirements extracted from the Workers Compensation (Physiotherapy, Chiropractic and Osteopathy Fees) Order 2026. Check the effective date before you update your fees.
Do I need SIRA approval to treat CTP clients?
No. SIRA states that approval from SIRA isn't required to deliver treatment services in the CTP scheme. This differs from workers compensation, where physiotherapists need SIRA approval. Check whether insurer approval is required before you treat, because an insurer can deny liability or decline a treatment request.
What mistakes lead to rejected or reduced invoices?
Mistakes that can lead to rejected or reduced invoices include charging above the maximum, leaving out claim or provider numbers, treating without needed pre-approval, and applying workers compensation rules to a CTP claim. Check each of these before you send an invoice.
Getting injury-claim billing right is a repeatable process
Keep the two schemes separate, check the dated source before each fee change, and send complete invoices to the right insurer. If you're organising insurer billing alongside Medicare and private clients, see how splose supports physiotherapy practices. Solo physiotherapists can start with splose for individual practitioners.
