Introduction

The 2026 Licence Appeal Tribunal decisions, including the Allstate admin time ruling, have established a working standard for attendant care billing: invoices must be built on contemporaneous, day-by-day records, not reconstructed after the fact. Here is the minimum standard your clinic needs to meet.

Contemporaneous Records: The Minimum Standard

A 2017 FSCO decision, combined with the 2026 LAT decisions on provider billing, establishes a clear minimum standard for attendant care and treatment invoices:

| Element | Requirement | |---------|-------------| | Date | The specific date the service was provided | | Start and end time | The exact duration, not a rounded estimate | | Service description | A specific description of the service, not a generic one | | Provider signature | Signed by the person who provided the service | | Contemporaneous | Recorded at the time of service, or within 24 hours |

This is not aspirational. It is the baseline the Tribunal expects. Invoices that do not meet this standard face an uphill battle, and the 2017 case shows they only survive in unusual circumstances.

For attendant care specifically, daily logs are non-negotiable. A weekly summary prepared on Friday from memory is not a contemporaneous record. A monthly invoice built from Form 1 estimates is not a contemporaneous record. The log must be kept day by day, service by service.

How to Set Up a Contemporaneous Logging System

You do not need expensive software. You need a system that is easy enough that people will actually use it.

1. Use a shared digital log.

A Google Sheet, a shared Excel file, or a practice management system. The format matters less than the habit. Columns: date, start time, end time, service provided, provider name, provider signature or initials.

2. Log at the point of service.

The best time to log attendant care is when it happens. A notebook in the kitchen. A phone app. A tablet next to the treatment room. The further removed the logging is from the service, the less reliable it becomes.

3. Review weekly, not monthly.

Set a recurring calendar reminder for Friday afternoon. Review the week's logs for gaps, errors, or missing signatures. Fix them while the memory is fresh, not three months later when the insurer asks.

4. Attach logs to invoices.

Submit the daily log with the invoice. It preempts questions about whether the services were actually provided and demonstrates that your clinic takes documentation seriously.

5. Never reconstruct from Form 1 documents.

Form 1 is an assessment tool for calculating monthly entitlement. It is not a billing log. Using it as a memory aid for invoice preparation is exactly the practice the 2017 decision warns against.

Conclusion

The 2017 FSCO outcome is the exception that proves the rule. The 2026 LAT billing decisions, from Allstate admin time to the HCAI invoicing rulings, all run in one direction: documentation quality determines outcomes. See the 2026 LAT decision roundup for the full pattern. Contemporaneous records are not optional, and retroactive reconstruction is not a strategy.

If your clinic or your patients' caregivers are keeping attendant care logs retrospectively, change the system now. A log written at the point of service is the difference between an invoice that survives scrutiny and one that bets everything on a procedural lucky break.