The Irish OT Invoice: What Goes On It, and the VAT Question Nobody Answers

What to put on the invoice

Nine fields. One line each on why it earns its place.

• Your name and CORU registration number. “Occupational Therapist” is a protected title: since 31 March 2017 only a person on the CORU register may use it, and unauthorised use is a criminal offence. Putting the number on the invoice is the cheapest proof you are the real thing, and councils and solicitors look for it.
• Your business address. Where you trade from, not where you happen to be that week.
• Your tax reference number. The number Revenue knows you by. Clients running a business will ask for it eventually, so save yourself the follow-up email.
• An invoice number, sequential, no gaps. If you ever have to explain a year’s income, a sequence with holes in it is the first thing that gets picked at.
• The invoice date.
• The client’s name and address. Whoever is actually paying. If a family member is paying for a parent’s assessment, the payer goes here and the person you assessed goes in the description.
• A description of the service. This is the field doing real work. “OT services” tells nobody anything. “Home assessment and written report for Housing Adaptation Grant application, 14 Elm Road” tells the client, the council and future you exactly what was bought.
• The service date, which is not the invoice date. You visited on the 3rd and invoiced on the 19th. Both dates matter, and only one of them is usually on the page.
• The amount, and how to pay you: IBAN and BIC, and a payment term you actually mean. Thirty days is a term. “On receipt” is a hope.

The three fields OTs most often leave off

CORU number, tax reference number, and the service date as distinct from the invoice date.

None of the three feels urgent when you are writing the invoice. All three become urgent later: the CORU number when a council queries whether the report came from a registered practitioner, the tax reference number when a corporate client’s accounts department holds payment, and the service date when you are trying to reconstruct which visit a payment relates to.

The law asks for less than the template sites imply

Search for an Irish OT invoice template and you will find a dozen pages listing “required” fields. Read them closely and they are describing a VAT invoice.

That is a specific document with a specific obligation attached. Revenue’s rules put the duty to issue a VAT invoice on an accountable person supplying certain classes of customer, such as another accountable person, a Department of State or a local authority. If your work is exempt medical care and you are not registered for VAT, you are not issuing VAT invoices, and Revenue is explicit that “a person carrying out only exempt activities or non taxable activities may not register for VAT.”

So what does bind you? Records. Sales invoices sit in the list of documents you have to keep, and Revenue’s instruction is short: “You must keep the original of these documents for six years.”

That is the honest frame. Your invoice is not a compliance form. It is the evidence of a transaction, and you need to be able to produce it for six years.

The VAT question, properly

Here is where the template pages stop and the real question starts.

Revenue’s manual limits the medical exemption to medical care provided by recognised medical professionals registered on a statutory register in the State. Occupational therapists are named in the manual’s own appendix, as a profession designated under the Health and Social Care Professionals Act 2005. So registration gets you through the door. It does not settle what happens once you are inside, because the manual then applies a second test to the work itself.

Exempt medical care means services protecting, maintaining or restoring a person’s health, or diagnosing and treating disease. A course of therapy is squarely that.

A report is a different animal. Revenue’s manual lists medico-legal reports at the standard rate, and it lists “medical reports for statutory purposes”, giving fitness to drive certificates and fitness reports on prospective adopters as its examples. The reasoning comes from the Court of Justice: in Unterpertinger, a doctor’s report on a person’s state of health for a disability pension claim was held not to qualify, because its purpose was to inform somebody else’s decision.

Now look at what an Irish OT is most often asked to write. A council needs an OT report before it will approve a Housing Adaptation Grant for an extension, a stairlift, a through-floor lift, a fixed track hoist, or a major change of use to a room. The report’s purpose is to let the council decide.

Same OT. Same headed paper. Possibly the same week. On Revenue’s own logic, not obviously the same supply.

We are not telling you those reports are standard rated. Revenue’s examples are certificates and medico-legal work, not grant assessments, and the distinction between assessing a person’s needs and reporting on them for a decision is genuinely arguable. The point is that the question exists and that nobody has put it in front of Irish OTs before.

The €42,500 line

The VAT registration threshold for a person supplying services only is €42,500.

Which of your income counts towards it depends on which of your supplies are taxable, and that depends on the purpose test above. If every euro you bill is exempt treatment, registration is not on the table at all. If some of your work is not exempt, the arithmetic changes and it changes quietly, because report work tends to be the part of a practice nobody tracks separately.

We are not going to do that sum for you. Nobody writing a guide should. Three things to actually do: split your invoices by type of work rather than blending a month of treatment and a report into one line. Keep report income visible as its own number in your books. Then take one specific question to your accountant: are the reports I write for local authorities and for grant applications exempt medical care, or are they standard rated under the purpose test in Revenue’s manual? Bring the manual. It is a public PDF and most accountants will not have read it, because most of their clients are not writing statutory reports.

The Housing Adaptation Grant, and the €300 that comes back

Worth knowing, because it changes the conversation you have about your fee.

The grant is run by local authorities and covers up to €40,000 or 100% of the cost of the work, whichever is less, tapering with household income and cutting out above €75,000. An OT report is required for the bigger jobs: extensions, stairlifts and through-floor lifts, fixed track hoists, and significant changes to how a room is used.

The part clients rarely know: the local authority can arrange the assessment, or the applicant can employ an OT privately and, in Citizens Information’s words, “get up to €300 of the cost from the local authority as part of the grant.”

Say that out loud when you quote. A family choosing between waiting for a council assessment and paying you privately is making a different decision once they know part of your fee comes back to them. Note the ceiling honestly, and note that councils administer the scheme themselves, so their forms and their evidence requirements differ by county. Check the local authority’s own page before you promise a client anything about their application.

Getting paid, and getting the invoice out

Sequential numbers. IBAN and BIC on every invoice. A payment term you will actually chase. Records kept for six years, digital or paper.

None of that is hard. It is just tedious enough that most private OTs are rebuilding the same document from a copied file, retyping their CORU number and their bank details every time, and quietly hoping the numbering has not slipped.

Carearoo’s invoicing is free for Irish clinicians. Save your details once, including your CORU number, your IBAN and your BIC, and every invoice after that takes about a minute. Amounts in euro, VAT exempt by default with a 23% option if you charge it, travel billed per kilometre or per hour, and a PDF at the end. No cost, and no card.

And report drafting for Ireland is live too: seven Irish report types, including the Housing Adaptation Grant OT report, draft from your notes on your own template, with your first report free.

Frequently asked questions

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