Implementation of E-Invoice in Malaysia - Frequently Asked Questions (FAQs) for Healthcare Industry - Updated on 14 June 2024

Sep 21, 2026

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Implementation of e-Invoice in Malaysia is addressed through healthcare-industry frequently asked questions updated on 14 June 2024. The document explains how hospitals should handle invoicing workflows across different payer scenarios, clarifies when e-Invoices must be issued and validated by IRBM, and describes options for consolidated e-Invoices. It also covers e-Invoice treatment for independent consultants under co-provision and outsourcing arrangements, and whether locum doctors and nurses require e-Invoices for service payments, including references to applicable exemptions and ongoing review.

LanguageEnglish

CategoryInvoices

FormatPDF

Pages8

Reading Time3 min

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Implementation of e-Invoice in Malaysia - Healthcare Industry FAQs

Invoicing arrangements for different payers

Consolidated e-Invoice and timing of submission to IRBM

Independent consultants: co-provision vs outsourcing

Locum doctors and nurses: e-Invoice requirements and exemptions

| | | | | | | --- | --- | --- | --- | --- | | IMPLEMENTATION OF E-INVOICE IN MALAYSIA FREQUENTLY ASKED QUESTIONS (FAQs) FOR HEALTHCARE INDUSTRY
(UPDATED ON 14 JUNE 2024) | | | | | | | No | Question | Response | | | 1 Currently, the issuance of invoices / bills by hospitals can vary depending on the party making payment for the medical services:
• Issuance of invoice / bill directly to self-paying patients;
• Issuance of invoice / bill to patients asthe buyer, with third party administrator (TPA) and Managed Care Organisation (MCO) as the payer;
• Issuance of invoice / bill to patients covered under insurance claim as the buyer, with insurance company as the payer;
• Issuance of invoice / bill to corporate bodies or companies as the payer for medical services provided to their employees;
• Issuance of invoice / bill to the patients as the buyer, with the guardian (parent or children of the patient) as the payer.
Upon the implementation of e-Invoice, will the same invoicing arrangement continue to apply or will the hospital be required to modify its current processes? For the scenarios mentioned herein , Buyer refers to the patient.
In the event the patient is a minor (below 18 years of age) , the Buyer’s details should be the details of the parent / guardian / any other relevant parties, as the case may be. | | | | | | | | | | | | --- | --- | --- | --- | --- | | | No | Question | Response | | | 2 Will hospital be allowed to issue consolidated e-Invoice to record the income generated from medical services provided to individual end consumers (i.e. , self-paying patients) who do not require e-Invoice? Yes, hospital is allowed to issue consolidated e-Invoice for transactions where patients do not require an e-Invoice. 3 Generally, the hospital would issue a proforma bill to the insurance company for the request of Final Guarantee Letter (FGL) .
In this regard, when should an e-Invoice be issued and submitted to IRBM for validation? Hospital is allowed to follow the current billing arrangement.
Where required, the hospital may issue draft / proforma invoices to insurance company for the request of FGL.
Where the Buyer requests for an e-Invoice to be issued, the hospital is required to issue thee-Invoice upon finalisation of the medical services billing (e.g. , upon discharging of patients) .
Where the Buyer does not request for ane-Invoice, the hospital may issue a normal invoice / bill as per current practice upon finalisation of the medical services billing and thereafter, aggregate these invoices / bills on a monthly basis and issue a consolidated e-Invoice to IRBM within seven (7) calendar days after the month end. | | | | | | | | | | | | --- | --- | --- | --- | --- | | | No | Question | Response | | | 4 Currently, independent consultants are engaged by the hospitals to provide medical consultancy services via two (2) arrangements:
(1) Co-provision of medical services
Under this arrangement, the hospital will issue a bill to patients for the hospital services, and the independent consultant will issue another bill to patients for the professional fees.
The hospital will issue a monthly statement to the independent consultant, providing a summary of the services provided by the said
independent consultant.
(2) Outsourcing arrangement
Currently, independent consultants will bill the hospital by issuing invoices for the total professional fees incurred during the month.
When the hospital issues invoices to the patients, the consultants’ fees are already included in the invoice.
Upon the implementation of e-Invoice, will the same invoicing arrangement continue to apply or will the hospital be required to modify its current processes? For e-Invoice purposes, hospital is allowed to follow the current billing arrangement as follows:
(1) Co-provision of medical services
• Hospital and independent consultant will each issue a separate e-I

FAQs

For hospitals, how can invoice issuance differ based on who pays for medical services?

Invoice issuance may differ depending on the payer: self-paying patients, patients with a TPA/MCO payer, patients under insurance claims, corporate payers for employee services, or guardians paying for the patient. The document notes that in these scenarios, the Buyer refers to the patient.

When should an e-Invoice be issued and submitted to IRBM for validation?

Hospitals are allowed to follow the current billing arrangement for required cases. If the Buyer requests an e-Invoice, the hospital must issue it upon finalisation of medical service billing (e.g., upon discharging patients). If the Buyer does not request an e-Invoice, hospitals may issue normal invoices/bills and then aggregate them monthly for a consolidated e-Invoice to IRBM within seven (7) calendar days after month end.

How should e-Invoice issuance work for independent consultants engaged by hospitals?

For co-provision, the hospital and independent consultant issue separate e-Invoices to the patient, and payment collection timing does not affect issuance. For outsourcing, hospitals issue one e-Invoice to patients covering both hospital and consultant services as a single provider, while the consultant (or the company representing consultants) issues e-Invoices to the hospital depending on the contract party.

Sep 21, 2026

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