The Lembaga Hasil Dalam Negeri (LHDN) released a set of Frequent Asked Questions (FAQs) on November 16, 2023, specifically tailored for the healthcare industry. Here's a breakdown and summary of key points regarding e-invoice implementation:

Can hospital still issue invoice for staff medical paid by hospital to document the expense as per current practice?
Yes, hospital is allowed to follow the current billing arrangement.

Where the transaction involve partial claim from insurance / third party administrator (TPA) and remaining portion covered by the patients himselves, hospital will issue one bill for the coverage to the insurance / TPA and one bill for the remaining balance to the patient. Upon implementation of e-Invoice, will the same invoicing arrangement continue to apply?
Hospital is allowed to follow the current billing arrangement. The said bill would have to be an e-Invoice upon implementation of e-Invoice.

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 IRB for validation?
Hospital is allowed to follow the current billing arrangement. When required, the hospital may issue draft proforma invoices to insurance company for the request of FGL. Once the invoicing/billing arrangement has been finalised, the hospital would be requried to submit the e-Invoice to IRB for validation.

Can the consultant fee billed by consultants to be include in the invoice as per current practice?
Yes, hospital is allowed to follow the current billing arrangement.

In a contract for service scenario, hospital may directly contract with individual doctors or contract with a company representing the doctors. With the implementation of e-Invoice, who should issue the e-Invoice to the hospital?
Where the contract for service is between hospital and individual doctor, the Supplier's details should be the individual doctor. The said doctor should be responsible to issue e-Invoice.
Where the contract for service is between hostpital and the company representing the doctors, the Supplier's details should be the company representing the doctors. The said company should be responsible to issue the e-Invoice.

Is an e-Invoice required to be issued for space rental (e.g. convenience stores, cafes) within the hospital compound?
Yes, the issuance of an e-Invoice is required for the space rental.

Which party's details should be used as Buyer's details in cases where parents / guardian / any other relevant parties are responsible for paying the medical expenses for their child who is below 18 years of age?
For the purposes of e-Invoice, the Buyer's details should be the details of the parent / guardian / any other relevant parties, as the case may be.

What is the treatment of e-Invoice for cases where a patient is referred to a sister company or a private hospital and gets discharged at the referred hospital?
Hospital is allowed to follow the current billing arrangement.

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.

What is the e-Invoice treatment for collection of deposits upon admission to hospitals?
Where the deposit is defundable, an e-Invoice should not be required upon receipt of the said deposit. However, if the deposit collected is non-refundable, an e-Invoice is required to be issued. The hospital may also follow the consolidated e-Invoice treatment for Buyers who do not required an e-Invoice.

What is the e-Invoice treatment for transactions involving payment from multiple payors?
Hospital is allowed to follow the current billing arrangement.

If hopital's annual turnover reaches RM100 million and is required to implement e-Invoice in Phase 1 (1 August 2024), is the consultants of the hospital requried to implement e-Invoice in Phase 1 as well even their annual revenue do not reach RM100 million?
The compliance obligation of e-Invoice should be from the issuance perspective. The consultants and the hospital would have to follow their respective thresholds for the implementation of e-Invoice.

Generally, there are two types of bills that would be prepared by the hospital to the patient - Summary Bill or Detailed Bill (i.e. detailed breakdown of charges incurred), which type of bill should be submitted for IRB's validation?
For the purposes of e-Invoice, the hospital would be required to issue the "Detailed Bill" as the e-Invoice, which is then submitted to IRB for validation.

*Click here for information on consolidated e-Invoice

Please do not hesitate to contact us for e-Invoice implementation and consultation at:

Ten Jia Sheng
014-911 1880
jsten@jsc-corp.com