Healthcare electronic invoicing
Billing in healthcare means complying with two systems at once. Almost every collections problem starts with treating them as if they were one.
If you bill for healthcare services, you answer to two authorities at once. To the DIAN (Colombia’s tax authority), because every sale is documented electronically, as in any other sector. And to the Ministry of Health and Social Protection (MinSalud), because a service charged to a payer (entidad responsable de pago) needs supporting documents that no other sector requires.
That means two validations, two codes and two formats that travel together. If the software only handles the DIAN side, the invoice goes out fine and then fails at filing. If it only handles the health side, there is no valid invoice.
In short
- Every health service provided is invoiced electronically with the DIAN, under Resolution 000165 of 2023 and its amendments, now compiled in the DIAN’s Unified Resolution 000227 of 2025 (Resolución Única).
- If the bill goes to a payer, the invoice is a healthcare electronic sales invoice (FEV) and needs RIPS (the individual record of health services provided) as supporting data, under Resolution 948 of 2026.
- The invoice gets its CUFE from the DIAN. The RIPS gets its CUV from the single validation mechanism. Without both, there is no filing.
- Resolution 2284 of 2023 sets the billing supporting documents and the single manual of returns, claim objections (glosas) and responses, with exhaustive grounds.
- Deadlines are short and chained. An institution’s cash flow is decided there, not in the contract negotiation.
The two circuits, and where they meet
DIAN invoicing. The invoice is issued as digitally signed XML, transmitted for prior validation and receives the CUFE, the unique electronic invoice code. It applies to everyone: the private patient who pays for their own visit, the company that contracts occupational health exams and the EPS (entidades promotoras de salud, Colombia’s health insurers).
Health supporting data. If the payer is an EPS, an insurer, a voluntary health plan, a family compensation fund (caja de compensación) or ADRES (the health system’s funds administrator), the invoice travels with the RIPS in JSON, which are validated separately and receive the CUV, the unique validation code. See what RIPS are.
Where they meet is the critical point: the data has to be the same in both documents. If the diagnosis in the clinical record does not match the one in the RIPS, or the billed service does not appear in the record, the inconsistency is not caught at billing. It is caught when it is already an objection.
The full circuit, step by step
- Care is provided, and the clinical record is left structured and coded.
- The account is built with the services actually provided.
- The invoice is generated in XML and, when applicable, the RIPS in JSON.
- It is validated: CUFE from the DIAN, CUV from the single validation mechanism.
- It is filed with the payer, with all supporting documents.
- It is audited. The payer can accept it, return it or raise objections.
- It is paid, or the objection process begins.
Every handoff that depends on a person copying data is a point where money is lost: a service that was not charged, a data point that does not match, a supporting document that was not attached.
The deadlines that decide your cash flow
They are chained, and missing one moves all the others:
| Stage | Deadline | Source |
|---|---|---|
| File the invoice with supporting documents | 22 business days from issue | Resolution 2284 of 2023 |
| The payer raises and communicates objections | 20 business days from filing | Law 1438 of 2011, art. 57 |
| The provider responds to the objection | 15 business days from receipt | Law 1438 of 2011, art. 57 |
| Correct a correctable objection | 7 additional business days | Law 1438 of 2011, art. 57 |
| The payer decides whether to lift the objection | 10 business days from the response | Law 1438 of 2011, art. 57 |
The first one sinks the most accounts. Not filing within the 22 business days is one of the exhaustive grounds for a return (devolución), and a return is not an objection: the whole account comes back and the clock restarts.
What a payer cannot require of you
This is the least known part, and the one that moves the most money. Resolution 2284 of 2023 was explicit:
- They cannot require a prior audit as a condition for filing.
- They cannot require the invoice to go through their own validation filters before it is filed.
- They cannot require the invoice to be sent in advance outside the process.
All three are classified as unauthorized delaying practices. The claims audit is the payer’s job after filing, not before.
In addition, the grounds for returns and objections in the single manual are exhaustive: they cannot be created, removed or modified. An objection based on an invented ground is not valid, and when unfounded objections are raised, the payer is required to pay late-payment interest under the terms of Decree 780 of 2016.
Knowing this changes the conversation at the reconciliation table, but it only helps if you have the traceability to prove when you filed and with which supporting documents.
Private-pay patients and independent professionals
If the patient pays directly, the circuit is much simpler: an electronic invoice with the DIAN and nothing else. No RIPS, no CUV, no filing and no objections.
The obligation does not depend on size. A psychologist, physician or physical therapist who bills on their own still issues an electronic invoice, and if they contract with a payer, they also generate RIPS with their own provider code. What changes is the scale: there is no billing department, the same person who provides the care does it, so the only sustainable way is for the invoice to come out of the care and not the other way around. See the billing and collections pillar.
What your software should do
- Issue the invoice from the care encounter, not rebuild it at month end.
- Generate the invoice and the RIPS in a single step, from the same source data.
- Validate before sending, and point to the error in the record that causes it.
- Store the CUFE and CUV linked to the account, not in a separate file.
- Track the 22 business day clock and warn you before it runs out.
- Attach the billing supporting documents required by Resolution 2284 of 2023, and handle credit and debit notes without breaking traceability.
- Manage objections with the supporting documents linked, so you can respond without rebuilding the case.
- Trace the full cycle: care, invoice, filing, objection and payment.
How Omneri solves it
- Electronic invoicing with the DIAN with the clinical support already linked, for private-pay patients and for payers.
- RIPS derived from the care encounter and validated before they reach the single validation mechanism, with each error pointed out in the record where it originates.
- CUFE and CUV linked to the account, available when you need to prove filing.
- Full traceability from care to invoice, from invoice to filing, and from there to payment or objection.
- Objection management with the clinical record and supporting documents in the same account.
- Contracts and rates applied at billing, with no parallel price lists.
- Regulatory updates included in the service.
- Account audit with Omni before filing, with structural RIPS validations checked by rule.
The details of how funds flow between payers and providers are in SIIFA, and the full regulatory picture is in regulations.
You can see what it looks like inside or request a demo.
Frequently asked questions
It is the process by which a provider documents and charges for a health service while complying with two frameworks at once: the electronic invoice with the DIAN, regulated by Resolution 000165 of 2023, and the sector’s own supporting data when the bill goes to a payer (entidad responsable de pago). In that case the invoice is a healthcare electronic sales invoice and travels with the RIPS, which are validated separately and get their own code.
They are codes from different systems. The CUFE is the unique electronic invoice code that the DIAN assigns when it validates the XML invoice, and it exists in every sector. The CUV is the unique validation code that the health sector’s single validation mechanism assigns when the RIPS pass MinSalud’s rules. To file a healthcare sales invoice with a payer, you need both.
Twenty-two business days from the invoice’s issue date, according to Resolution 2284 of 2023. Not filing the supporting documents within that period is one of the exhaustive grounds for a return, and a return means the whole account comes back and the process starts over. That is different from an objection, which disputes part of the amount but keeps the account in process.
No. Resolution 2284 of 2023 expressly prohibits payers from making filing conditional on a prior audit, on passing through their own validation filters or on sending the invoice in advance, and classifies those requirements as unauthorized delaying practices. The claims audit is the payer’s job after filing, not before.
Article 57 of Law 1438 of 2011 chains them together: the payer has 20 business days from filing to raise and communicate objections; the provider has 15 business days to respond, either accepting them or justifying why it does not accept them; if the objection can be corrected, the provider has 7 additional business days; and the payer has 10 business days from the response to decide whether to lift it fully or partially or to uphold it.
No. The grounds for returns and objections in the single manual adopted by Resolution 2284 of 2023 are exhaustive: they cannot be created, removed or modified. When a payer raises unfounded objections, or objections other than those provided for, it is required to pay late-payment interest under the terms of Decree 780 of 2016. To support that argument, you need traceability of the filing and its supporting documents.
No. If the patient pays directly, only electronic invoicing with the DIAN applies, with no RIPS, no CUV and no filing. RIPS are mandatory supporting data for the invoice when the bill goes to a payer: an EPS, insurer, voluntary plan, compensation fund or ADRES. Even so, it is worth having software that can do both, because your first contract changes the picture overnight.
The price is sized to the scale of the operation: how many professionals provide care, how many sites there are and which modules are turned on. Billing is not sold on its own, because its value lies in being derived from care and carrying the supporting documents with it. Sizing is done during the demo, with your real operation on the table, and that produces a specific figure instead of a range.
Tell us how your hospital or clinic runs today.
We set up a demo around your case: size, sites and critical modules.
Book a demo
