If you want to record a case note before you have a client's plan from the NDIS. A placeholder Service Contract may be created within the client profile.
Then once the actual plan is avaliable these details can be edited within the existing Service Contract on the client profile to match or a new Service Contract can be created.

Articles on how to edit or add a Service Contract can be found in our help centre
If required Case notes raised on the place holder Service contract can be moved via the Move Case note process.