While we acknowledge the intent to create greater equity and consistency across plans, the level of change proposed is substantial, and the absence of critical detail creates uncertainty about how these reforms will operate in practice.

Our primary concern relates to the proposed assessment process. The information released to date suggests that assessors may not be required to possess sufficient disability‑specific expertise and that the tools and processes may not capture the clinical complexity of many conditions.

Without a robust, well‑informed assessment foundation, there is a significant risk that participants will receive plans that do not accurately reflect their needs, and that inequities already present in the system will worsen rather than improve.