Plain-English Determinations Need a Reader Test, Not New Reasons

Plain language is not permission to improve a delegate's logic after sign-off. Freeze the human decision, test whether a recipient can find four essential answers, then permit only presentation edits that survive a semantic checksum and human approval.

The plain-English pass starts after the human decision and reasons are complete. That boundary matters. If AI spots a missing finding, unsupported step or unexplained conflict, the document goes back to the decision-maker. The model does not patch the gap with a more persuasive sentence.

Used properly, AI can test whether a recipient can locate four things: what was decided, why, what happens next and how to challenge it. That is a reader test, not a second determination process.

For a self-insured bank, insurer or other licensee, the safest unit of work is a frozen decision capsule. It contains the approved terms, reasons, evidence references and rights text. AI may diagnose presentation problems against that capsule. Every edit remains subject to human comparison and approval.

When is AI allowed into the letter?

The current in-force Safety, Rehabilitation and Compensation Act 1988 is Compilation No. 82, with a compilation date of 1 July 2026. Section 61 generally requires a written notice, served as soon as practicable after the determination, that sets out its terms, reasons and a statement about requesting reconsideration under subsection 62(2). Subsection 61(2) contains a limited exception for a subsection 16(1) determination paying the full amount of the cost of medical treatment to someone other than the employee.

Section 38 has a separate route for a section 36 or 37 determination made by a rehabilitation authority other than a relevant authority: the subsection 38(1) notice sets out the terms, the reasons and a statement that the employee may request Comcare to review the determination, and Comcare's subsection 38(4) decision is reviewable. Section 63 requires a reviewable-decision notice to give terms, reasons and an ART-rights statement. The governing provision, decision-maker and stage control the rights block. Never select it from a generic template.

Comcare's best-practice decision-making guidance says decisions must be made according to law and based on the relevant facts, and that records should include findings of relevant fact, the evidence on which those findings are based and the evaluation of those facts against the relevant provisions of the SRC Act. Communication should then use appropriate tone and plain English. Complete the reasoning, freeze it, then test the communication.

Create a protected-elements register before any AI review. It should capture:

• the exact operative terms, including entitlement, amount, period and effective date where applicable
• each material finding and the evidence the decision-maker relied on
• the statutory provision, test and legal terms used
• treatment of conflicting or contrary evidence
• names of authorised roles, not model-inferred authority
• the applicable reconsideration, Comcare-review or ART pathway, time statement and contact details

This is the decision capsule. Give each item an anchor such as [TERM_01], [FINDING_03] or [RIGHTS_02]. If an edit changes an anchored proposition, it is not a style edit. Return it to the human decision-maker.

This prompt freezes the boundary before the reader test. The decision-maker or authorised reviewer must verify the capsule against the signed-off reasons.

Build a protected-elements register for de-identified determination [CLAIM_NUMBER].

Sources:
- approved operative terms: [TERMS_DOCUMENT_ID]
- approved reasons: [REASONS_DOCUMENT_ID]
- approved rights text for this decision stage: [RIGHTS_TEMPLATE_ID]

Extract, without rewriting: operative outcome, scope, dates, amounts, material findings, evidence attribution, statutory provisions and tests, treatment of contrary evidence, required or optional next steps, review route, timeframe wording and contact channel.

Give every element a source anchor and exact short quotation. Mark inconsistencies or missing elements RETURN TO HUMAN DECISION-MAKER. Do not complete reasoning, infer a finding, reweight evidence, choose rights text or propose a substantive correction.

What must the recipient be able to answer?

Forget the readability score at first. A short letter can still conceal the decision. A long letter can still be navigable. Test answerability through four recipient tasks, with every answer anchored to the frozen text.

1. The decision task: What exactly was decided? The output should identify the operative result, its scope and when it applies. If the terms are split across the opening, reasons and an attachment, mark the answer ambiguous. Do not assemble a broader or narrower outcome than the decision-maker approved.
2. The reasons task: Why was that result reached? The output should point to the material findings, the evidence relied on and the statutory test applied. It may flag an unexplained jump. It must not supply the missing link, reconcile evidence or write a fresh reason.
3. The action task: What happens next? Separate an action the recipient must take, an option they may take, and an administrative step the authority will take. Do not turn an invitation into a requirement or promise a timing outcome that the approved notice does not support.
4. The review task: How can the decision be challenged? Confirm the governing provision, decision-maker, stage, route, timeframe wording, destination and any extension information. Section 61, section 38 and section 63 notices require distinct checks.

Use four statuses: FOUND, AMBIGUOUS, NOT FOUND and CONFLICT. Require an exact paragraph or page anchor for FOUND. An AI-produced answer without an anchor is a failure, even if it sounds plausible.

The review task is high risk. Under section 62, a reconsideration request must set out reasons and be given within 30 days after the day on which the determination first came to the notice of the person making the request, subject to any further period the determining authority allows. Under subsection 65(4), an ART application must be made within 60 days after the person making the application is served with notice of the decision, with a note pointing to the extension power in section 19 of the Administrative Review Tribunal Act 2024. The ART workers compensation page tells applicants to check the decision letter and confirms that a reviewable workers compensation decision is usually subject to a 60-day period. The human reviewer must verify the current statutory text, decision stage and approved channel before service.

This prompt runs the four-task test. A human must inspect every anchor and decide whether any presentation change is safe.

Run a recipient answerability test on de-identified notice [CLAIM_NUMBER] using only the frozen decision capsule and draft notice supplied.

Test four tasks:
1. What exactly was decided, including scope and operative date?
2. Why, identifying the stated findings, evidence and statutory test?
3. What must, may or will happen next?
4. How can the recipient challenge the decision at this decision stage?

For each task return FOUND, AMBIGUOUS, NOT FOUND or CONFLICT, plus exact document and paragraph anchors. Then suggest presentation-only changes such as headings, order, sentence splits or a defined-term callout.

Do not add a fact, finding, causal link, evidence evaluation, statutory conclusion, date, amount, obligation, promise or review right. If the source cannot answer a task, write RETURN TO HUMAN DECISION-MAKER.

A model passing all four tasks does not prove that the claimant will understand the letter. It is an early defect screen. The final check should include a human who was not involved in drafting, using the same four questions and reporting where the text made them search or guess.

How do you simplify without changing the decision?

The Australian Government Style Manual's plain-language guide recommends putting the important message first, using clear headings, short topic-based paragraphs, common words, active voice and short sentences. Those are useful presentation tools. They do not authorise a change to a statutory term, evidentiary finding or legal effect.

Permit low-risk moves only where the protected elements survive:

• move an exact approved outcome into a clearly labelled opening box
• add question headings that match the four reader tasks
• split a long sentence without changing qualifiers or logical connections
• define a necessary technical term beside its first use
• replace internal process jargon with an approved ordinary-language equivalent
• distinguish required action, optional action and authority action visually

Block edits that change must, may, is satisfied or is not satisfied; compress competing evidence into a new conclusion; remove a qualification; change who did or will do something; alter dates, periods or amounts; or make review rights sound narrower or broader.

Finish with a semantic checksum. Compare the approved capsule and edited notice proposition by proposition. The checksum should return the before text, after text, protected anchor, difference type and human disposition. It should treat moved text as a presentation change, but still flag any altered wording for inspection.

Fictional worked example

This scenario is fictional and de-identified. The approved reasons for [CLAIMANT_NAME] under [CLAIM_NUMBER] contain the operative terms at paragraph 42, the key evidence findings at paragraphs 18 to 31, and the reconsideration statement on the final page. The first page says only that the claim has been "considered".

The reader test marks the decision task AMBIGUOUS, because the outcome cannot be found at the start, and the reasons task FOUND, with source anchors. It marks the review task FOUND only after confirming that this is an initial determination and the source text points to reconsideration, not directly to ART.

A safe presentation proposal moves the exact paragraph 42 terms into an opening outcome box and adds headings for reasons and review options. It does not summarise paragraphs 18 to 31 into a new explanation. If a reviewer thinks those reasons need another causal step, the letter returns to the decision-maker. AI does not manufacture that step during copy-editing.

After editing, the checksum compares every protected element. A changed effective date, omitted qualifier or rewritten evidence finding fails. The authorised human resolves the failure and approves the final notice.

Do this Monday

1. Set the entry gate. Allow the reader test only after the human decision and reasons are complete and the decision-maker is identified.
2. Freeze a decision capsule. Anchor the terms, findings, evidence links, statutory tests, dates, amounts, actions and stage-specific review text.
3. Run the four tasks. Test decision, reasons, next action and review rights. Require source anchors for every FOUND result.
4. Limit the edit menu. Permit order, headings, sentence splits and approved definitions. Route substantive gaps back to the decision-maker.
5. Run the semantic checksum. Compare protected propositions before and after editing, then retain the redline and human disposition.
6. Use a fresh human reader. Ask someone outside the drafting chain to answer the same four questions before service.

Bottom line

Plain English should reveal a completed determination, not renovate its reasoning. AI can test whether four essential answers are findable and propose tightly controlled presentation changes. It cannot add the missing reason, change evidence weight or select the review pathway. Freeze the decision first, checksum every edit and keep final approval with an authorised human.

This article is general information and education only. It is not legal advice, and it is not advice about any individual claim. Decisions under the Safety, Rehabilitation and Compensation Act 1988 are made by human decision-makers on the individual merits of each claim, and claimants have reconsideration and review rights in respect of determinations. Seek advice specific to your scheme and circumstances.

References

1. Federal Register of Legislation, Safety, Rehabilitation and Compensation Act 1988, Compilation No. 82, compilation date 1 July 2026. https://www.legislation.gov.au/C2004A03668/latest/text
2. Comcare, Scheme guidance - Best-practice decision making under the SRC Act, SRC342, last updated April 2025. https://www.comcare.gov.au/scheme-legislation/src-act/guidance/best-practice-decision-making
3. Australian Government Style Manual, Quick guide: plain language. https://www.stylemanual.gov.au/style-manual-resources/quick-guides/quick-guide-plain-language
4. Administrative Review Tribunal, Workers' compensation. https://www.art.gov.au/applying-review/workers-compensation