A Reconsideration Request Needs an Issue Map, Not an Outcome Prediction

A section 62 request is stronger when each challenged term is tied to the original reason, evidence, alleged omission and requested change. AI can build that traceable map. It must not invent grounds, assess credibility or forecast what the reconsideration officer will decide.

A reconsideration request does not need an AI prediction. It needs a precise answer to three questions: what part of the determination is challenged, why, and where the supporting material sits.

The useful artefact is an issue-to-ground matrix connecting each challenged term with the original reason, relied-on evidence, the requester's human-selected reason, alleged omissions, new material, requested outcome and source support. Empty fields stay empty. AI does not improve grounds, rank arguments or estimate prospects.

This is a section 62 workflow under the current Safety, Rehabilitation and Compensation Act 1988, Compilation No. 82 in force on 1 July 2026. It is deliberately different from an ART pathway map. Reconsideration is the internal review that produces a reviewable decision. Section 64 concerns the later application to the Administrative Review Tribunal.

What can a section 62 issue map safely do?

Start by checking that the challenged document is a determination. Section 60 defines the term as a determination, decision or requirement made under a listed set of SRC Act provisions. A notice of intention to make a determination, or an administrative decision such as a deemed date of injury or the label of an accepted condition, does not become reconsiderable because a model labels it so. Comcare's application page gives practical examples.

For a request under section 62, the request must set out reasons and be given to the determining authority within 30 days after the day on which the determination first came to the requester's notice, unless the determining authority allows a further period, either before or after that period expires. On receipt, the authority must reconsider the determination or arrange reconsideration by a properly delegated person who did not make, and was not involved in the making of, the original determination. The reconsiderer may affirm, revoke or vary it.

Comcare's scheme guidance on reconsideration says a requester need not establish an error of fact or law. It also says the request need not be written, although writing is preferable, and unclear communication may require clarification. The matrix is an organising aid, not a new acceptance test.

For a self-insured bank, insurer or other licensee, the request may arrive through an internal team or third-party provider, and deciding which lane that incoming message opens is the earlier routing task, separate from the issue map built here once a section 62 request exists. The Comcare application page distinguishes licensee-managed requests from Comcare claims. The licensee must apply its own authorised process, delegations and licence arrangements.

The map can split a disagreement into challenged terms, trace both sets of reasons, separate existing from new material and expose missing anchors. It cannot invent legal grounds, assess credibility or decide whether the determination should change.

What belongs in the issue-to-ground matrix?

Use one row for one challenged term. Separate rows stop a general paragraph from concealing which reason and evidence relate to each requested change.

The minimum fields are below. Here, "ground" means the reason supplied by the requester, not an AI-drafted pleading.

1. Issue ID: a stable label such as I-01.
2. Challenged term: the exact term or a close paraphrase, with determination page and paragraph.
3. Original reason: the corresponding reason given in the determination, with its source anchor.
4. Evidence relied on: each source the determination identifies for that reason.
5. Ground supplied by requester: the requester's own reason, copied or closely paraphrased. If none is clear, record HUMAN CLARIFICATION REQUIRED.
6. Alleged omission or error: what the requester says was overlooked, misunderstood or incorrectly applied. Label it as an allegation, not a finding.
7. New material: document ID, date, anchor and the proposition the requester says it supports.
8. Requested outcome: the change the requester asks for, without turning it into a prediction.
9. Source support: exact coordinates for every factual assertion and a human verification status.

Add a timing lane outside the merits fields. Record when the determination came to the requester's notice, request receipt, requester identity, any extension request and the verified due date. A human must check every date against the source record and law.

The two 30-day rules have different triggers, and they sit inside the wider map of SRC Act statutory clocks. Section 62(3) concerns when the request must be given. Section 62(6) and regulation 11A(2) of the current SRC Regulations require a claimant's request to be decided within 30 calendar days starting on the day the determining authority receives it. Comcare's statutory-timeframes guidance confirms that receipt is day one, that the rule applies to Comcare and self-insured licensees, and that it does not apply to employer requests or own-motion reconsiderations.

There is a trap here. Regulation 11A(3) lists periods not counted for initial section 14 decisions while specified information or evidence is being obtained. Those pauses do not apply to a claimant's reconsideration request. New material belongs in the evidence lane, but it does not create an AI-managed pause button for the reconsideration clock.

Comcare's timeframes guidance also says the Regulations do not prescribe a deemed determination or reviewable decision if a determining authority misses a statutory timeframe. Flag the missed control for human escalation. Do not infer an outcome.

Before processing, de-identify the determination, request and attachments. The OAIC explains that removing direct identifiers alone may not achieve de-identification. A rare role, small team, product incident or precise operational date may still identify someone. Use an approved AI environment or equivalent and keep the re-identification key outside it.

This prompt builds the first-pass matrix from human-supplied reasons. A human must verify every source coordinate, ground, timing field and requested outcome before the map is used.

You are formatting a de-identified SRC Act reconsideration issue map.

Inputs:
1. Determination D-01 with page and paragraph labels.
2. Reconsideration request R-01 containing the requester's own reasons.
3. Source index with document IDs and coordinates.

Create one row per challenged term with:
Issue ID | challenged term | original reason | evidence relied on | ground supplied by requester | alleged omission or error | new material and stated proposition | requested outcome | source support | human verification status.

Rules:
- Use only the supplied material and preserve placeholders.
- Copy or closely paraphrase the requester's reason. Never generate or select a ground.
- Label an alleged omission as the requester's allegation, not a finding.
- Distinguish claim-file material from new material.
- Do not assess credibility, legal merit, prospects or likely outcome.
- Do not recommend affirming, varying or revoking the determination.
- Write HUMAN CLARIFICATION REQUIRED wherever the request is unclear.
- Write SOURCE ANCHOR REQUIRED wherever support cannot be located.

Return the matrix and a list of fields requiring human clarification.

Fictional worked example: Request [REQUEST_ID] challenges determination D-01 dated [DETERMINATION_DATE]. One matrix row reads:

• Issue I-01: challenged term [TERM_1] at D-01 p1 [3]; original reason [ORIGINAL_REASON_1] at D-01 p4 [11]; evidence relied on [EVIDENCE_A] p2 [6]; ground supplied by requester [REQUESTER_REASON_1] at R-01 p1 [5]; alleged omission [DOCUMENT_B] p3 [8] was not addressed; new material [DOCUMENT_C] p1 [4] is said to support [PROPOSITION_1]; requested outcome [REQUESTED_OUTCOME_1]; every field marked for human source verification.

That row does not say the omission occurred, the new material is persuasive or the requested outcome should follow. It shows exactly what the requester alleges and where the reconsiderer must look.

How do you stress-test the request without predicting prospects?

Stress-testing means checking structure and traceability, not simulating the reconsiderer's conclusion. Test whether every challenged term has a corresponding reason, every alleged omission points to an identified source, every new document has a stated purpose, and every requested change is intelligible. Leave the merits untouched.

This prompt performs the defect check. A human must decide whether any defect requires clarification, more material or a process response, and must control every communication with the requester.

Audit this de-identified reconsideration issue map for traceability only.

Check whether:
1. Each challenged term resolves to the determination.
2. Each original reason and relied-on source has an exact coordinate.
3. Each ground is present in the request rather than generated by the map.
4. Each alleged omission is labelled as an allegation and linked to a source.
5. Each item of new material states the proposition it is said to support.
6. Each requested outcome is explicit or marked HUMAN CLARIFICATION REQUIRED.
7. Timing fields identify their human-verified source.

Return defects and missing coordinates only. Do not repair the request, add grounds, assess credibility, apply a legal test, rank issues, estimate prospects or recommend an outcome.

For an incoming request, preserve the original exactly as received, applying the same receipt-integrity discipline that protects day one at intake. Keep the AI map as a separate working artefact with its version, operator, purpose and human reviewer recorded. The reconsiderer should be able to move from every matrix cell back to the determination, request or evidence without relying on the model's wording.

The review boundary also matters. Once reconsideration is complete, section 63 requires the reviewable decision notice to state its terms, reasons and the availability of an ART application. Section 64 identifies who may apply to the ART. Those are later steps. This workflow neither drafts an ART application nor predicts what the Tribunal might do.

Do this Monday

1. Choose one closed, fully fictional training matter and assign source IDs to the determination, request and attachments.
2. Configure the nine matrix fields and a separate timing lane. Make HUMAN CLARIFICATION REQUIRED the default for missing reasons or outcomes.
3. Run the mapping prompt in an approved environment, then have a second practitioner open every source coordinate.
4. Test the receipt-date control against regulation 11A. Confirm the workflow never pauses the claimant-request clock while evidence is awaited.
5. Record mapping errors, invented grounds, altered certainty, missing sources and timing mistakes as test failures.
6. Approve the workflow only for structuring and defect detection. Keep grounds, credibility, merits, extension decisions and outcomes human.

Bottom line

A reconsideration request needs traceability, not theatre. The issue-to-ground matrix shows what is challenged, why, and where the supporting material sits without manufacturing a legal case. It also keeps the request clock and the decision clock visible as separate controls. AI may organise the request, but humans choose the reasons, verify the sources and make every section 62 decision.

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, 1 July 2026: https://www.legislation.gov.au/C2004A03668/latest/text
2. Federal Register of Legislation, Safety, Rehabilitation and Compensation Regulations 2019, Compilation No. 2, 1 April 2024: https://www.legislation.gov.au/F2019L00423/latest/text
3. Comcare, Scheme guidance - Considerations in the reconsideration process, document SRC311, updated December 2024: https://www.comcare.gov.au/scheme-legislation/src-act/guidance/considerations-in-reconsideration-process
4. Comcare, Applying for a reconsideration of a determination: https://www.comcare.gov.au/claims/disagree-determination/reconsideration
5. Comcare, Scheme guidance: Statutory timeframes for decision-making under the SRC Act, document SRC339, updated April 2025: https://www.comcare.gov.au/scheme-legislation/src-act/guidance/statutory-timeframes-decision-making
6. Office of the Australian Information Commissioner, De-identification and the Privacy Act: https://www.oaic.gov.au/privacy/privacy-guidance-for-organisations-and-government-agencies/handling-personal-information/de-identification-and-the-privacy-act