We generally support the legislative reforms which implement the Participant Service Guarantee particularly service standards and time frames. We support legislative changes to allow easier and quicker plan variations for participants (for example for minor errors or changes of circumstances) and to clarify plan reassessments vs reviews (Schedule 1 - insertion of s 47A and new s 48 ). However, we remain concerned that there is very significant discretion and lack of clarity in the legislation in relation to the circumstances when variation or reassessment may occur at the discretion of the CEO. S 47A (1), (3) and (6) and s 48( 5) refer to NDIS Rule s as outlining these circumstances. Current versions of the draft Rules have not been provided in this consultation. The original d raft National Disability Insurance Scheme (Plan Administration) Rules 2021 s 10 and 11 ( as provided during the DSS consultati on ) provide d a very broad discretion for the CEO in relation to when plans can be varied and reassessed and on what grounds. A large number of matters were noted as potentially relevant matters for CEO decision making. Much further clarity and transparency to participants should be provided particularly in relation to the criteria or threshold that triggers the CEO’s initiative to vary a plan under s 47A or decide to reassess a plan under s 48(1) without consultation with participants. It should be very cle ar to all participants the precise circumstances in which their plan can be varied or reassessed by the NDIA on its own initiative, and this should never come as a surprise. We note the addition in the Bill before this Committee in s 47 A that ‘each variation must be prepared with the participant’ in response to feedback during DSS consultation that variation could occur without participant knowledge. However, we submit that this provision is vague and without content such that it is difficult to know what the legislation means - for example does it mean mere notifica tion, does it require agreement with the participant, does it require a meeting with a participant? Further specificity should be added so participants are aware of the exact role they will play in varying their plan. Ideally, variations should be reached by agreement with participants