There are two separate questions to be raised for this account. I will concentrate on the second, but it has clear implications for the first. Suppose that as a result of associative learning a certain auditory stimulus has become a secondary reinforcer. This is highly counter-intuitive. There are many situations every day in which we all seem to respond to secondary reinforcers in a way that doesn't involve HOT and yet in which the secondary reinforcers are consciously experienced.
Examples range from eating a meal to listening to music.
Rolls might respond in either of two ways. Neither of these strategies seems satisfactory, however. That is, a state might become conscious not in virtue of actually feeding into higher-order planning, but rather in virtue of its potential for feeding into such planning. This modification of the theory, however, would entail abandoning the account of how qualia emerge. It is more plausible that the order of explanation is the other way round, so that it is only if a state is conscious that it can feed into planning and the deliberate initiation of action.