Hi Chris,
I have absolutely no relation to TestComplete development and is just a user like you (see my disclaimer), but in my understanding, this task is much more difficult than keyword test to script conversion. I think so because usually scripts are like a programs and use code to access external data, links to shared library functions and other script units, etc. It does not seem to be an easy task to recognize what the code snippet does and convert it to keyword test operation where possible and leave the code as it is where conversion is not possible and do this in a way that preserves all code infrastructure (variables scopes, links between code units, general code flow, etc.).