Submission to Pharmac | Te Pātaka Whaioranga on proposed changes to diabetes medicines’ access criteria
Submission to Pharmac | Te Pātaka Whaioranga on proposed changes to diabetes medicines’ access criteria
11 June 2026
OraTaiao: Aotearoa New Zealand Climate and Health Council is responding to Pharmac | Te Pātaka Whaioranga’s call for submissions on proposed changes to diabetes medicines’ access criteria that remove ethnicity criteria.
Equity in health and climate policy is essential to improve and protect public health. For this reason, OraTaiao strongly opposes the proposed removal of the ethnicity-based access pathway for Māori and Pacific peoples. Removal of this pathway constitutes the reversal of a clinically-designed equity safeguard in a system with known entrenched inequities.
We are concerned that the proposal risks worsening existing inequities in diabetes outcomes, cardiovascular disease, chronic kidney disease, and premature mortality - as well as increasing health sector costs from treating worsening health with denial of these preventative medicines.
OraTaiao is also concerned that:
- the proposal ignores te Tiriti obligations and ignores the principles of current legislation - in particular, sections 6 and 7 of the Pae Ora Act 2022. OraTaiao notes that the Pae Ora Act 2022 continues in force as legislation ruling Pharmac | Te Pātaka Whaioranga’s work. This Act takes precedence over any Ministerial letters of expectation and other directions, and any other Pharmac | Te Pātaka Whaioranga policy including the recent Access Criteria Policy
- the proposal is founded on a Pharmac | Te Pātaka Whaioranga policy which we find problematic because it ignores current legislation which binds the Board and all Pharmac staff, is not congruent with te Tiriti, is internally inconsistent, lacks public consultation, and contradicts the Cabinet Circular on needs-based services
- Pharmac | Te Pātaka Whaioranga never developed or considered any options to retain the ethnicity criteria – despite these ethnicity criteria meeting the Cabinet Circular’s analytic requirements
- the proposal fails to fully reflect expert advice – which was even initially withheld from this consultation, despite Pharmac’s stated commitment to greater transparency
- details of how key evidence has been interpreted (contributing to Pharmac’s stance) have been withheld – despite Pharmac’s stated transparency commitments.
OraTaiao recommends that Pharmac | Te Pātaka Whaioranga:
- defer the removal of ethnicity criteria, pending further work and more robust public consultation
- amend the proposed special authority criteria by moving the ethnicity criteria’s position and by clarifying cardio-renal risk and early-onset T2DM
- publicly provide economic information for this proposal on QALY health gains, underlying assumptions, and PICOs used – particularly the counterfactuals undertake and publish a comprehensive equity impact assessment of this proposed change
- undertake analysis on whether, under the Cabinet Circular, retaining the ethnicity criteria for diabetes medicines would be allowable
- develop and consider an explicit option to retain the ethnicity criteria for diabetes medicines, if the Cabinet Circular’s requirements are met
- provide the Board with alternative interpretation of the evidence the Diabetes Advisory Committee assessed, that ethnicity criteria have improved, not lessened, access in Māori and Pacific peoples with known CVRD
- urgently revise the Pharmac | Te Pātaka Whaioranga Access Criteria Policy in line with the Cabinet Circular, that ethnicity and age are independent clinical/epidemiologic factors and discriminants, and release the revised Access Criteria for public consultation
- suspend the current Access Criteria Policy and not use it in proposal development until revised and consultation concluded
- for any consultation on proposals, provide full clinical advice readily, economic information that includes health benefit assumptions, and sufficient time (at least six weeks) to assess all consultation material , for any proposals.
Thank you for the opportunity to provide feedback, and we welcome further contact.
Read our full submission here.




