This consultation has now closed
Submissions closed at 5pm on Thursday 11 June 2026. Pharmac is no longer accepting feedback. You can still read the proposal and the evidence below.
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PHARMAC Public Consultation

Submission on proposed changes to Special Authority criteria

Empagliflozin, dulaglutide, and liraglutide, diabetes medicines that reduce the risk of serious heart and kidney complications.

My reasons Pre-selected. Untick any you disagree with
  • Consultation was rushed and not transparentThere has not been enough time for meaningful feedback on a change that harms Māori and Pacific. Key information was only provided after the original closing date. The diabetes community has been given only 8 working days to digest hundreds of pages and spreadsheets with no plain-language summary.
  • "No one loses access" is misleadingPharmac says no one currently on these medicines will lose access. That is only true for the exact medicine a person already takes. A Māori or Pacific person currently accessing an SGLT2 inhibitor (empagliflozin) through the ethnicity criteria would no longer be able to start a GLP-1 medicine (dulaglutide or liraglutide) unless they meet the new criteria. The GLP-1 criteria require prior treatment, and someone who has not been on empagliflozin long enough would not yet qualify. They keep their current medicine but lose the pathway to the next one.
  • Pharmac's public messaging leaves out the people who lose accessPharmac says one-third of those who would "gain" access are Māori and Pacific, but our reading is that those people would already be eligible now. This proposal does not appear to create any new access for Māori and Pacific people with type 2 diabetes. It delays access for many and, on our estimate, would completely remove access for around 7,000 Māori and Pacific people. The impact on those people has been absent from Pharmac's public messaging.
  • The 7,000 number itself is unreliableThe ~7,000 figure who lose access appears to be a rough mash of two different numbers in the Budget Impact Analysis (around 5,500 and 8,550). Pharmac is making multimillion-dollar health decisions affecting thousands of people based on a spreadsheet with inconsistent, unexplained figures.
  • The data quality is too poor to base this decision onPharmac's modelling is built on outdated clinical guidelines referencing UK recommendations. The UK's NICE guidelines updated in February 2026 recommend everyone with type 2 diabetes starts dual treatment with metformin AND empagliflozin, and GLP-1 medicines (like dulaglutide and liraglutide) are added for anyone at high risk of heart or kidney disease. Uptake assumptions (80–100%) are not validated by any peer-reviewed published data and appear to possibly double-count. They suggest glibenclamide is an alternative, a medicine not used in clinical practice here and not in line with any national or international guidelines. Diabetes prevalence rates vary across their website and documents and are often far lower than the Virtual Diabetes Register.
  • The proposal does not align with Health NZ Te Whatu Ora's own diabetes roadmapHealth NZ Te Whatu Ora's National Diabetes Roadmap 2026 says to "support the use of medicines with an equity focus by improving access and appropriate use," and to "develop and publish combined cardiovascular, kidney, and metabolic guidelines based on international best practice." This proposal does the opposite: it removes the equity-focused ethnicity criteria, and it narrows access to a single fixed five-year cardiovascular risk threshold that does not capture kidney or metabolic risk.
  • Māori and Pacific experience diabetes and its harms at far higher ratesAround 1 in 7 Pacific people and 1 in 12 Māori have type 2 diabetes vs 1 in 30 European. Māori have nearly double the cardiovascular death rate. Māori and Pacific reach kidney failure and dialysis at 3–5 times the rate.
  • The ethnicity criteria have been workingSince Pharmac added the ethnicity criteria, access has improved for Māori and Pacific compared with diabetes medicines that do not have them. The ethnicity criteria align with Pharmac's equity policy and the Crown's obligations under Te Tiriti o Waitangi. Pharmac's diabetes experts confirmed the criteria still meet the special measures test.
  • The political framing misrepresents the current access criteria's purposeThe current ethnicity criteria correct a documented disadvantage for Māori and Pasifika; removing them removes a tool that is working to close the equity gap. The combined press release from Hon Simeon Brown and Hon David Seymour stating "ethnicity shouldn't decide access" ignores that ethnicity predicts who develops diabetes young, faces kidney failure, and dies early. They also framed this around "the mother who is..." example, yet it is near impossible for the average mother with diabetes to reach the proposed access criteria.
  • A 5-year CVD risk assessment does not capture lifetime risk or kidney disease riskThe threshold misses factors more common in Māori and Pacific (mental health, sleep apnoea, gestational diabetes history). It is a snapshot of cardiovascular risk in the next five years, not risk of renal disease. This means an older adult diagnosed later in life would have a higher 5-year CVD risk than a younger adult in their 40s, despite the younger adult having a higher lifetime burden of diabetes and risk of complications, which will also likely cost the health system more. It also ignores that some older adults may be too frail or not clinically appropriate for these medicines.
  • Pharmac never presented this proposal to diabetes expertsThe Diabetes Advisory Committee received a different proposal (whether the ethnicity criteria were still relevant to Special Measures and in line with the Letter of Expectations and Cabinet Circular, and whether a clinician-assessed cardio-renal risk alternative would be more appropriate than the current 5-year CVD risk of 15%). That version was replaced with the 10% threshold by Pharmac staff and presented instead to an Obesity group, who noted it was "not about obesity treatment."
  • Expert advice does not appear to support this, yet Pharmac says it doesThe Diabetes Advisory Committee endorsed keeping the ethnicity criteria, stating Pharmac had not provided a sufficient alternative to reach the target population. They also supported a clinician's assessment of cardio-renal risk to widen the CVD risk criteria. Pharmac's Chief Medical Officer said experts found "most" Māori and Pacific would still qualify. The Obesity Treatments Advisory Group did say "many (but not all)" would still qualify, but only through the 10% threshold combined with the young-age-at-diagnosis criterion, and in the same record they said the 10% threshold is set high, that the PREDICT tool generally will not produce a 5-year score over 10% for someone with type 2 diabetes unless other risk factors are already identified, that PREDICT ignores renal risk, and that their strong preference was open listing for everyone. We cannot reconcile "most would still qualify" with that advice, and ask Pharmac to explain the difference and release the supporting data.
  • Pharmac is removing ethnicity criteria from other medicines without consultationPharmac's PTAC group produced access criteria for tirzepatide (Mounjaro) in August 2025 and semaglutide (Ozempic) in November 2025, for the same diabetes population, that remove both the ethnicity criterion and the clinician-judgement criterion (the one that let a clinician approve anyone they judged at high risk of cardiovascular or renal complications). Both PTAC recommendations kept the CVD risk threshold at 15%, so the removal of the ethnicity criterion and the clinician-judgement criterion was happening separately from, and before, the proposed move to 10%. Alongside this, the way the target population is described was narrowed from the Diabetes Advisory Committee's broad "high risk of cardiovascular and renal complications" to a fixed five-year CVD risk band of 10-14% in the later assessment documents. Together this raises a fair question about whether the decision to remove the ethnicity criteria was effectively made in advance, rather than informed by expert advice or this consultation.
  • Pharmac has modelled unrealistic uptake ratesReal-world uptake is ~51% Māori, ~49% Pacific, vs 36–37% European. Pharmac has modelled 80–100%, which is over-ambitious and goes against published evidence and expert advisors' point that Māori and Pacific people will be less likely to access a full CVD risk assessment.
  • Pharmac hasn't modelled the cost of those who lose accessThe impact on the estimated 7,000 losing access, their whānau, and the health system has not been costed. They have not modelled the impact of delaying access for Māori and Pacific people who would already have been eligible under the current criteria, who would now have to wait until their CVD risk reaches 10%.
My recommendations Pre-selected. Untick any you disagree with
  • Extend the consultation period furtherThere has not been enough time for meaningful feedback.
  • Provide the real numbers plainlyState clearly:
    • How many additional European and South East Asian people gain access
    • How many Māori and Pacific people retain access, and how many have delayed access
    • Explicitly model how many Māori and Pacific people lose access entirely

    Also show the rates of diabetes, CVD, kidney disease and death across all ethnic groups.
  • Clean up the data and modelling before consultingEnsure the modelling is based on real-world data, compared against the correct alternatives, and share those modelled costs.
  • Proceed with genuine, honest and respectful consideration of this feedbackThis would include:
    • Proactive release of Pharmac board and staff considerations from this consultation
    • Reconvening the Diabetes and Consumer Advisory Committees to consider the responses
    • Consulting with relevant Māori and Pacific governance groups
  • Explain honestly why expert recommendations were not followedThe Diabetes Advisory Committee recommended keeping the ethnicity criteria. Why did Pharmac choose to remove them?
  • Be transparent about government directives and their impact on funding and policy decisionsIf this proposal stems from government direction, Pharmac should say so directly rather than framing it as clinical necessity.
  • Prove the new criteria won't cause harmShow that the criteria have been broadened enough to include the entire target population, including Māori, Pacific and other high-risk groups such as South East Asian people, as set out in Pharmac's own Access Criteria Policy, which favours broad criteria to capture the whole group rather than using ethnicity or age to narrow it.
  • Make empagliflozin fully funded for everyone who would benefitFor everyone with type 2 diabetes, in line with UK guidelines.
  • Allow access to both empagliflozin AND GLP-1 medicines togetherSGLT2 inhibitors and GLP-1 medicines should be available to be used together for everyone considered at high risk of cardio-renal disease. Gold-standard treatment uses both groups. People should not have to choose.
  • Remove the extra GLP-1 restrictions still in place from the shortageThey were introduced during the worldwide shortage and should have been removed by now.
  • Keep the ethnicity-based criteria AND reduce the CVD thresholdThis is the option that improves access for everyone and does not leave high-need Māori and Pacific behind.
  • If the ethnicity criteria are removed, widen access using clinician-assessed cardio-renal risk instead of the 10% thresholdGo back to the clinician-assessed cardio-renal risk option that the Diabetes Advisory Committee originally received. A fixed 10% five-year CVD threshold does not capture the kidney and lifetime risk these medicines prevent.

Understanding PHARMAC's proposal

PHARMAC is proposing to amend the Special Authority criteria for three type 2 diabetes medicines (empagliflozin [Jardiance], dulaglutide [Trulicity] and liraglutide [Victoza]), stating it will "widen access." The two changes they are proposing are:

Everyone who accesses through either criteria still has to first have an HbA1c of 53 mmol/mol or higher AND have tried other treatment for 3 to 6 months. People are also still not allowed to use both empagliflozin and dulaglutide or liraglutide together, which is best practice for people at high risk of heart or kidney problems.

Lowering the cardiovascular risk threshold is a good thing, and it would help more people who currently miss out. But removing the ethnicity criteria means many Māori and Pacific people who are at high risk of heart or kidney disease would miss out altogether, or only get these medicines once they are sicker. This page shows why the two changes are not equivalent, and what removing the ethnicity criteria would do to Māori and Pacific access.

Have your say
Submissions close 5pm, Thursday 11 June 2026

PHARMAC first gave the public about two weeks to respond, with submissions originally closing 28 May. After pushback, the window was extended by two weeks to 11 June. Further detail on the proposal was only released late on a Friday night, leaving roughly 8 working days to read, digest and respond on a change with serious equity consequences.

You can make a submission by emailing consult@pharmac.govt.nz or through PHARMAC's online consultation form.

Māori & Pasifika
Other
The proposal at a glance
The population
~25%
are Māori & Pasifika
Who has diabetes
~31%
of all diabetes
What PHARMAC's proposal would do over 5 years
Share eligible & accessing now
~45%
of those eligible and accessing
Proposed share eligible & accessing
~17%
estimated in 5 years

Only 25% of the NZ population are Māori & Pasifika, but they make up about 31% of people with diabetes, and have far higher rates of it. The ethnicity criteria lifted their share of people on these medicines to ~45%. PHARMAC's proposal would pull that back to an estimated ~17% within 5 years.

1. Who has diabetes

Māori and Pasifika are about a quarter of the population but make up far more of the people living with diabetes and its worst complications.

Type 2 diabetes prevalence
Māori ~1 in 12
Pasifika ~1 in 7
vs European ~1 in 30
NZ Health Survey / MoH. See also the Virtual Diabetes Register.
Heart failure (under 50)
Māori 6×
Pasifika 7.5×
the European/other rate
Chan et al, BMJ Heart 2023
Dialysis / kidney failure
Māori ~3×
Pasifika ~5×
the European rate
Walker et al 2018 / 2019

2. Empagliflozin (Jardiance) closes the equity gap

Māori and Pasifika are far more likely to die without this medicine. Because their risk starts so much higher, getting the medicine prevents more deaths, and brings them back toward everyone else. It's not that the drug works differently in their bodies; it's that they have the most to lose without it.

Māori
High risk
53% ↓
fewer deaths with the medicine
Pasifika
High risk
49% ↓
fewer deaths with the medicine
European
Lower risk
33% ↓
fewer deaths with the medicine

The medicine does the most good for the people who are most likely to die without it. That's how it closes the gap.

Mortality reduction with SGLT2i use. Chepulis, Paul et al, Diabetologia 2026 (HR 0.475 Māori, 0.507 Pacific, 0.667 European). Bar heights illustrate relative baseline risk of death without the medicine.

Māori and Pacific people do not have an unfair advantage from accessing these medicines earlier. They have an unfair disadvantage from not getting access to these medicines.

Healthcare is already delivered on an uneven playing field. People do not enter the system with equal access, equal resources or equal opportunity to receive care.

This is why the ethnicity criteria exist. They are an evidence-based response to documented, higher clinical need, and four years of prescribing data show they have improved access for Māori and Pacific.

Ethnicity as an evidence-based marker of need: Loring et al 2024 (NZMJ); Te Karu, NZ Doctor 2026. Criteria improving access: Tamatea, Te Karu et al 2025 (Health Systems & Reform); Paul, Keenan, Rodrigues et al 2023 (NZMJ).

3. Who actually gets these medicines

Start with how common diabetes is in each group. Māori and Pacific people are far more likely to have type 2 diabetes than European people. When a medicine has no ethnicity criteria (like metformin or insulin), Māori and Pacific make up a smaller share of those getting it than their disease burden would suggest. The ethnicity criteria is the thing that lifted that share for empagliflozin, dulaglutide and liraglutide.

How common type 2 diabetes is, by group (rate per population)
Pacificabout 1 in 7
Indianabout 1 in 10
Māoriabout 1 in 12
Europeanabout 1 in 30
A Pacific person is about 4 times as likely, and a Māori person about 2.5 times as likely, to have type 2 diabetes as a European person.

Virtual Diabetes Register 2024 (age-standardised rates per 1,000: Pacific 136.2, Indian 102.7, Māori 82.1, European/other 33.1). Counts: European/other 209,469; Māori 58,146; Pacific 50,245; Indian 28,914; total 346,774. Māori and Pacific are about 31% of all people with diabetes while about 25% of the population.

Māori & Pasifika Everyone else
Share of people getting metformin & insulin who are Māori & Pasifika (no ethnicity criteria)
30%70%
Only ~30% of people on these medicines are Māori & Pasifika. Without a criteria, despite their much higher rate of diabetes, Māori & Pasifika get left behind.
Share of people getting empagliflozin, dulaglutide & liraglutide who are Māori & Pasifika (with ethnicity criteria)
45%55%
~44–45% of people on these medicines are Māori & Pasifika. The ethnicity criteria lifted access to better reflect their share of the disease.

Tamatea, Te Karu et al 2025 (Health Systems & Reform), 2023 recipients: of those on GLP-1 agonists (dulaglutide/liraglutide), 31.1% were Māori and 14% Pacific (~45%); of those on SGLT2 inhibitors (empagliflozin), 21.7% Māori and 22.2% Pacific (~44%). For medicines with no eligibility restrictions: insulin recipients were 16.9% Māori and 13% Pacific (~30%); metformin recipients 16.7% Māori and 13.3% Pacific (~30%).

4. The uptake gap: what Pharmac assumes vs what really happens

Pharmac's headline projection assumes nearly everyone eligible will start the medicine. No ethnic group in published NZ data gets close.

Pharmac assumes
up to 100% by Year 5
Māori (real)
50.8%
Pasifika (real)
48.8%
European (real)
36–37%
Real-world initiation rates: Chepulis et al 2025, BMC Health Services Research (cited in DAC June 2025, para 5.14). Pharmac assumption: TAR 589, para 1.1.3.

5. The "gain": what PHARMAC tells you vs what's actually happening

What PHARMAC tells you
23,378 people gain access
PHARMAC's headline figure over 5 years, presented as a straightforward win for access.
What's more likely
~19,300 genuinely new, almost all non-Māori & Pasifika
~4,100 of the "gain" are Māori & Pasifika who already qualified and are just moved to a new pathway, not new access. Source: Pharmac BIA; reconstruction.
What this means for Māori & Pasifika

No one already on these medicines loses access. The change applies to new applications from 1 August 2026, so it is future Māori and Pacific patients who are affected. Three outcomes:

Keep access Māori and Pacific already on the medicine before August 2026 stay on it.
Delayed access Future Māori and Pacific who would have qualified on ethnicity must now wait until 5-year cardiovascular risk reaches ≥10% or kidney disease develops. They get the medicine later, once sicker.
Lose access Future Māori and Pacific who never cross that clinical threshold would not get these medicines at all. On our reading of Pharmac's analysis this is roughly 7,000 people over five years.
Who the "new access" actually goes to
Non-Māori/Pasifika gaining access (~19,300)
Māori & Pasifika who already had it (~4,100)
23,378
~19,300
people who actually get new access, almost all non-Māori/Pasifika, not 23,378
Māori & Pasifika losing access entirely
7,000
Māori & Pasifika lose access completely over 5 years
each figure ≈ 1,000 people · our row reading suggests closer to ~8,550

Source: Pharmac Budget Impact Analysis (5-year new initiators = 23,378). The 4,100 / 19,300 split and the ~7,000 loss are our reading of the BIA; the workings (Objective ID A1978502) are not public. BIA base case, BIA board paper.

6. With real uptake, far fewer people actually share these medicines

Apply the real published uptake rates (instead of Pharmac's near-100% assumption) and the "23,378" shrinks a lot, and the medicines reach far fewer people than the headline suggests.

Māori & Pasifika Everyone else
PHARMAC's assumption: nearly everyone eligible starts the medicine (~23,378 over 5 years)
17%83%
What real uptake looks like (~37–51% start in published data)
8%42%half never start
Illustrative. Applying real-world initiation rates (~37–51%, Chepulis et al 2025) to PHARMAC's eligible pool roughly halves the number who actually start the medicines, and Māori & Pasifika make up only a small slice of those who do. Exact totals depend on the BIA spreadsheet workings (Objective ID A1978502), which are not public.

7. What the proposal would do to rates of access to these medicines for Māori & Pasifika

Side by side: the Māori and Pacific share of these medicines now (with the ethnicity criteria) and the projected Māori and Pacific share by Year 5 under the proposal.

Māori & Pasifika
Everyone else
Now, with the ethnicity criteria
~45%
The Māori and Pacific share of people on these medicines was lifted to reflect their high rate of diabetes.
Tamatea, Te Karu et al 2025
Year 5, under the proposal
~17%
A drop of nearly 30 points, below even the no-criteria baseline of ~30%.
Pharmac BIA

From ~45% to ~17%. The proposal undoes exactly what the ethnicity criteria fixed.

Māori and Pacific peoples are about 25% of the population and about 31% of people with diabetes, and have far higher rates of it (Pacific about 1 in 7, Māori about 1 in 12, against about 1 in 30 European). The ethnicity criteria lifted their share of people on these medicines to about 45%, better reflecting that burden. At ~17%, the proposal would push that share below even a population-based share of 25%, for the group with the highest rates of diabetes and the worst complications.

Year-5 projection derived from Pharmac's own Budget Impact Analysis modelling (~13–17% range).

8. The proposal does not align with Health NZ Te Whatu Ora's own diabetes roadmap

Health NZ Te Whatu Ora published a National Diabetes Roadmap in 2026. Its section on improving access and appropriate use of medications sets out these points:

8. Align New Zealand's diagnostic threshold for diabetes and pre-diabetes with international standards to facilitate timely and appropriate diagnosis of diabetes and to minimize the risk of overdiagnosis of pre-diabetes.

9. Support the use of medicines with an equity focus by improving access and appropriate use.

10. Develop and publish combined cardiovascular, kidney, and metabolic guidelines to support the optimal use of medicines based on international best practice.

The proposal runs against Health NZ Te Whatu Ora's own roadmap. Point 9 calls for medicines to be supported with an equity focus, yet the proposal removes the equity-focused ethnicity criteria. Point 10 calls for combined cardiovascular, kidney and metabolic guidelines based on international best practice, yet the proposal narrows access to a single fixed cardiovascular risk threshold (10% over five years) that does not capture kidney or lifetime metabolic risk.

Sources: Health NZ Te Whatu Ora National Diabetes Roadmap 2026; Health NZ Te Whatu Ora Diabetes Baseline Review. Listed with links in the proof tab.

Put it all together:

Pharmac says this proposal would widen access to 23,378 more people over five years, and that about one third would be Māori and Pacific. But on our reading of the Budget Impact Analysis, around 4,100 of those Māori and Pacific people already had access, and an estimated 7,000 Māori and Pasifika lose access completely. For Māori and Pacific, this proposal does not widen access. At best it delays it, and for an estimated 7,000 people it removes access entirely, in the group most likely to have the worst outcomes. (The 4,100 and 7,000 are our estimates from Pharmac's Budget Impact Analysis; the underlying workings, Objective ID A1978502, are not public.)

Sources:
• Prevalence/complications: NZ Health Survey, MoH; Chan et al, BMJ Heart 2023; Walker et al, Int J Equity Health 2018 & Semin Nephrol 2019.
• Effectiveness: Chepulis, Paul et al, Diabetologia 2026 (open access).
• Prescribing shares: Tamatea, Te Karu et al 2025, Health Systems & Reform, "Indigenous Leadership and Advocacy in Pro-Equity Eligibility Criteria for New Diabetes Medicines in Aotearoa New Zealand"
• Uptake: Chepulis et al 2025, BMC Health Services Research; Pharmac TAR 589 (2025-12).
• Gain/loss & Year-5 share: Pharmac Budget Impact Analysis (5-yr new initiators = 23,378). The ~4,100/~19,300 split, ~7,000 loss, and ~17% Year-5 share are reconstructions from the BIA; spreadsheet workings (Objective ID A1978502) are not public, so 7,000 can't be independently validated, and our row reading points to ~8,550. Use 7,000 publicly unless the workings can be cited.

Show me the proof

The claims on this page, each with a quote and a link to the source. Where a source is a paywalled journal, the full citation is given so it can be looked up. Quotes from advisory committee records should be checked against the original PHARMAC documents, linked in the source library at the bottom.

Claim by claim
Pharmac's own Diabetes Advisory Committee said keep the ethnicity criteria, and that they meet a strict legal test
In its 26 June 2025 record, the Committee set out at length why the criteria are clinically appropriate and meet the legal test. The key passages:
Members considered that no evidence had been provided to change its previous considerations that the ethnicity criteria were clinically appropriate.
Māori and Pacific peoples with type 2 diabetes have demonstrated differential cardiovascular and renal risk that cannot be fully captured in any other way and is independent of clinical variables. Pharmac (and its clinical advisors) had been unable to identify any other factor that could be used to identify this group that could be workably applied as a criterion in clinical practice.
The basis for Pharmac's 2021 funding of SGLT2i/GLP-1a used strict analytical criteria to meet human rights legislation requirements for 'Special Measures', under s.19(2) of the New Zealand Bill of Rights Act and s.73 of the Human Rights Act.
That legal test includes a lack of any reasonable alternative that does not use ethnicity, a real prospect the criteria would address the disadvantage, and that the measure is not wider than necessary. The Committee found the test still met, and recorded that the assessment aligns with the Government's own Cabinet Office circular CO (24) 5 on needs-based service provision.
Having ethnicity criteria recognised that SA criteria are but one of many parts of a system that will be required to redress funded access inequities; alone as an action it was insufficient, but it was still necessary.
The Committee also recorded that people who do not meet the ethnicity criterion but who are at high risk, including South Asian people, are still captured through the other criteria, so the criteria are not over-inclusive. Alongside keeping the ethnicity criteria, the Committee supported a clinician's assessment of cardio-renal risk to widen access, rather than the fixed risk threshold later put forward. It also warned that removing the criteria would likely reduce prescribing for Māori and Pacific.
Some Members considered that... if the criteria were revised to exclude the ethnicity component, then it was possible that prescribing for these populations would reduce.
Source: Diabetes Advisory Committee record, 26 June 2025 (paras 5.4, 5.15, 5.16, 5.17). DAC record (PDF)
The estimated numbers: who gains, who already had access, and who loses it
If approved, Pharmac estimates that around 10,000 more people could benefit in the first year, increasing to around 23,000 people after five years. People already receiving these medicines will not be affected by the proposed changes.
Source: Hon David Seymour, Beehive press release. Press release · Consultation page
The 23,378 five-year figure is Pharmac's. Our reading of the Budget Impact Analysis splits it into roughly 19,300 genuinely new people (almost all not Māori or Pacific), about 4,100 Māori and Pacific who already qualified under the existing criteria, and around 7,000 Māori and Pacific who lose access entirely. The underlying workings (Objective ID A1978502) are not public, so this split is our estimate and cannot be independently confirmed.
Source: Pharmac Budget Impact Analysis. BIA base case (XLSX) · BIA board paper (XLSX)
"No one will lose access", and why that does not tell the whole story
No one currently receiving these medicines will lose access. They will continue treatment and will not be affected by the proposed changes.
Source: Pharmac, reported by RNZ, 21 May 2026. RNZ article
This is true only for the exact medicine a person is already on. A Māori or Pacific person currently accessing an SGLT2 inhibitor (empagliflozin) through the ethnicity criteria would, under the proposal, no longer be able to start a GLP-1 medicine (dulaglutide or liraglutide) unless they meet the new criteria. The GLP-1 criteria require prior treatment, and someone who has not been on empagliflozin long enough would not yet qualify. So some people do lose access to a treatment pathway, even though they keep the medicine they are already taking.
The removal of the ethnicity criterion was being lined up before this consultation
The criteria the Diabetes Advisory Committee worked with in June 2025 included two routes that reach the defined target population: the Māori and Pacific ethnicity criterion, and a clinician-judgement criterion (the one that let a doctor approve anyone they judged at high risk, without a specific test score).
DAC-stage criteria: 3.1 Patient is Māori or any Pacific ethnicity; or ... 3.6 In the opinion of the treating relevant practitioner the patient is at high risk of cardiovascular or renal complications of type 2 diabetes.
By August 2025, for tirzepatide (Mounjaro), and again in November 2025 for semaglutide (Ozempic), PTAC recommended Special Authority criteria for the same diabetes population that drop both the ethnicity criterion and the clinician-judgement criterion, keeping only fixed clinical thresholds (pre-existing CVD, a 5-year CVD risk score, young age at diagnosis, kidney disease). Both of those PTAC recommendations kept the threshold at 15%, so the removal of the ethnicity criterion and the clinician-judgement criterion was happening separately from, and before, the proposed move to 10%.
PTAC tirzepatide criteria, August 2025: 3. Any of the following: 3.1 pre-existing cardiovascular disease or risk equivalent; or 3.2 an absolute 5-year cardiovascular disease risk of 15% or greater; or 3.3 high lifetime cardiovascular risk due to being diagnosed in childhood or as a young adult; or 3.4 diabetic kidney disease.
The clinician-judgement criterion (3.6) is gone, and so is ethnicity. That criterion was the route that would have captured the broad target population the DAC defined. Removing it narrows access to a fixed calculator score.
The board-minutes timeline points the same way:
24 June 2025: two days before the Diabetes Advisory Committee met and reaffirmed the ethnicity criteria, the Board formalised the Access Criteria Policy, the policy framework later used to justify the change. The Board recorded it "aligns with recent legal advice provided to the Minister... on sections 6 and 7 of the Pae Ora (Healthy Futures) Act, 2022 and Pharmac's 2024/25 Letter of Expectation," and "involves defining the target population and setting broad, descriptive access criteria."
30 September 2025: the Board resolved to withdraw Pharmac's Te Tiriti o Waitangi policy and to put the Equity Policy under review, to align with the Letter of Expectations and Cabinet Circular CO (24) 5. The Te Tiriti policy is one of the documents that underpinned the original equity basis for the ethnicity criteria.
The 10% vs 15% threshold was already a live board item in September 2025. Item 4.5 in the 30 September minutes is redacted, but the 4 November minutes correct that item and quote it back:
Item 4.5, reword recommendation as it is not clear, provide the Board with a revised version of option 4, undertake a full health economic assessment of widened clinical criteria to a cardiovascular risk of greater than or equal to 10% (versus 15%).
So the substance of a redacted September board item is revealed in the November correction, and it is the 10% versus 15% threshold question at the centre of this consultation. The content (a clinical threshold option) is not obviously commercially sensitive or confidential, which raises a fair question about why it was redacted in the first place.
Sources: DAC slides June 2025; Board minutes 24 June, 30 September and 4 November 2025; PTAC records August and November 2025. PTAC Aug 2025 (PDF) · PTAC Nov 2025 (PDF)
The intended target population, and why the 10% threshold misses it
The intended target population for the funding of the two classes of medicines (SGLT2i/GLP1a) was those people with type 2 diabetes experiencing inadequate glycaemic control and either with established CV disease or at high risk of poor outcomes from cardiovascular or renal disease.
The target population was defined by cardiovascular or renal risk. The proposed fixed 10% five-year CVD threshold is a poor proxy for it: the Obesity Treatments Advisory Group recorded that the PREDICT tool generally will not score a person with type 2 diabetes above 10% unless other risk factors are already identified, and that PREDICT does not include renal outcomes at all. The way the population was described also narrowed across Pharmac's documents, from the DAC slides' broad "high risk of cardiovascular and renal complications" to the OTAG PICO's fixed "five-year CVD risk of 10-14%". The definition was narrowed to match the proposed criteria, rather than the criteria being built to serve the population the experts defined.
Sources: Diabetes Advisory Committee record, 26 June 2025 (paras 5.3, 5.6); DAC slides June 2025; OTAG record, 11 December 2025. DAC record (PDF) · DAC slides (PDF) · OTAG record (PDF)
What the Obesity Treatments Advisory Group actually said about "many but not all"
The Group considered that if the Special Authority criteria providing access based on Māori and Pacific ethnicity were removed, many (but not all) individuals from these populations would still qualify under other measures, such as the lower proposed CVD risk threshold (≥10%) and the criterion for high lifetime risk due to being diagnosed with T2DM in childhood or as a young adult.
This is the line Pharmac's public messaging draws on. Read in full, it says many but not all would still qualify, and only by combining the 10% threshold with the young-age-at-diagnosis criterion, not the 10% threshold alone. The Group qualified this heavily in the same record:
The Group considered that a 5-year CVD threshold of ≥10% to reflect 'high risk' is relatively high compared to other jurisdictions, where some use a 10-year risk ≥10% (equivalent to approximately 4% over 5-years).
The Group considered the standard CVD risk assessment tool (PREDICT) used in New Zealand would generally not calculate a 5-year risk score greater than 10% for those with T2DM unless additional cardiovascular risk factors had already been identified. In addition, the Group noted that the PREDICT CVD risk calculation does not include renal outcomes which may result in an underestimation of future cardio-renal risk.
The Group reiterated the significant benefits of SGLT-2 inhibitors and expressed a strong preference for open listing for all patients with T2DM... The Group considered that open listing would be the most effective approach to ensure the entire population impacted by the removal of ethnicity-based criteria is captured.
In other words, the Group's preferred solution was open listing for everyone, not the proposed 10% threshold. It also recorded that Māori and Pacific develop type 2 diabetes much younger and carry a cardio-renal disease burden six to seven times higher than other groups.
Source: Obesity Treatments Advisory Group record, 11 December 2025. OTAG record (PDF)
The public statement, set against the records
Our expert advisors have told us that expanding clinical eligibility criteria by lowering the five-year cardiovascular risk threshold will mean most Māori and Pacific peoples with type 2 diabetes and at high risk of cardiovascular or renal disease will meet the proposed criteria.
Source: Pharmac (attributed to Dr David Hughes), reported by RNZ, 21 May 2026. Set against the Diabetes Advisory Committee record, which endorsed keeping the ethnicity criteria. RNZ article · 1News report · DAC record (PDF)
Real-world uptake is far lower than Pharmac's modelled rate
Initiation of therapy was highest in Māori (50.8%) and Pacific (48.8%) patients (vs. 36.2% to 40.7% of other ethnic groups; P < 0.001).
These are the published real-world initiation rates, recorded in the DAC June 2025 record (para 5.14.3, citing Chepulis et al 2025). Pharmac's modelling assumed uptake of around 80 to 100% (TAR 589, para 1.1.3).
Source: Chepulis et al 2025, BMC Health Services Research (cited in DAC June 2025, para 5.14). Pharmac assumption: TAR 589, para 1.1.3. TAR 589 excerpt (PDF)
The ethnicity criteria improved access for Māori and Pacific
Early prescribing data showed higher uptake of funded SGLT2 inhibitors and GLP-1 receptor agonists among Māori and Pacific peoples. Pull the exact figures from the paper.
Source: Paul, Keenan, Rodrigues et al, "Inclusion of ethnicity in Special Authority criteria improves access to medications for Māori and Pacific peoples with type 2 diabetes," NZMJ 2023;136(1574):93-97. (Citation given; journal access may be required.)
Survival improves for Māori and Pacific on SGLT2 inhibitors
Survival for Māori and Pacific peoples with type 2 diabetes who are prescribed SGLT2 inhibitors improves and moves closer to that of non-Māori, non-Pacific peoples. Pull the exact hazard ratios from the paper.
Source: Chepulis, Gan, Simmons et al, "SGLT2 inhibitor use and disparities in all-cause mortality in type 2 diabetes," Diabetologia 2026. (Citation given; journal access may be required.)
Why ethnicity is a valid basis for the criteria
Source: Loring, Reid, Curtis et al, "Ethnicity is an evidence-based marker of need," NZMJ 2024. Also Tamatea, Te Karu et al 2025, Health Systems & Reform. (Citations given; journal access may be required.)
The political framing
Ethnicity shouldn't decide what funded options you can access to manage type 2 diabetes.
These medicines help lower blood sugar and reduce the likelihood of heart and kidney complications. Under this proposal more people with type 2 diabetes who are at high risk of heart or kidney complications could receive these medicines earlier. Everyone who needs this support should have access to it.
Source: Hon David Seymour, Beehive press release. Note the tension: if "everyone who needs this support should have access," that is the argument for keeping the ethnicity criteria, which were added precisely because Māori and Pacific need is documented and higher. Press release
The "based on need, not ethnicity" framing
Today's proposal is another step in our plan to deliver timely, quality healthcare for all New Zealanders, based on clinical need, rather than ethnicity.
Source: Hon Simeon Brown, Beehive press release. The ethnicity criteria were themselves a needs-based measure: Māori and Pacific carry a documented, higher burden of diabetes and its complications, so ethnicity was used as an evidence-based marker of need. Press release
The "mother raising her kids" example
This proposal is about people. It's about the mum managing her diabetes while raising her kids, the grandad who wants to be around to watch his grandchildren grow up, and the thousands of Kiwis who simply want to live longer, healthier lives.
Source: Hon Simeon Brown, Beehive press release. Even a high-risk Māori mother in her 40s, an ex-smoker living in deprivation, with a family history of cardiovascular disease, high blood pressure, high cholesterol and an elevated HbA1c, would find it difficult to meet the proposed criteria, unless she qualified through the chronic kidney disease criteria or a young age at diagnosis. So the example given may not actually reach the proposed threshold. Press release
The proposal contradicts Health NZ Te Whatu Ora's own diabetes roadmap
9. Support the use of medicines with an equity focus by improving access and appropriate use.
10. Develop and publish combined cardiovascular, kidney, and metabolic guidelines to support the optimal use of medicines based on international best practice.
Source: Health NZ Te Whatu Ora, National Diabetes Roadmap 2026 (section on improving access and appropriate use of medications for people with diabetes). National Diabetes Roadmap 2026 (PDF)
The proposal removes the equity-focused ethnicity criteria (against point 9) and narrows access to a single fixed five-year cardiovascular risk threshold that does not capture kidney or metabolic risk (against point 10, which calls for combined cardiovascular, kidney and metabolic guidelines).
Source library: PHARMAC documents
Source library: announcements and media
Source library: PHARMAC policies
Source library: Health NZ Te Whatu Ora
Source library: independent evidence