PHARMAC Submission — Diabetes Medicine Access Criteria

About you

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Date

Your role or relationship to diabetes Write this in your own words — it adds weight to your submission.

Your position on the proposed changes

I support reducing the cardiovascular risk threshold from 15% to 10% I do not support removing the ethnicity-based criteria

My reasons

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Consultation process

There has not been enough time for meaningful consultation on this change. Decisions affecting Māori and Pacific communities need proper engagement and opportunity for feedback. PHARMAC states this proposal will improve access to these medicines but has not clearly shown how this conclusion was reached. Without this information, communities cannot provide informed feedback.

Evidence and equity

The ethnicity criteria have improved access for Māori and Pacific people compared with medicines that do not require Special Authority, showing that this approach has been effective. These medicines are important because they reduce the risk of death and serious complications in type 2 diabetes, especially for Māori and Pacific people — who experience significantly higher diabetes-related death rates than other groups. Removing the ethnicity-based criteria is likely to reduce access and cause harm to Māori and Pacific people.

Missing information

PHARMAC has not provided information on the wider impacts of this change, including potential harm to Māori and Pacific communities, costs to the health system and economy, or how these medicines compare with alternative treatments. PHARMAC has not removed extra restrictions on GLP-1 criteria that were introduced during a worldwide shortage, which continue to delay access.

Access and clinical evidence

Empagliflozin should be available for all people with type 2 diabetes in line with international guidelines, with little or no restriction. Combination treatment with both groups of medicines should be available for people who have a high risk of heart or kidney disease over their lifetime. Alternative medicines have harms that have not been outlined in PHARMAC's proposal — such as weight gain, risk of low blood glucose — and many do not have additional benefits for preventing heart or kidney disease.

My recommendations

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Allow enough time for meaningful, transparent consultation on this proposal. Provide clear data to show how this proposal improves access and is cost-effective. Provide evidence that removing the ethnicity criteria will not cause harm to Māori and Pacific communities. Ensure the Special Authority criteria align with current evidence and expert guidance. Retain the ethnicity-based criteria. Proceed with reducing the cardiovascular risk threshold from 15% to 10%.

Additional comments (optional)

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Submission on proposed changes to Special Authority criteria

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