Submission to PHARMAC Review

Submitted to PHARMAC Review 21/06/2021

Submission form

To help us to consider your submission we are asking that you focus on the following questions. There is the opportunity to provide additional feedback at the end. We expect to get a high response and ask that, where you can, you are concise. Once you have completed your submission please send it to: pharmacreview@health.govt.nz

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Submission questions

Tell us about your current experience with PHARMAC

1.     What is your understanding of what PHARMAC does?   PHARMAC runs something like a national formulary (or medicines list) in the sense that it determines those prescription medicines that are covered under our tax-payer-funded public health system, in particular the level of public subsidy (full or part charge) that listed medicines enjoy, and the conditions under which they may be provided (e.g. specialist only). Its brief has recently been formally and publicly extended to medical devices. Behind that description of its role lies an entire structure of evaluation and assessment that determines how and when medicines are brought onto the list.   Uniquely, PHARMAC also undertakes direct price negotiation with pharmaceutical companies. There are many health technology, pharmaceutical and clinical service agencies of different configurations around the world, but very few if any of them that I am aware of negotiate prices directly with the companies involved. The precursor to this was the establishment, in the health reform period of the late 1980s, of a commercially-informed unit in the Department of Health in order to secure better prices than had been possible under a more traditional bureaucratic model that had held sway until then.  
2.    What has been your experience of working with PHARMAC?   I have had very little to do with PHARMAC directly. I am a retired health policy and health services academic and have had an interest in the agency as a uniquely New Zealand institutional innovation and thus as an academic subject of interest.   This focus started before the formation of PHARMAC, since I had an interest in the issue of high-price medicines in the late 1980s when New Zealand started to go through a reform period in health (as elsewhere). In the 1990 election the Research Medicines Industry (forerunner to Medicines NZ) ran a series of four advertisements during the campaign period, one of which I reproduce below (it is an illustration from a book I edited in the 1990s on the topic of pharmaceutical policy in New Zealand). At that point I realised that the issue of funding medicines was of such high political moment that the local branch of the international pharmaceutical industry was prepared to enter a New Zealand election.   My interest in medicines funding and policy has remained from that period – as a special case study. My role, therefore has been as academic observer and commentator, and so I have not had much direct involvement with PHARMAC directly, except over the last year or two I have been in touch with PHARMAC staff to check a number of facts and figures. I have also written a number of “opinion” pieces in the media because I see PHARMAC as a highly beneficial agency and feel it is much maligned in public debate, and insufficiently defended. This more active role in public debate coincides with my formal retirement from university employment. I now hold Emeritus and Honorary positions at the University of Auckland. This has allowed me to be freer to enter public debate, while at the same time maintaining my expertise in the area. My books on pharmaceuticals can be found at: https://peterdavisnz.com/books/3/; https://peterdavisnz.com/books/6/; https://peterdavisnz.com/books/7/; https://peterdavisnz.com/books/9/    
3.    What are the challenges with PHARMAC’s functions for funding medicines and devices?   I see three major challenges.   1)    The primary challenge faced by PHARMAC now, as in the past and as will be in the future, is retaining sufficient public trust and political support to do what is the almost impossible task of applying a limited set of funds to an almost limitless potential demand, while at the same time being under the relentless scrutiny of an active media and subject to the savvy and strategic pressure of the international pharmaceutical industry as expressed and applied through its local representatives (Medicines New Zealand). Social media is likely to add to this pressure as an aggregator of groups and opinions on controversial matters.   2)    Another important bulwark of trust and credibility is the medical profession (and other health professionals, including pharmacists). I get the sense that the medical profession is now largely supportive of PHARMAC’s work, although in a passive way, and it still seems to be the case that individual specialists can go public when a therapeutic product they are particularly committed to does not get funded in a timely fashion. This seems to have picked up as PHARMAC has moved from medicines prescribed by family doctors (GPs) through to specialists and now to hospitals. The expertise required is higher, the moral pressure magnified, and the power of particular clinical lobby groups greater. It is striking how active the Cancer Society’s Chris Jackson has been prepared to be (it is fortunate that we now have a cancer control agency that is able to provide information from less of an advocacy position (https://teaho.govt.nz/reports/cancer-state)). If each major therapeutic area had advocates this energetic, the work of PHARMAC would be very much harder.   3)    One development that has made PHARMAC’s job harder, but also more essential, has been the tendency for drug regulatory agencies to increasingly pass medicines through a process of expedited review. This means the data available are more limited with poorer research designs, shorter time periods of clinical trial assessment, lack of appropriate comparator, use of proxy or surrogate measures, and so on (for example, among others, see https://heatinformatics.com/sites/default/files/images-videosFileContent/bmj.l4340.full_.pdf). This means the agency’s job is harder – because the necessary information is just not there – but also all the more essential because probably the great majority of these “pass-throughs” are insufficiently proven and may add precious little of clinical significance, and yet potentially are still likely to be very expensive.   The most recent and striking example of where the drug regulatory agencies are passing some of the hard decisions on is the recent decision of the FDA (US Food and Drug Agency) to accept an Alzheimer’s medicine despite opposition of almost all its science advisers (https://www.theguardian.com/society/2021/jun/07/fda-announce-decision-new-alzheimers-drug-aducanumab). As with cancer, regulatory bodies are under public pressure to give the benefit of the doubt to new drugs.  

What do you know about PHARMAC’s processes?

4.     What do you think works well with the processes PHARMAC uses to assess the funding of medicines and medical devices?   The foundation to PHARMAC’s credibility in decision-making is its range of expert advisory committees, which in turn then feed into PTAC (Pharmacology and Therapeutics Advisory Committee). This provides a solid basis of expertise that ensures that PHARMAC’s clinical decisions are well grounded. This is fundamental to its credibility in the clinical community.   The importance of clinical expertise has always been central to assessing drugs, but in the early days it seemed to outside observers that these committees in the pre-PHARMAC days were affected by conflicts of interest (declared and undeclared) since many clinicians had various ties with the pharmaceutical industry, such as payments for advice, lectures, conference attendance, clinical trials and so on. This could involve companies whose products were being concurrently assessed. As far as I am aware this is no longer an issue.   The second important feature of PHARMAC’s processes is it use of advanced economic analyses (Cost Utility Analysis (CUA)) in moving beyond solely clinical criteria to health outcomes and the relative potential effectiveness of different “investments” of public money designed to improve health and other social outcomes. This approach is not only of assistance in deciding among competing drug-funding decisions, but also in setting a benchmark against the price being asked by the manufacturer in question and against other potential “investments”, both in health (for example, non-pharmacological interventions) and outside health (for example, safety investments in transport).  
5.     What do you think are the barriers to accessing medicines and devices?   The main barrier to accessing medicines that are “on the schedule” is the cost and availability of attending a prescriber (i.e. a GP or specialist). It should also be noted that New Zealand has many drugs available for purchase “over-the-counter” (OTC) from the pharmacist that in other jurisdictions are only available by prescription. Thus, it is possible that it makes more sense to get an OTC (say, for pain relief) from a pharmacist and pay the unsubsidised commercial rate rather than a fee to see a doctor to get a fully-subsidised script. This is part of the pharmaceuticals story in New Zealand that is not well known, although, in a public health system, OTC access should not be seen in any way as a real substitute for attending a GP for most conditions requiring medication.   By definition medicines that are not “on the schedule” are not available in New Zealand. This is where much of the controversy with PHARMAC is. Unfortunately, we do not have the figures publicly on how many people are involved. It could be a fraction of one per cent of the prescribed patient population, but obviously it gets more than its fair share of media publicity (for obvious reasons). This puts PHARMAC on the defensive.   Most stories in this area lack balance. For example, if a patient says that a drug is a “breakthrough” drug or a life-saver, that gives the story sufficient credibility in the popular mind and the media to carry the day, even when those claims may be manifestly untrue (in other words, the drug is not a breakthrough, and it does not significantly extend life expectancy). It seems hard for PHARMAC to rebut these claims, although it does have a routine reply along the lines of “limited budget, difficult trade-offs”.   However, I believe PHARMAC could do more to outline the merits of different drugs that are not “on the schedule”, although it has to take care not to undermine its bargaining position with drug companies. For example, it does seem extraordinary that, according to media reports, people seem prepared to sell their houses and go over the Tasman to access drugs available in Australia when there might be real questions as to whether those drugs are really a significant clinical advance over what is available in New Zealand.   Medicines New Zealand has touted a special fund for specified drugs (for example, high-priced, “innovative” cancer drugs) to be taken out of the PHARMAC process and given special, expedited treatment. This idea has gone through various iterations in the United Kingdom, supported by the industry and by the medical charities, and by politicians who feel under pressure particularly when it comes to patients awaiting the release and funding of cancer treatments. On any objective assessment, however, it is hard to see the benefits of such a system, except for the companies concerned. Firstly, it privileges one group of drugs over others and, unless new funding is released, it removes funding available for other new drugs. Secondly, it undermines the integrity of the assessment system since these drugs are seen to get an easier ride. Thirdly, most evaluations of these schemes have found them to be costly and poor value for money. As these concerns have become more evident, the UK has inched towards the PHARMAC model, attempting to negotiate with companies for lower prices in return for earlier, probationary access to the market.   As for medical devices, this is early days. As I understand it, the “gatekeeper” to access is again a medical professional, presumably a specialist who will decide whether or not a patient requires a medical device. The untold story here is that PHARMAC’s role is just as much quality control as price management, if not more so. Medical technologies do not have to meet the same regulatory oversight as medicines, and PHARMAC will provide a much-needed review of the effectiveness of different versions/makes of devices (for example, see https://bpac.org.nz/BT/2012/December/12_metalHips.aspx).  
6.     Is there any other country that does it better? What is it that it does better and would any of those systems apply here?   PHARMAC is almost unique in that it has a fixed budget within which it makes decisions on listing new medicines on the national schedule. I say “almost unique” because I am not absolutely sure that it is the only agency in this position, but it has allowed PHARMAC to deliver major savings to the New Zealand taxpayer (the budget would otherwise have to be treble its current size without the price savings PHARMAC has made).   Although the emphasis is understandably on PHARMAC’s cost savings, it actually performs an important quality control function. For example, many of the drugs that PHARMAC does not fund actually are turned down because they add little clinical value (at least in relation to their price). With medical devices this is even more the case since these do not undergo nearly as rigorous a review process as medicines.   I believe that PHARMAC could do the New Zealand health system a great service if it retained its budgetary and quality control functions with medicines and medical devices, but added onto this portfolio other technologies and services in a non-budgetary advisory role. This is the job done by the UK’s NICE (National Institute for Health and Care Excellence); that is, providing advice and guidelines on new technologies, procedures and services. New Zealand used to have an agency along these lines known as the National Health Committee, which was disbanded in 2016 (https://www.health.govt.nz/about-ministry/ministry-health-websites/national-health-committee), as it also had a guidelines group, which was disbanded in 2012 (https://www.health.govt.nz/about-ministry/ministry-health-websites/new-zealand-guidelines-group). It could be said that both of these actions where short sighted because our system now lacks a central operationally-focused knowledge and advice source in these crucial areas.   This would not necessarily be an onerous task since there is an array of such agencies around the world all addressing very much the same questions and all that PHARMAC (or, preferably, a renamed PHARMAC) would have to do is act as a kind of clearinghouse and synthesiser of this information. At least in the first instance. It could be that in due course (the renamed?) PHARMAC might move to a more overtly budgetary responsibility for new technologies, services, procedures and interventions as it does for medicines and devices, but at this stage it would be worth trying out this new expanded role without a budgetary function to see if it works.   Medicines New Zealand would like to see PHARMAC moved to being without a budget, as is the case with the UK’s NICE, but this would rob the organisation of its key cost-saving function. NICE approves drugs, but then passes the job of funding them onto the NHS. Although it might seem intellectually attractive to separate the two functions – assessment and funding – in the end, in a country the size of New Zealand, assessing a drug or device without funding it would lead to a major “postcode lottery” as different budget holders responded in different ways to the budgetary challenge. The alternative to that would be to set a ruling from the centre, which would bring us back to PHARMAC’s role again. It would also lead to New Zealand paying much more for drugs than it does now.  

What should PHARMAC’s role include in the future?

7.     How might PHARMAC look in the future? What needs to change for this to happen?   I make four suggestions. A change of name and extension of function. An expanded and consolidated skills base and function in health technology assessment. The more active use of existing data to assist the sector. And a better projection to the public   Change of name and extension of function   We need to take the emphasis off PHARMAC as purely a medicines agency. That has started with the agency taking on medical devices. This is because PHARMAC is New Zealand’s premier agency dedicated to the evidence-based assessment of health technologies. As argued above, the disbanding of the National Heath Committee (and the Guidelines Group) means that we now have no central agency dedicated to evaluating new technologies, procedures and services for the New Zealand health system.   I propose that we rename PHARMAC “The Therapeutic Products and Services Agency” (THERPSA (or something similar)) or just PHARMAC+, retain its budgetary and assessment responsibility for medicines and medical devices, and add assessment and advisory functions for new technologies, procedures and services. As argued above, there is an array of such agencies around the world, both bureaucratic and academic, and therefore much of the work would be as a clearing house bringing together such information, synthesising it and making recommendations. There could be a series of expert committees to service this function.   Development of evidence-based health technology skills base   Perhaps because PHARMAC has done such a good job on prescription medicines, New Zealand has languished on a wider suite of health technology and clinical service assessment skills. There has been the National Health Committee and the New Zealand Guidelines Group, but both of these have now been extinguished. This means that there is currently no official and respected skills base for evaluating new technologies, procedures and clinical interventions independently of the companies and clinicians promoting them.   There is a world-wide network of such assessment centres. Thus, New Zealand would not have to “reinvent the wheel” but rather draw on this network and provides its own evaluations system, much as PHARMAC does for prescription medicines, and now for medical devices. Such a formalised assessment function could probably strengthen the current medicines evaluation system by assisting clinicians on advisory committees by bringing together international evidence in a rigorous and systematic fashion.   Active use of existing data   There is a huge amount of easily accessible data in our health system that is generated by health transactions and that can be associated with individuals via their NHI (National Health Index) number. This is world-leading, and we do not make enough of it.   PHARMAC could easily use these data both for its own purposes and for public benefit. For example, there supposedly is a function of pharmacovigilance, but this is rarely carried out rigorously or successfully. If PHARMAC is to take on medical devices it should be establishing what amount to clinical registries by setting up a system of data capture and tracking post-device insertion outcomes by way of visits to the doctor, ED, etc. This would be non-invasive since the data are available and anonymised. There is no need to know the identity of the patients involved. Similarly with the introduction of new drugs or generic equivalents. These can be tracked.   I co-supervised a PhD thesis where this was done for PHARMAC decisions as follows: https://pdfs.semanticscholar.org/3c05/3350b3f31d27807f9cb94145d195bea27842.pdf https://link.springer.com/article/10.1007/s40258-014-0110-0 https://link.springer.com/article/10.1007/s10488-014-0606-9 https://www.sciencedirect.com/science/article/pii/S1098301515019816   Better projection to the public   PHARMAC needs to do a better job of projecting to the public. At present Medicines New Zealand and the medical charities dominate the narrative. Almost nobody comes to the defence of PHARMAC publicly. Indeed, the only two I am aware of in the media are both retired academics (myself and one other)!   If we take as an example Medicines New Zealand’s “Medicines Landscape”, this is basically a demolition job on, and searing indictment of, PHARMAC, and yet many if not all the assertions are at least subject to debate, in many instances are at best half-truths, and almost all misleading and tendentious. This narrative, and these “factoids” are picked up and recycled by media, by medical charities, and patient groups and aggrieved individuals   To take a simple example, PHARMAC is shown to have one of the lowest investments in in the OECD in pharmaceuticals, when taken as a proportion of health vote (about 5%). This is true, and the clear implication is that New Zealand is underfunding. And yet on a $1 billion dollar budget PHARMAC has saved $2 billion dollars; in other words, if PHARMAC had not made these savings, the budget would need to treble. This would put PHARMAC’s proportion of the health vote at around 15%, which would put it probably above the OECD average. So, the agency is a victim of its success, on this particular statistic.   PHARMAC needs to provide a Q&A replying to each of the assertions of Medicines New Zealand. It also needs to provide much more information on how New Zealand’s take-up of pharmaceuticals compares internationally. Obviously, it cannot be too active, because this might attract pushback, but a world-leading public agency of this calibre cannot be left to be “put in the stocks” to be pelted, without some defence. Otherwise, the credibility and legitimacy of the agency will be undermined and we will be all the worse for that.  
8.     How might PHARMAC look in the future? What needs to change for this to happen?   I make four suggestions. A change of name and extension of function. An expanded and consolidated skills base and function in health technology assessment. The more active use of existing data to assist the sector. And a better projection to the public   1.     Change of name and extension of function   We need to take the emphasis off PHARMAC as purely a medicines agency. That has started with the agency taking on medical devices. This is because PHARMAC is New Zealand’s premier agency dedicated to the evidence-based assessment of health technologies. As argued above, the disbanding of the National Heath Committee (and the Guidelines Group) means that we now have no central agency dedicated to evaluating new technologies, procedures and services for the New Zealand health system.   I propose that we rename PHARMAC “The Therapeutic Products and Services Agency” (THERPSA (or something similar)) or just PHARMAC+, retain its budgetary and assessment responsibility for medicines and medical devices, and add assessment and advisory functions for new technologies, procedures and services. As argued above, there is an array of such agencies around the world, both bureaucratic and academic, and therefore much of the work would be as a clearing house bringing together such information, synthesising it and making recommendations. There could be a series of expert committees to service this function.   2.     Development of evidence-based health technology skills base   Perhaps because PHARMAC has done such a good job on prescription medicines, New Zealand has languished on a wider suite of health technology and clinical service assessment skills. There has been the National Health Committee and the New Zealand Guidelines Group, but both of these have now been extinguished. This means that there is currently no official and respected skills base for evaluating new technologies, procedures and clinical interventions independently of the companies and clinicians promoting them.   There is a world-wide network of such assessment centres. Thus, New Zealand would not have to “reinvent the wheel” but rather draw on this network and provides its own evaluations system, much as PHARMAC does for prescription medicines, and now for medical devices. Such a formalised assessment function could probably strengthen the current medicines evaluation system by assisting clinicians on advisory committees by bringing together international evidence in a rigorous and systematic fashion.   3.     Active use of existing data   There is a huge amount of easily accessible data in our health system that is generated by health transactions and that can be associated with individuals via their NHI (National Health Index) number. This is world-leading, and we do not make enough of it.   PHARMAC could easily use these data both for its own purposes and for public benefit. For example, there supposedly is a function of pharmacovigilance, but this is rarely carried out rigorously or successfully. If PHARMAC is to take on medical devices it should be establishing what amount to clinical registries by setting up a system of data capture and tracking post-device insertion outcomes by way of visits to the doctor, ED, etc. This would be non-invasive since the data are available and anonymised. There is no need to know the identity of the patients involved. Similarly with the introduction of new drugs or generic equivalents. These can be tracked.   I co-supervised a PhD thesis where this was done for PHARMAC decisions as follows: https://pdfs.semanticscholar.org/3c05/3350b3f31d27807f9cb94145d195bea27842.pdf https://link.springer.com/article/10.1007/s40258-014-0110-0 https://link.springer.com/article/10.1007/s10488-014-0606-9 https://www.sciencedirect.com/science/article/pii/S1098301515019816   4.     Better projection to the public   PHARMAC needs to do a better job of projecting to the public. At present Medicines New Zealand and the medical charities dominate the narrative. Almost nobody comes to the defence of PHARMAC publicly. Indeed, the only two I am aware of in the media are both retired academics (myself and one other)!   If we take as an example Medicines New Zealand’s “Medicines Landscape”, this is basically a demolition job on, and searing indictment of, PHARMAC, and yet many if not all the assertions are at least subject to debate, in many instances are at best half-truths, and almost all misleading and tendentious. This narrative, and these “factoids” are picked up and recycled by media, by medical charities, and patient groups and aggrieved individuals   To take a simple example, PHARMAC is shown to have one of the lowest investments in in the OECD in pharmaceuticals, when taken as a proportion of health vote (about 5%). This is true, and the clear implication is that New Zealand is underfunding. And yet on a $1 billion dollar budget PHARMAC has saved $2 billion dollars; in other words, if PHARMAC had not made these savings, the budget would need to treble. This would put PHARMAC’s proportion of the health vote at around 15%, which would put it probably above the OECD average. So, the agency is a victim of its success, on this particular statistic.   PHARMAC needs to provide a Q&A replying to each of the assertions of Medicines New Zealand. It also needs to provide much more information on how New Zealand’s take-up of pharmaceuticals compares internationally. Obviously, it cannot be too active, because this might attract pushback, but a world-leading public agency of this calibre cannot be left to be “put in the stocks” to be pelted, without some defence. Otherwise, the credibility and legitimacy of the agency will be undermined and we will be all the worse for that.  
9.    Are there additional or different things that PHARMAC should be doing?   I have four suggestions.   Hire a medical director.   PHARMAC should require transparency of the disbursement of funds either directly or indirectly to health professionals, medical charities and other advocacy groups by pharmaceutical companies which benefit from public subsidies. Each year companies should be required to publish a public record of such disbursements. Registers along these lines are available in Australia and touted for the United Kingdom.   PHARMAC should require pharmaceutical companies to desist from direct-to-consumer-advertising (DTCA) of products that are either under consideration or “on the schedule”. Outside the United States, New Zealand is the only country that permits DTCA of prescription medicines. For products that are under consideration or “on the schedule” this should not be permitted since it undermines the evidence-based use of these products. DTCA could still apply to OTC and to drugs not “on the schedule”.   The government should ask PHARMAC to take on the assessment of sunscreens and other important therapeutic products that are borderline cosmetic where there is a pressing public reason for doing so (public/preventive health pay-off but inadequate testing regimes and misleading advertising claims). However, it should not be expected to subsidise them. They should be available on an OTC basis, as at present.  
10.  What do the wider changes to the Health and Disability system mean for PHARMAC?   The primary change suggested under the review was the reduction or abolition of DHBs. This was a step to a more uniform, less cluttered national health care delivery system with clear operational separation from the Ministry of Health. PHARMAC has always been an agency with a national brief, and has retained an independence of the Ministry. So, the changes are consistent with this role.   With the move to a more “national” health system, central operational decisions become more important as part of a broader strategic framework that tries to ensure greater uniformity of the health care delivery system. PHARMAC’s expanded assessment brief could play a useful role in determining nationwide investments.   A Maori Health Authority (MHA) has also been established. I am not in favour of PHARMAC been split up since that would weaken its position vis a vis the pharmaceutical companies with whom it has to negotiate prices and access to the national schedule.    

How should PHARMAC address the need for greater equity in the decisions it takes, in particular for Māori, Pacific, disabled people?

11.  How well does PHARMAC reflect the principles of Te Tiriti o Waitangi?   I am not qualified to answer this. PHARMAC is a technical agency. It could work harder to ensure that more staff and members of its board are Maori, but I would not want to weaken its independence from political and popular pressure by giving it a more elaborate governance structure and/or increasing the number of political/other pressures points.  
12.  How can PHARMAC achieve more equitable outcomes?   People with rare disorders claim to be treated unfairly. People with non-life-threatening conditions claim to be treated unfairly vis a vis those who have potentially early loss of life. The young can claim that the elderly take a disproportionate share of funds because they have many illnesses and disabilities, while the young have an entire life before them which could be blighted by a health condition. People who could benefit from very expensive drugs that are not funded believe they are not treated adequately. Even the pharmaceutical industry argues that it is treated unfairly in New Zealand because it is paying lower prices here than overseas, and yet still needs to pay for R&D, so New Zealand is free-riding on other countries. In other words, this is a minefield of claims and counter-claims on fairness that is very hard if not impossible to arbitrate satisfactorily.   The principal sources of “inequitable outcomes” are the disparate health risks to which different social groups are exposed – for example, lower socio-economic, Maori and Pacifika are disadvantaged in this respect – and the differential access to high-quality primary care, which is the starting point for access to adequate treatment (where the same groups are disadvantaged, possibly with rural communities in the mix too). Neither of these are within PHARMAC’s powers to influence and depend on decision-making and policies implemented by the government of the day.   I believe that PHARMAC can do its best for equitable outcomes by doing its job well, without fear or favour, applying transparent and objective criteria that are widely accepted by its professional peers. Once it departs from this, then the clarity and impact of its mission becomes, in my view, clouded and undermined.  

Additional feedback

Is there anything else that you think the Review Panel should consider?   At the beginning of the previous term of this government the Ministry of Health started a programme for the review of the Medicines Act. There was a very sophisticated and comprehensive information document together with an online submission procedure, to which I contributed substantially. Nothing has eventuated. The Review Panel should ask that this process be re-started, possibly taking into account any relevant recommendations the Review Panel might make.   There used to be a Medicines Policy that was current. That is no longer the case as I understand it. There needs to be a “reboot” of the National Medicines Policy, particularly in the light of any changes to PHARMAC resulting from this review.   The independence of PHARMAC from the political process (other than funding) is paramount. This allows PHARMAC to do the job it does, and it removes from politicians the temptation and pressure to intervene. The pharmaceutical area is a heady mix of commercial imperative (charge what the market can bear and recoup R&D), moral pressure (saving, extending, and improving lives through health interventions), and, belatedly, evidence-based decision-making in the context of multiple calls upon the public purse. There is fundamentally no countervailing power that can weigh against the combination of commercial imperative and moral pressure – other than evidence-based decision-making, together with the monopsony power of an independent agency.  

Contact information

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NamePeter Davis
Email addresspb.davis@auckland.ac.nz
OrganisationRetired academic affiliated to the University of Auckland

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Tēnā koe mō tō tuku urupare mai.

5 comments

  1. […] The Interim Report of the review of PHARMAC has just been published, with the thrust of 213 submissions being critical. Eighty per cent of submissions came from representatives of the pharmaceutical industry, people with personal stories of distress, and patient advocacy groups. The remainder were health professionals, with just two submissions from academics, of which I was one. […]

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  2. Hi Peter, An interesting assessment of PHARMAC. The issues identified in the review are not new, we mentioned some of them in our 2006 paper, Centralized Drug Review Processes In Australia, Canada, New Zealand, And The United Kingdom, https://doi.org/10.1377/hlthaff.25.2.337. You mention about HTA in NZ having been undertaken in the past by the NHC and NZGG, both groups now disbanded, but you failed to mention that HTA was also undertaken by the New Zealand Health Technology Assessment unit (NZHTA) based in Christchurch which undertook HTA work for both the NZ and Australian governments. This group’s website while now offline can be retrieved through the wayback machine, a December 2005 picked at random for illustration, https://web.archive.org/web/20051212173002/http://nzhta.chmeds.ac.nz/ NZHTA also blonged to the internationa network of agencies who undertook HTA in their respective countires, namely INAHTA see https://www.inahta.org/ All the best Ray

    Liked by 1 person

      • Hi Peter, all good, yes the INAHTA link is in the public domain should there should be no worries with its use, NZHTA was a member of INAHTA and then my research group HSAC that I established at Canterbury was also a member, all the best Ray

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