Submission on Pharmac's proposal to delist gluten-free foods

NZORD submission to PHARMAC consultation on delisting of gluten free foods - 30 April 2003.

NZORD expresses its concern at a consultation that appears to be driven by cost considerations alone, without any reference to the medical benefits or risks to patients who require gluten-free food. Such an approach seems contrary to PHARMAC's over-riding objective to obtain the "best health outcomes that are reasonably achievable from within the funding provided".

We are surprised that there is no reference to any therapeutics advisory committee recommendations and this absence suggests the idea has not gone down this path. Nor is there any suggestion that PHARMAC's consumer advisory committee has been involved in any way. I am aware that the Coeliac Society is less than impressed with the prior notification it had from PHARMAC on this matter.

Advice received from the Coeliac Society indicates there are many medical benefits and risks associated with provision or non-provision of gluten-free products, but the proposal makes no reference to these at all. The implication is that this work has not been done. There certainly was no cost/benefit analysis mentioned in support of the proposal.

NZORD supports the extensive efforts that PHARMAC has made in recent years to get best value from pharmaceutical expenditure, but suggests that in this case the process seems less rigorous than usual. We suggest that the Board direct PHARMAC staff to obtain suitable evidence of the costs and benefits, in consultation with the Coeliac Society and other expert advisors.

John Forman
Executive Director