Advocacy and submissions
Ensuring that the voices and needs of our practices are effectively represented and championed remains a core pillar of the mahi we undertake on behalf of our practices. Through strong advocacy, we hope to influence policies where we can, create positive change, and safeguard the interests of our members and their patients.
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Advocacy for Additional Vaccine Ordering Safety Checks
ProCare has recently written to Healthcare Logistics (HCL) advocating for an additional safety measure to help reduce vaccine ordering errors in general practice.
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Submission on Medical Council of New Zealand's proposal of professional standards for physician associates (PAs)
ProCare agrees that the proposed standards are workable across the settings in which PAs practice. However, while we support the flexibility the standards provide, their current state could lead to potential risks such as unwarranted variation in scope of practice and deployment between services, as well as differing approaches to credentialling and supervision.
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Submission on Pharmac's proposal to widen access to some immunisations
ProCare supports wider access to the funded influenza vaccine for children aged 6 months to 5 years from 2027. We noted the proposed expanded access to the pneumococcal vaccine and suggested that older adults with moderate to severe COPD would benefit too. We also encouraged strong health promotion and clear messaging to increase vaccine uptake.
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Submission on proposed changes to Special Authority criteria for Type 2 diabetes medicines
ProCare supports lowering the CVD risk threshold from 15% to 10% and expanding access to effective medicines earlier in the disease pathway. However, we strongly oppose the removal of Māori and Pacific ethnicity as a standalone eligibility criterion. This element of the proposal represents a significant step backward in equity-focused health policy.
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Submission on the Ministry of Health's Draft Mental Health and Wellbeing Strategy
As New Zealand's largest mental health and wellbeing provider, ProCare Fresh Minds' offers perspective and recommendations on the strategy. We agree that the strategy sets a clear direction for the future of mental health, but call for clearer access pathways, stronger integration across services, workforce planning, which are necessary for the strategy's effectiveness.
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Feedback on proposed changed to ACC Cost of Treatment and Definitions Regulations
ProCare largely supports the Ministry of Business, Innovation, and Employment's consultation paper, advocating for a blanket percentage increase of 9.45% across all regulated treatment rates. ProCare provides further feedback on clarifications to the consultation, including invoicing time limits that do not increase administrative burden or financial risk for general practices.
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Letter to Health NZ advocating for CPCT
ProCare urges Health NZ to continue funding the Comprehensive Primary and Community Care Teams (CPCT) programme, highlighting evidence of the positive impact it has had on strengthening clinical capability.
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Feedback on the regulation of Physician Assistants/ Associates (PAs)
ProCare supports the intent of the proposed scope of PAs but makes several key recommendations regarding the scope of practice, supervision requirements, cultural competency expectations, and ensuring an appropriate professional title.
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Submission on cultural competence, cultural safety, and hauora Māori
ProCare supports the Council’s draft standards on cultural competence and safety, while calling for clearer guidance, practical implementation, and shared responsibility. It emphasises alignment with Te Tiriti o Waitangi and offers support to enable consistent, real-world application.
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Submission on the proposed integrated national palliative care model
ProCare supports the national palliative care model’s focus on early intervention and whānau‑centred primary care, but stresses that better resourcing and infrastructure planning is needed to deliver this consistently.
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Submission opposing the Healthy Futures (Pae Ora) Amendment Bill
ProCare opposes the proposed amendments to the Pae Ora Act. We highlight that by weakening Māori leadership structures and cultural safety requirements, progress towards equitable healthcare would be undermined.
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Supporting new IMG supervision and peer support framework
ProCare supports the development of a more flexible, two‑tiered supervision model for International Medical Graduates (IMGs). We suggest several recommendations to ensure IMGs are well supported and safely integrated into the New Zealand health system.
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Letter to Pharmac on proposed changes to prescription lengths
ProCare raises concerns about extending prescription lengths to 12 months, emphasising risks to patient safety, monitoring, and continuity of care - particularly for vulnerable communities.
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Submission supporting Associate Psychologist role
ProCare supports the introduction of an Associate Psychologist role to help meet workforce needs. We agree with the role, but recommend a different title, such as “Assistant Psychologist” or “Mental Health Clinician”, to more accurately reflect the scope of the role.
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Submission supporting funding advanced melanoma treatments
ProCare supports Pharmac’s proposal for funding pembrolizumab, dabrafenib, and trametinib. We recommend implementing care pathways, guidelines, and funded training to ensure safe delivery of the treatments within primary care.
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Submission supporting funding Estradot
ProCare supports Pharmac’s proposal to fund Estradot alongside the existing Estradiol TDP Mylan patches, emphasising that multiple brands improve patient choice, clinical flexibility, and therefore, equitable outcomes.
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Submission on modernising health workforce regulations
ProCare supports modernising health workforce regulations, endorsing stronger patient‑centred input and more efficient regulatory processes. We firmly oppose a single regulator and emphasise the need to retain profession‑specific authorities such as the Medical and Nursing Councils.
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Opposition to the principles of the Treaty of Waitangi Bill
ProCare strongly opposes the Principles of the Treaty of Waitangi Bill, highlighting that the Bill would negatively impact Māori health outcomes.
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Feedback on proposal on expanding ADHD treatment access
ProCare strongly supports Pharmac’s proposal to widen prescribing rights for ADHD stimulant medications. We recommend allowing vocationally registered GPs to initiate treatment for under‑17s, as well as calling for dedicated funding and training for GPs to safely take on this expanded role.
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Letter to Pharmac requesting funding for naloxone
ProCare urges Pharmac to fund take‑home naloxone to ensure availability of the product to at‑risk people, their whānau, and frontline responders, to help prevent avoidable opioid‑related deaths across Aotearoa.
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Submission on the Suicide Prevention Action Plan 2025–2029
ProCare Fresh Minds supports the proposed suicide prevention actions, stressing the need for strong leadership, co-ordinated cross‑government effort, and sustained funding – especially for primary care, where most people first seek help.
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Proposal to increase prescribing duration
ProCare supports the Ministry of Health in increasing prescribing duration but recommends a shift to 6‑month, not 12‑month, prescriptions, citing safety concerns and the need for regular clinical review.
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Letter to Pharmac to remove the renewal criteria for stimulant treatments
ProCare strongly supports removing the renewal criteria for stimulant treatments, noting that this change would reduce unnecessary administrative burden and barriers for patients, whānau, pharmacists, GPs, and specialists.
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Submission to fund medicines for lung cancer, breast cancer for chronic obstructive pulmonary disease (COPD) and for the prevention of RSV
ProCare supports funding new treatments for lung cancer, breast cancer, COPD, and RSV. The submission highlights how this would improve equitable access especially for vulnerable communities.
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Submission on Smokefree Environments and Regulated Products Amendment Bill (No 2)
ProCare supports the Smokefree Environments and Regulated Products Amendment Bill (No 2), endorsing stronger regulations. We make several recommendations, including that single use vaping products should only be provided by a licenced smokefree service provider, stronger restrictions on the geographical distance of specialist vape providers from schools, marae, and early childhood services, and fines for non-compliance of vape advertising to be re-invested into smoking cessation services.
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Proposal to widen access to empagliflozin for chronic heart failure
ProCare strongly supports widening access to empagliflozin for chronic heart failure, highlighting that improved access would reduce hospitalisations for patients, address inequities particularly for Māori and Pacific peoples, and remove strain on the healthcare system.
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Supporting funding of lisdexamfetamine for ADHD
ProCare strongly supports funding lisdexamfetamine for ADHD, noting its once‑daily, extended‑release design that improves symptom control, which would improve outcomes for school-aged children with ADHD.
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Submission on Therapeutic Products Act Repeal Bill
ProCare uses the Therapeutic Products Act Repeal Bill as an opportunity to urge the Government to modernise the outdated Medicines Act. We call for the enablement of Nurse Practitioners, Nurse Prescribers, and Pharmacist Prescribers to fully utilise their scope.
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Letter to Pharmac supporting the funding of several medications
ProCare supports widening access to aripiprazole LAI, ferric carboxymaltose, methylnaltrexone bromide, and key biologics for psoriasis. We note that improved access would help reduce longstanding gaps in health outcomes.
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Support for funding of glucose monitors, insulin pumps, and insulin pump consumables
ProCare is supportive of the proposal to fund continuous glucose monitors, insulin pumps, and consumables, which would improve equitable access and patient choice. ProCare makes several recommendations, such as to include people with type 2 diabetes in this proposal, and to reduce barriers to initial patient access via primary care.
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Letter with recommendations to reduce barriers to HPV screening
ProCare supports the progress made in HPV self‑screening and recommends further improving access by enabling Registered Nurses to undertake HPV primary self‑testing.
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Submission on childhood vaccinations to be given in pharmacies
ProCare strongly believes that general practices, Māori providers, and outreach services should remain the primary providers of all childhood immunisations up to age four.
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Letter on HPV cervical screening rollout
ProCare supports the HPV primary screening rollout and welcomes the funding initiative but highlights significant gaps in operational readiness that creates confusion and extra workload for primary care.
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Submission on Therapeutic Products Bill
ProCare supports the HPV primary screening rollout and welcomes the funding initiative but highlights significant gaps in operational readiness that creates confusion and extra workload for primary care.
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Supporting the Smoked Tobacco Regulatory Regime
ProCare supports the proposed Smoked Tobacco Regulatory Regime, endorsing stronger controls on smoked tobacco and vaping products to reduce harm and protect communities.
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Supporting the Sale and Supply of Alcohol (Community Participation) Amendment Bill
ProCare supports the Sale and Supply of Alcohol (Community Participation) Amendment Bill, endorsing stronger community influence over local alcohol regulation to reduce alcohol‑related harm.
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Supporting Pharmac’s proposal to amend pharmaceutical schedule rules on prescribing and dispensing of class B controlled drugs
ProCare supports Pharmac’s proposal to amend the prescribing and dispensing rules for Class B controlled drugs, endorsing longer electronic prescription periods to improve access and reduce pressure on general practice.
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Letter to Pharmac on proposal to fund elexacaftor with tezacaftor and ivacaftor (trikafta) for people with cystic fibrosis
ProCare supports Pharmac’s proposal to fund Trikafta for people with cystic fibrosis, endorsing improved access to a life‑extending treatment and reduced financial burden for patients and whānau.
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Submission on Smokefree Environments and Regulated Products Amendment Bill
ProCare supports the Smokefree Environments and Regulated Products (Smoked Tobacco) Amendment Bill, but calls for stronger controls on retailer numbers, nicotine levels, and youth access as essential steps toward achieving Smokefree 2025.
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Supporting funding of auto injectors for severe anaphylaxis
ProCare supports Pharmac’s proposal to fund adrenaline auto‑injectors for severe anaphylaxis, endorsing improved equitable access to lifesaving treatment and reduced financial barriers for vulnerable communities.
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Submission on proposed changes to the promotion and provision of healthy drinks in schools
ProCare supports the proposed changes to promote and provide healthy drinks in schools, endorsing stronger regulations while recommending that requirements be extended to secondary schools to maximise health benefits and equity.
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Supporting Pharmac’s proposal to widen access to influenza vaccine
ProCare supports Pharmac’s proposal to widen access to the influenza vaccine for Māori and Pacific peoples aged 55–64, endorsing the initiative as a vital step to reduce inequities and prevent severe flu-related illness.