H202101848 Doc 1.pdf

Memo
Date:
7 December 2020
To:
COVID-19 Vaccine and Immunisation Programme Steering Group (SG)
Copy to:
Emily Black, Solicitor, Health Legal, Olivia Payne
, Senior Solicitor, Health Legal
Kelvin Watson, Group Manager, COVID-19 Immunisation, Testing & Supply
Wendy Il ingworth, Group Manager, Public Health System Policy
From:
Casey Pickett, Manager Public Health Policy
Subject:
Non-residents eligibility for COVID-19 immunisation
For your:
Direction
Purpose
This memo provides you with advice on whether non-residents in New Zealand should have
access to publicly funded COVID-19 immunisation.
Summary
As part of the COVID-19 Immunisation Strategy and Programme, we need to clarify who in
New Zealand will be eligible for publicly funded COVID-19 immunisation.
Most non-residents would not currently be eligible for publicly funded COVID-19
immunisation. We propose pursuing a new Ministerial Direction to expand eligibility for
COVID-19 immunisation to anyone in New Zealand, which would include people on
temporary visas (including work, student and visitor visas). This can support us to maximise
uptake and work towards population immunity. It is also consistent with the principles set out
in the COVID-19 Immunisation Strategy.
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We expect that while there wil be a fiscal cost, this can likely be absorbed within baseline
while visitor numbers are low, unless uptake is substantially higher than expected.
The proposed approach wil mean that any future policy work to relax border controls would
need to consider the impact on COVID-19 immunisation, given that relaxing the borders
would increase the number of people on temporary visas. For example, work could consider
whether to only allow people on visitor visas in if they have been immunised, or whether they
should remain eligible for publicly funded COVID-19 immunisation.
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Action
Please provide any feedback or comment on the proposed policy position at the Steering
Group meeting on 8 December 2020.
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Recommendations
It is recommended that you:
1.  agree  To progress advice to Ministers on expanding eligibility for COVID-19
Yes/No
immunisation to anyone in New Zealand, which would include people on
temporary visas
2.  agree  That we pursue a stand-alone Ministerial Direction to support this policy,
Yes/No
rather than changes to contractual arrangements with DHBs.
Immigration status currently limits access to publicly funded immunisation…
Under clause B23 of the Health and Disability Services Eligibility Direction 2011 (the
Direction) , a person who has, or is suspected of having, an infectious disease or a
quarantinable disease are eligible for certain publicly funded services (including diagnosis
and treatment) to address risks to others, irrespective of eligibility status.
COVID-19 testing and treatment services have been publicly funded for everyone in New
Zealand under this clause. However, non-residents wil  not be eligible to publicly funded
vaccines under this clause. Immunisation is preventative and wil  generally not be given to a
person “who has, or is suspected of having, and infectious disease”.
Immunisation is publicly funded for eligible people specified in the Direction. In general, this
would include all:
• Children
• New Zealand citizens (including people from Cook Islands, Niue and Tokelau)
and permanent residents
• Refugees and protected persons
• Australian citizens or permanent residents who have lived, or intend to live, in NZ
for two years or more
• People with a valid work visa who wil  be in NZ for at least two years.
This means adults who wil  be in NZ for less than two years or people who are in NZ
unlawfully would not be eligible for a publicly funded COVID-19 vaccine at present.
…but enabling anyone in New Zealand to access free COVID-19 vaccination supports
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our goal of population immunity over time
We need to encourage uptake of COVID-19 vaccines to work towards population immunity.
Someone can transmit or become seriously il  from COVID-19 regardless of their residency
status, and they could also place their whānau or community at risk of harm.
Of those living in New Zealand temporarily, as at October 2020 there are approximately
196,000 people with w
Released  ork visas, 68,000 people with student visas and 1,300 people with
other temporary visas in New Zealand.1 This includes Recognised Seasonal Employer (RSE)
workers who may return to New Zealand regularly. As at April 2020, there were also
approximately 55,000 people on visitor visas in New Zealand, most of whom were from India,
1 MBIE, Migration Data Explorer, retrieved on 27 November 2020 from:
https://mbienz.shinyapps.io/migration data explorer/.
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China and Great Britain.2 All up, this could mean approximately 320,000 non-residents are in
New Zealand.

We do not have data on how many Australian citizens or permanent residents would not
currently be eligible for publicly funded health services, such as immunisation. Nor do we
have data on the number of people in New Zealand unlawfully, though some of this group
may be particularly vulnerable to the risks of contracting and transmitting COVID-19.
We recommend that anyone in New Zealand should be eligible for publicly funded
COVID-19 immunisation
In Appendix one we have assessed the option to expand access to free COVID-19
immunisation to anyone in New Zealand against the COVID-19 Immunisation Strategy
principles.
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Based on this assessment, we recommend expanding eligibility to COVID-19
immunisation to anyone in New Zealand. This option is consistent with the draft advice
Act
from the National Ethics Advisory Commit ee:
From an epidemiological perspective, all individuals living in a geographic area (such as
New Zealand) must be considered as part of the immunisation programme, regardless of
their immigration status. This includes all non-residents currently living in, or unable to
leave, New Zealand.3
We will continue to work with the Ministry of Foreign Affairs and Trade (MFAT) on whether
Information
any non-residents could be covered by reciprocal health agreements, and what other
countries are doing.4

While any reciprocal agreements would be unlikely to change our policy position of broad
eligibility, they could be used to support New Zealanders overseas to be immunised.

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We are also consulting with Immigration Policy in the Ministry of Business, Innovation and
Employment (MBIE). Their initial feedback is that they are likely to be broadly supportive, but
we are waiting for further input. We wil  repor
the  t back if it is likely that we wil need to make any
changes to our policy position.
There is an interface between border settings and visitors’ access to COVID-19
Immunisation
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There is an interface between access to COVID-19 immunisation and border controls. The
number of people on visitor visas (NB: this does not include those on work-related or student
visas, such as RSE workers) who could access publicly funded COVID-19 immunisation will
remain low where strict border controls are in place. These controls mean that comparatively
few people on visitor visas are arriving in New Zealand, and they must have an approved
reason. Only 8,550 overseas visitors arrived in September 2020 (Statistics NZ).
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2 MBIE, Tourism Data Factsheet, released 1 May 2020, https://www.mbie.govt.nz/dmsdocument/11382-tourism-
data-factsheet-covid-19-response-4-may-2020.
3 National Ethics Advisory Committee, Ethics and Equity: Resource Al ocation and COVID-19: An Ethics
Framework to Support Decision Makers (draft version, 2020).
4 For example, Australia wil  be covering al  visa holders except those on tourist or transit visas.
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There are also visitors who are currently unable to leave New Zealand to return to their home
country, whose access to publicly funded COVID-19 immunisation can help us work towards
population immunity.
However, it may not be cost effective for the Government to fund COVID-19 immunisation for
large numbers of people on visitor visas who will only be staying in New Zealand for a short
time. This is because immunising this group is unlikely to contribute to population immunity,
though it could contribute to the global recovery.
Any future policy work to relax border controls needs to consider the impact on COVID-19
immunisation, for example, considering whether to only allow in people on visitor visas if they
have been immunised, or whether they should remain eligible for publicly funded COVID-19
immunisation.
Broad eligibility would support the proposed sequencing approach
Some non-residents, such as some of those on work visas, are likely to be included in the
groups identified as a priority in the Sequencing Framework due to their risk of contracting or
transmit ing the virus.
However, we wil  need to consider how non-residents are included in the different population
cohorts, particularly where there are data gaps and we may not have good information about
them.
Implementation
A ministerial direction or contractual changes would be needed
S9(2)(h)
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Fiscal implications can likely be absorbed within baseline
Our initial estimate is that the additional cost of expanding eligibility to non-residents would
be approximately $19.8 mil ion. This assumes:
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• 100 percent uptake by 320,000 people who would otherwise not be eligible,
(which may not take into account Australians who would otherwise not be
eligible),
• a cost of S9(2)(j)  person, including vaccine consumables and administration, and
• no additional cost of the vaccine itself, given we are likely to have surplus
quantities.
Current costings for the COVID-19 Immunisation Programme assume 100 percent uptake for
the resident New Zealand population, and factor in a contingency of $38.5 million. Ful  uptake
is likely to be unrealistic for both the New Zealand resident population and non-residents.
Given the above factors, we consider that it is reasonable to assume that expanding access
to non-residents could be absorbed within baseline funding, while visitor numbers remain
low. If the success of the COVID-19 Immunisation Programme changes this (i.e. due to very
high uptake), we would need to report back to Ministers seeking additional funding.
Communications and engagement
People who are in New Zealand unlawfully may be harder to reach, due to the potential fear
that interacting with government by being immunised could lead to them being deported.
Further work wil  be needed to mitigate this risk and encourage uptake, including:
• communications with messaging that no identifying information on visa status would
be shared with Immigration NZ; and
• supporting vaccinators, community providers and other outreach services to engage
with this group.
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