IN-CONFIDENCE
In
-Confidence
Office of the Minister for COVID-19 Response
Cabinet
Reconnecting New Zealanders with the World: Self-Isolation Pilot
Proposal
1
This paper reports back on the design of the self-isolation pilot agreed by Cabinet as
part of the Reconnecting New Zealanders work programme [CAB-21-MIN-0305
refers]. The purpose of the pilot is to explore some parts of the border, health, and
Managed Isolation and Quarantine (MIQ) systems that will be needed to roll out self-
isolation as one entry pathway for medium risk travellers.
2
This paper seeks:
2.1
Agreement to elements of the design of the pilot, with final operational plans
approved by me and significant operational decisions delegated to
Reconnecting New Zealand Ministers, and
2.2
Approval for costs of the pilot.
Relation to government priorities
3
This paper supports the ongoing response to COVID-19 by setting out a pilot of one
new travel pathway under the Reconnecting New Zealanders approach.
Executive Summary
4
In August, Cabinet endorsed an approach that would introduce low, medium and
high-risk pathways for travellers based on their COVID-19 risk under the
Reconnecting New Zealanders with the World work programme. Cabinet also agreed
to a self-isolation pilot.
5
Self-isolation, as part of a medium risk pathway, would allow more people to enter
New Zealand and isolate either at home or in suitable rented accommodation. This
would allow for greater freedoms for travellers, potentially lower costs, and reduce
demand for places in MIQ.
6
A pilot is proposed to operate from October to December 2021.
7
The pilot is intended to test the systems and processes that would be needed to run
self-isolation under the medium risk pathway. The pilot will operate under a lower
domestic vaccination rate than will be in place at the time of a wider roll-out of self-
isolation, and potentially while parts of New Zealand are still in Alert Level 2 or
above. This means that the pilot must have strict public health-driven protocols in
place to minimise the risk of introducing COVID-19 into the community, but still
provide valuable insights into our options for the future.
8
The primary public health risk of the pilot is that self-isolation may increase the risk of
spread of COVID-19 into the community, compared to the risk associated with
participants entering MIQ.
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9
I am proposing that the pilot seek to balance the objectives of Reconnecting New
Zealanders, and the constraints on border, health and MIQ systems due to the
current outbreak.
Pilot design
10
I propose that the pilot run between October and December, with a total cap of 150
participants. The pilot will only run where the region in which it is located is at an Alert
Level of 2 or lower. Due to the current outbreak in Auckland, I consider that
Christchurch is the most appropriate location for the pilot. However, I seek Cabinet’s
agreement to delegate decision-making on the inclusion of Auckland in the pilot, at a
later date, to the Prime Minister and myself.
11
s 9(2)(g)(i)
12
I also propose that Cabinet agree in principle to allow travel to all countries that are
not designated very high risk. Although country risk is an important consideration, we
also need to take into account both the risk of travel, and the viability of the pilot, in
considering countries where New Zealanders are able to travel to. Moreover, the
purpose of the pilot is to test onshore systems and processes, rather than our ability
to accurately assess risk offshore. Officials will consider the overall risks posed by
travellers and propose suitable mitigations.
Participant selection
13
I recommend that Cabinet confirm its previous in-principle decisions on the criteria for
participant selection – fully vaccinated New Zealand citizens and residents (who are
able to leave and re-enter), travelling to approved countries (ie non very high risk
countries), with a self-isolation plan in place - aside from the criterion that requires
participants to travel for less than 3 weeks.
14
I propose that the primary participants of the pilot are businesses, and seek Cabinet’s
views on the inclusion of Ministers, officials, and other individuals attending overseas
events as New Zealand delegates.
15
Business participants will be selected through a public expressions of interest (EOI)
process run centrally by MBIE. Places will be balloted by MBIE in a way that ensures
an even spread across the travel window. MBIE will engage with stakeholders to
ensure a diverse range of businesses are aware of the opportunity to submit EOIs for
balloting.
Requirements for participants
16
When in self-isolation, participants will be required to remain at their accommodation
for 14 days, not allow visitors, and comply with testing and monitoring requirements.
Participants will need to have accommodation arrangements consistent with agreed
guidance, and can only isolate alone, or with other participants in the same travelling
party. To meet these requirements, participants may need to rent accommodation for
the period of their self-isolation.
17
I am proposing that all participants agree to a compliance monitoring regime. There
are three options for Cabinet to consider, including ankle or wrist bracelet electronic
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monitoring technology, app-based monitoring technology, or random spot checks. I
consider that the app-based technology is the best fit for the long-term operation of
the pilot.
Evaluation
18
I will report back to Cabinet in February on provisional evaluation findings of the pilot.
I expect the pilot to test a number of operational matters across the border system,
delivery of services to people self-isolating, and the compliance monitoring regime. I
also expect to evaluate participants’ experience in travel and self-isolation, and those
of other stakeholders (eg employers).
19
Due to the strict requirements of participants in self-isolation, the pilot will not
necessarily test the efficacy of self-isolation at large in preventing transmission of
COVID-19 into the community.
Funding
20
MBIE seeks funding of $3.769 million in new operating funding for the self-isolation
pilot (based on 150 participants).
Background
21
In August, Cabinet endorsed a risk based approach to Reconnecting New
Zealanders based on three entry pathways for low, medium and higher-risk
travellers, and invited the Minister for COVID-19 Response to report back on the
design of a self-isolation pilot under the medium risk pathway [CAB-21-MIN-0305].
22
The ability to connect with the rest of the world is critical for our business links, and
social connections. The Reconnecting New Zealanders work programme will seek to
improve outcomes for New Zealanders by increasing our opportunities for travel,
while aiming to preserve the gains that we have achieved through our Elimination
Strategy.
23
Self-isolation would allow for more people who have a lower risk of COVID-19 to
isolate in their own homes or suitable rented accommodation instead of entering
MIQ. This would reduce the demand for MIQ, potentially reduce costs for travellers,
and increase the freedoms and benefits that New Zealanders enjoy through travel.
Purpose of the Pilot
24
The purpose of the pilot is to test parts of the border, health, and MIQ systems that
will be needed to inform the roll-out of self-isolation as one entry pathway for medium
risk travellers. The pilot will allow us to test operational readiness and identify areas
where further work is required to scale up the approach.
25
The pilot will not be able to tell us everything we need to know about the medium risk
pathway. By its nature, the pilot is smaller in scale and operating in advance of the
systems needed to deliver the medium risk pathway. Critically, it is a first step away
from full MIQ for people entering New Zealand. However, conducting the pilot now
will enable officials to glean lessons and test processes in advance of substantive
policy or operational decisions in 2022.
26
The pilot is not intended to assess our ability to accurately assess risk offshore, nor is
it intended to have a significant impact on the demand for MIQ places in 2021.
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27
The pilot is part of a wider approach to informing the Reconnecting risk-based
pathways, which has a number of concurrent workstreams. For example, New
Zealand Customs is leading the development of the traveller health declaration
system, and the Future Borders sprint process, which will enable the verification of
travellers’ health information, and the operationalisation of changes to border
processes, respectively.
28
The Ministry of Health is piloting point of arrival testing, which may be used in
conjunction with the self-isolation pilot to inform the logistics of delivering tests on
arrival for medium risk travellers. Day 6/7 testing is also being rolled out in MIQ, and
will be implemented for all returnees arriving after 30 September to inform the relative
risks of different managed isolation lengths.
29
I consider that there will be further opportunities to test different aspects of risk-based
pathways at different scales and locations in early 2022. Lessons can also be
gleaned from self-isolation for people coming under one-way Quarantine-Free Travel
(QFT) from the Pacific.
Risk context
30
The pilot will operate when vaccination levels are lower than they will be for the wider
roll out of a medium risk entry pathway. The design of the pilot attends to this
additional risk, inasmuch as possible, however it will increase the risk of introducing
COVID-19 into the community. While I consider that on the whole this risk is
acceptable, mitigations are required.
31
Accordingly, there are some limitations to the pilot that will cause it to look different
than a future medium risk pathway. The design is more restrictive than what is
intended for self-isolation in the future, but we will still learn critical information about
the border system and processes, the delivery of services in self-isolation (eg
testing), compliance monitoring, enforcement, and the participant experience.
Self-Isolation Pilot Design Parameters
32
Given the inherent risk associated with running a pilot of this nature, the design
parameters of the pilot seek to balance the objectives of Reconnecting New
Zealanders, the purpose of the pilot, and the constraints on border, health, and MIQ
systems.
33
The design parameters are grouped across:
33.1
The overall pilot settings,
33.2
The selection process for participants,
33.3
The requirements placed on participants, and
33.4
The approach to evaluating the pilot.
Decision Making
34
This pilot is a complex undertaking and requires that detailed operational plans be
made. I am proposing that Cabinet agree the high-level parameters for the design of
the pilot, that some significant operational decisions are delegated to the
Reconnecting New Zealanders Ministerial Group (RNZMG), and that I will approve
final operational plans undertaken by agencies.
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35
MBIE is the lead agency for the pilot. The Ministry of Health and New Zealand
Customs will also be required to support its design and delivery.
36
Officials will provide regular reporting on operational decisions (that are not otherwise
delegated) to the RNZMG. The first report to RNZMG will be after the proposed
Expressions of Interest (EOI) process has closed.
Overall pilot settings.
Pilot dates
37
I propose that the pilot take place from the end of October to December 2021.
38
Indicative timeframes are provided below. These dates are subject to change, and
will not be finalised until completion of the pilot design.
EOI process goes live
Thursday 30 September
EOI process closes
Saturday 9 October
Ballot completed
Thursday 14 October
Successful applicants advised
Friday 15 October
Final approval of participants
At least one week before departure
Arrival window opens
Saturday 30 October
Final arrivals in New Zealand
Wednesday 8 December
Final travellers exit self-isolation
Wednesday 22 December
39
Given that these timeframes are extremely tight, any delay risks delivery of the pilot.
Overall cap on participants
40
I propose to cap the total number of participants in the pilot to 150. This cap reflects
operational feasibility for border, health, and MIQ systems at this juncture.
41
I consider that there needs to be an even spread of participant arrivals across the
pilot period (particularly given MIQ will be used as contingency in the event of the
pilot being paused). Customs advise that Christchurch and Auckland Airports can
accommodate a maximum of 10 pilot participants per flight under their current
settings, which would allow for participants to be processed separately from other
passengers after arrival (though further work may determine some degree of
flexibility).
42
Additionally, 150 participants will be sufficient to fulfil the pilot’s intended purpose,
which is to test the systems and processes needed to run self-isolation. The 150-
participant cap is considerably larger than the first tranche of the South Australia self-
isolation pilot, which involved 50 Defence Force staff.
Alert Levels
43
The pilot will not go ahead if the region in which the pilot is located is at Alert Level 3
or higher. In the event of an Alert Level change to 3 or higher during the pilot, the
pilot will be suspended. Pilot participants self-isolating during an Alert Level change
to 3 or higher will remain self-isolating. Other participants would be guaranteed MIQ
entry on return (including those participants offshore and those yet to depart).
44
The suspension of the pilot and having participants return into MIQ will reduce the
strain on the local workforce to support people who are self-isolating. During a
community outbreak there will be an increase in the number of people self-isolating,
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which will draw on the same resources as the pilot, so I do not consider it appropriate
to have more people entering self-isolation at that time.
Location requirements
45
I have considered different options for the location of the pilot. Pertinent
considerations include proximity to airports with direct international connections,
proximity to MIQ facilities, and proximity to health services.
46
I recommend that the pilot is located in Christchurch. While Auckland has the most
international connections, I have significant concerns about the health and MIQ
workforces in Auckland currently dealing with the domestic COVID-19 outbreak.
Wellington Airport does not currently receive ‘red’ travellers, and so does not have
the direct international connections required to support the pilot.
47
Christchurch has direct international links with Singapore (currently four Singapore
Airlines flights arrive per week), so it is feasible that the participants in the pilot could
organise to transit through Singapore.
48
I consider that participants’ place of self-isolation should be limited to within 50km
travel of Christchurch International Airport. Appendix 1 provides an indicative map of
this boundary. This distance accounts for:
48.1
Proximity to MIQFs (in the event a participant tests positive for COVID-19),
48.2
Proximity to health services (if required due to a COVID-19 or non-COVID-19
related medical event),
48.3
MBIE-arranged transportation logistics (including mitigating against the need
to stop before arriving at participants’ places of self-isolation),
48.4
Travel time required to conduct COVID-19 testing,
48.5
District Health Board boundaries (so as to avoid cutting across them), and
48.6
Likely availability of food delivery services (noting that participants will be
required to confirm their ability to procure food via contactless delivery in their
self-isolation plans).
49
Locating the pilot in Christchurch, with this distance requirement, and in concert with
accommodation requirements (eg dwellings without shared ventilation or other
household members – discussed further under ‘self-isolation requirements’), may
reduce EOIs, because participants will likely need to secure temporary rental
accommodation. However, these constraints would likely be true of other locations.
50
In the future, people entering New Zealand to undertake self-isolation will likely do so
via Auckland Airport given its greater international connections. It is also likely that
there are a greater number of businesses interested in the pilot that are located in
Auckland.
51
For these reasons, Cabinet could consider including Auckland in the pilot once it has
returned to Alert Level 2 or lower.
52
s 9(2)(g)(i)
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s 9(2)(g)(i)
53
My officials also advise that setting up and running the pilot in more than one location
at the same time is not feasible given the tight timeframes of the pilot. Doing so
would require doubling efforts related to consultation with key stakeholders (eg Iwi),
logistics (eg arranging transportation, designing airport procedures), and
procurement (eg of monitoring technologies). It would also be a significant drain on
the health workforce – particularly in Auckland – to set up multiple testing and health
check processes while the system is already under significant pressure. Given the
range of circumstances under which participants may be required to enter MIQ
(outlined under ‘contingency planning’), MIQ workers across numerous sites would
need to be briefed on new procedures.
54
If Cabinet chooses to include both Auckland and Christchurch in the pilot, officials
advise there is a high chance that stated timeframes for the pilot will not be
achievable, that there will be operational disruption across health and MIQ
workforces, and that the risk of spreading of COVID-19 to the community would
increase.
55
At this time, I consider it appropriate for Cabinet to delegate decision-making on the
inclusion of Auckland in the pilot to the Prime Minister and myself. Officials will
consider expanding the pilot once Auckland has remained at Alert Level 2 for 14
days.
Approved countries
56
In order to limit the risk that participants are infected with COVID-19 while travelling, I
consider that the risk of countries they travel to should be taken into account.
However, in order for the pilot to be viable we also need to take into account what
ability New Zealanders have to enter different countries or territories, and the health
measures or quarantine they may face upon entry.
57
I propose that Cabinet agrees to approve travel for the purposes of the pilot to any
country that is not considered very high risk. I consider that the combination of pre-
departure testing, the selection process for participants (including the support of their
employer), and the requirements for self-isolation are sufficient to minimise risk from
all other countries.
58
In addition, before applications receive final approval, officials will consider the
overall risks posed by travellers based on their itineraries, and propose suitable
mitigations.
Pacific QFT
59
Officials note that in considering Pacific one-way QFT, CBC authorised the Prime
Minister, Attorney-General, Minister for COVID-19 Response and the Minister of
Immigration to have Power to Act to take further decisions if necessary on requiring
New Zealand citizens returning from Samoa, Tokelau, Tonga and Vanuatu to submit
a seven day self-isolation plan to the Ministry of Health, including meeting the
requirements of having an COVID-19 test on arrival and on day five (CBC-21-MIN-
0089).
60
As Samoa, Tokelau, Tonga and Vanuatu have all been assessed by the Director-
General of Health as meeting the health requirements for QFT, and this arrangement
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is currently in the implementation phase, I propose that arrivals from these countries
not be included in the self-isolation pilot. Advice on any self-isolation measures to be
applied to arrivals from these low-risk countries will be provided separately.
Contingency planning
61
MIQ contingency will be reserved for all participants. MIQ contingency may be
required in the event of an Alert Level change (and the pilot’s suspension), change to
a country’s risk status (rendering it a very high risk country), if a participant presents
as symptomatic upon arrival to New Zealand, if a participant breaches self-isolation
requirements, or if the person tests positive for COVID-19. For this reason, officials
will seek to stagger the arrival of participants across the pilot period. This
contingency will not affect the availability of MIAS vouchers.
Selection process for participants
Eligibility
62
Eligibility for the pilot is one of our key levers for mitigating risk.
63
I recommend that Cabinet confirm its previous in principle decisions on the criteria for
participant selection:
63.1
New Zealand citizens and residents1 who have been fully vaccinated in New
Zealand with Cominarty (Pfizer-BioTNech COVID-19 vaccine) and have made
a short trip away from New Zealand;
63.2
Travelling to one of an approved list of countries (ie not a very high risk
country);
63.3
Able to supply a self-isolation plan as part of their application that meets the
Ministry of Health’s requirements.
64
Participants will be required to supply their self-isolation plan following balloting, and
prior to their final verification (having indicated in their EOI that they will be able to do
so).
65
I no longer consider that we need to limit the trip length to 3 weeks. This requirement
is unnecessary from a public health perspective as individuals infected more than two
weeks prior to returning to New Zealand are likely to have recovered prior to travel,
resulting in the duration of time overseas not influencing the risk of infection on arrival
in New Zealand.
66
In rescinding this requirement, and for an abundance of clarity, I seek Cabinet’s
confirmation that eligibility be limited to people who are in New Zealand at their time
of application (as opposed to people who otherwise meet eligibility criteria, but are
outside of New Zealand at that time).
67
I propose that the primary participants of the pilot are businesses with employees
required to travel internationally for business purposes. I therefore expect the
majority of places to be allocated to businesses.
68
I seek Cabinet’s view as to whether we should also extend participation to Ministers,
officials, and other individuals (eg iwi representatives, businesses, youth
1 Who have the ability to leave and re-enter New Zealand
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representatives, non-government organisations) attending overseas events
(examples listed in Appendix 2) as New Zealand Government delegates.
69
Prioritising places for business is consistent with the objectives of Reconnecting New
Zealanders. The New Zealand business community is significantly invested in
ensuring that travel connections with the rest of the world can be increased, while
also minimising disruptions from community spread and lockdowns. Accordingly, I
expect high levels of compliance with self-isolation requirements. I also seek
Cabinet’s view as to whether we should impose a duty on employers to take all
reasonable steps to ensure their employees comply with self-isolation requirements.
Failure to do so could result in employers being charged with an offence (see ‘legal
analysis’ section for further discussion).
70
Affording a smaller allocation to Ministers, officials, and other individuals engaging in
global events as New Zealand Government delegates is also consistent with the
objectives of Reconnecting New Zealanders, in being at the table as the world begins
to open up.
Selection process
71
Officials have advised that there is significant interest in the pilot, with DPMC
receiving over 1100 subscriptions for updates about the pilot. However, it is unclear
whether demand for the pilot will exceed the cap of 150 places, noting that eligibility
criteria and self-isolation requirements could dampen demand.
72
Given the very tight timeframes for the pilot, officials are limited in their ability to run
an assessment and prioritisation process.
s 9(2)(h)
73
I propose that a public EOI process be run centrally by MBIE, whereby employers
apply on behalf of their employees. Eligible EOIs would balloted by MBIE, in a way
that ensures an even spread across the travel window (ie by week). MBIE would
engage with stakeholders to ensure a diverse range of businesses (eg iwi-led
businesses) were aware of the opportunity to submit EOIs for balloting.
74
s 9(2)(h)
75
Business NZ has expressed comfort with the proposed option to ballot eligible EOIs.
76
I expect that employers will be required to provide a range of declarations in their
applications (eg that employee travel is for legitimate business purposes, and needs
to be conducted overseas).2 If sole traders are eligible to submit an EOI, they will
need to complete declarations on their own behalf, which removes a layer of
assurance.
2 A false declaration, made pursuant to the Oaths and Declarations Act 1957, provided in the context
of an application constitutes an offence under the Crimes Act 1961.
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77
Should Cabinet decide to extend participation to Ministers, officials, and other
individuals attending overseas events as New Zealand Government delegates, I
would invite Cabinet to specify how many pilot places should be reserved for these
participants, and delegate selection of these participants to the Prime Minister and
myself.
78
Once MBIE has completed requisite approval processes, it will report the final list of
participants to the RNZMG for their information.
Operationalisation of end-to-end journey
Transit
79
Officials will need to consider how the pilot participants will safely travel en route,
enter the red pathway at the airport and partially move through that process before
being separated off from other ‘red’ travellers, collect their luggage, and safely move
through the airport to their transportation that will take them to their accommodation.
This will require working with airlines and airports on how to do this feasibly and
safely.
Transportation
80
Given the risks associated with the pilot, I recommend that transportation to
participants’ place of self-isolation be arranged by MBIE. I do not consider that
allowing passengers to use their own transport is appropriate at this time.
81
I also do not recommend domestic transfers by air or land to other parts of the
country, as this increases the risk, complexity and cost of the pilot, especially to
support participants outside of main centres where there are MIQ facilities. This
option could be reconsidered as part of the medium risk pathway next year.
Chartering domestic red flights from other airports (eg Auckland to Christchurch)
would involve logistical challenge
s 9(2)(b)(ii)
.
Requirements for participants in self-isolation
82
Participants will be legally required to comply with self-isolation requirements. I
propose that Cabinet agree the high-level requirements of participants in self-
isolation, with final detail to be determined by me, on the advice of MBIE and MoH.
83
In order to participate in the pilot, participants must:
83.1
have travel arrangements consistent with agreed guidance, and
83.2
have accommodation arrangements either at home or in temporary rental
accommodation consistent with agreed guidance (eg private dwelling, no
shared ventilation).
84
Whilst in self-isolation, participants will be required to:
84.1
remain in their place of self-isolation for 14 days,
84.2
be alone, or with other participants from the same travelling party,
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84.3
not allow any visitors to enter the premises, aside from medical staff for
testing purposes, and emergency or other essential services if required (eg
fire, ambulance, New Zealand Police, plumbing)3
84.4
comply with all testing requirements set out by MoH, and
84.5
comply with all monitoring requirements.
85
If a participant fails to comply with self-isolation requirements, they could be a)
required to enter MIQ (at their own cost), and b) charged under existing COVID-19
legislation. I also seek Cabinet’s view as to whether we should impose a duty on
employers to take all reasonable steps to ensure their employees comply with self-
isolation requirements.
Isolating with household members
86
I consider that permitting participants to self-isolate with others who haven’t travelled
with them could make the pilot more accessible, particularly for those who usually
live with other household members.
87
However, there is an increased risk of exposure to COVID-19 in household members
(approximately 50% in the current outbreak), and of non-compliance (insofar as all
household members would be subject to the same requirements as participants).
Additional MIQ contingency would need to be reserved for household members. For
these reasons, I do not recommend allowing participants to self-isolate with
household members. They could, however, be permitted to isolate with members of
the same traveling party.
Testing, health, and welfare checks
88
Given that participants fall under the purview of the COVID-19 Public Health
Response (Air Border Order) 2020, they will be required to complete pre-departure
testing, unless they are travelling from a country exempted from that requirement.
89
Once in self-isolation, testing requirements will be no less frequent than those of
people in MIQ.
90
Health and welfare checks will be conducted on people in self-isolation, to be agreed
by MoH. These checks may be conducted through technology (email or app) rather
than by phone or in person.
Interface with pilot of point of arrival rapid testing
91
MoH is investigating how point of arrival testing can be established. As an initial step,
I have agreed that MoH will establish a small-scale trial of rapid testing methods at
the point of arrival into New Zealand. The intention is to test a subset of participants
in the self-isolation pilot using point of arrival testing trial, however it is unknown
whether it will be feasible to incorporate point of arrival testing into this pilot.
Compliance mechanisms
92
I consider that some form of compliance monitoring of participants is required due to
the level of risk involved in the pilot. As there is a risk that participants have COVID-
3 Protocols are to be developed regarding a) alerting emergency services to the fact that people are
participants in the self-isolation pilot, and b) requirements of people performing other essential
services (eg vaccination and testing).
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19, and the population is still vulnerable to outbreaks, it is important to monitor
participants’ movements.
93
I propose that all participants are required to comply with a monitoring regime. There
are three monitoring options for Cabinet to consider:
93.1
Option 1:
Electronic monitoring using a lightweight wrist or ankle
bracelet capable of GPS tracking if the participant moves outside a set
range from their self-isolation location. This option provides a high level of
assurance, insofar as it monitors the location of the person wearing the
bracelet at all times. However, this option requires more ‘hands on’
management (ie to fit and remove the device), may be of limited acceptability
to participants, and is likely to be more resource-intensive to scale (beyond
the pilot).
93.2
Option 2: Electronic monitoring using a smartphone app that uses GPS
monitoring and biometric facial recognition to verify the participant is at their
self-isolation location. This option would provide a medium level of assurance,
insofar as a participant’s location would only be verified at the time of a ‘ping’
to their phone. If a participant left their place of self-isolation without their
phone, their movements would not be immediately known. Such breach
would only be determined if their phone was ‘pinged’ during the time the
participant was away and failed to respond in the required timeframe.
93.3
Option 3: Conducting regular and random phone-based checks. This
option would provide a low level of assurance, insofar as there would be no
certainty that a participant is where they say they are, or if they have
remained in their place of self-isolation, except when field-based checks are
made. Whilst this option may be easiest to pursue at pace, it would be
resource-intensive, and therefore potentially limited in its scalability.
94
Officials also considered investigating the capabilities of the Emergency Caller
Location Information (ECLI) Service – currently used to locate 111 callers – to
monitor the location of each participant’s mobile device. This option was disregarded
due to time constraints of the pilot.
95
None of the above options would be able to monitor for visitors to the residence, nor
are there implementable technologies that could monitor for this.
96
Any electronic monitoring technology chosen would need to meet stringent
government security, data handling and privacy requirements.
97
It is difficult to make a direct comparison with current ‘monitoring’ costs in MIQ. The
per-participant costs of each electronic monitoring option are expected to be ~$2,000
for the ankle or bracelet option and ~$2,760 for the app (based on 150 participants
all being monitored by the same option). These costs are relatively high because
quotes are based on a small-scale pilot (whereas costs may reduce considerably at
scale).
98
I recommend that we pursue electronic monitoring using a smartphone app for the
purposes of the pilot. Whilst electronic monitoring using a lightweight wrist or ankle
bracelet may provide a greater level of assurance, officials consider that app-based
technology (whether the specific app used for the purposes of this pilot, or another
app) has greater scalability.
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99
The phone-based app would be supplied by the current providers of Corrections’
home detention monitoring service. Breaches would be escalated to the New
Zealand Police as necessary.
100
It is important that Cabinet is aware that the smartphone app option carries
implementation risks. The app has not yet being published on any New Zealand app
stores (eg Apple App Store, Google Play). To date, it has only been published in
North America.
s 9(2)(g)(i)
101
The provider of the app-based option is seeking to publish the app so that it is
available through a recognised app store in New Zealand. In the event this is not
possible in required timeframes, mobile devices with the app already loaded by the
provider could be given to participants at the airport for their period of self-isolation
(noting this measure would involve additional cost).
102
I invite Cabinet to rank its preferred monitoring options, in the event the smartphone
app option cannot be finalised in time for participants’ return. I understand Cabinet
may also wish to pursue multiple monitoring options. It is important to note, however,
that doing so will place pressure on MBIE’s ability to stand-up compliance monitoring
within the pilot’s tight timeframes, and increase costs (due to loss of scale).
Participant fees
103
I do not intend to recover costs from pilot participants. Due to the nature of self-
isolation, and accommodation requirements for the pilot, costs will be shifted to
participants (eg accommodation if rental property is used, food costs). Given these
potential costs, I consider that charging for participation may reduce EOIs.
104
However, should Cabinet seek to recover costs from participants, my officials advise
that relevant costs could include:
104.1 Monitoring: ~$2,760,
104.2 Transport: ~$310, and
104.3 Consumables (such as personal protective equipment, sanitiser, signage,
information packs): ~$550.
105
These three costs total ~$3,620 (excluding GST) per participant. These costs would
likely reduce at scale (ie in the course of a future rollout of self-isolation). In any
event, this combined cost is greater than the MIQ fee of $2,696 (excluding GST) for
liable New Zealand citizens and Permanent Residents (which does not reflect full
cost recovery).
106
Alternatively, Cabinet could decide to combine some of these costs. Cost recovering
$1000 (the approximate costs of transport and consumables) may be an appropriate
alternative. These costs would be recovered by MBIE on a contractual basis, outside
of the COVID-19 Public Health Response (Managed Isolation and Quarantine
Charges) Regulations 2020.
107
I propose that in the event a participant is required to enter MIQ:
107.1 Because they breach conditions of their self-isolation – they
will be liable for
MIQ fees
IN-CONFIDENCE
107.2 Because they test positive for COVID-19 – they
will not be liable for MIQ fees
(analogous to treatment of community cases, and in the interests of ensuring
participants are not dissuaded from disclosing symptoms)
107.3 Because the pilot is suspended prior to their departure or while they are
overseas due to an Alert Level change – they
will be liable for MIQ fees
107.4 For other contingency-related reasons beyond participants’ control –
decisions will be taken as context demands.
Evaluation
108
I propose that an evaluation and reporting approach be developed by MBIE in
consultation with MoH for my agreement. This will include the specifics of what is
being evaluated and any associated metrics.
109
Due to the limitations of scale and design of the pilot to ensure the public’s safety, I
do not expect to assess every aspect of the self-isolation in the pilot for readiness for
rollout as a medium risk entry pathway.
110
I expect that the pilot will test the operational readiness of the system for self-
isolation, and inform where processes will need to change for a wider scale roll-out.
This includes processes at the border, services required for people in self-isolation
including things like transit to their accommodation, and delivery of testing services.
111
I also expect to test the participants’ experience in self-isolation. We will be informed
by the ease by which participants can either isolate at home, compared to those
isolating in rented accommodation, and their experience with access to contactless
delivery services for things like food. We will also be able to determine the
effectiveness of the agreed monitoring technology, and the experience for the user.
112
I will report back to Cabinet in February on provisional evaluation findings, and
further work required to investigate the roll out of self-isolation to the general public.
113
I will report back on:
113.1 The border system and processes,
113.2 The delivery of services in self-isolation,
113.3 Monitoring, compliance and enforcement,
113.4 The participant experience, and
113.5 The experience of other stakeholders.
Limitations of the pilot
114
As New Zealand is in the process of vaccinating the public, and maintains an
elimination strategy, our priority for the design of the pilot is to limit the risk of COVID-
19 further entering the New Zealand public.
115
The timing of the pilot means that infrastructure key to the wider rollout of self-
isolation as a medium risk entry pathway will not be fully instituted in time (eg the
traveller health declaration system).
IN-CONFIDENCE
116
The pilot is limited in its scalability for the medium risk entry pathway. What is
operationally feasible for a capped number of participants may not necessarily reflect
what is operationally feasible for a higher number of travellers in some areas.
117
The pilot is also limited in its replicability. Business participants will not necessarily be
representative of the general public.
Legal Analysis
Adding a Part to the COVID-19 Public Health Response (Isolation and Quarantine) Order
2020
118
To give legal effect to the pilot, a new part will be added to the COVID-19 Public
Health Response (Isolation and Quarantine) Order 2020. This part will effectively:
118.1 Exempt a person from MIQ,
118.2 Set out self-isolation requirements for participants (eg to remain at their place
of self-isolation for 14 days, submit to COVID-19 testing),
118.3 Require a participant who fails to comply with these requirements to enter
MIQ, at their own cost, and
118.4 Prohibit unauthorised persons (eg members of the public) from entering a
pilot participant’s place of self-isolation.
119
I seek Cabinet’s view as to whether we should also impose a duty on employers to
take all reasonable steps to ensure their employees comply with self-isolation
requirements. There is a comparable duty on PCBUs in the COVID-19 Public Health
Response (Required Testing) Order 2020 to facilitate the compliance of affected
persons employed or engaged by the PCBU with testing and medical examination
requirements. Breaching this duty is an infringement offence.
120
Under this new part, a person (whether that be a participant, an unauthorised person,
or an employer) would commit an offence if they intentionally failed to comply with a
requirement or duty. They would be liable on conviction to imprisonment for a term
not exceeding six months, or a fine not exceeding $4,000.
121
If we elect to recover costs from participants, such requirement would also be set out
in this part, and recovered on a contractual basis by MBIE.
122
Consequential amendments to the COVID-19 Public Health Response (Air Border)
Order 2020 may also be required to give legal effect to the pilot (eg exempting
participants from the requirement to have a confirmed MIAS allocation on arrival).
123
My officials advise that amending Orders in this way will require significant work at
pace. Any delay in Cabinet’s decision-making will constrict policy development and
drafting and risks the pilot commencing without legal effect. In this situation,
participants would need to be granted exemptions to MIQ, with conditions imposed
on that exemption (ie self-isolation requirements). There would be no recourse to
offence provisions for unauthorised persons entering a place of self-isolation, nor a
duty placed on employers.
IN-CONFIDENCE
P
rivacy Analysis
124
Officials are exploring the pilot’s information sharing and privacy implications. The
key privacy issues are likely to arise in two areas; as part of self-isolation plans, and
in relation to compliance monitoring.
125
Self-isolation plans may require that participants share details of their homes and
households, including family members if they are able to isolate with the participants.
126
Compliance monitoring options require contact with participants at unknown times of
the day. This could also require a geo-location to be provided during the spot check.
s 9(2)(h)
127
There are a number of Privacy Act obligations to be met by relevant government
agencies as the detailed design of the pilot is progressed. For example, participants
will need to be told in advance of any collection of their personal information, the
purpose(s) for which their personal information will be used, and the intended
recipients of their personal information. Officials will consider the consequences if
all/any part of the required information is not provided.
128
The provision of personal information is a mandatory element of participation in the
pilot, which will be based on voluntary participation. This means that the personal
information required will be given by consent of the participants.
s 9(2)(h)
Financial Implications
129
The overall cost of the pilot for 150 participants is estimated to be $3.769 million
(excluding health-related costs). These costs include:
Personnel and related costs
2.884m
Monitoring (based on app option,
excluding cost of mobile devices)
0.414m
Transport
0.047m
Participant related consumables (eg PPE)
0.083m
One Off Charges (eg web forms)
0.342m
Total
3.769m
130
These costs are subject to change as the design of the pilot is finalised, and will need
to be adjusted if Cabinet decides on other monitoring options.
131
MBIE is seeking a total of $3.769 million4 in new operating funding to fund the self-
isolation pilot within the current financial year ending June 2022 from the COVID-19
Response and Recovery Fund established as part of Budget 2020.
4 Assuming Cabinet agrees to a cap of 150 participants
IN-CONFIDENCE
132
The funding sought does not include health-related costs (eg for testing, health
checks), because those elements of the pilot design have not yet been finalised.
Officials may need to seek further funding for health-related costs on completion of
pilot design.
Legislative Implications
133
An amendment to the COVID-19 Public Health Response (Isolation and Quarantine)
Order 2020 will be required to give legal effect to the self-isolation pilot.
Impact Analysis
134
There are no legislative implications, therefore a regulatory impact statement is not
required.
Population Impacts
135
The use of a pilot will inform the wider reconnection approach for New Zealanders,
and contribute to further the availability of safe international travel for all New
Zealanders in the future.
136
Through its design the pilot will have inequitable access. Some of the principal
impacts will be caused by the selection of participants, the cost of participation, and
the self-isolation requirements.
Selection of participants
137
The selection criteria for participants in the trial is very limiting in terms of
accessibility. The business travel focus will exclude much of the population from
selection, insofar as the pilot will not be open for personal and family travel.
Moreover, most employers will not need to have employees travelling internationally.
Pilot requirements
138
The recommended location of the pilot is restrictive. This will either restrict access to
those outside of Christchurch, or increase the costs to those who will need to rent
accommodation in Christchurch.
139
The inclusion of Auckland in the pilot would increase its accessibility, but it will also
increase the impact on the local health and MIQ workforces. It could potentially
impact the public should there be community transmission as a result of pilot.
Auckland has been disproportionately impacted in health and economic terms by
domestic outbreaks since August 2020.
140
The restrictiveness of the self-isolation requirements will likely be limiting. Some
employers will be able to rent accommodation that fits the requirements for the pilot,
but at a higher cost that may exclude some.
Differences in cost to people arriving via MIQ versus self-isolation pilot
141
Given that it is proposed participants not be charged, those people who enter New
Zealand via MIQ will be treated differently from participants in terms of cost recovery
(by virtue of needing to pay MIQ fees, unless eligible for a waiver).
Treaty Analysis
142
Officials will ensure Māori and Māori business are aware of the opportunity to submit
EOI for participating in the pilot.
IN-CONFIDENCE
H
uman Rights
143
s 9(2)(h)
144
145
146
147
Consultation
148
The Ministry of Health, New Zealand Customs, Crown Law, Treasury, New Zealand
Police, the Ministry of Foreign Affairs and Trade, the Ministry of Transport, the
Ministry of Justice, the Ministry of Social Development have been consulted in the
development of this paper.
149
The paper was prepared jointly by DPMC and MBIE.
Communications
150
Public communications and engagement will be jointly agreed and undertaken
between MBIE and DPMC. Participation interest in the pilot is very high. Timing of
official announcements will need to be carefully synchronised with the ability to
deliver supporting communications and engagement so as to keep stakeholders and
the public well informed and reassured about the purpose and processes of the pilot.
Proactive Release
151
We intend to proactively release this paper and its associated minute within the
standard 30 business days from the decision being made by Cabinet, with any
appropriate redaction where information would have been withheld under the Official
Information Act 1982.
Recommendations
The Minister for COVID-19 Response recommends that Cabinet:
1
Note the purpose of the self-isolation pilot is to explore some parts of the border,
health, and MIQ systems that will be needed to roll out self-isolation as one entry
pathway for medium risk travellers
IN-CONFIDENCE
2
Note the pilot will increase the risk of introducing COVID-19 into the community,
compared to the risk associated with participants entering MIQ
Self-Isolation Pilot Design Parameters
3
Note given the inherent risk associated with running a pilot of this nature, the design
parameters of the pilot may be more restrictive than those used for a wider scale roll-
out of self-isolation
4
Note MBIE is the lead agency for the pilot
5
Note the Ministry of Health and New Zealand Customs will also be required to
support its design and delivery
6
Agree significant operational decisions are delegated to the Reconnecting New
Zealanders Ministerial Group
7
Agree final operational plans be approved by the Minister for COVID-19 Response
8
Note officials will provide regular reporting on operational decisions (that are not
otherwise delegated) to the Reconnecting New Zealand Ministerial Group
Overall pilot design
9
Agree the pilot will operate from late October to December 2021
10
Note the Minister for COVID-19 Response recommends the pilot be limited to
Christchurch due to the impacts of the current outbreak on the health and MIQ
workforces and public in Auckland
11
Note that if Cabinet chooses to include both Christchurch and Auckland in the pilot at
this time, officials advise the strain on the Auckland public health workforce and the
operational difficulty of running the pilot in two regions concurrently could undermine
the pilot and increase risk to the public
12
Agree that the pilot be located in Christchurch
13
Note that officials will consider expanding the pilot once Auckland has remained at
Alert Level 2 for 14 days
14
Agree to delegate decision-making on the inclusion of Auckland in the pilot to the
Prime Minister and the Minister for COVID-19 Response
15
Note that MIQ contingency will be reserved for pilot participants
16
Agree the pilot will be suspended in the event of an Alert Level change to 3 or higher
in the region the pilot is located
17
Agree that pilot participants self-isolating during an Alert Level change to 3 or higher
will remain self-isolating
18
Agree that other participants overseas or yet to depart during an Alert Level change
to 3 or higher be guaranteed MIQ entry on return
19
Note that the arrival of participants must be staggered across the pilot period
because MIQ contingency needs to be reserved and Christchurch and Auckland
Airports can only accommodate 10 participants per flight
20
Agree that the number of participants be capped at 150
IN-CONFIDENCE
21
Agree to allow travel to all countries except very high risk countries
22
Note Samoa, Tokelau, Tonga and Vanuatu are not included in the self-isolation pilot
as one-way Quarantine Free Travel is in the implementation phase
Eligibility and selection process
23
Confirm Cabinet’s previous in principle decisions on the criteria for participant
selection, that participants must be:
23.1
New Zealand citizens and residents (who have the ability to leave and re-
enter) who have been fully vaccinated in New Zealand with Cominarty (Pfizer-
BioTNech COVID-19 vaccine) and have made a short trip away from New
Zealand;
23.2
Travelling to one of an approved list of countries (eg not a very high risk
country);
23.3
Able to supply a self-quarantine plan as part of their application that meets
the Ministry of Health’s requirements
24
Rescind Cabinet’s in principle decision that trip length be no longer than 3 weeks
25
Confirm that eligibility be limited to people who are in New Zealand at their time of
application for the pilot
26
Agree that the primary participants of the pilot are businesses with employees
required to travel internationally for business purposes
27
Agree to include sole traders
28
Agree to extend participation to Ministers, officials, and other individuals (eg iwi
representatives, businesses, youth representatives, non-government organisations)
attending overseas events as New Zealand Government delegates
29
Indicate how many pilot places should be reserved for official delegation participants
30
Agree to delegate selection of official delegation participants to the Prime Minister
and the Minister for COVID-19 Response
31
Agree that in selecting participants a public EOI process be run centrally by MBIE,
whereby employers apply on behalf of their employees
32
Agree that MBIE ballot eligible EOIs in a way that ensures an even spread across the
travel window
33
Note that MBIE will report the final list of participants to the to the Reconnecting New
Zealand Ministerial Group when final approval processes are complete for its
information
Transportation
34
Agree that MBIE arrange transportation to participants’ place of self-isolation
Requirements in self-isolation
35
Agree that, in order to obtain final approval to participate in the pilot, participants
must:
IN-CONFIDENCE
35.1
have travel arrangements consistent with agreed guidance, and
35.2
have accommodation arrangements consistent with agreed guidance (eg
dwelling house with no shared ventilation), and
36
Agree that, in self-isolation, participants be required to:
36.1
remain on the premises of their isolation accommodation for 14 days, and
36.2
isolate alone, or with other participants from the same travelling party, and
36.3
not allow any visitors to enter the premises, aside from medical staff for
testing purposes, and emergency or other essential services if required (eg
fire, ambulance, police, plumbing) and
36.4
comply with all testing requirements set out by MoH, and
36.5
comply with all monitoring requirements
Isolating with household members
37
Agree that participants not be allowed to self-isolate with household members
Compliance mechanisms
38
Note that pursuing multiple monitoring options will place pressure on MBIE’s ability to
stand-up compliance monitoring within the pilot’s tight timeframes, and increase
costs
39
Agree to rank its preference for participants to either:
39.1
Wear a lightweight ankle or wrist bracelet capable of GPS tracing,
And / or
39.2
Comply with electronic monitoring using a smartphone app (recommended)
And / or
39.3
Comply with regular and random phone-based checks
Participant fees
40
Agree to either:
40.1
Not recover costs from participants (recommended)
Or
40.2
Agree to cost recover $1000 from participants (the approximate costs of
transport and consumables)
41
Agree that participants who enter MIQ:
41.1
Because they breach conditions of their self-isolation will be liable for MIQ
fees
41.2
Because they test positive for COVID-19 will not be liable for MIQ fees
41.3
Because the pilot is suspended prior to their departure or while they are
overseas will be liable for MIQ fees
IN-CONFIDENCE
41.4
Because of other contingency-related reasons will be exempt or liable for MIQ
fees, subject to decision making as context demands
Evaluation
42
Invite the Minister for COVID-19 Response to report to Cabinet on provisional
evaluation findings in February
43
Note the design of the pilot will limit the value of the evaluation approach due to the
risk measures required
44
Agree that the following aspects of the approach to self-isolation are evaluated:
44.1
The border system and processes,
44.2
The delivery of services in self-isolation (eg testing),
44.3
Monitoring, compliance and enforcement,
44.4
The participant experience, and
44.5
The experience of other stakeholders
Legal Analysis
45
Note that an amendment to the COVID-19 Public Health Response (Isolation and
Quarantine) Order 2020 and consequential amendments to the will be required at
pace to give legal effect to the pilot
46
Indicate whether a duty should be imposed on employers to take all reasonable steps
to ensure their employees comply with self-isolation requirements
47
Note that any person would commit an offence if they intentionally failed to comply
with a self-isolation requirement or duty in the COVID-19 Public Health Response
(Isolation and Quarantine) Order 2020
48
Note that such person would be liable on conviction to imprisonment for a term not
exceeding six months, or a fine not exceeding $4,000
49
Note that consequential amendments to the COVID-19 Public Health Response (Air
Border) Order 2020 may also be required to give legal effect to the pilot
50
Note that any delay in Cabinet’s decision-making will constrict policy development
and drafting, and risks the pilot commencing without legal effect
Financial Implications
51
Note that MBIE is seeking a total of $3.769 million in new operating funding to fund
the self-isolation pilot within the current financial year ending June 2022
52
Note that officials may need to seek further funding for health-related costs once the
pilot design has been finalised
53
Approve
the following changes to appropriations to provide for and give effect to the
policy and recommendations above, with a corresponding impact on the operating
balance and net core Crown debt:
IN-CONFIDENCE
$m – increase /(decrease)
Vote Building and
Construction
2025/26 &
2021/22
2022/23
2023/24
2024/25
Minister for COVID-19
Outyears
Response
Multi-Category Expenses
and Capital Expenditure:
Isolation and Quarantine
Management MCA
Departmental Output
Expenses:
Operational Support
3.301
-
-
-
-
(funded by revenue Crown)
Non-departmental Output
Expenses:
Delivery of Services
0.468
-
-
-
-
Total Operating
3.769
-
-
-
-
54
Agree that any under-expenditure in the
Isolation and Quarantine Management multi-
category appropriation for MIQ be carried forward to the following financial year to
recognise the uncertain timing of subsequent expenditure, with the final amount to be
transferred confirmed as part of the baseline update process following the
presentation of MBIE’s audited financial statements
55
Note that funding is ring-fenced to MIQ and cannot be transferred to other
appropriations, and that once MIQ winds down, any remaining funding is to be
returned to the Crown
56
Agree that the proposed changes to all appropriations above be included in the
2021/22 Supplementary Estimates and that, in the interim, the increase be met from
Imprest Supply
57
Agree that the expenses incurred in the above recommendations be charged to the
COVID-19 Response and Recovery Fund established as part of Budget 2020
Human rights
58
s 9(2)(h)
59
Communications
60
Note public communications and engagement will be jointly agreed and undertaken
between MBIE and DPMC
IN-CONFIDENCE
61
Note timing of official announcements will be need to be carefully synchronised with
the ability to deliver supporting communications and engagement so as to keep
stakeholders and the public well informed and reassured about the purpose and
processes of the pilot.
Hon Chris Hipkins
Minister for COVID-19 Response
IN-CONFIDENCE
A
ppendix 1: 50km radius around Christchurch International Airport
Note: This map is indicative only. I propose that participants’ place of self-isolation be limited
to within 50km travel from Christchurch International Airport. The 50km radius does not
necessarily translate to 50km travel. For example, this radius includes Akaroa, which is
approximately 85km travel from Christchurch International Airport. For reference, Amberley
is approximately 49km away, and Rakaia is approximately 55km away.
IN-CONFIDENCE
A
ppendix 2 – Overseas events for possible attendance by official delegations
Event
Country
Expo 2020 (including possible MFA visit)
United Arab Emirates
COP 26
United Kingdom
Minister for Trade and Export Growth visits to US
EU, Switzerland, and United States
and Europe
Aid Programme
Pacific Islands and others
International Law Commission Campaign
United States
World Geothermal Congress
Iceland
