16 December 2025
Paul Stewart
[FYI request #32918 email]
Kia ora Paul
Your Official Information Act request, reference: GOV-044511
Thank you for your email of 19 November 2025, asking for the following information under the Official
Information Act 1982 (the Act):
I am a Health researcher conducting research on the funding of NZ health services. In particular
the arrangements around the funding of procedures or health interactions where a conflict of
interest may arise for one or more parties. For example, the forthcoming Medical Products Bil
would theoretical y al ow Doctors to own Pharmacies and potential y profit from writing
prescriptions and directing patients to their own business to have them fil ed. I understand that
similar conflicts may currently exist in ACC funded healthcare where Doctors can refer patients
covered by ACC for tests that the referring Doctor may have a financial interest in the delivery of.
In short, I have concerns around managing the conflicts of interest that arise in a vertical y
integrated healthcare model where referrers wil increasingly have a financial interest that
potential y conflicts with the best interests of the patient and the funder (private, public, ACC,
insurance etc)
I would be interested in any information that ACC can provide me with around the consideration
of such potential conflicts of interest. Any guidelines around how such conflicts are managed. If
such guidelines exist then any information around how they were derived. Any financial analysis
of the potential costs of vertical integration (referrers owning or otherwise having an
arrangement with referees). Any ethical analysis of the potential risks and harms to patients.
Any legal analysis of the potential risks and liabilities. Any other information that ACC holds that
may be of relevance to my concerns.
Our response
ACC’s policy on conflict of interest is our Declarations of Interest policy, this is attached. Staff names
have been deemed out of the scope of your request and removed.
The scope of this policy includes vendors and third parties who are engaged to undertake work on
behalf of ACC.
This policy adheres to the Public Service Commission’s Model standards for Conflicts of interest
(Model Standards). These standards guide the identification, assessment, and ongoing management of
actual, potential, and perceived conflicts. You can view the Model Standards online here: Model
standards: Conflicts of interest - Te Kawa Mataaho Public Service Commission
GOV-044511 Page 1 of 2
In addition to this, all contracted suppliers must adhere to the conflict of interest requirements in
clause 18 of the ACC Contract for Services Standard Terms & Conditions, which you can view at:
www.acc.co.nz/assets/contracts/health-contract-terms-conditions.pdf
The medical council of New Zealand also references the following:
Microsoft Word - Doctors and health-related commercial organisations - February 2023 (Word version
of statement published on MC
We have not been able to identify any financial, legal or ethical analysis in relation to conflicts of
interest or vertical integration. Accordingly, we are refusing this part of your request as the information
does not exist, or despite reasonable efforts, cannot be found. This decision is made under section
18(e) of the Act.
As this information may be of interest to other members of the public
ACC may publish a copy of this response on ACC’s website. All requester data, including your name
and contact details, will be removed prior to release. The released response will be made available
www.acc.co.nz/resources/#/category/12. Please also view this page about making requests and our
published responses https://www.acc.co.nz/contact/official-information-act-requests.
If you have any questions about this response, please get in touch
You can email me at [email address].
If you are not happy with this response, you can also contact the Ombudsman via
[email address] or by phoning 0800 802 602. Information about how to make a
complaint is available at www.ombudsman.parliament.nz.
Ngā mihi
Christopher Johnston
Manager Official Information Act Services Government Engagement
GOV-044511 Page 2 of 2
