Dear Health New Zealand,

The Pharmac Schedule allows for funded dispensings of quantities greater than 90-day or 180-day lots at one time in some pragmatic circumstances such as Original Pack (OP) pharmaceuticals (e.g. Inhalers), items packed as Multiples (e.g. some Oral Contraceptives), items that last longer that three months (e.g. Insulin Pumps, Allergic Emergency devices such as Epipens, some Vaccines), etc. There may be other circumstances where the total quantity dispensed or the total number of days supply dispensed could have legally exceeded the prescribed amount for a three month prescription.

Changes to the Medicines Regulations 1984 around increasing the period of supply are in effect as of 1 February 2026. The changes increase the prescribing limit to 12 months and creates a new 3 month dispensing limit where there previously was no limit. The Pharmac Schedule typically funded dispensings only up to 180 days' supply of an Oral Contraceptive and up to 90 days' supply for other pharmaceuticals, but had rules allowing for exceptions in cases such as those listed above.

The Medicines Regulations as of 1 February 2026 does not have provision for dispensing more than these limits in the cases listed above (without authorization by the Director-General of Health for a patient, or a specified class or classes of patients). This creates a conflict between the Medicines Regulations and the Pharmac Schedule. This could result in dispensings that exceed the legal limits, more frequent dispensing of smaller quantities to not exceed the legal limits, and other unforeseen consequences.

I seek the following under the Official Information Act 1982 for the 2024 pharmaceutical year (1 February 2024 - 31 January 2025):

1. Where the days supply is recorded or calculated as exceeding 90 days' supply, excluding Oral Contraceptives, provide a count of:
* the number of dispensings; and
* the number of unique NHI (National Health Index) numbers recorded for these dispensings
2. Where the days supply is recorded or calculated as exceeding 180 days' supply for Oral Contraceptives, provide a count of:
* the number of dispensings; and
* the number of unique NHI (National Health Index) numbers recorded for these dispensings

Please use the same inclusion criteria given in the Technical information tab of the Pharmaceutical Data Web Tool https://tewhatuora.shinyapps.io/pharmace..., i.e.:

The inclusion criteria for the set of subsidised community-dispensed pharmaceuticals presented is as follows:
* have a date of dispensing between 1 Jan 2019 and 31 Dec 2024
* only includes pharmacy prescriptions (for individuals) and excludes bulk and practitioner supply orders, nicotine replacement therapy orders, haemophilia treatments, some treatments for hepatitis C and historic growth hormone information, vaccines, medicines for rare disorders, cancer and other hospital medicines
* excludes records created for the purpose of managing claims such as brand switch fees and 'owe claims' where prescription item was not filled
* excludes records where chemical formulation information was not recorded.

I also seek the same for the 2025 pharmaceutical year (1 February 2025 - 31 January 2026), acknowledging that the data may be currently incomplete.

Yours faithfully,

Tiffany Wright