NAATI credential compliance, subcontracting practices and national oversight of interpreting and translation services in Health New Zealand
P. Peach made this Official Information request to Health New Zealand
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From: P. Peach
Tēnā koutou,
I am requesting the following information under the Official Information Act 1982 relating to the procurement, oversight, and NAATI credential compliance of interpreting and translation services within Health New Zealand — Te Whatu Ora.
I note that Health New Zealand does not appear on the MBIE Language Assistance Services participating agencies list, and that some regional divisions operate their own in-house interpreting services while others appear to procure externally. My questions reflect this complexity.
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SECTION A: NATIONAL OVERSIGHT AND PROCUREMENT STRUCTURE
1. Whether Health New Zealand has a national policy or framework governing the procurement and delivery of interpreting and translation services, or whether procurement decisions are made independently by each regional division.
2. A list of all external interpreting and translation providers currently contracted to Health New Zealand at a national or regional level, including the region they serve, the commencement and expiry date of each arrangement, and whether the contract was competitively tendered.
3. Whether any regional divisions of Health New Zealand participate in the MBIE Language Assistance Services panel contracts for telephone, video, or face-to-face interpreting, and if so which divisions and under what arrangements.
4. For regional divisions that operate their own in-house interpreting services (such as Te Toka Tumai Auckland), details of how those services are structured, including the number of interpreters employed or contracted, the languages covered, and the employment status of practitioners (directly employed, contracted, or casual).
5. The total expenditure by Health New Zealand on interpreting and translation services — both in-house and externally procured — for each financial year from 2019/20 to 2024/25, and year-to-date for 2025/26, broken down by regional division and provider where available.
6. The total number of interpreting sessions or assignments delivered under Health New Zealand contracts for each financial year from 2019/20 to 2024/25, and year-to-date for 2025/26, broken down by regional division, service type (telephone, video, face-to-face, in-house), and language where available.
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SECTION B: SUBCONTRACTING ARRANGEMENTS
7. Whether Health New Zealand's external interpreting and translation providers are permitted to subcontract assignments to third parties, including overseas-based agencies or individual contractors located outside New Zealand.
8. Any conditions or restrictions in Health New Zealand's contracts with interpreting and translation providers regarding the use of subcontractors, including any requirements that subcontractors be based in New Zealand or hold an appropriate New Zealand work visa.
9. Whether Health New Zealand requires providers to disclose the identity, location, or credentials of individual interpreters or translators — including subcontractors — who carry out assignments on Health New Zealand's behalf.
10. For regional divisions that operate in-house services and exhaust their in-house capacity: what arrangements exist for overflow demand, including whether in-house services subcontract to external providers or individual interpreters, and on what terms.
11. Any instances where Health New Zealand became aware that an assignment was conducted by a person located outside New Zealand or by an uncredentialled subcontractor, and any action taken as a result.
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SECTION C: NAATI CREDENTIAL COMPLIANCE
12. What mechanism, if any, Health New Zealand uses at a national level to verify that individual interpreters and translators — whether in-house, externally contracted, or subcontracted — hold a valid NAATI credential or Working Towards NAATI (WTN) status.
13. Whether individual regional divisions have their own credential verification processes, and if so whether Health New Zealand holds any information about what those processes are.
14. Whether Health New Zealand requires its external interpreting and translation providers to maintain and supply a current register of credentialled practitioners working under Health New Zealand contracts, and if so whether such registers have been received and reviewed.
15. Any audits, spot checks, or compliance reviews conducted by Health New Zealand — at a national or regional level — on its interpreting and translation providers or in-house services since 1 July 2024 to verify NAATI credential compliance, including the methodology and findings of any such reviews.
16. Any instances since 1 July 2024 where a provider or in-house interpreter was found not to hold the required NAATI credential or Working Towards NAATI (WTN) status, and any consequences or remedial action taken.
17. Any complaints received by Health New Zealand since 1 July 2024 from staff, patients, or members of the public regarding the qualifications or conduct of an interpreter or translator, and any actions taken.
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SECTION D: INTERPRETER AND TRANSLATOR PAY VISIBILITY
18. Whether Health New Zealand has any information about the rates or fees paid by its external providers to individual interpreters or translators for assignments conducted on Health New Zealand's behalf.
19. The pay rates or remuneration bands applicable to in-house interpreters employed or contracted by Health New Zealand regional divisions, where this information is held centrally.
20. Whether Health New Zealand has ever sought, as part of contract negotiations, tendering processes, or performance reviews, any information about the pay or working conditions of interpreters or translators engaged through its provider contracts.
21. Any internal policies, briefings, risk assessments, or correspondence within Health New Zealand regarding the fair remuneration or employment conditions of interpreters and translators, including any concerns raised about the margin between rates paid to external providers and rates passed on to practitioners.
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If any part of this request is refused, please:
- Identify the specific OIA provision relied upon for each withholding;
- Consider whether the public interest in transparency around publicly funded health services and the fair treatment of workers outweighs any commercial sensitivity; and
- Release any information that can be made available in redacted or aggregated form.
I am happy to receive this information in electronic format.
Ngā mihi
From: hnzOIA
Tçnâ koe,
Thank you for your email.
Under the Official Information Act (OIA), agencies are required to respond
to requests for official information as soon as reasonably practicable and
no later than 20 working days after receiving them.
If your request is for data that Health NZ holds, have you checked
[1]Lighthouse first to see if the data you are seeking is already
published?
Lighthouse is a searchable catalogue that makes a range of data and
analytics products available to New Zealanders to enable easier, faster
access to insights about health services.
You can find further information about how OIA timeframes are calculated,
including the Ombudsman’s OIA calculator, at the link below:
[2]Official information calculators | Ombudsman New Zealand
We will provide a response to your request in line with the statutory
timeframes set out in the OIA.
We appreciate your understanding and patience during this time.
Ngâ mihi,
Health NZ | Te Whatu Ora
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https://www.ombudsman.parliament.nz/agen...
From: hnzOIA
Kia ora P Peach,
Thank you for your Official Information Act request of 28 March 2026: Your
full request is set out at the bottom of this email.
Health NZ has undertaken an initial scoping exercise on your request with
our business units and across our regions and 18 Health NZ Districts.
The information you have requested includes the time period when Health NZ
did not exist (prior to 1 July 2022). Before it was established on 1 July
2022 there were 20 former District Health Boards (DHBs) in existence and
each procured its own services. To collate and prepare the information
requested would be a substantive collation and research exercise across
all former DHBs and the current Health NZ districts. This means your
request may be refused under section 18(f) of the Official Information Act
1982 (OIA). We would like to work with you to avoid this and ensure we can
provide a response that best meets your needs.
Suggested refinement.
We invite you to consider the following refinement.
* You narrow the scope of your request to a specific Health NZ district.
A link to the districts can be found here:
[1]https://www.healthnz.govt.nz/about-us/wh...
* For your selected district the timeframe for your request is for the
2025/2026 Financial Year.
In addition, could you please confirm that the interpretation services are
for spoken languages only or include the translation of written material
into other languages.
We appreciate you are under no obligation to amend your request, however
requests that require substantial collation or research may be refused
under section 18(f) of the OIA. We would like to work with you to avoid
this and ensure we can provide a response that best meets your needs.
Please note, under section 15 of the OIA, any clarification or amendments
made to a request within seven days after the date it is received, that
request may be treated as a new request and the time limit for the
response restarts.
Please let us know if you are happy with these refinements and your
selected district or otherwise. We would appreciate a response by 5pm
Tuesday 14 April 2026.
Ngā mihi,
Peteli
Government Services (OIA)
[2][email address]
[3]A blue and white sign<br><br>AI-generated content may be incorrect.
Health New Zealand | Te Whatu Ora
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Full Request
SECTION A: NATIONAL OVERSIGHT AND PROCUREMENT STRUCTURE
1. Whether Health New Zealand has a national policy or framework governing
the procurement and delivery of interpreting and translation services, or
whether procurement decisions are made independently by each regional
division.
2. A list of all external interpreting and translation providers currently
contracted to Health New Zealand at a national or regional level,
including the region they serve, the commencement and expiry date of each
arrangement, and whether the contract was competitively tendered.
3. Whether any regional divisions of Health New Zealand participate in the
MBIE Language Assistance Services panel contracts for telephone, video, or
face-to-face interpreting, and if so which divisions and under what
arrangements.
4. For regional divisions that operate their own in-house interpreting
services (such as Te Toka Tumai Auckland), details of how those services
are structured, including the number of interpreters employed or
contracted, the languages covered, and the employment status of
practitioners (directly employed, contracted, or casual).
5. The total expenditure by Health New Zealand on interpreting and
translation services — both in-house and externally procured — for each
financial year from 2019/20 to 2024/25, and year-to-date for 2025/26,
broken down by regional division and provider where available.
6. The total number of interpreting sessions or assignments delivered
under Health New Zealand contracts for each financial year from 2019/20 to
2024/25, and year-to-date for 2025/26, broken down by regional division,
service type (telephone, video, face-to-face, in-house), and language
where available.
---
SECTION B: SUBCONTRACTING ARRANGEMENTS
7. Whether Health New Zealand's external interpreting and translation
providers are permitted to subcontract assignments to third parties,
including overseas-based agencies or individual contractors located
outside New Zealand.
8. Any conditions or restrictions in Health New Zealand's contracts with
interpreting and translation providers regarding the use of
subcontractors, including any requirements that subcontractors be based in
New Zealand or hold an appropriate New Zealand work visa.
9. Whether Health New Zealand requires providers to disclose the identity,
location, or credentials of individual interpreters or translators —
including subcontractors — who carry out assignments on Health New
Zealand's behalf.
10. For regional divisions that operate in-house services and exhaust
their in-house capacity: what arrangements exist for overflow demand,
including whether in-house services subcontract to external providers or
individual interpreters, and on what terms.
11. Any instances where Health New Zealand became aware that an assignment
was conducted by a person located outside New Zealand or by an
uncredentialled subcontractor, and any action taken as a result.
---
SECTION C: NAATI CREDENTIAL COMPLIANCE
12. What mechanism, if any, Health New Zealand uses at a national level to
verify that individual interpreters and translators — whether in-house,
externally contracted, or subcontracted — hold a valid NAATI credential or
Working Towards NAATI (WTN) status.
13. Whether individual regional divisions have their own credential
verification processes, and if so whether Health New Zealand holds any
information about what those processes are.
14. Whether Health New Zealand requires its external interpreting and
translation providers to maintain and supply a current register of
credentialled practitioners working under Health New Zealand contracts,
and if so whether such registers have been received and reviewed.
15. Any audits, spot checks, or compliance reviews conducted by Health New
Zealand — at a national or regional level — on its interpreting and
translation providers or in-house services since 1 July 2024 to verify
NAATI credential compliance, including the methodology and findings of any
such reviews.
16. Any instances since 1 July 2024 where a provider or in-house
interpreter was found not to hold the required NAATI credential or Working
Towards NAATI (WTN) status, and any consequences or remedial action taken.
17. Any complaints received by Health New Zealand since 1 July 2024 from
staff, patients, or members of the public regarding the qualifications or
conduct of an interpreter or translator, and any actions taken.
---
SECTION D: INTERPRETER AND TRANSLATOR PAY VISIBILITY
18. Whether Health New Zealand has any information about the rates or fees
paid by its external providers to individual interpreters or translators
for assignments conducted on Health New Zealand's behalf.
19. The pay rates or remuneration bands applicable to in-house
interpreters employed or contracted by Health New Zealand regional
divisions, where this information is held centrally.
20. Whether Health New Zealand has ever sought, as part of contract
negotiations, tendering processes, or performance reviews, any information
about the pay or working conditions of interpreters or translators engaged
through its provider contracts.
21. Any internal policies, briefings, risk assessments, or correspondence
within Health New Zealand regarding the fair remuneration or employment
conditions of interpreters and translators, including any concerns raised
about the margin between rates paid to external providers and rates passed
on to practitioners.
Statement of confidentiality: This email message and any accompanying
attachments may contain information that is IN-CONFIDENCE and subject to
legal privilege. If you are not the intended recipient, do not read, use,
disseminate, distribute or copy this message or attachments. If you have
received this message in error, please notify the sender immediately and
delete this message
References
Visible links
1. https://www.healthnz.govt.nz/about-us/wh...
2. mailto:[email address]
From: P. Peach
Tēnā koe,
Thank you for your response and for the initial scoping exercise. I am happy to work with Health NZ to refine my request and appreciate the constructive approach.
I accept that collating information across former District Health Boards prior to 1 July 2022 would be unduly burdensome, and I am happy to limit my request to the Health NZ period only.
In terms of district scope, I propose narrowing my request to the three largest Health NZ districts by population: Auckland (Te Toka Tumai), Wellington (Capital, Coast and Hutt Valley), and Canterbury (Te Whatu Ora Waitaha). I consider this a reasonable middle ground focused on the districts most likely to hold substantial and comparable information on interpreting procurement.
In terms of timeframe, I propose the period from 1 July 2022 (the establishment of Health NZ) to the date of response, including year-to-date figures for 2025/26. This covers three full financial years within the Health NZ era and captures the period both before and after the NAATI credentialling requirement came into force on 1 July 2024, which is directly relevant to my request.
To confirm the scope of services: my request covers spoken language interpreting services and written translation services, for community and ethnic languages and te reo Māori. It does not extend to New Zealand Sign Language.
I confirm that my request is otherwise unchanged across all sections - subcontracting arrangements, NAATI credential compliance, and interpreter pay visibility - as these apply to the three districts and timeframe specified above.
Response to section 18(f)
I note that section 18(f) is a discretionary ground for refusal, and that the Ombudsman's guidelines require agencies to consider releasing parts of a request that can be answered without substantial collation even where other parts cannot. I ask that Health NZ evaluate each of my questions individually and release answers to those that can be provided without substantial collation, identifying by question number any questions it considers require further research.
I also note that several of my questions are policy and process questions requiring no collation of records - for example, whether providers are permitted to subcontract, whether credential registers are required, and whether procurement criteria include consideration of practitioner pay. These can be answered from existing policy knowledge and do not engage section 18(f).
Given the significant public interest in accountability around publicly funded health services and compliance with the NAATI credentialling requirements, I ask that Health NZ exercise its discretion in favour of release where any doubt exists.
If Health NZ intends to refuse any part of this request, I ask that it provide written reasons specific to each question refused so that I may consider whether to refer the matter to the Office of the Ombudsman.
Ngā mihi,
P. Peach
From: hnzOIA
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Kia ora P Peach,
Thank you for your Official Information Act request of 28 March 2026
regarding NAATI credential compliance of interpreting and translation
services. Please find attached our response to your request.
If you have any questions, please get in touch at
[1][email address]
If you are not happy with this response, you have the right to make a
complaint to the Ombudsman. Information about how to do this is available
at [2]www.ombudsman.parliament.nz or by phoning 0800 802 602.
Ngā mihi,
Peteli
Government Services (OIA)
[3][email address]
[4]A blue and white sign<br><br>AI-generated content may be incorrect.
Health New Zealand | Te Whatu Ora
Statement of confidentiality: This email message and any accompanying
attachments may contain information that is IN-CONFIDENCE and subject to
legal privilege. If you are not the intended recipient, do not read, use,
disseminate, distribute or copy this message or attachments. If you have
received this message in error, please notify the sender immediately and
delete this message
References
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