Ember Innovations Submission to the Therapeutic Products Act 2022
This Bill would thwart the progress of our Health Transformation.
Ember Innovations oppose the amendments to the Therapeutic Products Bill in its current form. The current detrimental lack of evidence-based alternatives further complicated by additional layers of bureaucracy proposed in the Bill will leave those in distress with extremely limited options.
We believe that the proposed amendments to the Bill will have negative implications on the availability of innovative and efficacious alternative therapeutic choices to treat mental health and addiction. It is our strong belief that this bill will have significantly negative implications to innovation in mental health and addiction treatment.
Whilst the proposed changes will make things like surgery safer, the Bill fails to take into account the recommendation of He Ara Oranga (the 2018 Enquiry into Mental Health and Addiction) which highlighted the importance of improving access to effective treatments to improve mental health and advance New Zealand’s health and wellbeing goals, and reducing bureaucracy. The proposed changes will add an additional layer of bureaucracy, further reducing access to effective treatment and choice/autonomy.
It is particularly concerning in regard to its failure to include acknowledgement and explicit support alternative options for evidence-informed mental health treatments that may have lower risks than certain traditional medications. The exclusion of a specific mention of known and promising therapeutic approaches as alternative treatments is counter to ‘He Ara Oranga’ which highlighted the need for alternative mental health treatments and sufficient choice for people with lived experience’s autonomy and wellbeing.
This Bill also fails to provide meaningful considerations to te Tiriti O Waitangi by ignoring the needs of Tāngata whenua and the importance of rongoā Māori such as mirimiri, romiromi, maramataka and rongoā rākau.
Furthermore, tāngata whaiora/ those with lived experience of Mental Health and Addiction challenges already report widespread access and affordability challenges to treatments they see as essential to their healing such as micronutrients. Additionally, contrary to best practice and current evidence, the current Bill does not adequately protect and acknowledge the significant potential therapeutic benefits that extended research into innovative alternatives to traditional treatments such as psycho-active medicine, ketamine and psilocybin may offer to mental health and addiction.
There are already severe difficulties facing individuals and families trying to access and afford appropriate care. Many often struggle to find support and are left behind by our healthcare system. (850,000 New Zealanders cannot access the Mental Health Support they need) This bill would make this situation even worse by preventing the use of non-traditional treatments that could potentially improve mental health before needing more acute options.
For addiction treatment, psychoactive treatments have been found to show greater promise in helping individuals reduce substance use and ultimately overcome their addiction than current mainstream approaches. The amendments proposed in this Bill would slow down research progress in this area, making it harder for individuals to access clinical trials for the treatment they need.
In order to promote the availability of alternative therapeutic choices to treat mental health and addiction and to meet the intent of the 2018 Mental Health and Addiction Inquiry, the Bill should include meaningful consideration of the various evidence-informed treatments, psychonautics, spiritual practices, mātauranga Māori, and the perspectives/ healing narratives of Tāngata Whenua and Tāngata Whaiora.
The Bill should include relevant provisions to provide access to alternative treatments and grant health professionals and rongoā practitioners the right to prescribe whatever treatments they deem appropriate, in collaboration with those within their care, provided they have received the necessary training.
We recommend that New Zealand Parliament takes a more progressive stance on this issue, and use wording that explicitly encourages innovation, access and choice across the spectrum of need. This includes explicitly supporting rongoā and micronutrients which already have robust evidence behind their efficacy, and further supporting research and clinical trials into the use of psychedelic medicines to treat mental health and advancing access to these treatments where evidence-based. Furthermore, the Bill should take into account He Ara Oranga’s recommendation to reduce bureaucracy and provide world-leading mental health services.